Last Revised: July 2023
1. ABOUT US
As used in this Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Personal Information also includes Student Data (as defined below).
2. WHO DOES THIS POLICY APPLY TO?
This Policy applies to all users of the Services. For the avoidance of confusion, “you” or “your” in this Policy refers to all users of the Services, including teachers, parents, and administrators accessing, using, or receiving our Services.
When our Services are used by providers of educational services, such as schools, school districts, teachers, and authorized school users and administrators (collectively, “Schools”) for educational purposes, we collect and process Personal Information about students (“Student Data”) for and on behalf of the Schools. Our collection and use of Student Data is governed by our contracts with the Schools, as well as by applicable student privacy laws, such as FERPA, COPPA, and state student data privacy laws.
If you were given access to the Services by the School you are affiliated with, this Policy does not govern how your School might collect, use, or disclose your information. Please consult with your district and/or School for more information about their privacy policies and practices, including your district’s and/or School’s collection, use, or disclosure of your Personal Information.
4. STATE-SPECIFIC NOTICES
California – If you are a resident of the state of California, please see our “Privacy Notice for Residents of California” section for additional California-specific information and disclosures.
Nevada – If you are a resident of Nevada, you may have the right to opt out of the sale of certain Personal Information to third parties in certain circumstances. inquirED does not currently engage in “sales” (as defined under N.R.S. § 603A) of your Personal Information. Please feel free to contact us at email@example.com for additional questions or concerns regarding this matter.
You are accessing, using, or receiving our Services when you:
Access or use the inquirED application available via our applications and/or services ending in “inquired.org” and/or “inquired.com”; or
Communicate with us, such as by submitting a question through our website; registering for and/or attending an event; corresponding with us by phone, email, or otherwise; subscribing to one of our mailing lists, newsletters, or other forms of marketing communications; or providing information requested by us to comply with our professional obligations.
6. WHAT PERSONAL INFORMATION WE COLLECT
a. Information we collect directly from you or from your school
Personal Information we collect from you or from your School may include:
Full name and contact information, including email address and business mailing address
Payment information (if applicable)
User content, feedback, assignments, and annotation files, such as content provided by students and content provided by teachers and administrators relating to students
School, grade, and classroom affiliation
Access and usage data about your use of the features and functionality of the Services
Login information, such as username and password
Information provided in response to surveys and promotions we make available to you
b. Information we collect from third parties
Information from other sources: We may obtain information from other sources, including through our service providers, affiliates, third-party information providers, business partners, or through transactions such as mergers and acquisitions. We may combine this information with other information we collect from or about you. In these cases, our Policy governs the handling of the combined Personal Information. We use this information to operate, maintain, and provide to you the features and functionality of the Services, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you. We may also collect information about you that is publicly available.
When we provide our Services to Schools, some of the above information is directly related to an identifiable student and is maintained by the School or related entity or organization, or by us on behalf of such entity. This Policy refers to that type of information as “Student Data.” Student Data may include “educational records” as defined by the Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. § 1232(g).
c. Information we collect automatically when you use the Services
We and our third-party service providers may automatically collect information about you and your computer or mobile device when you access, use, or receive our Services, by using certain technologies that are further described below. These technologies help us learn more about how our users like to engage with our Services and help us improve our offerings and the functionality of our Services. These technologies may include:
Mobile device identifiers
7. HOW WE USE PERSONAL INFORMATION
Please note: We do not sell Student Data. For more information on the limited purposes for which we use Student Data, please see below and the “Privacy Disclosures for Children and Students” section.
We use the Personal Information we collect to operate, maintain, and provide our Services, to make several features and functionality of the Services available to you, and as directed by your School, parent, or guardian (if applicable). We also use your Personal Information to support your questions and concerns, to personalize your content so that it is relevant to the state, city, or country you are using the Services from, and to send you relevant news, alerts, and marketing communications. We also use this Personal Information to help with our business operations, including development of new products and services. In addition, we may use the Personal Information to comply with our legal and contractual obligations, including enforcing our contractual rights, protecting our business interests, and investigating and protecting against any fraudulent activity. We also may use your Personal Information for any other lawful, legitimate business purpose.
We may combine any of the Personal Information that we collect from you with other information, including information we obtain from third parties, or with information derived from any other products or services we provide. We will use this information for the purposes described in this Policy.
8. RECIPIENTS OF PERSONAL INFORMATION
In accordance with how we use your Personal Information, we may share your Personal Information with the following:
Other users of the Services. Other registered users of our Services, such as teachers or administrators, may be able to see your profile information (e.g., username, profile photo, title and other employment- or education-related information and content, and other preferences and information), view the information and other content you provide, and communicate with you within the Services.
Service providers and advisors. Third-party vendors, independent contractors, and other service providers that perform services for us or on our behalf (which may include providing mailing or email services, tax and accounting services, payments processing, data enhancement services, fraud prevention, web hosting, or providing analytic services) may be able to see your profile information (e.g., username, profile photo, title and other employment- or education-related information and content, and other preferences and information).
The public. When you use our Services or engage with us on our social media platforms, content and information that you post on message boards, blogs or posts, or that you allow us to make public may be available to other visitors to our Services and to the general public.
Social media networks. When you use our Services, content that you share through social media may be shared with your social media account provider and your friends, followers, or contacts on the connected social network.
Law enforcement, regulators, and other parties for legal reasons. Third parties as required by law or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) comply with legal process; (c) respond to requests from public or government authorities, including public or government authorities outside your country of residence; (d) enforce the terms of our agreement and pursue available remedies or limit the damages that we might sustain; and/or (e) exercise or protect our rights, privacy, safety, or that of our affiliates, clients, you, or others. We may also disclose Personal Information to governmental regulatory authorities as required by law, including for tax or accounting purposes, in response to their requests for such information or to assist in investigations.
Merger or acquisition. In connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company, the company receiving the Personal Information would be obligated to follow this Policy.
Consent. We may disclose Personal Information with any other entity disclosed to you at the time we collect your information or with your consent or at your direction.
We may also share information with others in a de-identified, aggregated, or otherwise anonymized form that does not reasonably identify you directly as an individual.
9. MARKETING AND ADVERTISING
Please note: As explained further below, we do not disclose Student Data for targeted advertising purposes. For more information about our third-party tracking and online advertising in other contexts, please see below.
a. Advertising Service Providers
We may work with providers of advertising services (“Advertising Service Providers”) to collect and use information about your access and use of nonaffiliated websites and applications in order to provide behavioral data to us. Advertising Service Providers include advertising networks, data exchanges, traffic measurement service providers, marketing analytics service providers, and other third-party service providers. Such Advertising Service Providers enable us to display advertisements based on your use of the Services and other websites or applications you have visited, including for inquirED content, products, or services that may interest you. Such providers also help prevent you from seeing repeated advertisements and enable us to research the usefulness of certain advertisements.
10. DO-NOT-TRACK PREFERENCES
Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. We do not currently respond to browser DNT signals or other mechanisms that might enable consumers to opt out of tracking on our Services.
11. PERSONAL INFORMATION PREFERENCES CONTROL
Below are some ways you can control the collection and use of your information in connection with the Services.
a. Email marketing preferences
From time to time, we may use Personal Information to send you details of new products or services, updates, and other information that may be of interest to you. If you no longer want to receive these communications from us, you may opt out of receiving our promotional emails by following the instructions to unsubscribe included in those communications. If you opt out, we may still send you non-marketing communications, including information about your accounts and our transactions with you.
b. Information storage preferences
You may, at any time, log into your account and manage or modify the Personal Information stored in your account. In addition, you may contact us at firstname.lastname@example.org for any questions or concerns about the Personal Information we have about you.
c. Additional privacy rights
In accordance with applicable privacy law, and depending upon the jurisdiction in which you reside, you may have the right to request to access, correct, or delete your Personal Information or request to opt out of certain types of data practices. Eligible users can submit a request by emailing us at email@example.com.
Please note that if you are a student who accesses the Services through a School, or the student’s parent or legal guardian, you must contact your School to submit a request to access, modify, or delete your Personal Information.
d. Reliance on teacher, administrator, or parental instructions
We may rely on the instructions that we reasonably believe are given by a teacher, administrator, parent, or legal guardian in connection with a student. For example, if a person calls our customer support number and provides the account information we request, we may assume that the person calling is the teacher, administrator, parent, or legal guardian of such student. We will not be responsible for any disclosure made in good faith and following reasonable procedures in responding to a request for disclosure of a student’s information from such individual.
12. SECURITY OF YOUR PERSONAL INFORMATION
We take our responsibility to protect your Personal Information seriously. We have implemented security measures designed to prevent your Personal Information from being lost, used, accessed, altered, or disclosed in an unauthorized or unlawful way. However, no method of transmission over the internet or method of electronic storage is 100% secure, and we cannot and do not guarantee that Personal Information is completely secure and safe from such risks. By using the Services, you understand and assume the risks associated with your activities on the internet. If you have reason to believe that your information is no longer secure, please contact us at firstname.lastname@example.org.
13. THIRD PARTIES
We may update this Policy from time to time. When we make material changes to this Policy, we will revise the “Last Revised” date at the top of this Policy. All changes to this Policy are effective when they are posted on this page.
15. CONTACT INFORMATION
We welcome your comments or questions about this Policy. Feel free to email us at email@example.com. You may also contact us at our address: inquirED, 4422 N Ravenswood Ave, Chicago, IL 60640.
16. PRIVACY DISCLOSURES FOR CHILDREN AND STUDENTS
a. Student data principles
We consider Student Data to be confidential and do not use Student Data for any purpose other than to provide the Services to the Schools and in accordance with any contractual agreements with the Schools.
Student Data is owned and controlled by the School.
Our collection, use, and disclosure of Student Data is governed by our agreement with the applicable School, and by the provisions of FERPA, COPPA, and applicable state laws that relate to the collection of Student Data.
We collect, maintain, use, and share Student Data only for an authorized educational purpose and as described in any contractual agreements with the School, or as directed by the School or the applicable educator, parent, or guardian.
We do not use or disclose Student Data for targeted advertising purposes.
We do not build a personal profile from Student Data other than in furtherance of an educational purpose.
We maintain a data security program reasonably designed to protect Student Data.
We will clearly and transparently disclose our data policies and practices to our users.
We will never sell Student Data unless the sale is part of a corporate transaction, such as a merger, acquisition, bankruptcy, or other sale of assets, in which case we will require the new owner to continue to honor the terms provided in this Policy or we will provide the School with notice and an opportunity to opt out of the transfer of Student Data by deleting the Student Data before the transfer occurs.
We will not make any material changes to our Policy or contractual agreements that relate to the collection or use of Student Data without first giving notice to the School and providing a choice before the Student Data are used in a materially different manner than was disclosed when the information was collected.
b. Student Data we collect
Student Data we collect includes:
School, grade, and classroom affiliation
Access and usage data about students’ use of the features and functionality of the Services
Messages and user content
Feedback provided by students
Information provided in response to surveys we make available to students (if any)
Student Data may include “educational records” as defined by the Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. § 1232(g).
c. How we use Student Data
Our use of Student Data is in accordance with our agreements with the School and subject to the School’s instructions and control. Generally, we use Student Data to operate, maintain, and provide our Services to Schools and to support, improve, and develop our educational product and service. This may include:
To permit teachers and other School users to monitor students’ engagement and performance, plan lessons, and otherwise support instruction
To provide teachers and School users with reports and education or product recommendations
To customize the user experience
For analytics purposes, to understand how our Services are accessed and used and how they perform, so that we may improve design and functionality. We also collect analytics on aggregate information that does not identify any individual user.
To diagnose problems, troubleshoot issues, and provide maintenance and support
For clarity, we do not use Student Data: (a) to advertise or market to students on our Services or to direct targeted online advertising to students on our Services, (b) to develop a profile of a student other than for the purpose of providing educational services or as authorized by School, or (c) for any other commercial purpose unless authorized by School or permitted by applicable law.
d. How we share and disclose Student Data
We disclose Student Data solely as needed to provide the Services on behalf of specific Schools in accordance with our contractual agreements with those Schools. Please note that Student Data and teacher account usage data may be disclosed to or accessible by users who are authorized to use the Services on behalf of the School. Student Data may also be accessible to anyone who accesses your account with your login credentials. To avoid unauthorized access to Student Data, please do not distribute your login credentials and keep all login information secure.
In addition, depending on the manner in which the Services are used by the School and the terms of the agreement between the School and inquirED, we may provide access to certain Student Data to the student and/or to the parent or guardian of the student about whom the records relate, for the purpose of monitoring student usage and activity and evaluating the effectiveness of the School’s use of the Services. We also disclose Student Data to our trusted service providers who have a legitimate need to access such information on our behalf, subject to appropriate contractual terms to protect such data. Furthermore, we may disclose Student Data in connection with a business transaction or to support our legal rights and obligations, as described under the “Recipients of Personal Information” section above.
e. How we use De-Identified Student Data
We may collect and use De-Identified Data to operate, analyze, improve, market, or develop educational sites, services, or applications to recommend content or services relating to school or educational purposes, and to demonstrate the effectiveness of our products or services. “De-Identified Data” means data from which all personally identifiable information, including direct and indirect identifiers, has been permanently removed or obscured so that the remaining information does not reasonably identify an individual and there is no reasonable basis to believe that the information can be used to identify an individual. If we share or publicly disclose De-Identified Data, that data will be aggregated or anonymized to reasonably avoid identification of a specific School or individual student.
f. How we retain Student Data
We do not knowingly retain Student Data beyond the time period necessary to support the School’s educational purpose. We do not delete or de-identify any Student Data from an active student user account associated with a School except at the direction of the School.
Please note: Schools are responsible for maintaining current student rosters and identifying Student Data that the School no longer needs for an educational purpose by submitting a deletion request. School users may contact us at firstname.lastname@example.org to request deletion of Student Data. Even if we do not receive a deletion request from a School, we may delete or de-identify Student Data after a period of inactivity in accordance with our standard data retention practices.
We may not be able to immediately or completely delete all data in all instances, such as information retained in technical support records, customer service records, backups, and other similar business records. We do not delete information that has been de-identified or disassociated with personal identifiers such that the remaining information cannot reasonably be used to identify a particular individual. We will also not delete any Student Data that has been transferred or stored in a personal account except at the request of the parent or student.
g. Access to Student Data
We provide a mechanism for Schools to allow parents and legal guardians to review Student Data upon request. If you are a student, or the parent or legal guardian of a student, please contact your School to submit a request to access, review, or modify Student Data. We will work with the School upon the School’s request to help facilitate responses to these inquiries.
h. Questions about Student Data
If you have questions about specific practices relating to Student Data provided to inquirED by the applicable Schools, please direct your questions to your School.
17. PRIVACY NOTICE FOR RESIDENTS OF CALIFORNIA
Residents of California may be entitled to certain rights with respect to Personal Information that we have collected about them under the CCPA:
Right to Know and Access. The right to request to know more about the specific pieces or categories of Personal Information we have collected, the categories of data sources, and the categories of third parties with whom we have shared the Personal Information for a business or commercial purpose in the past 12 months, and to access a copy of your Personal Information.
Right to Request Deletion. The right to request the deletion of Personal Information that we have collected from you, subject to certain exceptions.
Right to Correction. The right to request we correct inaccuracies in your Personal Information, taking into account the nature of the data and the purposes for which we process that data.
Right to Opt Out of Sale or Sharing of Personal Information. The right to direct us not to “sell” (as such term is defined by the CCPA) Personal Information we have collected about you to third parties or to “share” your Personal Information for cross-context behavioral advertising.
You also have the right to be free of discrimination for exercising these rights. Note that if the exercise of these rights limits our ability to process Personal Information (such as in the case of a deletion request), we may no longer be able to provide you our Services or engage with you in the same manner.
To request to exercise these rights, please email us at email@example.com.
We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account, if you have one. In certain circumstances, we may decline or limit your request, particularly when we are unable to verify your identity or locate your information in our systems, or as permitted by law.
You may authorize another person (your “agent”) to submit a California consumer rights request on your behalf. Authorized agents must submit the request via email to firstname.lastname@example.org and include a signed letter from the inquirED user confirming the agent has permission to submit the request on the user’s behalf. In certain circumstances, we may need to request additional information to verify the identity of the user about whom the request is being made and/or to verify that the user has provided the authorized agent permission to submit the request, and it may take additional time to fulfill agent-submitted requests. Please note that for privacy and security reasons, we will direct future communications to the inquirED user on whose behalf the request was made. We may deny a request in the event we are not able to verify the authorized agent’s authority to act on your behalf.
Shine the Light. California “Shine the Light” law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. We do not share your Personal Information with third parties for direct marketing purposes without consent.
Minors. We do not sell the Personal Information of consumers we know to be less than 16 years of age.