Privacy

Privacy Policy

Privacy Matters. As a leader in the STEM education market, the learner is at the core of everything we do. Our clients have entrusted us with sensitive and personal information that often includes information about students. We are keenly aware of the weight of these obligations and take our responsibility to you very seriously. This privacy statement covers how we collect, use, disclose, and process information as we provide our products and services to our customers and end users.

Who We Are. Pitsco Education, LLC, (“PITSCO”) is the controlling company for Pitsco, Inc. (“Pitsco,” “Pitsco Education”) and The Technological Fluency Institute, Inc. (“TFI”). When we refer to “PITSCO,” “us,” “we,” or “our” in this privacy policy, it refers to Pitsco Education, LLC.

Our Sites. PITSCO hosts several sites including those at synergy.pitsco.com (“Synergy”), robo-review.pitsco.com (“Robo-Review”), and www.techfluency.org/esess (“E-SESS”), collectively our “Education Sites,” which are for use by both children and adults. Please refer to the Children’s Privacy section for more information. Our sites also include www.pitsco.com, esess.org, and other marketing sites, collectively our “Corporate Sites.” We do not intentionally gather, use, or disclose personal data from Corporate Site visitors who are under the age of 13, and our Corporate Sites are not intended for children under this age.

Children's Privacy

This Children’s Privacy section applies to our Education Sites.

Information We Collect from Children

The Short Version. We collect only the information necessary for children to use the services provided by our Education Sites, such as a username, password, and any information submitted by the user. A parent or authorized school official must provide permission for the creation of an account for any child under 13.

Information collected from children is used at the direction of and under the control of a sponsoring educational institution. We rely on each school or institution to provide appropriate notice to parents of their use of third-party services, such as those provided by the Education Sites of PITSCO. The sponsoring institution is also responsible for obtaining any required consent and/or authorization to collect information from children as permitted by the Children’s Online Privacy Protection Act, alternatively known as COPPA. All accounts for children under the age of 13 (or a higher age as might be required by local laws) must be authorized by a parent or other authorized school official. Please see the Educational Institution Privacy Notice for more information regarding how accounts created by education institutions differ from any accounts created outside an educational environment.

We collect information voluntarily provided to us when a user registers on one of our sites or utilizes the services provided by those sites. The personal information that we collect from children may include the following:

• User Account Information. We collect usernames, passwords, and similar security information used for authentication and access to accounts provided by our services.
• Additional Personal Information. We may additionally collect information such as first name, last name, and grade level about children.
• User Submissions. Our services permit children to respond to multiple-choice questions, type responses into open text fields, and record the date and/or time a process or assignment was completed. These responses may include personally identifiable information. Information submitted by a child can be viewed only by the child, other children who were partnered for a shared assignment or experience, and authorized educators or supervisors.
• Recorded Content Our services include support for recording video and/or audio for the purposes of remote proctoring of assessments. These recordings are collected and stored by one of our business partners. For more information, please visit proview.io. Their privacy policy is available here.

We automatically collect certain information when children visit, use, or navigate our Education Sites. This information does not reveal the child’s specific identity, such as names or contact information, but may include device and usage information, such as IP addresses, browser type and version, device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when our services were used, and other technical information. This information may be collected using cookies, web beacons, and other similar technologies.

How We Use Information We Collect from Children

The Short Version. We use the information we collect from children to allow them to experience the educational experiences provided by the Sites.

Uses of information collected from children include the following:

• Use of Site Functionality. The information provided by children is used to permit them to use the services and functionality provides by the Sites.
• Personalized Experiences. The information provided by children is used to personalize the child’s experience by presenting projects and assignments tailored to the individual child.
• Our Business Purposes. Information collected from children may be anonymized or aggregated to fulfill business purposes such as data analysis, developing new or improved products and services, identifying usage trends, and determining the effectiveness of our educational content.
• Classroom Management. In the context of school accounts, information collected from children may be used to allow teachers and educators to track progress, completion, and performance within the Sites.

How We Share Information We Collect from Children

The Short Version. We share information we collect from children only when we are required to do so, when it has been properly anonymized or aggregated to prevent personal identification of a child, or when we have the consent of a parent or school official.

In limited cases, we may share information collected from children outside of PITSCO. Information collected from children is not shared with other companies, organizations, or individuals except in the following circumstances:

• With Authorized Consent. We may disclose personal information of children for any purpose when we have school or parental consent.
• Compliance with Laws. We may disclose information where we are legally required to do so to comply with applicable law, governmental requests, judicial proceedings, court orders, or legal processes, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). Fulfilling these obligations may require information to be shared outside a child’s country or region of residence.
• Third-Party Service Providers. We may share limited data with third-party vendors or service providers for the purpose of data analysis, email delivery, hosting services, or other related services. We do not share, sell, rent, or trade any personal information for children with third parties for their promotional purposes or for the use of targeted advertising.
• Business Transfers. We may share or transfer children’s information in connection with, or during negotiations of, any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of company assets, financing, or acquisition of all or a portion of our business (including in connection with any bankruptcy or similar proceedings).
• Business Partners. We may share children’s information with our business partners to offer certain products or services such as single sign-on integrations, video proctoring services, and/or connections to other educational sites or technologies.

Contacting Us Regarding Children’s Privacy

If your child has an account that is associated with a school or educational institution, please contact the school or district administrator with any questions prior to contacting us.

If you would like to review the personal information your child has provided to us, or if you would like to ask us to cease collecting or using personal information that we have collected from your child or to delete the personal information we have collected from your child, or if you have questions or concerns about this policy or our privacy practices, you may contact our Data Privacy Officer, who is responsible for overseeing all questions related to this policy, at privacy@pitsco.com or mail us at:

Pitsco Education, LLC
Attn: Data Privacy Officer
915 E Jefferson St
Pittsburg, KS 66762-6012
United States of America

When contacting us regarding this privacy policy, please include your name, your child’s name, and explicit instructions regarding your child’s information. We are committed to responding to your request as quickly as we are reasonably able to do so.

Please note that if a child contacts us with a question about our products and/or services, we will collect personal information from that child only as necessary to respond to the child’s request. Any contact information collected will be deleted or anonymized to protect the child’s information after providing our response.

Conflicting Terms

This section on Children’s Privacy works in conjunction with the General Privacy Policy. Where there are terms that differ, this section on Children’s Privacy takes precedence.

General Privacy Policy

Information We Collect

Information You Provide to Us

The Short Version. We collect information that you provide to us such as name, address, contact information, passwords, payment information, and information specific to services you use.

We collect information that you voluntarily provide to us when registering on one of our websites or online services, when participating in activities on our websites (such as entering contests or giveaways), utilizing one of our services, or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us,the choices you make, and the products and features you use. The personal information we collect can include the following:

• Information About Individuals. We may collect your first and last name; email address; physical, mailing, and/or billing address; phone number; and other similar contact information.
• Information About Institutions. Some services we provide require information about the school, district, or organization using the service such as the institution name and physical and/or billing address. Other information may be collected such as a primary contact name and corresponding contact information.
• User Account Information. We collect usernames, passwords, and similar security information used for authentication and access to accounts provided by our services.
• Payment Data. We collect data necessary to process your payment if you make purchases, such as credit or debit card numbers, the security code associated with your payment method, or purchase order details. PITSCO does not store payment data. All payment data is stored by our payment processors, CyberSource and/or CenPOS. You can review the CyberSource privacy policy here and the CenPOS privacy policy here. You can contact the payment processor(s) directly with any questions via the contact information provided.

Information Collected Automatically

The Short Version. Some information, such as IP address and browser and device type, are collected automatically when you visit our websites.

We automatically collect certain information when you visit, use, or navigate our websites and online services. This information does not reveal your specific identity (such as your name or contact information) but may include device and usage information, such as your IP address, browser type, device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our services, and other technical information. This information may be collected using cookies, web beacons, and other similar technologies.

Information Collected from Other Sources

The Short Version. We may collect limited data from public databases, marketing partners, and other outside sources.

We may obtain information about you from other sources, such as public databases, joint marketing partners, and other third parties, that we may aggregate with information you provide to us. Examples of the information we receive from other sources include your job title and/or job classification, the educational institution(s) you serve, grade levels you teach or administer, or other details about the educational institution(s) you are associated with such as enrollment numbers, government funding sources, and purchasing patterns.

Our Corporate Sites may also utilize cookies, pixels, web beacons, or similar technologies to monitor the effectiveness of advertisements posted on other sites including social media sites, such as the Facebook “Custom Audience pixel.” Any data collected in this manner is anonymized and does not include personal data from your social profiles. We do not utilize this technology on our Education Sites.

How We Use Your Information

The Short Version. We use the information we collect to allow you to experience the services provided by the Sites.

Uses of the information you provide to us include the following:

• Use of Site Functionality. . The information you provide to us is used to permit you to use the services and functionality provides by the Sites.
• Personalized Experiences. The information you provide to us is used to personalize your experience by presenting projects and assignments tailored to your interests and activity on the Sites.
• Our Business Purposes. Information collected may be anonymized or aggregated to fulfill business purposes such as data analysis, developing new or improved products and services, identifying usage trends, and determining the effectiveness of our educational content.

The information we collect automatically is primarily used to maintain the security and operation of our websites and online services, for internal analytics and reporting purposes, and for continued innovation and improvements to our sites and/or services.

The information we collect from other sources is used to improve the accuracy and relevancy of the marketing information we provide to you, to associate your account with the appropriate institution(s), and for other business purposes including internal analytics and reporting purposes and continued innovation and improvements to our products, sites, and/or services.

HubSpot, Inc. We utilize HubSpot to manage email subscriber lists, to send email to our subscribers, provide access to our company blog, deliver free content downloads, and facilitate other promotions. We do not utilize HubSpot for contacting children. For more information about the privacy practices of HubSpot, please visit legal.hubspot.com/privacy-policy.

Infor CRM. We utilize Infor CRM to track customer service requests submitted by users of our sites and to track details regarding each customer’s journey with us from sales to service. If a child contacts us via one of our support channels, we will collect personal information from that child only as necessary to respond to the child’s request. Any contact information collected will be deleted or anonymized to protect the child’s information after providing our response. For more information about the privacy practices of Infor CRM, please visit www.infor.com/about/privacy.

Sharing of Your Information

The Short Version. We share information only with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.

We only share and disclose your information in the following situations:

• Compliance with Laws. We may disclose your information where we are legally required to do so to comply with applicable law, governmental requests, judicial proceedings, court orders, or legal processes, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). Fulfilling these obligations may require information to be shared outside your country or region of residence.
• Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
• Vendors, Consultants, and Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. We may allow selected third parties to use tracking technology on our websites and services, which will enable them to collect data about how you interact with the services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand online activity. Unless described in this policy, we do not share, sell, rent, or trade any of your information with third parties for their promotional purposes.
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of company assets, financing, or acquisition of all or a portion of our business (including in connection with any bankruptcy or similar proceedings).
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
• With Your Consent. We may disclose your personal information for any other purpose with your consent.

How We Store Your Information

The Short Version. We may transfer, store, and process your information in countries other than your own. We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

Our servers are located in the United States. If you are accessing our websites or services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information in the United States, Canada, and other countries.

If you are a resident in the European Economic Area, then these countries may not have data protection or other laws as comprehensive as those in your country. We will, however, take all necessary measures to protect your personal information in accordance with this privacy policy and applicable laws.

PITSCO complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States and has certified its compliance with it. As such, we are committed to subjecting all personal information received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.

With respect to personal information received or transferred pursuant to the Privacy Shield Framework, PITSCO is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this policy will require us keeping your personal information longer than 90 days past the termination of the user’s account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

How We Protect Your Information

The Short Version. We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the Internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our websites and services is at your own risk. You should access the services only within a secure environment.

Your Choices About Your Information

If you no longer wish to receive emails from us, you may opt out of receiving emails from us by following the instructions included at the bottom of each email. Please note, if you opt out of receiving marketing messages from us, we may still send you service-related emails for administrative purposes.

Access to information of students or children is provided and controlled by the sponsoring educational institution. If you have questions regarding reviewing, correcting, updating, or deleting personal information for a student, please contact the educational institution directly.

Following termination or deletion of an account, we may keep information or content for a reasonable period for backup, archival, or audit purposes, but all data will be deleted from production systems as soon as possible. We may retain anonymized or aggregated data for longer periods to fulfill business purposes such as data analysis, developing new or improved products and services, identifying usage trends, and determining the effectiveness of our educational content.

If you have any questions regarding your information or you would like to review and make corrections, updates, or deletions to your personal information stored by us, you may do so by logging into your account or by contacting us using the contact information in the How to Contact Us section.

Links to Other Websites and Service

We are not responsible for the practices employed by websites, applications, or services linked to or from our websites and services.

Changes to Our Privacy Policy

The short version. We will update this policy as necessary to stay compliant with relevant laws and changes in security best practices.

We may update this privacy policy from time to time. You are encouraged to review this policy frequently to be informed of how we are protecting your information. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification.

How to Contact Us

If you have questions or comments about this policy or our privacy practices, you may contact our Data Privacy Officer, who is responsible for overseeing all questions related to this policy, at privacy@pitsco.com or mail us at:

Pitsco Education, LLC
Attn: Data Privacy Officer
915 E Jefferson St
Pittsburg, KS 66762-6012
United States of America

When contacting us regarding this Privacy Policy, please include your name, contact information for follow-up, and details of your request. Because correspondence is not always secure, please do not include credit card or other sensitive information in your email or mail to us.

Educational Institution Privacy Notice

This Educational Institution Privacy Notice applies to the Education Sites of PITSCO including those at synergy.pitsco.com (“Synergy”), robo-review.pitsco.com (“Robo-Review”), and www.techfluency.org/esess (“E-SESS”). This Notice is intended to help school officials, school users, and parents understand what data we collect, why we collect it, and what we do with it. This Notice summarizes the most relevant portions of the PITSCO Privacy Policy and its statement on Children’s Privacy and includes additional information relevant to schools, educators, and the students in their classes.

Information We Collect About or From Students

The short version. We collect only the information necessary for students to use the services provided by our Education Sites such as a username, password, and any information submitted by the user or sponsoring educational institution. A parent or authorized school official must provide permission for the creation of an account for any child under 13.

We collect information voluntarily provided to us when a user registers on one of our sites or utilizes the services provided by those sites. The personal information that we collect from students may include the following:

• Student Account Information. When an account is created on one of our Education Sites, we may collect personal information about students including a first and last name, username, password, and class information (class name, period name, grade level, and so on) as provided by a teacher or school official. Our sites do not permit account registration directly by the student.
• Student Submissions. Our Education Sites permit students to respond to multiple-choice questions, type responses into open text fields, and record the date and/or time a process or assignment was completed. These responses may include personally identifiable information. Information submitted by a child can be viewed only by the child, other children who were partnered for a shared assignment or experience, and authorized educators or supervisors.
• Additional Information. We automatically collect certain information when students visit, use, or navigate our Education Sites. This information does not reveal the child’s specific identity, such as names or contact information, but may include device and usage information, such as IP addresses, browser type and version, device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when our services were used, and other technical information. This information may be collected using cookies, web beacons, and other similar technologies.

How We Use Information Collected from Students

The short version. We use the information we collect from or about students to allow them to experience the educational experiences provided by the Sites.

• Use of Site Functionality. The information provided by students is used to permit them to use the services and functionality provides by the Education Site(s).
• Personalized Experiences. The information provided by students is used to personalize the student’s experience by presenting projects and assignments tailored to the individual students.
• Classroom Management. The information provided by students is used to allow teachers and educators to track student progress, completion, and performance.
• Our Business Purposes. Information collected from students may be used in anonymized or aggregated form to fulfill business purposes such as data analysis, developing new or improved products and services, identifying usage trends, and determining the effectiveness of our educational content.

How We Share Information Collected from Students

The short version. We share information we collect from students only when we are required to do so, when it has been properly anonymized or aggregated to prevent personal identification of a student, or when we have the consent of a parent or school official.

In limited cases, we may share information collected from students outside of PITSCO. Information collected from students is not shared with other companies, organizations, or individuals except in the following circumstances:

• With Authorized Consent. We may disclose personal information of students for any purpose when we have school or parental consent.
• With School Officials. School or district administrators have access to student information stored within that school or district’s account. Teachers have access to student information stored within their classes.
• Compliance with Laws. We may disclose information where we are legally required to do so to comply with applicable law, governmental requests, judicial proceedings, court orders, or legal processes, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). Fulfilling these obligations may require information to be shared outside a child’s country or region of residence.
• Third-Party Service Providers. We may share limited data with third-party vendors or service providers for the purpose of data analysis, email delivery, hosting services, or other related services. We do not share, sell, rent, or trade any personal information for children with third parties for their promotional purposes or for the use of targeted advertising.
• Business Transfers. We may share or transfer student information in connection with, or during negotiations of, any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of company assets, financing, or acquisition of all or a portion of our business (including in connection with any bankruptcy or similar proceedings).
• Business Partners. We may share student information with our business partners to offer certain products or services such as single sign-on integrations or connections to other educational sites or technologies.

The Rights of Parents and Guardians

In compliance with the Federal Education Rights and Privacy Act (“FERPA”), parents and/or guardians are entitled to access to their student’s information. The parents of students who use the services provided by our Education Sites may request access to or deletion of their child’s personal information by contacting the sponsoring educational institution. Parents may also request deletion of their child’s account through the sponsoring educational institution to prevent the collection of any additional information about or from their child.

Parental Consent. Prior to the creation of student accounts, the educational institution or teacher creating the accounts is responsible for obtaining parental consent. By using the services provided by our Education Sites, educational institutions and teachers represent and warrant that they have received the necessary consent from parents or guardians or have the authority to provide consent on behalf of parents or guardians. PITSCO accepts the sponsoring educational institution’s creation of accounts and use of the services as permission to collect information from students and children who may be below the age of 13 (or a higher age as may be required by local laws) and to access our services. Because our services may integrate or link to other sites or services, such as Thinkscape (mythinkscape.com), LockDown Browser (web.respondus.com/he/lockdownbrowser), Proview (proview.io), or other similar websites, it is the responsibility of schools to obtain parental consent for students to use these associated services as well.

It is highly recommended that all schools provide full disclosure to students, parents, and/or guardians regarding their use of the Education Site(s) provided by PITSCO and that they make a copy of our privacy policy available to parents and guardians.

Conflicting Terms

This Notice works in conjunction with the PITSCO Privacy Policy and the section on Children’s Privacy. Where there are terms that differ, this Notice takes precedence.

How to Contact Us

If you would like to review the personal information your child has provided to us, or if you would like to ask us to cease collecting or using personal information that we have collected from your child or to delete the personal information we have collected from your child, please contact the sponsoring school official. If you have questions or concerns about this policy or our privacy practices, you may contact our Data Privacy Officer, who is responsible for overseeing all questions related to this policy, at privacy@pitsco.com or mail us at:

Pitsco Education, LLC
Attn: Data Privacy Officer
915 E Jefferson St
Pittsburg, KS 66762-6012
United States of America

When contacting us regarding this Privacy Notice, please include your name, the student’s name, and explicit instructions regarding the student’s information. We are committed to responding to your request as quickly as we are reasonably able to do so.

Please note that if a child contacts us with a question about our products and/or services, we will collect personal information from that child only as necessary to respond to the child’s request. Any contact information collected will be deleted or anonymized to protect the child’s information after providing our response.