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Privacy Policy

TEACHSTONE PRIVACY POLICY

Last Modified: September 15, 2021
Effective Date: September 15, 2021

Teachstone, Inc. a Virginia benefit corporation f/k/a Teachstone Training, LLC, (referred to in this Privacy Policy as “Teachstone,” “we,” “us,” or “our”) respects your privacy and we are committed to being transparent about how we collect, use, and share your personal information. Please read this Privacy Policy carefully to understand your choices and our policies and practices regarding how we use your information. If you do not agree with this Privacy Policy, do not access or use our products or services or interact with any other aspect of our business.

This policy explains:

  1. What this policy covers
  2. What information we collect about you
  3. How we collect information
  4. How we use personal information
  5. How we share personal information
  6. How to access and control your personal information
  7. Where we store and process personal information
  8. Cookies and similar technologies
  9. Other important privacy information
  10. How to contact us

1. WHAT THIS POLICY COVERS.

This Privacy Policy covers the personal information we collect about you when you use our products or services, Teachstone’s websites, including the sites located at: teachstone.com, class.teachstone.com, teachstone.org, class.teachstone.org, and teachstonetraining.com (each, a “Teachstone Website,” and collectively, the “Teachstone Websites”), or otherwise interact with Teachstone (such as attending Teachstone events), unless a different privacy policy is displayed or provided to you. If you are an employee or independent contractor of Teachstone, this policy does not apply to information we collect about you through the course of that relationship. This policy also explains your choices about how we use information about you and your choices, including how you can object to certain uses of personal information about you and how you can access and update certain information about you.

Teachstone offers a wide variety of products and services, and we refer to all of our products, services, events, and the Teachstone Websites collectively as our “Services.” Our Services include the following:

  • Observation Data Services. Our Observation Data Services include CLASS-based observation collection for observers and teachers, reporting and analysis for administrators, observers, and coaches.
  • Learning Resources. Our Learning Resources include online professional development and coaching on a one-on-one our group basis for coaches and teachers, professional development recommendation engine, professional development progress reporting and analysis for administrators and coaches.
  • CLASS Learning Community. Our CLASS Learning Community includes web-based forums that allow Teachstone customers to interact with each other and our staff. Access to our CLASS Learning Community requires participation in a Teachstone-based training program or purchase of a qualifying Teachstone products or services.
  • One-on-one coaching. We provide individualized coaching services for our customers to enhance their abilities as teachers, coaches, observers, and instructors.
  • Group coaching. We provide group coaching services for our customers to enhance their abilities as teachers, coaches, observers, and instructors.
  • Certification and recertification services. We provide certification services that show the reliability and knowledge of our customers related to observation and use of CLASS.
  • Calibration services. We provide calibration services that help ensure our customers maintain their reliability and ability to recertify for areas in which they are certified.
  • Online Learning. We provide asynchronous and blended learning programs that educate our customers and help them become more proficient in their understanding and application of CLASS in and outside of the classroom.

2. WHAT INFORMATION WE COLLECT ABOUT YOU.

We collect information about you when you provide it to us, when you use our Services or otherwise interact with us, and when other third parties provide information about you to us, as further described below. When we obtain personal information about you from third parties, we protect that personal data in accordance with this policy and any additional restrictions imposed by the source of the data. As used in this Privacy Policy, “personal information” (or “personal data”) means any information relating to an identified or identifiable natural person (who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person). Personal information does not include Non-Personal Information (as defined in Section 9.6 below), such as anonymized or aggregate data.

We rely on various legal reasons and permissions (each, a “legal basis”) to process your personal data, including your consent, when given, a balancing of legitimate interests, necessity to enter into and perform contracts, and compliance with legal obligations, for a variety of purposes described below.

You have choices when it comes to the Services and features that you use and the data you share. When you are asked to provide personal data, you can decline. Many of our Services require some personal data to operate and provide the Services or features to you. If you choose not to provide data necessary to operate and provide certain Services or features, then you cannot use those Services or features. Likewise, when were are required by law to collect personal data or when we need to collect personal data to enter into or carry out a contract with you, and you do not provide the data, we will not be able to enter into the contract; or if this relates to existing Services you are using, we may have to suspend or terminate your access to those Services. We will notify you if that is the case at that time. Where providing the data is optional, and you choose not to share personal data, certain features like personalization that use the data will not work for you.

In order to use some of our Services, you are required to activate and use a Teachstone User Account (a “Teachstone User Account”). In some cases, you can create a Teachstone User Account yourself, and in other cases a Teachstone User Account may have been created for you by, or on behalf of, an organization that you are affiliated with (such as your employer).

The information we collect depends on the context of your interactions with us and the choices you make (including your privacy settings), the Services and features you use, your location, and applicable law. The information we collect can include the following:

  • Identity Data: Your full name, nickname, preferred title (e.g., Mr., Ms., Dr., etc.), date of birth, gender, country, and preferred language (collectively, “Identity Data”).
  • Contact Data: Your e-mail address, phone number, physical address, mailing address, and other similar contact information (collectively, “Contact Data”).
  • Profile Data: Your Login Credentials, profile photo, and other biographic information associated with your Teachstone User Account (collectively, “Profile Data”).
  • Login Credentials: Passwords, password hints, security questions and answers, and similar security information used for account access and authentication (collectively, “Login Credentials”).
  • Educational background and occupation data: Data related to your educational background (such as your certifications and degrees), your occupation, your employer or associated organization (such as your occupation, job title, employer’s name, and your employee number), your industry, and other similar data.
  • Interests and preferences: Data about your interests and preferences, such as the subjects or grade levels that you teach, dietary preferences (which may be provided in connection with an event registration), and the products, services, and topics that interest you. Your interests and preferences may be inferred or derived from other data that we collect.
  • Financial Data: Data necessary to process payments, such as credit or debit card number, expiration date, CVV/CSV/CSC or other security code, and billing address, or other payment information (collectively, “Financial Data”).
  • Transaction Data: Information about transactions between you and Teachstone, including information about payments associated with your Teachstone User Account, and details about the Services, products, and subscriptions you have purchased from us.
  • Subscription and licensing data: Information about your subscriptions, licenses, and authorizations relating to our Services.
  • Interaction and usage data: Information about your use and interaction with our Services or your potential or intended use of our Services, such as:
    • Technical Data: Data about the devices you use to access our Services, including the device hardware, operating environment (such as browser type and version, browser plugins installed, operating system type and version, regional and language settings, screen size and/or resolution, windows size, and page size), access dates and times, internet protocol (IP) addresses, URLs of referring/exit pages, and other similar data (collectively, “Technical Data”).
    • Usage Data: Data about our Services and features that you use, including your settings relating to our Services and how our Services perform, and data about the Teachstone Websites and pages, articles, media, and other content you access (collectively, “Usage Data”).
    • Payment and account history: Data about the products, services, features, and event registrations you purchase (or that others purchase for, assign to, your account) and the activities associated with your Teachstone User Account.
    • Relationships and social data: Data about the other Teachstone users that you interact with through our Services, the individuals and organizations that you are affiliated with (such as your employer), and third parties that refer you to us or to whom you refer Teachstone.
    • Other input: Other text, media, and submissions you provide when you use our Services.
  • Content: Content of files you submit, upload, receive, or create through our Services and other messages and communications you submit or receive through our Services (such as messages you send or receive through the CLASS Learning Community and your profile photo).
  • Coaching and observation data: Teacher and coaching observation data, evaluations, recommendations, and scores.
  • Feedback: Information you provide to use and the content of messages you send us, including feedback, survey data, and reviews of our Services.

3. HOW WE COLLECT INFORMATION.

We use different methods to collect information from and about you, including through:

  • Direct interactions. You may give us your personal information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you:
    • request, order, or apply for our Services;
    • create or activate a Teachstone User Account;
    • subscribe to our Services or publications;
    • request marketing to be sent to you;
    • enter a competition, promotion, or survey; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data and Usage Data about your equipment, browsing actions, and patterns. We collect this data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy in Section 8 below for further details.
  • Third parties or publicly available sources. We will receive personal information about you from various third parties and public sources, including as described below:
    • Technical Data and Usage Data from analytics providers, such as Google.
    • Contact Data, Financial Data, and Transaction Data from providers of technical, payment, and delivery services.
    • Coaching and observation data from other users of our Services.
    • Identity Data and Contact Data from publicly available sources.
    • Various types of information about you from your organization if you access or use our Services through an Organization End User Account.

4. HOW WE USE PERSONAL INFORMATION.  

4.1.  Overview of how we use personal information.

How we use the information we collected depends, in part, on the Services and features you use, how you use them, any preferences you have communicated to us, and whether your Teachstone User Account is an Organization End User Account (as described in Section 6.3 below). We use data to:

  • Provide our Services, including securing, troubleshooting, and providing support and customer service related to our Services. We also share data when it is required to provide the Services or carry out the transactions you request.
  • Improve and develop our Services.
  • Personalize our Services and make recommendations.
  • Advertise and market to you, which includes sending promotional communications, targeted advertising, and presenting relevant offers to you.
  • Operate our business, including analyzing our performance, meeting our contractual and legal obligations, and performing research.

When we process personal data about you, we only do so with your consent and/or as necessary to provide the Services to you, operate our business, meet our contractual and legal obligations, protecting the security of our systems, users, customers, and third parties, or to fulfill other legitimate interests of Teachstone as described in this Section 4 and in Section 5 below. When we transfer personal data from the European Economic Area, we do so based on a variety of legal mechanisms, as described in Section 4.3 below.

4.2.  More details on the purposes of processing.

Below are additional details about the purposes for which we process information:

  • Provide and Improve our Services. We use and process information to operate our Services. We also use information to contact you, such as contacting you by phone or email to inform you when a subscription is ending or to discuss your subscriptions, licenses, and renewal options with you. We also communicate with you about updates to our Services, your subscriptions, and your event registrations. We also use information to continually improve our Services, including adding new features, options, and capabilities.
  • Personalization. Some of our Services include recommendations and other personalized features, which may use automated processes to tailor your experiences using our Services based on the information we have about you, including inferences we make about you and your use of our Services, activities, and location.
  • Customer Support. We use information to provide customer care and support services.
  • Protecting Rights, Property, and Safety. We use information to protect the safety of our Services, our customers, and third parties. We also use information to detect and prevent fraud, enforce agreements, resolve disputes, and protect our rights and property. For example, we may use automated processes to detect and prevent activities that violate our rights or the rights of others, such as unauthorized access to Teachstone User Accounts.
  • Relevant Offers. We use information about you to provide you with relevant and valuable information regarding our Services. We analyze information from a variety of sources to predict the information that will be most interesting, useful, and relevant to you and to deliver that information to you in a variety of ways.
  • Promotional Communications. We also use information to deliver promotional communications. You can sign up for e-mail subscriptions and choose whether you wish to receive promotional communications from us by e-mail, physical mail, and telephone. For more information about managing your communication preferences and contact information, see Section 6 below.
  • Processing Transactions. We use information to carry out your transactions with us. For example, when customers purchase subscriptions to our Services, we process their financial information, and when customers purchase physical goods, we use their contact information to deliver the purchased items.
  • Business Operations. We use information to analyze our operations and perform business intelligence, which enables us to make informed decisions.
  • Legal Compliance. We process information to comply with the law. For example, we use the location of our customers to comply with applicable sales tax laws. We also process information to help our customers exercise their data protection and privacy rights.
  • Research and Development. We use information to enhance our current Services and to develop new products and services. For example, we use information, often in an aggregate or de-identified form, to better understand our customers’ needs, which helps inform that development. We also use information, with appropriate technical and organizational measures to safeguard the rights and freedoms of individuals, to conduct research, including for public interest and scientific purposes.

4.3.  Legal bases for processing (for European Economic Area users). If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have a legal basis for doing so under applicable laws. The legal bases depend on the Services and features you use and how you use them, and whether you access and use our Services through an Organization End User Account (as described below in Section 6.3 of this Privacy Policy). Accordingly, we collect and use your information only when:

  • We need it to provide the Services to you or your organization, including to operate the Services, provide customer support and personalized features, and to protect the safety and security of the Services;
  • It satisfies a legitimate interest (which is not overridden by your data protection interests), such as to market and promote the Services, to protect our legal rights and interests, to fulfill our contractual obligations to your organization, and for research and development;
  • You give us your consent to do so for a specific purpose; or
  • We need to process your information to comply with a legal obligation.

5. HOW WE SHARE PERSONAL INFORMATION.

We share information we collect about you in the ways discussed below, including in connection with possible business transfers.

5.1.  Sharing with other users.  When you use our Services, we share certain information about you with other users of our Services.

            5.1.1.  Organization End User Accounts.  In this Privacy Policy, “Organization End User Account” refers to (1) a Teachstone User Account that was created, authorized, or provided to you by, or on behalf of, your employer or other organization you are affiliated with, and/or (2) a Teachstone User Account that becomes managed by your employer or other organization (such as if you create or activate a Teachstone User Account using an e-mail address with a domain name that is owned by your employer and your employer chooses to associate that e-mail address with your employer’s organizational account with Teachstone). If you use our Services through an Organization End User Account, your organization can:

  • Control and administer your Teachstone User Account, including controlling privacy-related settings; and
  • Access, process, delete, and share your personal data, including coaching and observation data, interaction data, diagnostic data, and the contents of your communications and files associated with your Teachstone User Account.

At the request of your organization, we may also act on your organization’s behalf to share information about you with third parties.

            5.1.2.  For Collaboration.  When you use our Services, you can create and upload content, which may contain information about you, and grant others permission to view, edit, copy, download, or share that content based on the settings selected by you or your administrator (if you access our Services through an Organization End User Account).

            5.1.3.  Coaches and Observers.  As part of our Observation Data Services, we may share coaching and observation data related to classroom instruction and feedback from coaching and observers between the relevant teachers, coaches, observers.

            5.1.4.  Social Features and CLASS Learning Community.  When you use social features in our Services (such as the CLASS Learning Community), other users may see some of your activity. You should be aware that any information you provide through shared or publicly available portions of our Services (including profile information associated with your Teachstone User Account) may be viewed by other Teachstone users. Your posts and certain profile information may remain even after your Teachstone User Account is closed. To request removal of your information from shared or publicly accessible websites operated by Teachstone, please contact us as provided below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to and why. To learn more about the social features and other functionality, please review documentation or help content specific to the applicable Teachstone Services.

5.2.  Sharing with third parties.  We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Services. If you access our Services through an Organization End User Account, we also share information as directed by your employer or other organization.

            5.2.1.  Service Providers.  We use various third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, billing and payment processing, technical support and services, database management, contact management, analysis, and other services for us, which may require us to store information about you on their systems or may require them to access or use information about you. Before providing our service providers with access to information about you to perform services on our behalf, we require such service providers to enter into binding contracts with us that require them to comply with policies and procedures designed to protect your information.

            5.2.2.  With your consent.  We share information about you with third parties when you give us consent to do so. We will not knowingly disclose your personal information to a third party if we know or have reason to believe that the third party will use your personal information for direct marketing purposes, unless you opt-in or otherwise expressly consent for such sharing.

            5.2.3.  Pursuant to your organization’s directions.  If you access our Services through an Organization End User Account, we also share information as directed by your employer or other organization. For example, if your organization decides to integrate observation scores from our Services with a third-party system for tracking observation scores, we may share information about your observation scores with that third-party system as requested by your organization.

            5.2.4.  Compliance with Applicable Laws, Enforcement Requests, and Protecting Rights and People.  We may share information about you with a third party if we have a good faith belief that sharing that information is reasonably necessary: (i) to comply with any applicable law, regulation, legal process, subpoena, or governmental request; (ii) to enforce our agreements, policies, and terms of service; (iii) to protect the integrity and security of our Services; (iv) to protect Teachstone, our customers and users, children, or the public from harm or illegal activities; or (v) to respond to an emergency which we believe requires us to disclose information to assist in preventing the death or serious bodily injury of any person.

5.3.  Business transfers.  We may share or transfer information we collect under this Privacy Policy to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our users is among the assets transferred. When applicable, you will be notified via e-mail and/or a prominent notice on or through the Services if such a transaction occurs and of any choices you may have regarding your information.

6. HOW TO ACCESS AND CONTROL YOUR PERSONAL INFORMATION.  

6.1.  Generally.  Many of our Services allow you to access, update, and delete your personal information by logging in to your Teachstone End User Account through the Teachstone Websites. If you have any questions or requests related to this Privacy Policy or our processing of your personal information, you may contact us using any of the methods described in Section 10 below.

6.2.  Your communication preferences.  You can choose whether you wish to receive marketing or promotional communications from Teachstone by e-mail, physical mail, and telephone. If you receive promotional e-mail messages from us and would like to opt-out, you can do so by following the directions contained in those messages. Through the settings available when you login to your Teachstone User Account, you can elect whether or not to receive periodic updates from the system about your activity in the Learning Resources and Observation Data Services. You may also unsubscribe from Teachstone e-mails by clicking the unsubscribe link we include at the bottom of every e-mail we send.

6.3.  Organization End User Accounts.  Many of our Services are intended for use by organizations, such as schools and school systems. If your employer or other organization provides you with access to our Services and/or you access our Services through an Organization End User Account, your use of our Services is subject to your organization’s policies, if any. In that case, your choices may be limited, and you should direct your privacy inquiries, including any requests to exercise your data protection rights, to your organization’s administrator. When we provide Services through an Organization End User Account, your organization is the “data controller” and we are the “data processor.” We are not responsible for the privacy or security practices of our customers, including any organization you are affiliated with, which may differ from those set forth in this privacy statement. In addition, you may lose access to your Teachstone User Account and to the Services, content, and materials associated with that account, if your affiliation with that organization ends.

6.4.  European Economic Area Users.  If you are an individual in the European Economic Area (EEA), you have the following rights under data protection laws in relation to your personal data, which you may exercise by contacting us using any of the methods described in Section 10 below:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data (commonly known as the “right to be forgotten”). This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: If you want us to establish the data’s accuracy. Where our use of the data is unlawful but you do not want us to erase it. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

            6.4.1.  What we may need from you.  We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

            6.4.2.  Response time.  We try to respond to all legitimate requests within 30 days. Occasionally it could take us longer than 30 days if your request is particularly complex or you have made multiple requests. In that situation, we will notify you and keep you updated.

            6.4.3.  No fee usually required.  You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

7. WHERE WE STORE AND PROCESS PERSONAL INFORMATION.  

7.1.  International transfer of information we collect.

We collect information globally and primarily store and process that information in the United States. We may transfer, process, and store your information outside of your country of residence to wherever we, or our third party service providers, operate for the purpose of providing our Services. Whenever we transfer your personal information, we take appropriate measures to protect it.

We transfer personal data from the European Economic Area and Switzerland to other countries, such as the United States, some of which have not yet been determined by the European Commission to have an adequate level of data protection. When we engage in such transfers, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections travel with your data. To learn more about the European Commission’s decisions on the adequacy of the protection of personal data in the countries where Teachstone processes personal data, we suggest that you review this article on the European Commission website.

7.2.  Privacy Shield Notice.

Teachstone participates in and complies with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks and the Privacy Shield Principles regarding the collection, use, and retention of information about you that is transferred from the European Union, the European Economic Area, the United Kingdom, or Switzerland (as applicable) to the United States. We ensure that the Privacy Shield Principles apply to all information about you that is subject to this privacy policy and is received from the European Union, the European Economic Area, the United Kingdom, and Switzerland.

Under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, we are responsible for the processing of information about you we receive from the European Union, the European Economic Area, the United Kingdom, and Switzerland and onward transfers to a third party acting as an agent on our behalf. We comply with the Privacy Shield Principles for such onward transfers and remain liable in accordance with the Privacy Shield Principles if third-party agents that we engage to process such information about you on our behalf do so in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.

If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. You can learn more about the Privacy Shield Program by visiting the U.S. Department of Commerce’s Privacy Shield website at: https://www.privacyshield.gov/. To view our Privacy Shield certification, please visit our public Privacy Shield listing at: https://www.privacyshield.gov/participant?id=a2zt00000008hARAAY&status=Active.

We are committed to resolving complaints about our collection and use of your personal information, and we encourage you to contact us as provided below should you have a Privacy Shield-related (or general privacy-related) complaint. We have further committed to refer unresolved Privacy Shield complaints to the JAMS Privacy Shield Program, an alternative dispute resolution provider in the United States. Please visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you. We will cooperate with JAMS pursuant to the JAMS International Mediation Rules, which are accessible on the JAMS website at: http://www.jamsadr.com. Through this third-party dispute resolution provider, we have also committed to cooperating and complying with the information and advice provided by an informal panel of data protection authorities in the European Economic Area, the United Kingdom, and/or the Swiss Federal Data Protection and Information Commissioner (as applicable) in relation to unresolved complaints (as further described in the Privacy Shield Principles). You may also contact your local data protection authority within the European Economic Area, the United Kingdom, or Switzerland (as applicable) for unresolved complaints. Under certain conditions, more fully described on the Privacy Shield website, including when other dispute resolution procedures have been exhausted, you may invoke binding arbitration. We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

8. COOKIES AND SIMILAR TECHNOLOGIES.

8.1.  Cookies and Local Storage.  We may use cookies and other similar technologies, such as HTML 5 local storage, to provide the Teachstone Websites and our Services. Cookies are small text files placed onto your device when you visit and interact with the Teachstone Websites. Local storage is a technology that allows a website or application to store information locally on your device. These technologies enable us to provide and enhance your experience using the Teachstone Services.

8.2.  How We Use Cookies and Local Storage.  We use these technologies to provide the Teachstone Services to you and to analyze and improve our Services. Our uses generally fall into one of the following categories:

            8.2.1.  Essential Processes and Security:  To enable essential functions of the Teachstone Services, such as to facilitate logging you in to the Teachstone Services, facilitating payments, protecting your security, and helping us fight spam, abuse, and violations of the agreements governing your use of the Services.

            8.2.2.  Preferences:  To remember information about your browser and your preferences.

            8.2.3.  Performance, Analytics, and Research:  To help us understand and measure how you use our Services and to improve our Services.

8.3.  Blocking and Removing Cookies.  We are committed to protecting your privacy, as described in this Privacy Policy. Most browsers allow you to modify your settings to accept or deny all cookies or to request your permission each time a website attempts to place a cookie on your device, and most browsers allow you to delete cookies that have already been placed on your device. However, our Services will not function properly if you prevent our Services from placing cookies on your device.

9. OTHER IMPORTANT PRIVACY INFORMATION.

9.1.  Updates to this Privacy Policy.  We update this Privacy Policy when necessary or appropriate to provide greater transparency or in response to

  • feedback from customers, regulators, and others,
  • changes to our Services,
  • changes in technology,
  • changes in our business, or
  • changes in our data processing activities or policies.

When we modify this Privacy Policy, we will give you notice by posting the amended Privacy Policy on one or more of the Teachstone Websites and, if the changes meaningfully affect your rights, by e-mail (if your e-mail address is included in your Teachstone User Account). The amended Privacy Policy will include an effective date, and it will be effective on that date. We encourage you to periodically review this Privacy Policy to understand how we are protecting your information.

9.2.  Payment Information and Processing.  We may, from time to time, use one or more third party payment processors, including Stripe, Inc. (“Stripe”), to process payments made in connection with the Teachstone Services, and we may share or transmit your Financial Data to our payment processors. You acknowledge and agree that the processing of payments is subject to the terms and privacy policies of our payment processors and that we are not responsible for enforcing them. You acknowledge and agree that payments processed using Stripe are subject to the Stripe Terms of Service (https://stripe.com/us/terms) and the Stripe Privacy Policy (https://stripe.com/us/privacy), as amended from time to time by Stripe.

9.3.  Children Under Age 16.  We are committed to protecting the privacy of children under the age of sixteen (16) years (each a “Child” and collectively, “Children”). Access to and use of the Teachstone Services by Children is prohibited. The Teachstone Services are not designed for or marketed to Children, and we do not knowingly collect personal information from Children. If we learn we have collected or received personal information from a Child, we will delete that information. If you believe we might have any information from or about a Child, please contact us.

9.4.  Third Party Sites.  Our Services may contain links to other websites that are operated by third parties, including the websites of our other users, customers, or service providers. Once you have clicked on a link connecting you to such third party website, you will leave the our Services and be taken to a website that we do not control. This Privacy Policy does not apply to any personal information (or other information) collected on a third party site. We suggest you read the privacy policy of the third party site before providing any personal information on such third party site. We are not responsible for any use by any person or entity of any information that you may provide while accessing or using any websites or services provided by a third party.

9.5. Google API Data Usage. Some of our Services utilize or link to TORSH applications. TORSH applications offer an optional integration with Google Calendar through the Google API. When this integration is enabled and authorized by the user it will use the Google Calendar integration for the purposes of scheduling events. Events scheduled within TORSH applications can be added to the user’s Google calendar by the TORSH application. The TORSH application can also use the user’s schedule on Google Calendar to determine if they have availability for an event. TORSH will only use information from Google Calendar for the purpose of scheduling events and will not share any data from Google APIs with anyone and will not store that information longer than is necessary to schedule the event. TORSH applications access this information through the Google API which requires authorization from the user.

9.6.  Do Not Track Policy.  California law requires that operators of websites and online services disclose how they respond to a Do Not Track signal. Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the website or online service that a user visits, indicating that the user does not wish to be tracked. Because there is not yet a common understanding of how to interpret Do Not Track signals, we do not currently respond to Do Not Track signal.

9.7.  Use of Non-Personal Information.  As used in this Privacy Policy, “Non-Personal Information” means information or content other than personal information, including, for example, aggregated, generalized, anonymized, or de-identified information about our users and other information that does not identify any individual. We may use Non-Personal Information (including, for example, aggregated information about our users or information that does not identify any individual) for any purposes whatsoever (including without limitation, advertising, marketing, enhancing, designing, or developing products and/or services, and research), and we may share Non-Personal Information with others, including our partners, affiliates, and our service providers.

            9.7.1.  Google Analytics.  We may, from time to time, use a tool called “Google Analytics” (including Google Analytics Demographics and Interest Reporting features) to collect information about your use of our Services, which helps us provide content that is relevant to you and optimized for the devices that you use (such as smartphones and tablets). We respect and value your privacy, and we never combine the information collected through the use of Google Analytics with your personal information. We use the information we receive from Google Analytics only to improve our Services and our content and marketing. Google’s use and sharing of information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use (http://www.google.com/analytics/tos.html) and the Google Privacy Policy (http://www.google.com/privacypolicy.html). For more information, see “How Google uses data when you use our partners’ sites or apps” at www.google.com/policies/privacy/partners/. You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using Google’s Ad Settings (https://www.google.com/settings/ads) tool. As an added privacy measure, you can use the Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout/).

9.8.  Our retention of personal information.  We retain personal data for as long as necessary to provide our Services and fulfill the transactions you have requested, or for other legitimate purposes, such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different types of information, the context of your use of our Services or our other interactions with you, the actual retention periods can vary significantly. After the applicable retention period, we will either delete or anonymize your personal information or, if that is not reasonably feasible (for example, because the information has been stored in a backup archive), then we will securely store your personal information and isolate it from any further use. If we anonymize your personal data (so that it can no longer be associated with you), we may use that information indefinitely without further notice to you.

  • Account information. We retain the information associated with your Teachstone User Account until your Teachstone User Account is closed. After your Teachstone User Account is closed, we will retain some of your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
  • Organization End User Accounts. If you access or use our Services through an Organization End User Account, we will retain your personal information as long as required by the administrator of your Organization End User Account.
  • Marketing information. If you have chosen to receive marketing communications from us, we retain your Contact Data and your marketing preferences unless you specifically ask us to delete such information.

            9.8.1.  Personal information in backups.  After personal data is deleted or anonymized in our production (primary) systems, copies of the personal data may remain in our backups for a limited period of time until it is overwritten, replaced with subsequent backups, or otherwise deleted pursuant to our backup retention schedule. Personal data that was previously deleted or anonymized based on your request or the expiration of the applicable retention periods, but which remains in our backups, will be put beyond use, and we will:

  • not use the personal data to inform any decision in respect of any individual or in a manner that affects the individual in any way;
  • not give any other organization access to the personal data (or, in the case of a service provider hosting a backup on our behalf, we will ensure that the service provider is prohibited from accessing the personal data);
  • protect the personal data with appropriate technical and organizational security measures; and
  • permanently delete the personal data in accordance with our backup retention schedule.

If we ever access or restore data from our backups, we will take appropriate technical and organizational measures to ensure that personal data that was previously deleted or anonymized pursuant to your request is not processed again after the restoration and is promptly deleted or anonymized again.

9.9.  Security.  We have implemented appropriate security measures so safeguard your personal data from accidental loss or deletion and from unauthorized access, use, alteration, and disclosure. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to access that information. We require all such persons to process your personal data only pursuant to our instructions, and all such persons are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach, and we will notify you and any applicable governmental authority of a breach when we legally required to do so. The safety and security of your information also depends on you. You are responsible for safeguarding your Login Credentials associated with your Teachstone User Account and notifying us immediately if you suspect your Login Credentials for your Teachstone User Account have been compromised. We urge you to be careful about giving out information in public areas of the Teachstone Services. The information you share in public areas may be accessed by any of our users. You are strongly cautioned to never share sensitive information with other users through the Teachstone Services.

10. HOW TO CONTACT US.  

You may contact us with questions relating to this Privacy Policy by e-mailing us at [email protected], by chatting with us through the online chat system on the Teachstone Website at https://teachstone.com/contact/, by calling us at 866-998-8352, or by writing to us at: Teachstone, ATTN: Privacy Policy Team, 675 Peter Jefferson Parkway, Suite 350, Charlottesville, VA 22911.