LEARNstyle Privacy Policy
Introduction
This Privacy Statement provides information on how LEARNstyle Ltd collects, uses, and protects personal information. LEARNstyle supports the most critical processes of managing student, class, and school data, and we are committed to the highest standards of protection for personal data at all times. When we refer to “us,” “we,” “our,” or “LEARNstyle” in this Privacy Statement, we are referring solely to LEARNstyle.
Privacy is a fundamental right for all individuals. Our clients entrust us with the personal information of both employees and parents and students. On this basis, we take the responsibility attached to this information very seriously. We are a signatory of the Student Privacy Pledge.
This Privacy Statement governs all the manners in which LEARNstyle collects personal information directly from you as an individual. Whether you are a visitor to our websites, request a trial of our products or a whitepaper, or any other communication with us (such as attendance at a conference or trade show), this Privacy Statement governs our use of personal information for products and services that we provide directly to you as what is known as a “data controller.” How we collect information and how we use information may differ based on our relationship with you as an individual. We have identified below the different relationships we may have with you, and our respective use of information we collect.
When a customer’s privacy statement/policy governs
If you are an end-user (parent or student, applicant or employee) of our customer (a school or school district) and you are using LEARNstyle products and services through our customer (your school or school district), we are considered a “data processor.” In these cases, your school or school district’s privacy statement or privacy notice governs the use of any personal information.
Our Privacy Statement does not supersede the terms of any agreements between us and your school or school district (our customer), nor does it affect the terms of any agreement between the student and the student’s school or school district.
What Information We Collect and How We Use It
The nature of the personal information we collect and how we use it depends on the context in which we collect that personal information. Please see the section below that applies to you.
A. Website Users
You may visit any LEARNstyle website without having to log in or provide any personal information. If you are on a LEARNstyle website to access a service or product, you may need to log in to make use of the functionality of the particular product
Information We Collect
Directly from you. You may voluntarily provide us with information when you complete a form or survey on our website or subscribe to our blog or newsletters. This may include some or all of the following categories of information: Name and Role; Job title; Signature; Profession; Social media account name; User name; Telephone Number; Street Address; and Email address.
You may also provide information when you register for an account through a LEARNstyle website to log in to use a product or service.
We collect information about the pages you visit and how you access and use the LEARNstyle websites using cookies, tracking technologies and other third party analytics tools. Specifically, We and our service providers use cookies and similar technologies such as local storage (HTML5), web beacons, Javascript, and eTags on our websites. This information includes information about the devices you use to access the LEARNstyle website including unique device identifiers, IP addresses, operating systems, browsers, and cookies. Depending on your device settings, we may also collect information about your geographical location and what websites you may travel from to our website. We use this information to better understand our customers and users, so that we may provide more effective advertising and products.
Information from third parties. We may supplement the information we collect with information from other third parties that we use to promote our products and services. For example, we may receive information from a third party about how well an online marketing or email campaign performed, or from conference and trade show organizers.
How We Use This Information
We use the information collected to provide and improve our website services and our products and to analyze usage information for sales and marketing purposes. We also use the information collected to communicate with you in any manner that you have requested. This analysis is necessary to further our legitimate interest in understanding our users and their interactions with us and our websites to best iterate and improve our websites and communications, including marketing purposes, and to provide you with the content that you have requested. Third-party information that we collect from social media may be used to provide you with requested information or our newsletter or contact you regarding our services, opportunities, products, and/or events.
How We Share This Information
Where we use third-party analytics tools to help us understand how the LEARNstyle websites are used, these parties will have access to some of your personal information. This includes analytics tools such as Google Analytics. We also share information with our vendors and service providers and other third parties for legal or business purposes, but only as permitted and subject to required limitations.
B. Customers (Schools and School Districts)
If you are a customer of LEARNstyle, we are providing our products and services directly to your school or school district and we are a “data controller” for purposes of the personal information collected in connection with the customer accounts.
Information We Collect
Directly from you. We collect the information necessary to provide the educational technology services as directed by you. The information collected from you depends on the specific product and what is needed to integrate with your systems and to set up and maintain accounts. This includes information in the following data categories:
Account information
The exact elements will depend on the product and what specific information you as a customer provide us, but often we receive from you include pupil records of students and parents of students enrolled in your school or district, such as directory information, email addresses, student IDs, account credentials, courses students are enrolled in, health information kept in student records.
We also collect employee account information including user names, email addresses and titles to initially set up products and services for you.
Indirectly from you, we collect device and usage information when you access and use our products and services, including information that your browser or the mobile app sends when you are using it. This data may include your unique device identifier, IP address, your browser type and configuration, the date and time of your use of the product or service and cookie data. Specifically, we and our service providers use cookies and similar technologies such as local storage (HTML5), web beacons, Javascript, and eTags. The purpose of collecting such information is for the improvement of our products and services to better meet the needs of our customers and their users.
All data sent between client systems and LEARNstyle servers is encrypted via SSL. Certificates are from industry-trusted providers, using a minimum of 2048-bit RSA encryption on SHA-256 algorithms. All LEARNstyle servers are restricted to a minimum of TLS 1.2/1.3 Previous protocols are disabled. All data on LEARNstyle servers is encrypted at rest using a minimum of asymmetric AES 256-bit encryption. All-access to underlying LEARNstyle infrastructure is tightly controlled and monitored through industry-standard best practices and protocols.
How We Use This Information
We use your information to provide you with the features and functionality of the LEARNstyle products and services, as well as to communicate directly with you and allow you to communicate with other LEARNstyle users. It is necessary for us to use your information in this manner in order to provide you with the services your school district has requested pursuant to its agreement with LEARNstyle.
We may also use de-identified and aggregated information to understand and improve our products and services. For absolute clarity, we do not provide any student data or personally identifiable information for marketing purposes.
How We Share This Information
We share information to provide LEARNstyle products and services to you and further improve them. Within LEARNstyle, your information will be accessed only by those who have a need to provide the LEARNstyle products and services. We use vendors to help us provide LEARNstyle products and services to your school or school district. For example, if your school or school district has a hosted LEARNstyle product or service and Azure provides our cloud hosting facilities.
LEARNstyle operates both training services and software solutions to various boards. Software solutions supporting both student training and inventory tracking are all cloud-based, running in Microsoft’s Azure environment.
The STMS (Student Training Management System) is used to schedule, track, coordinate and report on both High and Low Incidence training requests, and is used by internal LEARNstyle training staff as well as authorized board contacts.
The SEAit tool (SEA Inventory Tracking) provides end-to-end equipment life cycle management for AT and mobility / sensory equipment and is used exclusively by authorized board personnel and LEARNstyle system administrators.
The RISE tool provides all the necessary compliance tracking and system components a District, Board or School needs for Student Services and/or Special Education policies and procedures
All systems will collect and track various data points on students, parents and faculty.
Student Personal Information
LEARNstyle is a data processor with respect to student personal information and the LEARNstyle customer (school or school district) is the data controller. Where a LEARNstyle customer enters into an agreement with LEARNstyle to provide products and services, that LEARNstyle customer acknowledges that LEARNstyle is a data processor with respect to personal information received from that LEARNstyle customer or from a student/parent in connection with the LEARNstyle products and services.
Student Personal Data Ownership.
All student personal data remains the property of and is solely owned, and thereby controlled, by our LEARNstyle customers. You grant LEARNstyle a non-exclusive license, to use your data or other material of yours solely for the purpose of providing, maintaining, and supporting you and other licensees with LEARNstyle products and services.
LEARNstyle will only use student personal data for the purposes of providing the products and services that our customers (school or school districts) have contracted with us to provide and we will process student personal data according to instructions and the terms of our contract with our customers. Student personal data will never be used for any form of advertising by LEARNstyle or any of its affiliates.
C. Parents and Students
The school or school district decides how your personal information is used.
LEARNstyle provides products and services to end-users of a school or school district (our customers) as a “data processor.” The main responsibility of what is known as a “data controller” lies with the school or school district. This also means that the school or school district’s own privacy statement governs the use of student personal information. LEARNstyle’s customers determine what information we collect through the LEARNstyle products and services and how it is used, and we process that information according to our customer’s instructions and the terms of our contract with our customers.
This section of our Privacy Statement is provided for informational purposes and describes how parent and student personal information is used when LEARNstyle products and services are provided through a school or school district. How that information is used depends on the school or school district, so please consult your institution’s privacy statement.
Information We Collect
Information provided to us by a school or school district.
The LEARNstyle products and services integrate with our customer’s systems. The specific information that is collected from the school or school district depends upon the LEARNstyle product or service, but in general, this information includes but is not limited to: name, age, email address, student ID, account credentials, academic and student records, health information kept in student records, courses a student is enrolled in when we initially set up the products, and additional records as requested by the school or school district. LEARNstyle will receive regularly updated information to keep account information accurate and up to date.
Directly from a parent or student
Depending on the LEARNstyle products and services your school (or your child’s school) uses, we will collect the following data categories directly: name, age, email address, student ID, account credentials, academic and student records, certain health records, courses a student is enrolled in when we initially set up the products and services for your institution, and additional records as requested by the school or school district. LEARNstyle will receive regularly updated information to keep account information accurate and up to date.
How We Use This Information
On behalf of your School or school district. We use your information on behalf of and under the instruction of your child’s school or school district, which is the data controller. We use the information in accordance with our agreement with your child’s school or school district to operate, maintain, and provide the features and functionality of the LEARNstyle products and services. Your child’s school or school district determines how the personal information is used.
How We Share This Information
We share student information in accordance with our agreement with your (or your child’s) school or school district. Generally, this includes the sharing of such information inside and outside LEARNstyle under certain terms. Student information will be accessed inside LEARNstyle only by those who have a need to know to provide the LEARNstyle products and services and improve them. For example, our technical and client support teams may have access to personal information when the LEARNstyle products and services are implemented for your school or school district or when the software or other changes are required for support and maintenance purposes. We use vendors to help us provide the LEARNstyle products and services to you (or to your child) on behalf of our school or school district customers.
D. Sharing with Vendors, Partners, and Other Disclosures
Vendors. We engage directly with certain third-party companies to help us provide the LEARNstyle products and services to our customers or to you or to perform work on our behalf (“Vendors”). Our vendors are required to abide by our privacy and security instructions and are contractually restricted from using any personal information they access or receive from us for any purposes other than as needed to perform such services. We may use vendors to help us conduct marketing campaigns or events and disclose customer contact information necessary for those activities.
Software Subscriptions:
Information is disclosed to internal LEARNstyle employees only as required to (i) perform services contracted by the board (ii) perform system maintenance and updates (iii) provide support services.
Integration with other data providers mandated by the board may be integrated into LEARNstyle systems. This can include Student Information Systems, dashboard data aggregators, analytics providers, accounting systems or help desk ticketing systems. These systems will only be integrated at the request and approval of the board, with the scope of data and frequency determined and agreed upon prior to implementation.All information may be used in the process of security audits or investigations, to ensure the high level of privacy and security customers have come to expect from LEARNstyle. Other than the stipulations listed above, no data will be disclosed to any external 3rd party unless written approval from the Board, or as required by law.
Partners. Your institution may work with third-party companies to provide additional content and functionality which requires access to LEARNstyle products and services (“Partners”) Only with your institution’s permission, will we share information about you, such as your name, email, or student ID, that is required to provide you with access to the products and services that have been requested by your institution. In these cases, these Partners will enter into an agreement directly with your institution regarding the processing of any data at the direction of your institution.
Other Types of Disclosures.
We may also share your information where required under the following circumstances:
Where permitted by applicable law and by contracts with our customers, we may disclose your information in the course of a corporate transaction such as a merger, acquisition, sale of assets, or financing, or pursuant to a bankruptcy, dissolution proceeding or reorganization.
We may need to disclose your information to comply with legal or regulatory requirements and to respond to lawful requests, court orders, and legal processes. Where such disclosures relate to personal data we hold as a data processor on behalf of our customers, we will refer such requests to our customers where permissible.
We may need to disclose your information to protect and defend the rights, property, or safety of LEARNstyle, our customers, or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or other misuse of our systems.
We may utilize aggregated or de-identified (anonymized) information that is no longer associated with a person to enhance and promote LEARNstyle products and services. LEARNstyle does not rent, sell, or otherwise provide access to student personal data to third parties for marketing or advertising purposes.
Marketing.
We conduct marketing to promote LEARNstyle products and services but do not use or disclose information (whether personal information or otherwise) about students that we collect through the provision of LEARNstyle products and services for targeting of advertisements to students. When we conduct (or sponsor) events, conferences, and webinars, we will collect information about attendees, such as the session they attend and their contact information to provide them information about LEARNstyle products and services and other LEARNstyle information.
Marketing Preferences and Opt-Out.
Our marketing emails will always include an “unsubscribe” link so that you can change your preferences and opt out of receiving marketing emails or communications from LEARNstyle. You can also send us an email at info@LEARNstyle.com to unsubscribe. Please note that even if you opt out of marketing emails, we may still need to contact you with important information about your LEARNstyle account.
Interest-based Advertising.
We use third-party advertising tools to collect information about your visits to the LEARNstyle websites to provide targeted advertisements to you based on your browsing history on other websites or on other devices you may use. If you would prefer to not receive personalized ads based on your browser or device usage, you may generally express your opt-out preference to no longer receive tailored advertisements. Please note that you will continue to see advertisements, but they will no longer be tailored to your interests.
Google Analytics and Advertising.
We also use Google Analytics and other third-party cookies to collect certain information about your visits to our LEARNstyle websites. You can opt out of third-party cookies from Google Analytics using the Google Analytics opt-out browser setting add-on or other ad management tools. Cookies are used throughout systems to track user state, preferences and various other items.
All data is only collected if required for system functionality.
III. Data Retention
A. Website Users
We keep website usage information for as long as necessary for the purposes described above. Account information is retained until you delete the account and for a limited period thereafter. Where you have provided information in forms, we retain the information as long as it is required, depending on the nature of the request. If you unsubscribe from receiving marketing communications from us, we will keep a record of this to ensure that you do not receive such communications in the future.
B. Customers (Schools and School Districts)
We keep information collected on behalf of our customers for as long as necessary and pursuant to contractual terms. We dispose of information that is not held pursuant to contractual terms in a commercially reasonable time period or at the request of a customer.
IV. Security
LEARNstyle employs a variety of physical, administrative, and technological safeguards that are designed to protect personal information against loss, misuse, and unauthorized access or disclosure. We strive to continuously enhance our technical and operational security measures. Our measures consider the type and sensitivity of the data being collected, used, and stored, and the current state of technology and threats to information.
LEARNstyle’s security measures include data encryption, firewalls, data use and access limitations for personnel and vendors.
LEARNstyle independently verifies its security management system to the internationally recognized standard for security management.
LEARNstyle also aligns its privacy and security operations to best practices and relevant international regulations.
V. Access
A. LEARNstyle’s relationship to you.
Data Controller for Website Users – A “data controller” is an entity that determines the purposes for which and the manner in which any personal information is processed. Any third parties that act as our service providers are “data processors” that handle your personal information in accordance with our instructions. With respect to the personal data of our customers or received through our LEARNstyle websites, LEARNstyle is a controller in relation to the information that you enter directly into the website about yourself or when you register for an account through your school or school district.
Data Processor for Schools and School Districts – To the extent that LEARNstyle receives personal information through its customers’ (school or school district) use of LEARNstyle products or services, LEARNstyle is a processor and the LEARNstyle customer is the data controller.
B. Individual data subject rights.
In many of the LEARNstyle products and services, you will be able to access student information as well as change and delete some of the information by logging into the appropriately credentialed account. All information is restricted based on role and scope. Role-based security is used to restrict to only the types of information they should have; location scope enforces that they should only be able to see that information as it pertains to students and schools within their responsibility.
If you cannot access, correct, or delete the required information on your own, please follow these steps: For parents/students: LEARNstyle does not control your personal information. We provide our products and services on behalf of your school or school district. Please contact your institution to exercise your rights of access, rectification, erasure, or restriction of use of personal information. The institution needs to manage your request under applicable laws and LEARNstyle will support our schools and school districts with such requests.
VI. Education Privacy Laws
LEARNstyle, in its role as a vendor to educational agencies and institutions, both public and private entities (“Educational Agencies”), receives disclosures from the Educational Agencies, which include the personal information and other data (“Student Data”) contained in student records as well as directly from students and parents of students. Only information that is needed for LEARNstyle to perform services, which are outsourced to LEARNstyle by the Educational Agencies, is disclosed to LEARNstyle. These disclosures are authorized by the federal, state or provincial privacy acts.
LEARNstyle considers Student Data to be strictly confidential and does not use Student Data for any purpose other than improving and providing our products and services to the Educational Agencies or on the Educational Agencies’ behalf.
VII. Changes to This Privacy Statement
We may update this Privacy Statement and its last updated date to reflect changes to our data governance practices. If we propose to make any material changes, we will notify you by means of a notice on this page prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
Contact Us
If you have any questions or concerns about your privacy or this Privacy Statement, please Contact Us at privacy@learnstyle.com
You may also write to us at:
LEARNstyle
3377 Bayview Ave, Toronto, ON M2M 3S4
ATTN: Privacy
