Summit Learning Platform Privacy Policy

Our Privacy Policy is a reflection of our values and principles. We’ve listened to your questions, feedback and suggestions and through this Policy, have articulated our procedures and protections with respect to data privacy. 

SUMMIT LEARNING PLATFORM PRIVACY POLICY

Last Updated: March 19, 2018

Summit Learning is a personalized approach to teaching and learning inspired by the vision to equip every student to lead a fulfilled life. Summit Public Schools (“Summit” “we”, “us” and “our”), a California nonprofit public benefit organization and a 501(c)(3) nonprofit organization, owns and operates the Summit Learning Platform located at www.summitlearning.org (the “Platform”), and any other products and services that the Summit Learning Program (the “Program”) may provide now or in the future (collectively, the “Service” or the “Services”).

Summit designed the Services to facilitate strong relationships between teachers and students through real-time data about progress towards goals, access to ongoing feedback, and access to a wide range of learning resources that enable students to build on what they learn from the teacher by self-directing some of their learning, too.

As with all technology used in the classroom, protections must to be in place in order to safeguard student information. We have established the Summit Learning Platform Privacy Policy (the “Privacy Policy”) to clearly articulate our procedures and protections with respect to data privacy and to inform the schools and school districts that use the Services (each, a “Partner School” and, collectively, “Partner Schools”) and users of the Services of the ways in which we safely collect, use, and share user information. We are proud signatories to the Future of Privacy Forum’s Student Privacy Pledge.

This Privacy Policy explains how Summit protects the information we collect in order to provide the Services to students (“Students”) and their parents/legal guardians and the teachers, administrators, officials, and agents of their Partner School (“Licensed Users” and together with Students, “Users”).

Summit does not place ads in the Services or use information we collect for behaviorally- targeted advertising purposes. Summit does not and will not seek to profit from students or their schools, teachers, or parents. Summit does not and will not sell student data.

This Privacy Policy applies only to the Services and does not apply to any information collected from any Summit informational or other websites (“Summit Websites”). For information regarding Summit’s commitments with respect to the collection, use, disclosure, and security of data collected from the Summit Websites, please visit the Summit Learning Website Privacy Policy.

In addition, this Privacy Policy does not apply to websites or online services of companies that Summit does not own or control that you may access through the Services, including, for example, links to third-party companies that your Partner School may make available in the Services. These other services have their own privacy policies, and we encourage you to review them. We are not responsible for the privacy practices and policies of those third party companies.

  1. Users of the Services

We provide the Services directly to Partner Schools for their educational purposes and as allowed under applicable federal and state laws. The Services are provided for use by Students and Licensed Users pursuant to agreements that allow Summit to collect certain information in order to operate the Services and use and share in accordance with this Privacy Policy and applicable federal law. Accordingly, we collect information from Students only where a Partner School has entered into a signed Program Agreement with Summit and accepted a Data Privacy Addendum and the Summit Learning Platform Terms of Service (“Terms of Service”). Licensed Users of the Services are also governed by the Terms of Service. Parents/legal guardians can get more information about the Services here.

  1. Information We Collect

We collect different information depending on whether the User is a teacher, school administrator, parent or Student and how the User uses the Services. We collect two types of information about Users: (1) Information Provided Directly to Us and (2) Information Collected Automatically. Summit may also obtain information, including personal information, from external parties to update or supplement the information Users or Partner Schools have provided or we collected automatically.

Information Provided Directly to Us

The information that Licensed Users or their Partner School may choose to voluntarily provide to us while using the Services, or that entities may provide us at the direction of the Partner School, includes the following:

Account Sign-Up and Profile Information

  • Contact information such as full name and email address;
  • Username and password; and
  • Teacher information, including, but not limited to, name and years of experience.

Class and Student Information

  • Class rosters, homeroom, and grade level;
  • Student email address;
  • Student identification numbers such as school identification number or school information system identification number;
  • Student record information such as attendance, suspension, and expulsions;
  • Student demographic data, including date of birth, gender, ethnicity or race, and socioeconomic status;
  • Student subgroups, such as English learners;
  • Student subgroups,  such as students with disabilities;
  • Mentor observations;
  • Student outcome information such as grade level promotion and matriculation, AP and IB test information, college admission test scores, college eligibility and acceptance, and employment; and
  • Academic or extracurricular activities a student may belong to or participate in.

Course Information and Student Scores

  • Course data including coursework in applicable media (e.g., video, audio, text and images) and course progress;
  • Student scheduled courses;
  • Test scores, grades, standardized test results, and teacher feedback on coursework; and
  • Teacher curricula and notes and feedback to or about students.

Parent Information

  • Names, mobile phone numbers and email addresses of parents/legal guardians if provided to Summit from the Partner School or the parent/legal guardian.

Other

  • Answers to surveys about the Services or curricula; and
  • Feedback, suggestions, questions, and ideas submitted to Summit.

Information We Collect Automatically

Summit may collect certain information automatically through the Services to assist the functionality of the Services, such as Internet protocol (IP) address and other device identifiers that are automatically assigned to a User’s computer or device, browser type, operating system, Internet service provider, the date and time of a User’s use of the Services, and information about the links clicked and pages viewed within the Services.

Summit may use technologies such as cookies, pixel tags, local storage, mobile identifiers, and similar technologies to automatically collect this information. By using the Services, you consent to our use of cookies and similar technologies. If you choose to refuse, disable, or delete these technologies, some of the Services functionality may no longer be available.

To learn more about information we collect from Students see the section “How We Protect Students’ Personal Information” below.

Information Received from External Sources

We may also obtain information, including personal information, from external sources, such as content partners, providers of tests and assessments, and student information systems, to update or supplement the information you provided or we collected automatically. Local law may require you authorize the external sources to share your information with us before we can acquire it. We treat personal information we receive from external sources in accordance with this Privacy Policy, including if we directly combine that personal information with other personal information that we collect through the Service.

  1. We Limit Use of the Information We Collect

Summit uses the information it collects, as directed by its Partner Schools for educational purposes, including to:

  • Operate, develop, analyze, evaluate, and improve the Services;
  • Communicate with Users in connection with providing the Services;
  • Send parents informational alerts or other communications via SMS or email messages (see the section “How Summit Communicates with You” for information on how to manage or opt-out of communications);
  • Evaluate the efficacy of the Services and Program;
  • Administer surveys, studies, and interviews;
  • Provide curricula choice or recommendations;
  • Drive learning engagement and progress via content suggestions to Users
  • Maintain the security of the Services, troubleshoot, and perform audits;
  • Perform any other activities requested by Partner Schools for educational purposes or with the consent of a parent or legal guardian or Student of the age of majority;
  • Protect or defend the rights, safety, or property of Summit, Partner Schools or Users, or to comply with any law enforcement, legal, or regulatory process; or
  • Comply with applicable law.

Summit will not use the information we collect for behaviorally-targeted advertising purposes.

In addition, Summit will not use or authorize our Service Providers to use personal information from Users for the creation of commercial products or services. Summit does not sell or rent any personal information to any third party for any purpose – including for advertising and marketing purposes.

Summit will not use information collected from Student Users for any purposes other than Partner Schools educational purposes unless we have de-identified the information to a level that it cannot reasonably be linked to an identifiable Student.

  1. We Limit How Information Is Shared

Summit only shares information:

  • With the Partner Schools and other Users within a school for the Partner School’s educational purposes.
  • With a Student’s parents and legal guardians as authorized by the Partner School.
  • With Service Providers who help us provide the Services. Summit does not and will not grant Service Providers the right or permission to use your personal information beyond what is necessary to assist us in providing the Services. In addition, Service Providers must comply with this Privacy Policy, the terms of Summit’s agreements with Partner Schools, and applicable law. Further, we require Service Providers to employ reasonable and comprehensive data protection and security protocols. The Services use Service Providers for tasks such as document management; data hosting; and provisioning customer service tools. A list of our Service Providers can be accessed here (“Service Providers”).
  • With entities with whom we are obligated by law or our Terms of Service to share information. Summit may share information to third parties if we believe in good faith that sharing information is necessary or appropriate (i) to protect or defend the rights, interests, safety, or security of Summit, Partner Schools, Users, or Service Providers; (ii) to comply with any law enforcement, legal, or regulatory process (e.g. warrants, subpoenas, court orders), or other applicable laws and regulations; (iii) to prevent violations of the Terms of Service; and (iv) as otherwise required and permitted by law.
  • With successors in connection with a change to our organization. The Student Privacy Pledge requires us (and all pledgers) to commit to how we handle data in the event of a change to our organization such that all or a portion of our organization, our assets, the Service, or the personal information that we have collected might be transferred from Summit to another entity. Consistent with the Student Privacy Pledge and applicable state and federal laws, in connection with such a change to our organization, if any, this Privacy Policy will continue to apply to Users’ information. Accordingly, any successor entity would be required to only use and share personal information pursuant to this Privacy Policy (unless Users give consent to a new policy). If a successor entity will have access to personal information, we will provide Users with notice within thirty (30) days following the completion of such transition by posting on our homepage and/or by email to email addresses provided to us. If you do not consent to the use of your personal information by such a successor entity, if any, subject to applicable law, you may request its deletion from the successor company. Further, in the unlikely event that Summit files for bankruptcy or dissolution, we will protect your personal information, and we will not sell personal information to any third party.
  • With third parties, if directed or authorized by the Partner School or with parental consent, to the extent permitted by law and subject to our Terms of Service.

In the event Summit needs to demonstrate how Summit is used and its efficacy, spot industry trends, or to provide marketing materials for Summit, we will only share de-identified information.   We may share aggregated and/or non-personally identifiable information publicly (such as statistics about visitors, and traffic patterns). We will not share personal information for such purposes.

  1. We Support Parent Engagement

We support and encourage the involvement of parents and guardians in their Students’ education. Through the Services, parents and guardians can track their Student’s progress in real time. Parents, legal guardians, and students may, at any time, make a request for access, review, correction or deletion of personal information in the Services by contacting the appropriate official at the student’s school or school district. If the school determines that the request should be implemented, the school may either make the change themselves or submit the request to Summit. We will use commercially reasonable efforts and process such requests in a timely manner consistent with applicable law.

  1. How We Protect Student’s Personal Information

All Students who use the Services will be enrolled in a Partner School who has signed a Program Agreement to participate in Summit Learning. Pursuant to each Program Agreement and the Terms of Service, each Partner School has agreed and consented to our practices regarding the collection, use, and disclosure of personal information from Students as permitted by law.

Prior to a student accessing the Service, the child’s teacher or school administrator must create the Student’s account on the Service. When the school administrator or teacher registers its Students for accounts, Summit relies on consent obtained from Partner Schools acting as an agent of the Student’s parent or legal guardian, as permitted by the Children’s Online Privacy Protection Act (“COPPA”). For more information, please see our FAQ. Protecting student data privacy is our top priority - this is why we have signed the Student Privacy Pledge.

COPPA governs the collection of certain information from children under the age of 13 ("child" or "children"); for more information about COPPA and generally protecting children's online privacy, please visit OnGuard Online. While COPPA does not directly apply to non-profit organizations such as Summit, we voluntarily comply with COPPA’s guidelines regarding Students under the age of 13 as part of our commitment to transparency with parents regarding the collection and use of their child’s data.

The commitments we make regarding information collected from or about Students apply equally to all Students regardless of their age. Accordingly, where this Privacy Policy references Students or any information collected from or about Students, our Privacy Policy applies to Students under 13 years old as well as Students 13 years old and above.

What Information Does Summit Collect from Students and How Does Summit Use the Information?

We use information collected from Students to provide the Services to Students and as described further in this Privacy Policy and the Terms of Service. The Partner Schools have authorized Summit to collect the following information from Students necessary to use our Services:

  •  Classwork, for example: Project submissions (including documents and other media), assessment responses, and academic goals;
  •   Communications with teachers and mentors, for example: responses to teacher feedback, free-form notes, and requests for guidance; and
  •   Non-academic information, for example: college and career interests, college preparation artifacts (essays, letters of recommendation), reflections on academic progress and other self-assessments, anonymous survey responses, and offers to tutor peers.

In addition to the information entered by the child, we automatically collect some information from any use of our Service as set forth in the “Information Collected Automatically” section. We also receive from the student's teacher or student’s school, and link to the student’s account in our Summit systems, the information set forth here and here.

If we discover that we have collected personal information from a child in a manner inconsistent with this Privacy Policy, we will take appropriate steps to either delete the information, or seek consent for that collection.

What Student Information is Visible to Others?

The Service limits access to each Student’s account and the content thereon to the Student, the Student’s parents/legal guardians, teachers, school administrators, and other teachers in the Student’s school (depending on the setting selected by the school’s administrator). Accordingly, the Services do not permit any Student’s account or the content and grades thereon to be viewed or accessed by the general public. A student may choose to share coursework through certain non-Summit features (for example: sharing options available in Google Documents based on the school’s configuration).

How Long Does Summit Keep Children's Information?

Please see the section “Data Retention.”

Parental Choices

Please see the section“We Support Parent Engagement.”

  1. We Are Committed To Keeping Information Secure and Accurate

The security of personal information from our Users is important to us, and we are dedicated to keeping it secure. To prevent unauthorized access, disclosure, or improper use of User information, and to maintain data accuracy, we have established physical, technical, and administrative safeguards to protect the personal information we collect. In particular:

  • We restrict access to personal information to authorized Summit employees, agents, service providers, or independent contractors who need to know that information in order to process it for us, and who are subject to strict confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations;
  • We require that our Service Providers with whom we share student personal information employ data protection and security protocols consistent with this Privacy Policy;
  • We employ administrative, physical, and technical safeguards designed to protect personal information from unauthorized access, disclosure, and use or acquisition by an unauthorized person, including when transmitting and storing such information;
  • We use identification and authentication methods such as multi-factor authentication;
  • We employ strong encryption technologies to securely transmit all personal information, including data-in-transit encryption, and store all personal information, encrypted at rest;
  • We maintain a data backup and recovery capability that ensures a timely and accurate restoration of all personal information;
  • We maintain a secure software development lifecycle with industry recognized security practices to establish secure application(s), network, and infrastructure architectures;
  • We maintain event monitoring and response procedures for events which could impact functionality and/or availability of the Services;
  • We guard against security incidents and maintain incident response policies, plans and procedures focused on timely and effective incident response;
  • We employ industry leading intrusion detection measures focused on monitoring and identifying deviations in normal network, User, and Service behaviors;
  • We employ trained incident handling professionals with experience in security incident and event monitoring;
  • We perform application security testing (including penetration testing) and conduct security risk assessments focused on the identification and remediation of risks; and
  • We employ oversight and accountability procedures for risk management and remediation.

We continually develop and implement features to keep personal information safe. Should you discover any security bugs in our Services, we request that you contact us promptly at support@summitlearning.org.

Although we make concerted good faith efforts to maintain the security of personal information, and we work hard to ensure the integrity and security of our systems, no practice can be 100% guaranteed. The security of User information can be compromised by outages, attacks, human error, system failure, unauthorized use or other factors at any time. In addition, if we learn of a data breach, we will notify Users in accordance with the applicable state law.

For additional information on our security practices, please visit our FAQs.

  1. Data Retention

Summit will only retain personal information, including personal information from Students and Licensed Users, for a limited time. If a Partner School leaves our Program or requests removal of personal information, we will promptly direct our team to delete, dispose of, or de-identify the personal information. Our team will delete, dispose of, or de-identify the personal information in a commercially reasonable amount of time unless, consistent with applicable law, there is a compelling reason to retain such personal information. Our normal retention period will not apply if we have consent to retain such information or if we are required to retain such information to comply with our legal obligations or law enforcement requests, resolve disputes, to protect the safety and security of our Users or our Service, or enforce the Terms of Service, Program Agreement, including the Data Privacy Addendum, or any posted guidelines, policies or rules applicable to specific features of the Services.

If you are a User of the Services who wishes to have personal information removed from the Services, please review the information in the section “Partner Schools Can Delete Information” and contact your Partner School.

For additional information relating to deletion and retention policies, please see our FAQs.

  1. Partner Schools Can Delete Information

Partner Schools may request the review or deletion of information held by Summit in the Services. Summit will delete or de-identify such information in a commercially reasonable amount of time in compliance with applicable law, unless we otherwise have consent to retain such information or are required to retain such information to comply with our legal obligations or law enforcement requests, resolve disputes, or enforce the Terms of Service, Program Agreement, including the Data Privacy Addendum, or any posted guidelines, policies or rules applicable to specific features of the Services.

  1. How Summit Communicates with You

If, as a Licensed User, you created an account on the Service, provided an email or phone number to us, or otherwise opted-in to receive communications from us, we may send you messages and updates regarding your account, including privacy and security notices, updates regarding the Service, and information regarding products, and related features or services. These communications may include, but are not limited to, SMS, push notifications, email, telephone calls, and postal mail. If, as a Licensed User, you have an account with us, we'll also use your email address to contact you for customer service purposes, or for any legal matters that arise in the course of business. We may receive a confirmation when you open an email from us if your device supports it.

If, as a parent/legal guardian of a Student, you provided an email address or phone number to your school, your account (“Parent Account”) will be set up by your Student’s teacher or school. Summit, at the direction of the Partner School, may send an invitation to you to log in to your Parent Account via the email or phone number your Student’s teacher provided Summit to set up your Parent Account. The invitation may be sent via email or SMS text message. If, as a parent/legal guardian of a Student, you provide your telephone number to your Student’s school, you are consenting to Summit (on behalf of and at the direction of your child’s school) sending informational text messages closely related to the Partner School’s mission. If, as a parent/legal guardian, you would prefer not to receive our communications, you may opt-out using the "Unsubscribe" or "STOP" instructions contained in those communications or by turning off push notifications on your device.

  1. We Are Transparent About Changes

Summit may update this Privacy Policy from time to time. This Privacy Policy was last updated on the date marked by the "Last Updated" date at the top of this page. When we update the Privacy Policy, we will post the new Privacy Policy on our website www.summitlearning.org.

If we revise this Privacy Policy in a manner that is material, including, but not limited to changes to our promises with respect to the use, collection, and sharing of personal information, we will notify Partner Schools as provided in the Program Agreement and notify Users of such changes through the Services and/or by email using the address we have on file for such Users. The notice will indicate which sections contain material modifications and what choices Users may have. If a User continues to use the Service after the notice has been posted on the Services or sent via email, the User will have acknowledged that he or she accepts and agrees to the revised Privacy Policy.

  1. We Want To Hear From You

If you have any questions about this Privacy Policy or our practices, please contact privacy@summitlearning.org.

You can also reach us by calling (650) 257 9878 or writing to:

Summit Public Schools
780 Broadway Street
Redwood City, CA 94063
Attn: Summit Learning Program

 

 

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