Last updated: 11/17/2020
I. ACCESS BY STUDENT USERS
How Student Users may Access our Services. Certain Members of our Services who are teachers or other school administrator authorized by a school or district (“Teachers”) may use certain features of our Services, such as the BookPagez Digital Resource, to interact directly with Student Users (“Student Tools”). Student Tools may be used with Student Users only by Teachers, in an education setting as permitted by school or district policies, and where the Teacher has verified to us (using reasonable methods in light of industry standards and available technology) that they are a Teacher authorized to provide their consent (via the terms described in more detail in the BookPagez Digital Resource Terms of Service) for Student Users to use the Student Tool and disclose Personal Information (as defined herein) to us. “Personal information” (as further described in the Children’s Online Privacy and Protection Act (COPPA)) is information that can be used to personally identify a specific individual. BookPagez only collects Personal Information from Student Users whose Teachers have elected to use the Student Tool and have provided their consent for use by Student Users. That means, the only way that a Student User is permitted to access our Services is through a Student Tool, and the only way that a Student User is permitted to access a Student Tool is through an invitation, unique code, or link shared with the Student User by a Teacher. If we find that anyone under the age of 18 has otherwise accessed or attempted to access our Services other than as permitted herein, we will remove those individuals and any Personal Information they may have provided from our system.
Compliance with COPPA and FERPA
COPPA. COPPA requires operators of online services that collect Personal Information from individuals under the age of 13 to obtain “parental consent”, and to comply with certain rules with regard to how Personal Information collected from such individuals is processed, secured, and disclosed. COPPA permits schools and teachers using such online services in the education setting to act as the parent and provide consent to the operator of an online service to collect Personal Information from students who may be under the age of 13, for the use and benefit of the learning environment. When a Teacher connects with Student Users through the Student Tool, we collect certain information (“Student Information”) — which may include Personal Information. We have adopted this Policy and the processes and protocols described herein to ensure that we’re meeting the requirements of COPPA as applicable.
FERPA. Student Information may include information considered an education record subject to the Family Educational Rights and Privacy Act (“FERPA”). To the extent that FERPA applies to any Student Information we may receive as a result of your use of the Student Tool, BookPagez acts as a “school official” (as that term is used in FERPA).
No Ads. We do not display, place, or allow any third-party ads on any Student Tools or other parts of our Services enabled for use by Student Users. Our Student Tools are intended to create interactive learning experiences between students and teachers and deepen student engagement with their learning materials, not to sell anything to them.
II. WHAT INFORMATION WE COLLECT
When a Student User interacts with our Service through a Student Tool, we collect the following information.Information provided to us directly: We collect some information that Student Users enter directly through the platform.
Information obtained via third party integration: In some cases, we might obtain some information via a Student User’s interaction with third party providers that we integrate with — for example Google’s authentication services.
- Name or Nickname: We may collect a Student User’s nickname, first name only, or full name in order for the Teacher to be able to identify and distinguish between different students using the Student Tool.
- Response information: Using a Student Tool, Student Users are able to provide responses to questions or otherwise enter information or add content to materials shared by their Teacher (“Responses”). Such Responses may include text, voice recordings or other content formats as available.
Information collected automatically: We also collect some information automatically about a Student User’s device and browser while they use our Services.
- Google Identity Information: Student Users may be required to authenticate their identity via their existing Google account before they can access a Student Tool. Google will check that Student User’s Google credentials (these never get shared with us) and Google will share a Google Identity number for that Student User as confirmation. That Google identity number, which is in the form of an alphanumeric string associated with a particular Google user, will be immediately and permanently altered and stored in a hashed format in our system so that it cannot be used for any other purpose other than to authenticate that user.
- Device and system information: We may collect the IP address associated with that Student User’s use of the Services, and browser and device information for security and performance monitoring purposes which ensure that our Services are working and properly configured for different devices and browser types. We do not use a Student User’s IP address to identify or track their location or movements.
- Authentication Cookies: We store authentication cookies in order to enable our Services to identify and properly authenticate each returning user and ensure that users are only able to access their own information, and for anonymous session tracking so we understand overall usage.
III. HOW WE USE THIS INFORMATION
We collect and process Personal Information from Student Users only for the purposes of enabling use of Student Tools by Teachers and Student Users. We do not collect or process Personal Information from Student Users in order to advertise or market to Student Users or create behavioral profiles for marketing.
- To fulfill requests. Students may elect to use the Student Tool to submit Personal Information such as their name, or any information the Student User includes in their Responses. We collect and process that information to fulfill the Student User’s request to submit that information to you (the Teacher) and to allow you to access that information.
- Site traffic and Analytics. We collect and share certain Personal Information with Service Providers (as defined below) we use for analytics to understand how our services are used, including traffic, number of users, and user events which may be viewed in individual or aggregate form.
- Site Security and Operations. We collect and share certain Personal Information (such as IP address) with Service Providers (as defined below) for security and operations purposes to monitor for performance and maintenance issues, debugging and site security.
IV. WHO WE SHARE INFORMATION WITH
We do not sell the Personal Information of Student Users and we only share Personal Information of Student Users to the following parties:
- With Teachers. Student Tools on BookPagez enable Teachers to interact with Student Users so that they may share, complete, and receive education instruction and assignments virtually. Teachers will have access to all Student Information including Student Users’ engagement with the Student Tool, the name or nickname they provide, and Responses.
- With Service Providers. In order to provide our Services including Student Tools, we engage the services of third-party service providers who may host, store, transmit, and/or otherwise process information for us (“Service Providers”). Our Service Providers are not permitted to use or process our data, including Personal Information of Student Users for purposes other than to provide their services to us.
- With employees/agents. In addition to Service Providers, we may share Personal Information with certain employees or other agents we hire to help us build, improve and provide our Services. We limit access to those employees and agents who need access to this information to do their work and they are not permitted to use or share this information for any other purpose.
V. INFORMATION RETENTION AND CHOICES
How long we keep Student User information: We retain the Personal Information of Student Users only as long as necessary to provide the Services related to the Student Tool, which may be for as long as a particular Student User is using the Student Tool and the Teacher associated with such Student User is an active Member of our Services, and for some time thereafter as needed to fulfill our legal obligations.