Renaissance Privacy Hub
Last updated: March 22, 2023
Note to Parents of Students who use Renaissance’s Products
Our mission is to accelerate learning for all children and adults of all ability levels and ethnic and social backgrounds worldwide. To achieve this mission, Renaissance Learning, UK Ltd. (“Renaissance”) contracts with multi academy trusts and educational institutions that utilise our products in the classroom. If your child’s school uses products such as Renaissance Accelerated Reader®, Renaissance Star 360®, myON®, myIGDIs®, Schoolzilla®, Freckle® or Nearpod®, please see the Products: Data Protection Addendum below for more information. We deeply understand the trust our educational partners are placing upon us as a data steward and education technology provider. We are committed to the privacy and security of our customer data. Your child has rights to their personal data! We celebrate personal data rights and we work directly with our educational partners to fulfill data rights related questions and queries about our products.
Under data protection legislation, your school is known as what is called the “Data Controller.” The Data Controller is directly responsible for, and the party best situated to, respond to student personal data rights inquiries. As such, please direct any data privacy related query about our products to your school’s Data Protection Officer “DPO.” If your school needs support from Renaissance in responding to your request, we will provide that support to your school. And don’t worry. If you do reach out to Renaissance directly for data rights help in connection with one of our products, we’ll be glad to forward your request directly to your school’s DPO and provide them with any support they need in responding to you.
Products: Data Protection Addendum
Our products are predominantly used by school districts and boards, schools, multi-academy trusts (MATs) and other learning institutions (each an “Education Institution“). If you are using one of our products through an Education Institution, we will receive your personal data directly from the relevant Education Institution. In that case, we are acting as a ‘data processor’ on behalf of the relevant Education Institution, and the relevant Education Institution is the ‘data controller’ of your personal data. This means that the relevant Education Institution is responsible for the collection and use of your personal data, and we are merely using your personal data as instructed by the relevant Education Institution. Please our Data Protection Addendum for more information.
Updated Privacy Notice
In accordance with our data protection agreement, Renaissance is reaching out to inform you that we will be engaging a third party for their engineering and product development services. The name of the third party is: EPAM Systems, Inc. We have carefully reviewed EPAM’s security and privacy practices via our supplier diligence process. If you have any questions or concerns, please do not hesitate to contact us.
- For a list of sub-processors, please click here.
Website Privacy Notice
Effective date: March 22, 2022
RENAISSANCE LEARNING EEA/UK PRIVACY NOTICE
Welcome to Renaissance Learning’s EEA / UK Privacy Notice (“Privacy Notice”).
This Privacy Notice applies to the use of our Service by users located in the European Economic Area (“EEA”) or the United Kingdom (“UK”). If you are a user located in the US, please refer to our Privacy Hub https://www.renaissance.com/privacy/.
WHAT DOES THIS PRIVACY NOTICE COVER?
Renaissance Learning respects your privacy and is committed to protecting your personal data. We want to be transparent with you about how we collect and use your personal data in making available our platform, products, website and mobile apps (together, the “Service”) and tell you about your privacy rights and how the law protects you.
With that in mind, this Privacy Notice is designed to describe:
- WHO WE ARE AND HOW TO CONTACT US.
- USE OF OUR PRODUCTS THROUGH AN EDUCATION INSTITUTION.
- WHAT PERSONAL DATA WE COLLECT.
- HOW WE USE YOUR PERSONAL DATA AND WHY.
- WHO WE SHARE YOUR PERSONAL DATA WITH.
- HOW WE KEEP YOUR PERSONAL DATA SECURE.
- HOW LONG WE STORE YOUR PERSONAL DATA.
- YOUR RIGHTS RELATING TO YOUR PERSONAL DATA.
- MARKETING COMMUNICATIONS.
- OUR POLICY ON CHILDREN.
- THIRD-PARTY LINKS.
This Privacy Notice aims to give you information on how Renaissance Learning collects and processes your personal data through your use of the Service, including any data you may provide through the Service. It is intended to meet our duties of transparency under the “General Data Protection Regulation” or “GDPR”.
We reserve the right to update this Privacy Notice from time to time, and we will post any modifications or changes to this Privacy Notice on this page.
WHO WE ARE AND HOW TO CONTACT US.
Who we are.
RENAISSANCE LEARNING UK LTD (referred to as either “Renaissance Learning”, “we”, “us” or “our” in this Privacy Notice) is the ‘data controller’ of your personal data, including for the purposes of the GDPR.
Our address is: Sierra Quebec Bravo, 77 Marsh Wall, London E14 9SH, England.
How to contact us.
You can contact us by emailing: [email protected].
USE OF OUR PRODUCTS THROUGH AN EDUCATION INSTITUTION.
Our products are predominantly used by school districts and boards, schools, multi-academy trusts (MATs) and other learning institutions (each an “Education Institution”).
If you are using one of our products through an Education Institution, we will receive your personal data directly from the relevant Education Institution and this Privacy Notice will not apply to our use of such personal data. In that case, we are acting as a ‘data processor’ on behalf of the relevant Education Institution, and the relevant Education Institution is the ‘data controller’ of your personal data. This means that the relevant Education Institution is responsible for the collection and use of your personal data, and we are merely using your personal data as instructed by the relevant Education Institution.
If you are using one of our products through an Education Institution, please direct any queries or complaints about the use of your personal data to the relevant Education Institution.
WHAT PERSONAL DATA WE COLLECT.
All the personal data we collect about you is outlined in the table below.
Before you read that table, it might be useful to explain what “personal data” is. The GDPR definition of personal data can be found here. Essentially, personal data is information about an individual, from which that individual is either directly identified or can indirectly be identified. It does not include ‘anonymous data’ (information from which the identity of individual has been permanently removed). However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular individual).
|CATEGORY:||WHAT IT MEANS:|
|Identity Data||First name, last name, username or similar identifier date of birth and/or gender.|
|Contact Data||Billing address, email address and/or telephone number.|
|Files Data||Any personal data that may be contained in files that you choose to upload to the Service.|
|Usage Data||Logs of your activity when using one of our products including event logs, traffic data, geo-location data and other communication data.|
|Technical Data||Internet Protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the device you use to access or use the Service|
Data collected via cookies.
We also generate, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data, but once in aggregated form it will not constitute personal data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Service feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.
HOW WE USE YOUR PERSONAL DATA AND WHY.
We will only use your personal data for the purposes for which we collected it as listed in the table below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will update this Privacy Notice and we will explain the legal basis which allows us to do so.
You do not have to provide any personal data to us. However, where we need to process your personal data either to comply with law or to perform our obligations to you, and you fail to provide that data when requested, we may not be able to perform our obligations to you (for example, to make certain aspects of our Service available to you) but we will notify you if this is the case at the time.
In respect of each of the purposes for which we use your personal data, the GDPR requires us to ensure that we have a ‘legal basis’ for that use. Most commonly, we will rely on one of the following legal bases:
- Where we need to use your personal data to deliver our Service to you (including accessing our website and mobile apps, or using our products) (“Contractual Necessity”).
- Where we need to use your personal data for our legitimate interests, and your interests and fundamental rights do not override those interests (“Legitimate Interest”).
- Where we need to use your personal data to comply with our legal or regulatory obligations (“Compliance with Law”).
- Where we have your consent to use your personal data for a specific purpose (“Consent”).
We have set out below, in a table format, the purposes and applicable legal bases we rely on when we use your personal data.
|Account creation and management||To create and manage your account on our Service.||Contractual Necessity|
|Fraud prevention||To keep our Service and associated systems operational and secure.||Legitimate Interest. We have a legitimate interest in ensuring the ongoing security of our Service and associated systems.|
|Analytics and service improvement||To understand how our users use our Service, and improve it using that data.||Legitimate Interest. We have a legitimate interest in monitoring the use of our Service in order to improve it over time.|
|Legal compliance||To comply with our legal and regulatory obligations (for example, by ensuring that you are allowed to use our Service).||Compliance with law.|
|Marketing||To send you information about our products and services from time to time.||Consent.|
WHO WE SHARE YOUR PERSONAL DATA WITH.
Categories of recipients.
The table below describes who we share your personal data with, and why we share it.
|Our affiliates||Other companies within our corporate group may help us provide our Service to you.|
|Our service providers||Our service providers provide us with data hosting, IT, infrastructure, payments processing and other services that allow us to provide our Service to you.|
|Our advisers||Our lawyers, bankers, auditors, insurers and other advisers may need to access your personal data when providing their services to us.|
|Public authorities||Public authorities may require us to report our data processing activities in certain circumstances, which may involve disclosing some of your personal data.|
|Potential acquirers||We may disclose or transfer your personal data in the context of actual or prospective corporate events (for example the sale, transfer or merger of all or part of our business, assets or equity interests). For example, we may need to share certain personal data with prospective counterparties and their advisers.|
International transfers of your personal data.
Some of our affiliates, partners and external third-party suppliers are based outside Europe, so their processing of your personal data will involve transferring your personal data outside Europe.
Where we share your personal data with third-parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:
- Transfers to territories with an adequacy decision. We may transfer your personal data to countries or territories whose laws have been deemed to provide an adequate level of protection for personal data by the relevant European authorities.
- Transfers to territories without an adequacy decision. We may transfer your personal data to countries or territories whose laws have not been deemed to provide an adequate level of protection for personal data by European authorities. However, in these cases:
– we may use specific appropriate safeguards, approved by relevant European authorities, which are designed to give your personal data the same protection it has in Europe – for example, requiring the recipient to enter into the relevant form of the so-called ‘Standard Contractual Clauses’ or ‘International Data Transfer Agreement’ issued or approved from time to time; or
– in limited circumstances, we may rely on an exception or ‘derogation’ which permits us to transfer your personal data to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.
Should you wish to find out more about these controls and safeguards, please contact us.
HOW WE KEEP YOUR PERSONAL DATA SECURE.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We limit access to your personal data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected personal data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (including where we are legally required to do so), we may notify you of breaches affecting your personal data.
We retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.
To determine the appropriate retention period for your personal data, we consider the amount, nature and sensitivity of the relevant data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
YOUR RIGHTS RELATING TO YOUR PERSONAL DATA.
Your rights in connection with your personal data.
By law you have the right to:
- Request access to your personal data. This enables you to receive a copy of the personal data we hold about you, and to check that we are lawfully processing it.
- Request the correction of your personal data. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. This may not always be available.
- Object to our processing of your personal data. This right exists where we are relying on Legitimate Interest as the legal basis for our processing, and there is something about your particular situation which makes you want to object to our processing on this ground.
- Request the restriction of our processing of your personal data. This enables you to ask us to temporarily suspend the processing of your personal data, for example if you want us to establish its accuracy or our reason for processing it.
- Request the transfer of your personal data. This enables you to ask us to provide to you, or a third-party you have chosen, your personal data in a structured, machine-readable format.
- Withdraw consent. This enables you to withdraw your consent. This right only exists where we are relying on Consent as our lawful basis to process your personal data.
How to exercise your rights.
If you want to exercise any of the rights described above, please contact us.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data. This is a security measure to ensure that your personal data is not disclosed to any person who has no right to receive it.
Typically, you will not have to pay a fee to exercise your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We may also refuse to comply with your request in limited circumstances.
We try to respond to all legitimate requests within a month. It may take us longer than a month if your request is particularly complex or you have made a number of requests; in this case, we will notify you and keep you updated.
Please note that applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.
If you would like to make a complaint regarding this Privacy Notice or our practices in relation to your personal data, please contact us. We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved, please note that applicable privacy law gives you the right to contact your local data protection supervisory authority.
You can ask us to stop sending you marketing messages at any time by logging into the Service and changing your marketing preferences in your Account settings, or by following the opt-out link included in any marketing message sent to you.
Where you opt out of receiving these marketing messages, this will not apply to service emails, for example emails relating to an order that you have placed with us.
OUR POLICY ON CHILDREN.
Children should not use our Service except with the prior consent of a parent or guardian. For the purposes of this Privacy Notice, we define “children” as anyone under the age of 16.
We do not knowingly collect any personal data from children without parental consent. If we learn that the personal data of a child has been collected on our Service without prior parental consent, then we will take appropriate steps to delete the relevant personal data and will not use it or share it with third-parties. If you are a parent or guardian and discover that your child has a registered account on our Service without your consent, please contact us to request that we delete the child’s personal data from our systems.
Renaissance’s Commitment to Diversity, Equity and Inclusion in Education
Renaissance’s mission is to accelerate learning for all children and adults of all ability levels and ethnic and social backgrounds, worldwide. To that end, Renaissance is committed to producing content that is diverse, inclusive, and equitable for all learners.