PRIVACY POLICY
Last modified: April 19, 2019
This Privacy Policy explains how information is collected, used, and disclosed by ScribbleUp Learning, LLC (“ScribbleUp,” “we,” “us,” or “our”) in connection with your use of our websites, online services, software, and mobile applications that link to this Privacy Policy (each a “Service”; collectively, “Services”). Each time you use any Service, you consent to our collection, use, and/or disclosure of your information as described in this Privacy Policy. Each time you allow others to use any Service 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, we urge you to read this Privacy Policy in full, as well as our Terms of Use, and contact us if you have any questions.
We market and sell our products to adults who purchase or otherwise subscribe to our Services, which can then be used by children at the direction and under the supervision of these adults. We respect all of our users’ privacy, but 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, our privacy practices with respect to children under 13 are set forth below in our Children’s Privacy Policy section.
A special note to children: If you are under 13, please get permission from your parent or legal guardian before using our Services. You must be 18 or older to purchase or otherwise subscribe to any Service. We do not market or sell to children under 18, and we seek consent from a parent or legal guardian whenever we identify that a minor attempts to purchase or register for a subscription to any Service.
A special note to parents: Please help us protect your children’s privacy by instructing them never to volunteer their personal information online without your permission.
1. Information We Collect and How We Use It
Throughout this Privacy Policy, we use the term “Personal Information” to describe information that can be used to directly or indirectly contact or identify you, such as your full name, home or other physical 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.
We use the term “Non Personal Information” to describe 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 Personal 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.
A. Account Creation by Teacher and Parent Users
Teachers, parents, and other adult visitors over 18 use our apps by purchasing a subscription to any Service, downloading our Apps, or securing free trial access to any Service. During our online purchase process, we may collect and store your first and last name, street address, email address, phone number, and school and school district. We may also collect the username, password, and security question and answer you create, and if you volunteer your fax number, occupation, and class grade level, we may collect and store that information. If you choose to pay with a credit card, we may collect your credit card number, card type, expiration date, and security code. We may transmit this payment information for processing, and we do not store this information. If you choose to pay via purchase order, check, or money order, we collect the payment information that you mail to us. If you choose to create an account for free trial access to any Service, we may 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 may also collect information about whether you opt in to receive newsletters, updates, and/or offers from us.
We will not use the Personal Information collected during the account creation process for any purposes other than securing verifiable parental consent; fulfilling requested transactions; sending you order confirmations and other notifications you request or that are required by law; providing you with access to the Services, including ensuring proper licensing and providing necessary copyright permissions; receiving, requesting, and responding to Feedback including but not limited to usability, bug reports and test results; and providing the customer service, technical support, and sales support you request.
You control what information you provide to and about your child or students as you interact with the Services. 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. We will not ask you to enter, and you are specifically instructed not to enter, information about students that is not relevant to this legitimate educational purpose. 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. We may use information about students entered by teacher and parent users to provide services to your school educational institution. We will not keep such student information after you or the school educational institution instructs us to delete it. You may not disclose or otherwise use the student data entered on this site for any unauthorized purposes.
When you are logged in, we may automatically collect Non Personal Information about your use of the Service 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 Personal Information with or link it to any of the Personal Information mentioned above.
B. Correspondence with Us
We collect and retain Personal and Non Personal Information from you when you send us a message via our website, when you send us an email, or when you sign up to follow our social media accounts or for a newsletter on our website. We use such information solely to provide the services or support you request.
C. Location Information
We may collect and store information about your geographic location on our Services. Your location information is collected only if you enable your computer or mobile device to send us location information and/or if you expressly grant us permission to collect it by clicking “Allow” in a dialogue window that automatically pops up when you navigate to this website.
D. Automated Information
We may automatically receive and record certain technical information from your browser as you use our Services, including your IP address, to improve the functionality of our Services. When we collect an IP address, we combine it with other information submitted by the user’s browser, such as requests for files from the web server. We may compile this information to create access logs, which we analyze to determine trends, such as which pages are used the most, which browsers are most frequently used by visitors to access the site, and which areas of the world site users are accessing our products from most frequently.
2. How We Share the Information We Collect
We will not share any information collected through our Services with third parties, except as described below. We do not share Personal Information with third parties for their own marketing purposes. We do not sell ads.
A. Personal Information
Service Providers
We may share Personal Information with third-party service providers only if necessary for them to perform services on our behalf, including without limitation service providers who provide email services, process credit card payments, and provide services in support of our internal operations.
Corporate Affiliates and Corporate Business Transactions
We may share Personal Information with our parent company and other ScribbleUp-affiliated companies. If we enter into a business transition such as a merger, consolidation, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, or dissolution, your Personal Information may be among the assets we transfer. You acknowledge and consent that such transfers are permitted by this Privacy Policy, and that any acquirer of ours or that acquirer’s affiliates may continue to collect and use your Personal Information as set forth in this Privacy Policy.
Legal Compliance and Security
We reserve the right to disclose Personal Information when required to do so by applicable law—for example, in response to a court order, subpoena, legal process, or other claim or inquiry. We also may disclose Personal Information in response to a law enforcement agency’s request or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the rights, property, or safety of any person, violations of our Terms of Use, or to verify or enforce compliance with the policies governing our Services and applicable laws, or as otherwise required or permitted by law or legal requirements.
Consent
We may share your Personal Information with a third party if you consent to the sharing.
Authorized Educational Institutions and Third Parties They Authorize
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 educational institution, 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.
An educational institution may from time to time request that we provide the information we collect about students to third parties of its choosing. We will do so only with written authorization from the educational institution that acknowledges that we are providing that information as an educational institution’s agent, 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 an educational institution, we will destroy any information collected from students for educational institutions who no longer participate in our Services. We will also provide written verification that the data has been destroyed as requested.
B. Non Personal Information
This Privacy Policy does not limit our use of any Non Personal Information, and we reserve the right to use and disclose such information to third parties at our discretion.
3. Districts and School Systems
Under the terms of our contracts with schools, we may agree to act as a “School Official” as defined by the Family Educational Rights and Privacy Act (“FERPA”). If we agree to act as a School Official, we:
Perform an institutional service or function for which the school or district would otherwise use its own employees;
Have been determined to meet the criteria set forth in the school’s or district’s annual notification of FERPA rights for being a School Official with a legitimate educational interest in the education records;
Are under the direct control of the school or district with regard to the use and maintenance of education records; and
Use education records only for authorized purposes and will not re-disclose from education records to other parties (unless we have specific authorization from the school or district to do so and it is otherwise permitted by FERPA).
4. Account Holders’ Communication Choices
We provide you the ability to exercise certain controls and choices regarding our collection, use and disclosure of your information. If you opt in to receive our newsletters, updates, and offers, you consent to receive certain email communications from us, which may include newsletters, administrative notices, and special offers. You have a choice at any time to stop us from sending you emails for marketing purposes by updating your email preferences.
Please note that, despite any indicated email marketing preferences, we may still send you administrative emails regarding the operation of our Services.
5. Changing or Removing Personal Information and Closing Accounts
A. Reviewing Your Own Information
If the Personal Information you provided when you created an account changes, you must promptly notify us of those changes. You have the right to access, update and correct factual inaccuracies in the Personal Information that we collect through our Services, subject to certain exceptions. If you want to access, update, or correct your Personal Information, you must contact us at the address, email, or phone provided in Section 9. To help protect your privacy and the security of your Personal Information, we may request information from you to enable us to confirm your identity and right to access such information, as well as to search for and provide you with the Personal Information that we maintain. For information about how to review the Personal Information we collect from children under 13, please see our Children’s Privacy Policy section below.
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.
If you no longer wish to have your information 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.
B. Closing Accounts
If you no longer wish to use our Services, you may close your account by contacting us. Adults with parent or teacher access may do this by contacting the account holder, such as the school, to request deletion of their child’s information.
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 Personal 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.
6. Using the Services Outside the United States
We are based in the United States, and the information we collect is governed by and operated in accordance with United States law. If you are using the Services outside the United States, you consent to having your information and data transferred to the United States. While users from countries other than the United States may access certain of our Services, we make no representation that the Services are operated in accordance with the laws or regulations of, or governed by, other nations. If you are from any jurisdiction with laws or regulations governing the use of the Internet, including the collection, use and disclosure of Personal Information, that are different from those of the United States, you may only use the Services in a manner lawful in your jurisdiction.
7. How We Protect Information
We use reasonable technical, administrative, and physical security measures designed to safeguard and help prevent unauthorized access to your information, maintain data security, and correctly use the information we collect. These measures include, but are not limited to, the use of encryption, physical access controls, information access controls, and anti-virus and anti-malware software.
Additionally, your account may be protected by a password you use to access your online account, and we urge you to take steps to keep your usernames and passwords safe. Teacher and parent users are responsible for maintaining the confidentiality of their usernames and passwords, including student usernames and passwords. If you feel your password or a password of a student user has been compromised, you should change it immediately. When you are finished using our Services, you should log out of your account and exit your browser. Teacher and parent users are also responsible for notifying us immediately of any known or suspected unauthorized use(s) of account, or any known or suspected breach of security, including loss, theft, or unauthorized disclosure of login credentials. Any fraudulent, abusive, or otherwise illegal activity on your account may be reported to appropriate law enforcement agencies by us.
Please be aware that, despite our best efforts, no security measures are perfect or impenetrable. We cannot guarantee or warrant the security of any information you disclose or transmit to us on or through the Services and cannot be responsible for the theft, destruction, loss or inadvertent disclosure of your information.
8. Links to Other Websites
We may provide links to other websites that we believe may be of interest to our users. However, we are not responsible for the privacy practices employed by those websites, nor are we responsible for the information or content they contain. This Privacy Policy applies solely to information collected by us through our Services; thus, when you use a link to navigate to a third-party website, this Privacy Policy is no longer in effect. We encourage our users to read the privacy policies of these other websites before proceeding to use them.
9. Contact Us
Teachers, parents, and other adult visitors over 18 with questions or comments regarding this Privacy Policy may contact us using the information below:
Address: PO Box 90215, 5182 Liberty Ave, Pittsburgh PA 15224
Email: info@scribbleuplearning.com
Phone: (267) 702-0788
10. Changes to This Privacy Policy
We may periodically make changes to this Privacy Policy, including changes to keep pace with changing technology and as new or changed Services are released. We expect most such changes to be minor. Any non-material changes will take effect immediately upon posting of an updated Privacy Policy on our Services. You should periodically check our Privacy Policy for updates. However, there may be cases where changes to the Privacy Policy may be more significant. In such cases, we will first provide notice to users who are affected. If we make changes to this Privacy Policy that may affect our collection or use of Personal Information from children under 13, we will give notice and obtain the prior verifiable consent of a parent or legal guardian.
Your continued use of the Services after the effective date of the Privacy Policy will constitute acceptance of any changes. If you do not agree to the revised Privacy Policy, please refrain from using the Services.
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