Last Updated: August 27, 2021
- Information We Collect and Process
- How We Use Information
- When We Disclose Personal Information
- Children Under 13
- Your Choices
- Data Integrity and Data Retention
- Third Party Services and Links
- Google Services
- Data Transfers
- European Union (EU) Data Subjects – Legal Grounds and Your Rights
- California Privacy Rights
- Changes and Updates to This Policy
- Contacting Us
1. Information We Collect and Process
In describing our collection, use, processing, and sharing of information in this Policy, we refer to our collection and use of Personal Information. We collect Personal Information, as well as non-personally identifiable information through the Site.
In our operation of the Site, and our provision of services to you and other users, we collect, use, process, and retain all information, including Personal Information, that you disclose to us. Our use and disclosure of Personal Information is described in this Policy. Our disclosures of Personal Information to our affiliates and other third parties are described in greater detail under the "When We Disclose Personal Information" heading below. In general, the types and amount of Personal Information we collect vary depending on the activity. We endeavor to limit the collection of Personal Information to information we believe is minimally necessary to achieve our stated collection purposes.
The types of Personal Information we collect and process include:
- Contact information, such as your first and last name, email address, and telephone number.
- Account data, such as your username, password, and account settings.
- Profile information, such as a photo, biography, language, country, or other data.
- Shared content when you interact with other users or share content publicly, including by posting reviews on a course page, or submitting comments, questions, or feedback on the Site.
- Course activity data, such as course enrollment, curriculum materials, videos and other educational media, and the “Teacher Notebook” (as further described below).
- Survey and other data if you complete a survey or participate in a promotional offer on the Site.
- Communication and support data if you contact us for support or to report a problem or concern (regardless of whether you have created an account), such as your contact information, messages, and other data in connection with such communication.
We collect Personal Information you provide directly to us in our required submissions, such as in registration forms, teacher profiles, sign-ups for virtual or in-person events, requests for support, and emails or other communications you send us. We may also obtain Personal Information from our affiliates and partners. Additionally, some Personal Information may be collected automatically. This is described below in "Passive Data Collection."
Passive Data Collection. We may receive passively-collected information through a variety of methods including but not limited to:
Cookies and Web Beacons. Like most web-based services, we may use a variety of methods, including "cookies" and "Web beacons," to collect information. A cookie is a small data file that is transferred to an Internet user's browser by a web server. Cookies are designed to store basic information, such as a user's preferences. A Web beacon (sometimes referred to as a "clear GIF") is a small string of code placed in a web page, email message or other media format in order to gather statistical usage information.
We use the following specific cookies on our Site:
Strictly Necessary Cookies
These cookies are essential in order to enable you to move around the Site and use its functionalities.
These cookies remember choices you make such as the country you visit our Site from, language and search parameters. This data can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant.
These cookies collect anonymous or pseudonymous information on how people use our Site.
Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to you. Please note that if your browser is set to reject cookies, the Site may not recognize you when you return to the Site and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting cookies. To find out more about cookies and your choices with respect to collection and use of such data, you may visit www.allaboutcookies.org, or the Digital Advertising Alliance’s (DAA) opt-out page at http://www.aboutads.info/choices, or the National Advertising Initiative’s (NAI) opt-out page at http://www.networkadvertising.org/choices/.
Do Not Track
Do Not Track (“DNT”) is a privacy preference that users can set in their web browsers. When a user turns on DNT, the browser sends a message to websites requesting that they do not track the user. At this time, we do not track your or any other users’ Personal Information over time and across third party websites. We therefore do not respond to browser DNT signals. For information about DNT, visit www.allaboutdnt.org.
The information that we collect with these automated methods may include, for example, your IP address, information about how you interact with content, browser type, system type, device type, the content and pages that you access, the date and time you view pages, and the page from which you navigated to the Site.
Click-through URLs. In some of our email messages, we may use a "click-through URL" linked to content on the Site. When you click one of these URLs, you pass through a separate web server before arriving at the destination page. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
Location-Based Services. We may collect, use, process, and share precise location data, including the real-time location of your mobile or fixed location device.
Usage Information. We log information about your use of the Site, including the type of browser you use, how long you access websites, actions taken on our websites, whether you are a first-time user or repeat user, pages viewed, your IP address and the pages you visited before navigating to the Site.
2. How We Use Information
Generally, we use Personal Information to establish and enhance our relationship with our users through three main channels: (1) Communication; (2) Optimization and Research; and (3) Sharing Features. Below, we provide some specific examples of how we use the Personal Information and other information we collect.
Communication and Responding to Requests. We use user information, including Personal Information, to provide users with customer support, respond to users' requests, send updates, seek your opinions and feedback, and connect users to LER services, and to products and services of our licensees and other third parties.
Optimization and Research. We use user information, including Personal Information, behavioral metrics, and other non-personally identifiable information to operate, provide, improve, and maintain the Site, to develop new products and services, to prevent abuse and fraud, and for other administrative and internal business purposes.
We also use user information for research purposes in order to evaluate the effectiveness and use of our Site by different demographic groups within our user base. The purpose of our research is to optimize our Site and its educational goals. We share user information with our third party research partners to further these goals.
Sharing Features. We use user information, including Personal Information and any other information you submit directly or through passive means, to provide you with various ways to connect and share content (e.g., web content, media, and services) with third parties. For example, we may provide you with the opportunity to upload content in connection with a piece of curriculum you are adapting and, to the extent you choose to share such content through the Site, other users will see your username (which is your email address) on the Site.
We provide our users with teaching coaches who assist our users with implementing the content of our Site into their classrooms. We encourage our users to upload videos to these coaches so that they can more effectively help our users. If you send us any such videos, we will not use such videos for any commercial purpose and will only use such videos to provide virtual coaching to such user. We will not provide access to such videos to any third parties.
Similarly, we encourage our users to keep notes in the "Teacher Notebook" section of the Site and any such notes will not be used for any commercial purpose.
3. When We Disclose Personal Information
We do not rent or sell email addresses, phone numbers, or other Personal Information. We do not share Personal Information with third parties except in the limited circumstances described in this Policy.
Events. In connection with virtual and in-person events that we host, we may provide you with the option to share your registration information with the sponsor of such event. Each of these sponsors may have their own privacy policies. We do not control and are not responsible for these third parties, their privacy policies or their use or treatment of your Personal Information or other information. You should therefore carefully review all such third parties' privacy policies, as we make no representation regarding, and have no control over, how any third parties use your Personal Information or other information.
Service Providers. We may provide Personal Information to third parties for their use in performing internal business functions (e.g., email transmission, customer service, maintenance, security, data analysis, beta testing, or data hosting) on our behalf. We require such third parties to only collect and use Personal Information in accordance with this Policy, to maintain the confidentiality, security, and integrity of such Personal Information, and for no purpose other than providing us with our requested services.
A list of the service providers with whom we share your Personal Information is set forth below. This list may be updated at any time. Please check this Policy for the most current information.
We use the following service providers:
Google Single Sign-On
Site authentication is optionally provided via Google Single Sign-On. A Google email address is required, and no other Sprocket user information is shared.
An optional Google Classroom integration is provided for users who wish to store curriculum materials from Sprocket.
We use Google Drive to store user-uploaded files. No user information (except that captured in any file content) is shared with Google.
We use Google Analytics to analyze our users' use of the Site. Google Analytics provides us with aggregated data in order to help us make informed business decisions. We have indicated to Google that information collected through our use of Google Analytics on the Site should not be shared with third parties, even in an anonymous, aggregated fashion. Ultimately, Google, as a third party, controls information collected through Google Analytics and you should check and be comfortable with their privacy practices prior to using the Site.
Amazon Web Services
We use Amazon Web Services to store user-uploaded files, send emails, and track email bounce and receipt rates. No user information (except that captured in any email or file content) is shared with Amazon.
Facebook Single Sign-On
Site authentication is optionally provided via Facebook Single Sign-On. A Facebook account is required, and no other Sprocket user information is shared.
LinkedIn Single Sign-On
Site authentication is optionally provided via LinkedIn Single Sign-On. A LinkedIn account is required, and no other Sprocket user information is shared.
Interactive Features. If you use a forum, bulletin board, discussion group, user commenting features, or other interactive or social features that may be offered through any of the Site, you should be aware that any Personal Information you submit, display, or publish there is considered publicly available and can be read, collected, used, and disclosed by other users of those features, by us, and other third parties without restriction. To request removal of your Personal Information from our blog or community forum, contact us at the information provided at the end of this Policy. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.
Change of Ownership. In the event of a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, we reserve the right to transfer all of your Personal Information, including names, email addresses, and phone numbers, to that entity. We will use reasonable efforts to notify registered users of such a transfer (by a posting on our homepage, or by email to your email address that you provided to us, as chosen by us in our discretion).
4. Children Under 13
We do not knowingly seek or collect Personal Information from users under the age of 13. If we determine we have inadvertently gathered Personal Information from a user under the age of 13, we will promptly delete any and all such Personal Information from our records. The Children's Online Privacy Protection Act of 1998 and other laws have been established to protect the privacy of minors and we endeavor to abide by all applicable federal and state laws and guidelines regarding youth privacy.
5. Your Choices
Depending on your jurisdiction, you may have certain rights regarding our collection, use, and sharing of your Personal Information. If you have any questions regarding these rights, please contact us at: firstname.lastname@example.org. Please note that we may request additional information to respond to or fulfill any requests regarding your rights under applicable laws or regulations.
If you are a resident of California, the European Union, Switzerland, or United Kingdom, you have additional rights. See the applicable sections below.
Submitting Personal Information. If you do not want to submit Personal Information that is necessary to provide or use a service or to fulfill your request, you will not be able to access and/or participate in certain services provided through the Site. In addition, your refusal to submit Personal Information may limit our ability to respond to your technical support inquiry in a timely fashion.
Accessing and Editing Personal Information. You may, at any time, access, update, correct, or delete certain Personal Information that you have provided to us by updating your user profile or by contacting us at the mailing or email address provided at the end of this Policy.
Direct Communications. If you want to remove yourself from receiving direct communications, including email notifications of activities in the groups you have subscribed to, you can unsubscribe from such communications through the user profile page when logged into the Site. You can always opt out of any subscription for emails, involving any updates, information, postings, and/or news, by clicking “Unsubscribe” at the bottom of the email. You also acknowledge and agree that there may be instances where we may elect to notify you about administrative notices regarding your account with us, such as to inform you about changes to our terms, conditions, and policies, that your account may be expiring, or to provide you with other relevant administrative information about your account. Because this information is important to your interaction with us, you may not opt out of receiving these communications.
Account Deletion. If you submit Personal Information, you may delete your account with us at any time. If you delete your account, your Personal Information and any and all other account-related information including, but not limited to, user profile data and any other data or content specifically associated with your account, are also permanently deleted. Please be aware that if you delete your account, your Personal Information may be retained in our backup files and archives for a reasonable period of time for legal purposes. If you choose to have an account with us in the future, you will have to sign up for a new account, as none of the information you previously provided or saved within your account will have been saved.
We take industry-standard measures, including the implementation and maintenance of physical, electronic, and managerial procedures, in an effort to assure the security, integrity, and accuracy of all Personal Information that we collect. Our efforts include procedures designed to avoid unauthorized access, alteration, misuse or disclosure of Personal Information. Although we make good faith efforts to maintain the security of such Personal Information, we cannot guarantee that it will remain free from unauthorized access, use, disclosure, or alteration. Further, while we work hard to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent "hackers" or other unauthorized persons from illegally accessing or obtaining this information. Therefore, although we use industry standard practices to protect your privacy, we do not promise, and you should not expect, that your Personal Information will always remain private.
If we learn of a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Site and providing Personal Information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your account information and usage. The safety and security of your information also depends on you. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately.
7. Data Integrity and Data Retention
We collect and use Personal Information in accordance with this Policy and only for the purposes stated in this Policy and/or at the time we request such Personal Information from our users, or for such purposes to which a user may otherwise consent. We do not use or share our users' Personal Information in a way that is incompatible with the purposes for which such Personal Information was requested and authorized for use by us. We retain Personal Information for no longer than is commercially useful to carry out our business purposes, or as we believe may be legally required, including, to provide you any services, communications, or access to this Site, to document our business relationship with you, and otherwise as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Please be aware that even if you update or remove Personal Information that you have provided to us, your Personal Information may be retained in our backup files and archives for a reasonable period of time for legal purposes.
8. Third Party Services and Links
LER's content, including services, media, newsletters and communications that we send to our users, may contain links to content provided by third parties. Third party websites and services are not associated with or authorized by us, unless otherwise specifically indicated by us in this Policy or in communications that we send. We are not responsible for any content appearing on third party websites or for third parties' privacy or security practices regarding any information, including Personal Information, gathered at those third party websites or services. Any Personal Information or other information you provide on third party sites or services, including your contact details and/or geographic location with application providers when you opt in to their location services, and any Personal Information or other information collected by third parties through such third party sites or services, is provided directly to that third party and is subject to its policies governing privacy and security. We encourage you to learn about third parties' privacy and security policies before providing them with Personal Information.
9. Google Services.
The services detailed below are optional and provided as a convenience to you. Basic Site functionality does not require that you make use of any of these services.
Google Single Sign-on. You may choose to authenticate with the Site using your Google account with Google Single Sign-on. Basic profile information (name and email address) is requested and stored during this process for the purpose of account generation.
Google Drive and Google Picker. You may choose to allow access from the Site to your Google Drive account as a convenient way to upload or attach files. When importing files from Google Drive, the Google file identifier and file name are stored. The permissions on the file may be adjusted to allow it to be accessible to other Site users.
Google Classroom. The Site allows you to share materials to your Google Classroom classes. A list of your active classroom courses is requested but not stored on our servers. Additionally, permission is requested to allow access to student coursework to allow posting of materials to the course feed.
10. Data Transfers
The Site is hosted in the United States. If you use the Site from the European Union, or any other jurisdiction with laws governing data collection and use that may differ from United States law, please note that you are transferring your Personal Information outside of those jurisdictions to the United States. The United States does not have the same data protection laws as the European Union and other regions. We will take steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it. If you are located in the European Economic Area, United Kingdom, or Switzerland, we ensure an adequate level of protection is afforded to transferring your Personal Information out of the EU/EEA by ensuring, where required by law, at least one of the following safeguards is implemented:
- Transferring Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information by the EU Commission, or
- Using specific contracts approved by the EU Commission which give Personal Information the same protection it has in Europe.
You may be entitled, in accordance with applicable law, to request a copy of the specific safeguard by contacting us as described below.
11. European Union (EU) Data Subjects – Legal Grounds and Your Rights
If you are located in the European Union (EU) or the European Economic Area (EEA), the following applies additionally:
Legal Grounds for Processing
The processing of the above listed Personal Information is based on the following legal grounds:
- Contact information / Account Data / Communication and Support / Shared Content / Course Activity Data: We process
this data, Art. 6 (1) (b) GDPR in order to
- provide and administer our services;
- process your requests and orders for courses and curriculum, specific services, information or features;
- respond to an inquiry and any related activity that may result from your inquiry; and
- post your reviews, comments, feedback and/ or questions on the Site.
- System Data / Usage Data: We have a legitimate interest in processing this data, Art. 6 (1) (f) GDPR. Our interests
- ensuring the security and integrity of this Site and its content; and
- improving or otherwise develop this Site and our products and services.
- Surveys / Offers: We have a legitimate interest to process personal Data submitted by voluntary participation in a
survey or promotional offer, Art. 6 (1) (f) GDPR. Our interests are
- improving our Site and products; and
- promoting our services.
- Profile Data / Location Data: We collect and process this data only with your consent, Art. 6 (1) (a) GDPR.
The sharing of Personal Information is based on the following legal grounds:
- With teachers and other users of the Site: We share your data in order to provide our services, Art. 6 (1) (b) GDPR.
- As necessary to administer, market, or sponsor promotions and surveys: We share your data in order to provide our services according to the survey or promotion, Art. 6 (1) (b) GDPR.
- With legal, governmental, or judicial authorities: We share your data in order to defense rights, Art. 6 (1) (c) GDPR.
- As necessary to pursue a legitimate business or legal need, to prevent physical, financial, or other harm, injury or loss: We have a legitimate interest to share your data, Art. 6 (1) (f) GDPR. Our interest is to provide our services and prevent damages.
- With third party advertisers and networks, with third parties outside this Policy, aggregated or de-identified data: We share your data only with your consent, Art. 6 (1) (a) GDPR.
Data Subject Rights
Pursuant to the EU General Data Protection Regulation 2016/679 (GDPR) and where allowed by law, such as in the European Economic Area (EEA), United Kingdom, and Switzerland, and provided that the legal preconditions are fulfilled, if you are a resident of the EU, United Kingdom, or Switzerland, you have the right to:
- access your Personal Information;
- ask us to correct your Personal Information;
- ask us to delete your Personal Information;
- ask us to restrict processing of your Personal Information;
- obtain your Personal Information in a structured, machine readable format for data portability purposes;
- withdraw your consent at any time by emailing us at email@example.com
In addition, you can object to the processing of your Personal Information in some circumstances (including where we are using the data for direct marketing).
You further have the right to lodge a complaint with a data protection supervisory authority if you believe that our processing of your Personal Information does not comply with GDPR.
These foregoing data subject rights may be limited, for example, if fulfilling your request would reveal Personal Information about another person, or if you ask us to delete information which we are required by law to keep or have overriding legitimate interests in keeping. You can find more information here: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.
12. California Privacy Rights
In addition to the rights set forth in this Policy, California Civil Code Section 1798.83 permits California residents who are individual consumers or users of the Site to request certain information regarding its disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us via mail or email at the address identified in the "Contacting Us" section.
13. Changes and Updates to This Policy
We may update this Policy from time to time. If we do, we will update the "effective date" at the top of the Policy. If we make material changes to how we use Personal Information, we will attempt to notify you of the change and to give you the opportunity to exercise choice as to how your Personal Information is used. We will post the updated Policy on the Site, and if we have your email address, we will send notice of the update to that email address.
We encourage you to review this Policy periodically to stay informed about our collection, use and disclosure of Personal Information. Your continued use of the Site constitutes your agreement to this Policy and any updates.
14. Contacting Us
If you have questions about this Policy, you may contact us at firstname.lastname@example.org.
You may also write to us at:
Lucas Education Research
George Lucas Educational Foundation
P.O. Box 3494
San Rafael, CA 94912