Privacy Policy

 

At Beable Education, Inc., A Public Benefit Corporation (“Beable”, “we,” “us,” or “our”), we recognize that your privacy is important.  We created this Privacy Policy in order to demonstrate our commitment to your privacy. This Privacy Policy explains how information is collected, used, and disclosed by us in connection with the use of our websites, online services, and mobile applications that link to this Privacy Policy (each a “Service”; collectively, “Services”).  Your Personal Information is used solely for the purpose of facilitating and/or improving our Services.  We will not sell, rent or otherwise distribute your Personal Information to third-parties.  Each time you use any Service, you consent to our collection, use, and/or disclosure of your Personal Information as described in this Privacy Policy.  Personal Information includes information that can be used to directly or indirectly contact or identify you, such as your full name, address, email address, and telephone number.  Personal Information also includes anonymous information that is linked to information that can be used to directly or indirectly contact or identify you.  Personal Information does not include information that has been made anonymous or aggregated so that it can no longer be used, whether in combination with other information or otherwise, to contact or identify you.  

As used in this Privacy Policy, “Non-identifiable Information” includes information that cannot be used to directly or indirectly contact or identify you and that is not linked to information that can be used to directly or indirectly contact or identify you.  Non-identifiable Information includes passively collected information about your activities on our Services, such as usage data, to the extent that information is not linked to your Personal Information. 

Each time you allow others to use our Services via your account, you confirm that you have the right to consent on their behalf to our collection, use and disclosure of their information as described in detail below.  Accordingly, it is highly recommended that you read this Privacy Policy in full, as well as our Terms of Service, and contact us if you have any questions. 

Our products and Services are marketed and sold to schools, school districts and teachers who purchase or otherwise subscribe to our Services.  Once purchased or subscribed toour products and Services can be used by children, including children under the age of 13, at the direction and under the supervision of said teachers.  We recognize the need to provide additional privacy protections with respect to the personal information we collect from children under 13 pursuant to the United States’ Children’s Online Privacy Protection Act of 1998 (“COPPA”).  Accordingly, the Privacy Policy includes our privacy practices with respect to children under 13.   

Nonetheless, we encourage any parent or guardian to discuss protecting his or her child’s personal information and to instruct said child never to voluntarily disclose personal information online without parental consent.  Any child under age of 13 must receive parental consent prior to using our Services. 

1. Personal Information That May Be Collected.

(a) Identifying Information. In order to access our Services, Beable requests teachers, parents, and other adult visitors over 18 to create accounts in order to purchase a subscription to our Services.  At such time, we will collect certain personal identifying information, which may include: legal name, postal address, e-mail address, screen name, password, telephone number, and facsimile number. Beable may request additional information necessary to establish and maintain accounts.  If you choose to pay via purchase order, check, or money order, we collect the payment information that you provide to us.  If you choose to create an account for free trial access to our Services, we collect and store your full name, street address, and email address, occupation, school and school district affiliation, and username during that process.  Following both account creation processes, we also collect information about whether you opt in to receive our updates, and offers.

(b) Teacher Usage. Our Services include specific access to certain information for teacher, students, and parents. We collect the username and password provided by teachers or schools during the purchase process or otherwise assigned to teachers by your school or school district each time you login. We may also collect email addresses of teachers or other school employees or contractors to facilitate your use of our Services.    

We will not use this Personal Information for any purposes other than verifying your identity and authenticating your login; facilitating your access to contentwhich includes, among other things, subscriber based content such as reports and program updates; and monitoring subscription compliance.  If you personally purchase access to any Service, we may use your user credentials to provide the customer service, technical support, and sales support you request.  If a district, school, or teacher purchases access to our Services on your behalf, we may display your Personal Information on a page on our website to facilitate effective use of our Services. 

(c) Student Usage. School districts, school administrators or teachers, as applicable must create a roster for students and assign student user credentials before students can access the Services.  We collect and store the student login credentials created by teachers.  We will not use this Personal Information for any purpose other than providing teachers and students access to the Services.  If a district, school, or teacher purchases access to our Services on your behalf, we may display your Personal Information, such as your user name, on a page on our website to facilitate effective use of our Services 

If we learn we have collected Personal Information, as such term is defined under COPPA, from a child without parental consent, or if we learn a child under the age of 13 has provided us Personal Information beyond what we request from him or her, we will delete that information as quickly as possible. If you believe that a user under the age of 13 may have provided us Personal Information in violation of this Privacy Policy, please contact us at [support@beable.com].

(d) Account Activity. Initial access to the Services will require the school district, school administrators or teachers, as applicable, to enter your first and last name, class name, grade level, and school name. This information will be collected.  

After the creation of the student roster, school districts will have access to district wide reports that provide information on usage of the application, login frequency, and student performance. School administrators will also receive similar reports with information specific to said school administrators’ specific school.  Likewise, each teacher will receive similar reports with respect to students in each teacher’s classroom and may utilize these reports for any educational purposes consistent with this Privacy Policy.  Additionally, teachers will be able to give students assignments. 

Each student will be permitted to print and save materials created by them through standard browser functions.  Student created materials include, but are not limited to, essays, research reports, creative writing, and account information.  Students are not permitted to print and save responses to standardized assessments where a student’s possession and control would jeopardize the validity and reliability of that assessment.  In the event a student seeks to retain possession and control over such materials and is unable to do so through his or her browser, they may contact us at [support@beable.com].

 2. Uses Made of the Information.

We will not use any Personal Information we gather about you as you use the Services for any purposes other than verifying your identity and authenticating your login; facilitating your access to content, which includes, among other things, subscriber based content such as reports and program updates; and monitoring subscription compliance.  You control what information you provide to and about your students as you interact with the Services.  If you have teacher access, the student information you provide as you use the Services should be limited to information that is relevant to the legitimate educational purpose of improving student performance.  You are also responsible for keeping the student information that you enter accurate, complete and up to date.  If you recognize that student information is inaccurate, incomplete, or outdated, you are responsible for correcting it.  Any inaccurate, incomplete or outdated student information identified by a parent or guardian must be reported to the school district or school so that the school district or school can notify us of any necessary changes.  Please note, however, that the username you assign to each student for access to our Services need not be the student’s actual name.  We will use the inserted information about students to provide services to your school or school district.  We will not keep such student information after you or the school or school district instructs us to delete it.  You may not disclose or otherwise use any student Personal Information other than as expressly set forth herein or our Terms of Use. 

We automatically collect Non-identifiable Information about teacher users and parent users to support our internal operations, including information about how various features of the Service are used, what you download, and the number, frequency and length of each session.  We do not combine this Non-identifiable Information with or link it to any of the Personal Information mentioned above. 

 3. Use of Computer Tracking Technologies.

(a) No Tracking of Personal Information. Our Services are not set up to track, collect or distribute personal information not entered by user. Through web site access logs Beable does collect clickstream data and HTTP protocol elements, which generate certain kinds of non-identifying site usage data, such as the number of hits and visits to our sites. This information is used for internal purposes by technical support staff for research and development, user analysis and business decision making, all of which provides better services to the public. The statistics garnered, which contain no personal information and cannot be used to gather such information, may also be provided to third parties. 

(b) Use of Usage Information. Like most websites, we use automatic data collection technology when access our website. This information includes information about the child’s operating system, IP address, browser type and language, referring and exit pages and URLs, keywords, date and time, amount of time spent on particular pages, what sections of a website you visit, and similar information concerning your use of the Site and the Services (the “Usage Information”). 

We collect this Usage Information by using cookies and pixel tags (also called web beacons or clear gifs). Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of website users. 

We will use your Personal Information and Usage Information collected through the Site for the following purposes: 

1) To identify when a child’s account is accessed;

2) To respond to requests and to enhance the Services;

3) To respond to inquiries and identify changes to the Services;

4) To analyze the use of the Service and the people visiting to improve our content and Site and the Service;

5) To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies, or as otherwise required by law; 

6) For any other purposes disclosed at the time the information is collected or to which we receive consent; and

7) As otherwise specifically described in this Privacy Policy.

(c) Collection of Non-Identifiable Information. Beable may collect non-identifiable information from users that access our Services in order to provide better customer service. Examples of such collecting include: traffic analysis, such as tracking of the domains from which users visit, or tracking numbers of users; measuring user activity; Web site and system administration; user analysis; and business decision making. Such information is sometimes known as “clickstream data.” Beable or its contractors may use this data to analyze trends and statistics.

4. Consent—Parent Purchasers.  

For parents that individually purchase our Services, in the event we wish to collect Personal Information from a child, we will provide parental notice and seek verifiable parental consent via the email address provided during account creation.  In our initial email communication, we will identify the Personal Information we intend to collect from children, how we collect it, how we use it, how we disclose it, how the parent can consent to collection of such information, and your parental rights over such information.  As verification of your consent, our initial email to you will contain link for you to click confirming your consent. We will then send a separate message confirming we have obtained consent after a reasonable time delay. Our message confirming consent will also include information how to revoke parental consent to our collection of Personal Information.

5. Consent—School Districts As Agents.  

Where a school or school district contracts with us to offer the Services solely for the use and benefit of the school, and for no other commercial purpose, the school or school district may consent to the collection of a child’s Personal Information on parents’ behalf.    

We provide the schools and school districts using our Services with the notices required under COPPA, including a description of the Personal Information we collect from children, how we collect it, how we use it, how we disclose it, how the school or school district can consent to collection of such information, and all other rights over such information.

 6. Disclosure of Personal Information to Third Parties.

We do not disclose Personal Information to third parties.  Personal Information is used for internal purposes only. 

We may disclose the information we collect about a student to authorized employees or representatives of the student’s educational institution.  When, at the request of the school or school district, we acquire assessment or other information, including students’ Personal Information, from a third-party source, we will treat such information with the same confidentiality and security safeguards as though it were provided directly by the educational institution.  Additional agreements may be required by the third party to authorize transmission of such information to us. 

A school or school district may from time to time request that we provide the information we collect about students to third parties.  We will do so only with written authorization from the school or school district that acknowledges that we are providing that information as an agent of the school or school district, and that once the information is received by the third party, we no longer have any control over the use or disposition of the information.  If a written request to disclose the Personal Information of students to a third party is provided to us, the educational institution releases us from all responsibility over the use or disposition of such information. 

Upon written request by a school or school district, we will destroy any Personal Information collected from students who no longer participate in our Services.  We will also provide written verification that the data has been destroyed as requested.

7. Family Educational Rights and Privacy Act.  

We take commercially reasonable steps to protect the Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information supplied will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from us may not be secure.

(a) Perform an institutional service or function for which the school district or school would otherwise use its own employees; 

(b) Are under the direct control of the school district or school with regard to the use and maintenance of education records;  

(c)Use education records only for authorized purposes and will not redisclose the education records to other parties (unless we have specific authorization from the school district or school to disclose such records and such disclosure is permitted by FERPA); and 

(d) Have been determined to meet the criteria set forth in the school district’s or school’s annual notification of FERPA rights for being a school official with a legitimate educational interest in the education records. 

 

8. How We Protect Information.  

We employ a variety of safeguards designed to protect the Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Our measures consider the sensitivity of the information we collect, use, and store and the current state of technology. Our security measures include data encryption, firewalls, data use, and access limitations for our personnel.  Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information supplied will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from us may not be secure. Should we become aware of an unauthorized disclosure of your information, we will notify you as promptly as possible with regard to such unauthorized disclosure.

9. California Privacy Law: Do Not Track.  

As noted above, we do not track any additional data other than what you provided to us.   If you would like a report of that information, please contact us for such a report.  You may opt to not be tracked, but our programs require that you provide certain data in order to use our Services and if you opt to not be tracked, our Services may not be able to perform as intended.  

10. Privacy Policy Changes.  

Beable reserves the right to change its privacy policy statement at any time. A notice of any material change will be posted on our website home page and will become effective as of the date of posting with respect to information we then collect in the future.  It is and will be your responsibility to review our Privacy Policy from time to time to make sure you are aware of any changes

11. Access Rights to Data. 

Help Beable to keep customer personal information accurate. If customer’s personal information changes, or if customer notes an error upon review of customer information that Beable has on file, please promptly e-mail Beable at [support@beable.com] and provide the new or correct information.

There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the Personal Information that we hold about you.  In addition, your Personal Information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.  In the event that we cannot provide you with access to your Personal Information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions. 

Subject to the terms and conditions of your contract with us, if you no longer wish to use our Services, you may close your account by contacting us.  Student accounts may be created or deleted by a school district, school administrator or teacher, as applicable, via the Services application programming interface.  Parents that wish to do same must contact the account holder, such as the school, to request deletion of his or her child’s information. The school may contact Beable at [support@beable.com].

If you close your account, we have no obligation to retain your information, and we may delete any or all of your information without liability.  However, we may retain information related to you if we believe it may be necessary to prevent fraud or future abuse, if required by law, or for legitimate business purposes, such as analysis of aggregated, Non-identifiable Information, account recovery, auditing our records, and enforcing our rights and obligations under our agreements.  We disclaim any liability in relation to the deletion or retention (subject to the terms of this Privacy Policy) of information or any obligation not to delete your information. 

We strive to help parents ensure that their kids have a safe experience using our Services. If a parent or legal guardian has purchased our Services on his or her own and therefore has access to our Services other than through our relationship with a school or school district, such parents or legal guardian can review any Personal Information collected about their child, have this information deleted and/or request that there be no further collection or use of their child’s Personal Information. We take steps to verify the identity of anyone requesting information about a child and to ensure that the person is in fact the child’s parent or legal guardian. 

Please keep in mind that a request to delete Personal Information about a child or a request that there be no further collection or use of their child’s Personal Information may lead to the termination of an account, membership or other service.  Upon written request by a school, we will delete any Personal Information collected from students, and we will provide written verification that the information has been destroyed as requested. 

If you no longer wish to have Personal Information of a child collected by an application installed on a mobile device, you may uninstall the application by using the standard uninstall processes available on the mobile device or via the mobile application marketplace or network. 

12. Accountability. 

(a) Questions. If you have a question about this policy statement, you may contact Beable by e-mail at [support@beable.com].

(b) Terms of Use. If customer chooses to use Beable’s services, customer’s action is hereby deemed acceptance of Beable practices described in this policy statement. Any dispute over privacy between customer and Beable is subject to the provisions of this notice and to Beable’s Terms of Use Agreement which is hereby incorporated herein and which can be read at Terms of Use