Revision date: September 26, 2016
Note to Parents of Students who use Renaissance’s Products
When you access or use the Website, we may collect two types of information: (1) personally identifiable information; and (2) information that is not personally identifiable. Personally identifiable information includes information that identifies you personally, alone or in combination with other information available to us. Examples of personally identifiable information may include an individual’s name, address, telephone number, email address, or school.
As part of the standard operation of the Website, you may submit personally identifiable information. For example, when you create an account, you may provide personally identifiable information. In addition, should you attempt to communicate with Renaissance via the Website, email, or phone, you may provide us with personally identifiable information and we may keep your message, email address, contact information, and other personally identifiable information. At your option, you may provide additional personally identifiable information about yourself. When you visit the Website, however, you are not required to create an account with the Website or provide any personally identifiable information.
As part of the standard operation of the Website, we also collect non-personal information from you, including your browser type, operating system, IP address and the domain name from which you accessed the Website. In addition, we may collect information about your browsing behaviour, such as the date and time you visit the Website, the areas or pages of the Website that you visit, the amount of time you spend viewing the Website, the number of times you return to the Website, the referring web page, pages visited, location, your mobile carrier, device and application ID’s and other click-stream data.
Renaissance does not rent or sell personally identifiable information and non-personally identifiable information to other companies. Instead, we use information collected via the Website in the following ways:
- Contact you when necessary;
- Respond to you regarding information you have requested;
- Communicate with you regarding Renaissance or the Website;
- Provide you with customized content and advertising for various products or services;
- Administer the Website, monitor its usage, and diagnose problems with it;
- Remember you when you return to the Website, so that you don’t have to re-submit information and preferences;
- Contact you with information and promotional materials and offers from us as well as from our affiliates, partners and other third parties, if you have agreed to receive such communications;
- Conduct research to improve our content and services; and
- To protect the security or integrity of the Website and our business.
Renaissance may sell, transfer, or otherwise share some or all of its assets, including your personally identifiable information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.
We have the right, but not the obligation, to: (1) retain your personally identifiable information for as long as your account is active or as needed to provide you services or access to or use of the websites; and (2) retain and use your personally identifiable information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. We have the right, but not the obligation, to retain your non-personal information whether your account is active, inactive, or deactivated.
Do Not Track
Certain browsers have settings that allow you to turn on a “Do Not Track” (“DNT”) feature. The Website supports DNT by stopping the collection of information that allows us to tailor content based on your recent visits to the Website and third parties (e.g., Partner) websites. When you enable DNT on your browser, we stop the collection of unique browser cookies that links your browser to visits to this Website and across other websites. If you enable DNT on your browser, however, certain features of the Website may not function properly.
We may from time to time use third-party service providers to track and analyse usage of the Website. The third-party service providers access and use cookie and log information in combination with personally identifiable information, such as name, IP address and email addresses, to assist in tracking the Website. These third-party service providers are granted access to the information via the Website.
Subject to the usage of the third-party service providers discussed above, we do not intentionally or knowingly allow other parties to collect personally identifiable information about your online activities over time and across different websites, when you visit the Website, or use any of the services offered on the Website. We do not, however, have control over third parties’ activities, including if a third party accesses information based on your visit to the Website.
We also use “web beacons,” “pixel tags,” “clear GIFs” or similar means (individually or collectively “Web Beacons”) on our Website. A Web Beacon is an electronic image, often a single pixel, embedded on web pages. Web Beacons are ordinarily not visible to users. Web Beacons allow us to count the number of users who have visited certain pages of the Website, to deliver branded services, and to generate statistics about how our Website is used.
Renaissance maintains email lists to keep interested parties informed about our company, events, products, support, and more. We do not sell the addresses on our list, but we may make information available to specific business partners, sponsors, or service providers.
Users may voluntarily request to join our mailing lists by signing up or opting in through a form on our Website. To be removed from a Renaissance email and/or mailing list, email UKprivacyofficer@renlearn.co.uk with REMOVE ME in the subject line.
Accessing, Changing or Deleting Your Information
If your personally identifiable information changes or you desire to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete, Renaissance will take reasonable steps to permit the correction, amendment, or deletion of your information. To do so, please send an email message to UKprivacyofficer@renlearn.co.uk and putting the word “UPDATE” in the subject line of the message. If you desire to delete your account, please go to your account and follow the instructions to delete that account.
EU Individuals have the right to access their personal information. Upon request, Renaissance will grant individuals access to personal information that it holds about them provided there is no information about third parties. In such cases, Renaissance will redact such third party information.
Your personally identifiable information will generally be stored in databases maintained by Renaissance or our service providers. Most of these databases are stored on servers located in the United States. Renaissance may use third-party storage or service-provider companies to store your personally identifiable information, some of which may be outside of the United States.
We have taken certain physical, electronic, contractual and administrative steps to protect the confidentiality, security, and integrity of your personally identifiable information. However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee its absolute security. It is your responsibility to maintain the confidentiality of your Website account information.
EU – U.S. Privacy Shield
Renaissance is responsible for the processing of personal data it received, under the Framework. For personal data transferred from the EU, if Renaissance transfers your personal data to a third party, Renaissance will ensure that the third party is contractually obligated to process your data only for limited, specific purposes consistent with this Policy. Renaissance will also ensure that the third party will apply the same level of protection to that data as the EU-U.S. Privacy Shield Principles and will notify us if it makes a determination that it can no longer meet this obligation. Renaissance also complies with the Privacy Shield Principles for the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Framework, Renaissance is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Renaissance may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the EU-U.S. Privacy Shield, Renaissance strives to resolve all complaints about privacy and the collection or use of customer information. If you have questions about our parent company’s participation in the Privacy Shield program or have a complaint, please send an email to email@example.com. If you have any unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider JAMS or contact the UK’s Information Commissioner’s Office: https://ico.org.uk/for-the-public.
Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Links to Other Websites and Services
We constantly update the features of the Website to better serve you and all our customers, so this policy may also be revised from time to time. Renaissance may modify this policy without advance notice and any modifications are effective when they are posted here. By using the Website, you indicate your understanding and acceptance of the terms of the policy posted at the time of your use. If you have any questions, please contact us at your convenience.
Effective Date: September 15, 2016
Updates. Renaissance may revise this Policy from time to time and will make an updated version of this Policy available on a publicly accessible location. Subject to the foregoing, Renaissance will not make material changes to this Policy without first providing prominent notice to the educational institution and allowing them choices before data is used in any manner inconsistent with terms they were initially provided; and not make material changes to other policies or practices governing the use of Personally Identifiable Information that are inconsistent with contractual requirements.
School Control. The collection, input, use, retention, disposal, and disclosure of any Personally Identifiable Information submitted via the Applications are controlled by the School. Renaissance will not delete, change, or share any information from the Applications except as provided in this Policy unless we have a good faith belief that such action is necessary to: conform to legal requirements or to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements; or to enforce our contractual obligations. Renaissance also collects non-personally identifiable information, including aggregate data as described in this Policy.
- “Renaissance Application(s) or Application(s)” means Renaissance software products.
- “Authorised User” means a person, (including an educator, student or parent) given access rights to the Applications by or at the direction of the School who has the right to use the Applications under the licensing terms agreed upon by the School and Renaissance.
- “Personally Identifiable Information” (also known as Personal Data) includes: (i) a student’s name, (ii) the name of a student’s parent or other family members, (iii) the address of a student or a student’s family, (iv) a personal identifier, such as a social security number, student number, or biometric record, (v) other indirect identifiers, such as date of birth, place of birth, and mother’s maiden name, (vi) other information that, alone or in combination, is linked or linkable to a specific student that would allow a reasonable person in the school community, who does not have personal knowledge of the relevant circumstances, to identify the student with reasonable certainty, or (vii) information requested by a person who the educational agency or institution reasonably believes knows the identity of the student to whom record relates.
- “School” means customer schools, school districts or other educational organisations licensed to use the Applications.
Information, Including Personally Identifiable Information, That Renaissance Collects and Maintains.
- Usage Details. When Authorised Users access the Applications, Renaissance may automatically collect certain details about the Authorised User’s access to and use of the Applications. This information may include application or website traffic data, location data, logs and other communication data and the resources that educators and students access and use on or through the Applications.
- Device Information. Renaissance may collect information about an Authorised User’s computer device, mobile device, and Internet connection, including the device’s unique device identifier, IP address, operating system, browser type, and mobile network information.
- Stored Information and Files. The Applications also may access certain files, including metadata, stored on the Authorised User’s computing device in order to satisfy Authorised User requests to integrate those files into the functionality of the Applications (for example, to provide access to an e-Book or other stored materials).
- Information Input by Authorised Users. When using the Applications, Authorised Users will input information that is then stored by the Applications.
How Renaissance Uses Information. Renaissance will not use the Personally Identifiable Information it collects in the Applications to conduct targeted advertising directly to students, nor does it publicly disclose information submitted by Authorised Users. Renaissance uses the information, including Personally Identifiable Information, it collects:
- To provide Schools and Authorised Users with access to the Applications and its contents, and any other information, products or services, that the School requests from us.
- To provide Schools with account notices, including expiration and renewal notices.
- To carry out the respective obligations of Renaissance and Schools and enforce Renaissance’s rights arising from any contracts entered into with Schools, including for billing and collection.
- To notify Schools of changes to any products or services Renaissance offers.
- To estimate size and usage patterns.
- To store information about School and Authorised User preferences, allowing Renaissance to customize its services and Authorised Users’ experience.
- To maintain and improve Application performance or functionality.
- To improve educational products for adaptive learning purposes and for customizing learning; to demonstrate the effectiveness of Renaissance’s products; or for the development and improvement of educational sites, services, or applications.
Compliance with Applicable Law.
- Renaissance shall not disclose any Personally Identifiable Information from the Applications to any third party except: (i) if required by law or valid court order, (ii) as directed in writing by the School or, (iii) as permitted elsewhere in this Policy, including where the third party is bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential. Third parties are prohibited from using Personally Identifiable Information from the Applications to engage in targeted advertising.
- Privacy Shield. Renaissance’s U.S. Parent Company has certified with the EU-U.S. Privacy Shield with respect to the personal data they receive and process on behalf of our customers through our software and online services (the “Services”). Renaissance’s U.S. Parent has certified that it adheres to the Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement for personal data submitted by our customers in participating European countries through the Services, and their Privacy Shield certification is available here. They may also process personal data our customers submit relating to individuals in the EU via other compliance mechanisms, including data processing agreements based on the EU Model Clauses.
How Renaissance Shares Information.
- Renaissance and Renaissance’s U.S. Parent Company may share Personally Identifiable Information with third-party contractors to support operations of the Applications who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential. Third parties are prohibited from using Personally Identifiable Information to engage in targeted advertising.
- Renaissance and Renaissance’s U.S. Parent Company may share Personally Identifiable Information if it is required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request.
- Renaissance and Renaissance’s U.S. Parent Company may share Personally Identifiable Information if it reasonably believes disclosure necessary or appropriate to protect the rights, property or safety of Renaissance or Renaissance’s U.S. Parent Company, its customers or others, including to: (i) protect the safety of a child; (ii) protect the safety and security of the Applications; or (iii) enable Renaissance or Renaissance’s U.S. Parent Company to take precautions against liability.
- Renaissance and Renaissance’s U.S. Parent Company may share Personally Identifiable Information with law enforcement agencies or for an investigation related to public safety.
- Renaissance and Renaissance’s U.S. Parent Company may share Personally Identifiable Information with the Department for Education or entities working under its authority to support alignment studies and educational research, subject to contractual or other obligations to use the information only for such purpose and to keep the information confidential.
- Renaissance and Renaissance’s U.S. Parent Company may sell, transfer, or otherwise share some or all of its assets, including the Personally Identifiable Information it collects, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case the successor entity is subject to the same commitments set forth in this policy.
- Renaissance and Renaissance’s U.S. Parent Company may disclose aggregated information about Authorised Users and information that does not identify any individual or device.
Ownership. By providing access to the Applications, Renaissance does not own or directly manage any student information. All student information, including student records, remains the property of the School.
Parental Inquiries. Renaissance will direct all requests to review and/or correct erroneous information to the School. The Applications generally have functionality which allows School personnel to correct or modify records without any intervention by Renaissance. If a School requires Renaissance’s assistance to correct erroneous information, the School may contact Renaissance and Renaissance shall assist the School in correcting the erroneous information as directed by the School.
Privacy Shield Inquiries. If you are a resident of a European country participating in the Privacy Shield and you believe that Renaissance’s U.S. Parent Company maintains your personal data within the scope of their Privacy Shield certification, you may direct any questions or complaints concerning their Privacy Shield compliance to firstname.lastname@example.org.
ATTN: Privacy Officer
Renaissance Learning Inc.
PO Box 8036
2911 Peach Street
Wisconsin Rapids, Wisconsin 54495-8036
Privacy Shield Dispute Resolution. If you are a resident of a European country participating in the Privacy Shield and you have not received timely response to your concern from our U.S. Parent Company, or they have not addressed your concern to your satisfaction, you may seek further assistance, at no cost to you, from JAMS, which is an independent dispute resolution body in the United States.
Privacy Shield Related Arbitration. You may also be able to invoke binding arbitration for unresolved complaints but prior to initiating such arbitration, a resident of a European country participating in the Privacy Shield must first: (1) contact our U.S. Parent Company and afford them the opportunity to resolve the issue; (2) seek assistance from JAMS; and (3) contact the U.S. Department of Commerce (either directly or through a European Data Protection Authority) and afford the Department of Commerce time to attempt to resolve the issue. If such a resident invokes binding arbitration, each party shall be responsible for its own attorney’s fees. Please be advised that, pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the resident.
Privacy Shield U.S. Federal Trade Commission Enforcement. Our U.S. Parent Company’s Privacy Shield compliance is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
Security. Renaissance agrees to develop, implement, maintain and use commercially reasonable administrative, technical and physical security measures to preserve the confidentiality, integrity and availability of all data stored, managed, retained, accessed or used via the Applications.
- Renaissance will notify the School of any unauthorised release of Personally Identifiable Information that it becomes aware of within a reasonable amount of time and in accordance with applicable laws. The School agrees to provide the adult students and parents of the School’s minor students with direct notice of any such security breach as required by law. Except to the extent required by law, Renaissance will not communicate directly with adult students and parents of Schools’ minor students except as directed in writing by the School.
Data Retention. Personally Identifiable Information in student records is removed from the Applications after the School terminates its subscription to the Applications and, if requested in writing by the School, is returned to the School in a standard file format. Anonymous and aggregated data that does not include Personally Identifiable Information may remain on Renaissance’s systems and Renaissance may continue to use that information.
Third-Party Services. The Applications may operate with third-party software and services obtained separately by the School or Authorised Users (“Third Party Services”), (for example document management systems, third-party websites, etc.). While Renaissance may configure its Applications to operate with third-party services, Renaissance does not endorse, and is not responsible for the privacy policies, operation, or functionality of third-party services.
Recourse. Renaissance and Renaissance’s U.S. Parent Company set out three requirements for effective enforcement: (i) recourse for individuals to whom the data relate; (ii) follow up procedures for verifying that the attestations and assertions they have made about their privacy practices are true; and (iii) obligations to remedy problems arising out of failure to comply with the Principles and consequences for such organizations.
Contact Us. If you have any questions or concerns regarding how Renaissance’s U.S. Parent Company collects, uses, and shares Personal Identifiable Information under the Privacy shield Framework, please contact them using the information below.
ATTN: Privacy Officer
Renaissance Learning Inc.
PO Box 8036
2911 Peach Street
Wisconsin Rapids, Wisconsin 54495-8036
ATTN: Privacy Officer
Renaissance Learning UK Ltd
32 Harbour Exchange Square
London E14 9GE, United Kingdom