Newsela Privacy Policy

Newsela Privacy Policy

Last Revised: July 01, 2024

At Newsela, Inc. and on behalf of our wholly owned subsidiaries (Formative and Newsela Writing) and family of products and services, we want to inform and empower you to exercise meaningful control over how your personal information is collected and used.

1. ABOUT US

Newsela, Inc. and its subsidiaries and related companies (“Newsela,” “we,” “our” or “us”) know how important it is for you to understand how your Personal Information (as defined below) is collected, used, processed, and shared. Please read this Privacy Policy (“Policy”) carefully to understand our privacy practices. We may update this Policy from time to time as described in the “Changes to this Privacy Policy” section below. If you have any questions or concerns please contact us at privacy@newsela.com. As used in this Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Personal Information also includes Student Data (as defined below).

2. WHO DOES THIS POLICY APPLY TO

This Policy applies to all users of our Services who are 13 years of age or older. For information about Newsela’s collection, use or disclosure of Personal Information of children under 13 years of age, please see our “Privacy Disclosures for Children and Students.” For the avoidance of confusion, “you” or “your” in this Policy refers to all users of the Services, including teachers, parents and administrators accessing, using or receiving our Services.


3. IMPORTANT NOTICE FOR SCHOOL USERS

When our Services are used by providers of educational services, such as schools, school districts, teachers, and authorized school users and administrators (collectively, “Schools”) for educational purposes, we collect and process Personal Information about students (“Student Data”) for and on behalf of the Schools. Our collection and use of Student Data is governed by our contracts with the Schools, as well as by applicable student privacy laws such as FERPA, COPPA and state student data privacy laws.If you were given access to the Services by the School you are affiliated with, this Policy does not govern how your school might collect, use, or disclose your information. Please consult with your district and/or school for more information about their privacy policies and practices, including your district’s and/or school’s collection, use, or disclosure of your Personal Information. In addition to reviewing this Policy, please also see the Privacy Disclosures for Children and Students to learn more about how we collect, store, use and protect Student Data.


4. U.S. STATE-SPECIFIC, EU, AND UK NOTICES

  • EU and UK – If you are a resident in the European Union (“EU”) or United Kingdom (“UK”) using our Services, your use is subject to our Data Processing Agreement as well as our Standard Contractual Clauses as required under applicable data privacy laws.

  • California – If you are a resident of the state of California, please see our California Privacy Notice for additional California specific information and disclosures.

  • Nevada – If you are a resident of Nevada, you may have the right to opt-out of the sale of certain Personal Information to third parties in certain circumstances. Newsela does not currently engage in “sales” (as defined under N.R.S. § 603A) of your Personal Information. Please feel free to contact us at privacy@newsela.com for additional questions or concerns regarding this matter.

  • Please also see our Additional Privacy Rights section for more information about exercising your eligible privacy rights.

Please note, our Services is operated and managed on servers located within the United States (“U.S.”). If you choose to use our Services from other regions of the world with laws governing data collection and use that differ from U.S. law, then you acknowledge and agree that you are transferring your Personal Information outside of those regions to the U.S. and that, by providing your Personal Information on the Services, you authorize and consent to that transfer.


5. SERVICES

You are accessing, using or receiving our Services when you:

  • Access or use the Newsela websites, the Newsela mobile applications, any of our websites or applications that post this Policy, as well as any services made available through those websites, applications, application programming interfaces, online services, or extensions controlled and owned by Newsela; or

  • Communicate with us, such as by submitting an inquiry through our website, registering for and/or attending an event, corresponding with us by phone, email or otherwise, subscribing to one of our mailing lists, newsletters or other forms of marketing communications, or provide information requested by us to comply with our professional obligations.


6. WHAT PERSONAL INFORMATION WE COLLECT

We collect Personal Information about you when you voluntarily submit information directly to us by accessing, using or receiving the Services. We may also collect Personal Information from third parties, such as from Schools, service providers, public databases, business partners or affiliates, social media networks and/or through the use of cookies and other technologies. For further information on your choices regarding your Personal Information, see the “Personal Information Preferences & Control” section below.

a. Information we collect directly from you or from your school

Personal Information we collect from you or from your School may include:

  • Full Name and Contact information, including email address and mailing address

  • Payment information (if applicable)

  • Demographic data (only if required by your School and voluntarily provided)

  • User content, feedback, assignments and annotation files, such as content provided by students and content provided by teachers and administrators relating to students

  • School, grade, and classroom affiliation

  • Birthdate

  • Account information

  • A photograph of yourself (only if voluntarily provided)

  • Access and usage data about your use of the features and functionality of the Services

  • Login information such as username and password

  • Information provided in response to surveys and promotions we make available to you

b. Information we collect from third parties

  • Single Sign On:

    You may choose to access, use, or receive the Services by logging on or otherwise associating with another third party (for example, a Google, Microsoft or Clever account). In such instances, we may receive Personal Information from that third party to make it easier for you to create an account on the Services and display relevant content, such as your name, username, email address, language preference, or profile picture. The amount and type of Personal Information we collect from such third parties may depend on the privacy settings you or your School(s) have with that third party. Please review the third party’s privacy policy and data practices for additional information.

  • Information from Other Sources:

    We may obtain information from other sources, including through our service providers, other users (e.g., when an authorized legal guardian provides information relating to a student), affiliates, third-party information providers, business partners, or through transactions such as mergers and acquisitions. We may combine this information with other information we collect from or about you. In these cases, our Policy governs the handling of the combined Personal Information. We use this information to operate, maintain, and provide to you the features and functionality of the Services, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you. We may also collect information about you that is publicly available.

    When we provide our Services to Schools, some of the above information is directly related to an identifiable student and is maintained by the School or related entity or organization, or by us on behalf of such entity. This Policy refers to that type of information as “Student Data.” Student Data may include “educational records” as defined by the Family Educational Rights and Privacy Act (“FERPA”), 20 U.S.C. § 1232(g). For more information about ways in which we collect, use and process Student Data, please also see the Privacy Disclosures for Children and Students.

c. Information we collect automatically when you use the Services

We and our third-party service providers may automatically collect information about you and your computer or mobile device when you access, use or receive our Services, by using certain technologies that are further described below. This information helps us learn more about how our users like to engage with our Services and help us improve our offerings and the functionality of our Services. This information may include:

  • Cookies

  • Unique Identifiers

  • IP address

  • Web Beacons

  • Analytics technologies

  • Mobile device identifiers

For more information about our use of Cookies and the other technologies described above, please refer to our Cookie Policy.


7. HOW WE USE PERSONAL INFORMATION

Please Note: We do not sell Student Data. For more information on the limited purposes for which we use Student Data, please see below and the Privacy Disclosures for Children and Students section.

We use the Personal Information we collect to operate, maintain and provide our Services, to make several features and functionality of the Services available to you, and as directed by your School, parent or guardian (if applicable). We also use your Personal Information to support your questions and concerns, to personalize your content so that it is relevant to the state, city or country you are using the Services from, and to send you relevant news, alerts and marketing communications. We also use this Personal Information to help us with our research and/or business operations including development of new products and services. In addition, we may use the Personal Information to comply with our legal and contractual obligations, including enforcing our contractual rights, protecting our business interests, and investigating and protecting against any fraudulent activity. We also may use your Personal Information for any other lawful, legitimate business purpose.

We may combine any of the Personal Information that we collect from you with other information, including information we obtain from third parties, or with information derived from any other products or services we provide. We will use this information for the purposes described in this Policy.

Please note, Newsela’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

For further information on your choices regarding how we use your Personal Information, see the “Personal Information Preferences & Control” section below.


8. RECIPIENTS OF PERSONAL INFORMATION

In accordance with how we use your Personal Information, we may share your Personal Information with the following:

  • Other Users of the Services. Other registered users of our Services such as teachers or administrators may be able to see your profile information (e.g., username, profile photo, title and other employment- or education-related information and content, and other preferences and information), view the information and other content you provide, and communicate with you within the Services. Some of your data that is visible to others is dependent upon your privacy settings. For more information, please see the “Personal Information Preferences & Control” section.

  • Schools, District Administrators, and Teachers. Schools, district administrators and teachers so they can engage with our Services, understand and grade student performances, and tailor content and materials for continued use. For example, we may share your Personal Information with new teachers who use the Services in their classrooms when you enroll in such teachers’ classes, and we may share teacher Personal Information with other teachers within a School using the Services.

  • Service providers and advisors. Third party vendors, independent contractors, and other service providers that perform services for us, on our behalf, which may include providing mailing or email services, tax and accounting services, payments processing, data enhancement services, fraud prevention, web hosting, or providing analytic services.

  • Affiliates. Other affiliates of Newsela, Inc. so that they can improve our Services, and provide you with updates, information and marketing messages about products or services that may interest you.

  • The public. When you use our Services or engage with us on our social media platforms, content and information that you post on message boards, blogs or posts, or that you allow us to make public, may be available to other visitors to our Services and to the general public.

  • Social Media Networks When you use our Services content that you share through social media may be shared with your social media account provider and your friends, followers or contacts on the connected social network.

  • Law enforcement, regulators and other parties for legal reasons. Third parties as required by law or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) comply with legal process; (c) respond to requests from public or government authorities, including public or government authorities outside your country of residence; (d) enforce the terms of our agreement (being, as applicable, our Terms of Use Agreement for Public Services) and pursue available remedies or limit the damages that we might sustain; and/or (e) exercise or protect our rights, privacy, safety or that of our affiliates, clients, you or others. We may also disclose Personal Information to governmental regulatory authorities as required by law, including for tax or accounting purposes, in response to their requests for such information or to assist in investigations.

  • Merger or Acquisition In connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company, in which case the company receiving the Personal Information would be obligated to follow this Policy.

  • Consent. We may disclose Personal Information with any other entity disclosed to you at the time we collect your information or with your consent or at your direction.

We do not sell your Personal Information. For clarity, we may make recommendations within or through the Services of features, tools, and content on the Services to students based on their demographic information or activities on our Services. For example, we may suggest reading materials to a student based on the student having read a similar material in the past or based on the student’s age or grade level.We may also share information with others in de-identified, aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.


9. MARKETING AND ADVERTISING

Except to visitors to Newsela owned websites, we do not display advertisements on our Services made available to our customers. We also do not disclose Student Data for targeted advertising purposes. Please see Privacy Disclosures for Children and Students below for more information.

a. Advertising Service Providers

We may work with providers of advertising services (“Advertising Service Providers”) to collect and use information about your access and use of non-affiliated websites and applications in order to provide behavioral data to us. Advertising Service Providers include advertising networks, data exchanges, traffic measurement service providers, marketing analytics service providers, and other third-party service providers. Such Advertising Service Providers enable us to display advertisements based on your use of the Services and other websites or applications you have visited, including for Newsela content, products or services that may interest you. Such providers also help prevent you from seeing repeated advertisements and enable us to research the usefulness of certain advertisements.

b. Interest Based Advertising

As explained further below, we do not disclose Student Data for targeted advertising purposes. However, with regard to our other Services, we may permit third party online advertising networks, social media companies and other third-party services to collect information about your use of our Services over time so that they may play or display personalized or interest-based ads on other websites, apps or services you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar data collection technologies. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We offer you a “Cookie Banner” through which you can exercise certain control over the use of cookies on the Services.We also may use certain forms of display advertising and other advanced features through Google Universal Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies together to inform, optimize, and display ads based on your past visits to the Services. You may opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences. You may learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy at http://www.google.com/policies/privacy/partners. You can also view Google’s currently available opt-out options at https://tools.google.com/dlpage/gaoptout.To learn more about-interest based advertising and how you may be able to opt out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) resources and/or the Network Advertising Initiative’s (NAI) online resources, at http://www.aboutads.info/choices or http://www.networkadvertising.org/choices.

c. Opting Out of Behavioral Advertising

You can opt-out of certain behavioral advertising activities by doing one or more of the following. 

Browser Opt-Out:

You can access your personal browser tools to opt-out of behavioral and advertising activities. Please note that you will need to opt-out of each browser and device for which you desire to apply these opt-out features.

You can prevent the use of certain tracking tools on a device-by-device basis by using the controls in your web browser. These controls can be found in the Tools Internet Options menu for your browser, or as otherwise directed by your browser’s support feature. Through your web browser, you may be able to:

  • Delete existing tracking tools

  • Disable future tracking tools

  • Set your browser to provide you with a warning each time a cookie or certain other tracking tools are being set

Service Provider Opt-Out:

You can opt-out of the use of information for behavioral advertising by certain Advertising Service Providers we use by using their opt-out tools. For example - here are some of these Advertising Service Providers::

Industry Opt-Out:

Some Advertising Service Providers may participate in the Network Advertising Initiatives (NAI) Opt-Out Tool (http://www.networkadvertising.org/choices/) and/or the Digital Advertising Alliance (DAA) Consumer Choice Page (http://www.aboutads.info/choices/), and therefore you can opt-out of certain services by those Advertising Service Providers (and other NAI or DAA member companies) by visiting the links included here. Please click on the links to these tools to learn more about your choices. 

Mobile Opt-Out:

Your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information for behavioral advertising. You may also opt-out of certain tracking tools on mobile devices by installing the DAA’s AppChoice app on your mobile device (for iTunes, visit https://itunes.apple.com/us/app/appchoices/id894822870?mt=8, for Android, visit https://play.google.com/store/apps/details?id=com.DAA.appchoices&hl=en ). For more information, please visit http://support.apple.com/kb/HT4228, or https://support.google.com/ads/answer/2662922?hl=en and http://www.applicationprivacy.org/expressing-your-behavioral-advertising-choices-on-a-mobile-device, as applicable.

Please note the following with respect to opting out of behavioral advertising:

  • Some opt-out features are cookie-based, meaning that when you use these opt-out features, an “opt-out” cookie will be placed on your computer, tablet or mobile device indicating that you do not want to receive behavioral advertising from certain companies. If you delete your cookies, use a different browser, use a different device or buy a new computer or mobile device, you will need to renew your opt-out choice.

Opting-out of, deleting, rejecting, disabling or turning off tracking tools does not mean that you will no longer receive online ads. Opting-out of behavioral advertising only means that such ads will no longer be tailored to your specific viewing habits or interests, but you may continue to see ads on and about the Services.



10. DO NOT TRACK PREFERENCES

Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. We do not currently respond to browser DNT signals or other mechanisms that might enable consumers to opt-out of tracking on our Services.


11. PERSONAL INFORMATION PREFERENCES CONTROL (YOUR DATA RIGHTS)

Below are some ways you can control the collection and use of your information in connection with the Services.

a. Email Marketing Preferences

From time to time, we may use Personal Information to send you details of new products or services, updates, and other information that may be of interest to you. If you no longer want to receive these communications from us, you may “opt-out” of receiving our promotional emails by following the instructions to unsubscribe included in those communications. If you opt-out, we may still send you non-marketing communications, including information about your accounts and our transactions with you.

b. Information Storage Preferences

You may, at any time, log into your account and manage or modify the Personal Information stored in your account. In addition, you may contact us at privacy@newsela.com for any questions or concerns about the Personal Information we have about you.

c. Additional Privacy Rights

In accordance with applicable privacy law, and depending upon the jurisdiction in which you reside, you may have the right to request to access, correct or delete your Personal Information or to request to opt-out of certain types of data practices. Eligible users can submit a request by completing our Privacy Rights Request Form or emailing us at privacy@newsela.com. Please note that if you are a student who accesses the Services through a School, or the student’s parent or legal guardian, you must contact your School to submit a request to access, modify or delete your Personal Information. Please also review the Privacy Disclosures for Children and Students to learn more.

d. Reliance on Teacher, Administrator or Parental Instructions

We may, and you authorize us to, rely on the instructions that we reasonably believe are given by a teacher, administrator, parent or legal guardian in connection with a student. For example, if a person calls our customer support number and provides the account information we request, we may assume that the person calling is the teacher, administrator, parent or legal guardian of such a student. We will not be responsible for any disclosure made in good faith and following reasonable procedures in responding to a request for disclosure of a student’s information from such an individual.


12. SECURITY OF YOUR PERSONAL INFORMATION

We take our responsibility to protect your Personal Information seriously. We have implemented security measures designed to prevent your Personal Information from being lost, used, accessed, altered, or disclosed in an unauthorized or unlawful way. Additionally, Newsela implements required and optional data privacy and cybersecurity training for all employees upon onboarding and annually.

Please note, no method of transmission over the Internet, or method of electronic storage is 100% secure, and we cannot and do not guarantee that Personal Information is completely secure and safe from such risks. By using the Services, you understand and assume the risks associated with your activities on the Internet. We update our security practices upon advancements made in technology and enhancements to industry standards, and for the most updated information on our security practices please contact us at privacy@newsela.com.


13. RETENTION OF YOUR PERSONAL INFORMATION

We retain your Personal Information for as long as your account is active, authorized by your School, or for as long as is reasonably necessary to provide our Services. You can request your Personal Information to be deleted at any time by filling out our Privacy Rights Request Webform or emailing us at privacy@newsela.com.


14. THIRD PARTIES

We may provide links to other third-party websites or resources with whom we do not have a contractual relationship and over whom we do not have any control. Different rules may apply to the collection, use or disclosure of your Personal Information by these third parties. The use of technology by these third parties, and their policies and practices regarding your information and their sites and services, is within their control and not Newsela’s control. Those parties may use the information they collect from you consistent with their own terms of use and privacy policies, which we encourage you to carefully review. Please note, you acknowledge and agree that we may use YouTube to host video content and, where applicable, by using our Services you agree to be bound by YouTube’s terms of service

Newsela enters into agreements with authorized third parties that process Personal Information to help us provide our Services (“Subprocessors”). To see which Subprocessors we use, please review our Subprocessor Webpage.

If you have any questions regarding third parties, service providers, or subprocessors we use please reach out to privacy@newsela.com.


15. CHANGES TO THIS PRIVACY POLICY

We may update this Policy from time to time. When we make material changes to this Policy, we will revise the “Last Revised” date at the top of this Policy above. All changes to this Policy are effective when they are posted on this page. If you do not agree to the updated terms, you must cease using our Services.


16. CONTACT INFORMATION

We welcome your comments or questions about this Policy. Feel free to email us at privacy@newsela.com. You may also contact us at our address: Newsela Inc., Attn: Legal, 169 Madison Ave., #2770, New York, NY 10016.


Newsela Children & Student Privacy Policy

17. PRIVACY DISCLOSURES FOR CHILDREN AND STUDENTS

When our Services are used by providers of educational services, such as schools, school districts, teachers, and authorized school users and administrators (collectively, “Schools”) for educational purposes, we collect and process Personal Information about students (“Student Data”) for and on behalf of the School as a School Official. Our collection and use of Student Data is governed by our contracts with the School (including, to the extent applicable, the Newsela Terms of Use), as well as by applicable student privacy laws such as FERPA, COPPA and state student data privacy laws. This Privacy Disclosures for Children and Students explains the principles we apply to our collection and use of Student Data. In the event of any conflict between the School contract and the practices set forth in these Privacy Disclosures for Children and Students, the School contract shall govern. Please contact your School if you have any questions about the School’s privacy practices.

a. Who does this apply to

These Privacy Disclosures for Children and Students describe how we collect, use, protect and process Personal Information from or about students, including children under 13, through the provision of the Services to a School.

b. Children Under 13

We do not permit children under 13 to create an account and do not knowingly collect personal information from a child under 13 unless the child is provided access to the Services by the child’s School or an authorized legal guardian for use in an educational setting (e.g., the child under 13 is a student of a School). When a School uses the Services in the classroom or educational context, we rely on the School to provide appropriate consent Newsela to collect Personal Information from a student under 13 for the use and benefit of the School and for no other commercial purpose, as permitted by the Children’s Online Privacy Protection Act (“COPPA”). If you are a parent, please continue reading this Privacy Policy for Children and Students to understand how your child’s information will be collected and used by Newsela on behalf of your child’s school. For purposes of this section, the term “Student Data” includes Personal Information of a child under 13 who uses the Services in connection with a School.

c. Student Data Principles

We consider Student Data to be confidential and do not use Student Data for any purpose other than to provide the Services to the Schools and in accordance with any contractual agreements with the Schools.

  • As between us and the School, Student Data is owned and controlled by the School.

  • Our collection, use, and disclosure of Student Data is governed by our agreement with the applicable School, and by the provisions of FERPA, COPPA, and applicable state laws which relate to the collection of Student Data.

  • We collect, maintain, use and share Student Data only for an authorized educational purpose and as described in any contractual agreements with the School, or as directed by the School or the applicable educator, parent or guardian.

  • We do not use or disclose Student Data for targeted advertising purposes.

  • We do not build a personal profile from Student Data other than in furtherance of an educational purpose.

  • We maintain a data security program reasonably designed to protect Student Data.

  • We will clearly and transparently disclose our data policies and practices to our users.

  • We will never sell Student Data unless the sale is part of a corporate transaction, such as a merger, acquisition, bankruptcy, or other sale of assets, in which case we will require the new owner to continue to honor the terms provided in this Policy or we will provide the School with notice and an opportunity to opt-out of the transfer of Student Data by deleting the Student Data before the transfer occurs.

d. Student Data We Collect

Student Data we collect Includes:

  • Contact Information

  • School, grade, and classroom affiliation

  • Birthdate

  • Demographic Information (only if required by your School and voluntarily provided)

  • Account Information

  • A photograph of yourself (only if voluntarily provided when you create your account)

  • Access and usage data about students’ use of the features and functionality of the Services

  • Login Information

  • Messages and user content

  • Feedback provided by students

  • Information provided in response to surveys and promotions we make available to students (if any)

Student Data may include “educational records” as defined by the Family Educational Rights and Privacy Act (“FERPA”), 20 U.S.C. § 1232(g).

e. How We Use Student Data

Our use of Student Data in accordance with our agreements with the School and subject to the School’s instructions and control. Generally, we use Student Data to operate, maintain and provide our Services to Schools and to support, improve and develop our educational product and service. This may include:

  • To permit teachers and other School users to monitor students’ engagement and performance, plan lessons and otherwise support instruction;

  • To provide teachers and School users with reports and education or product recommendations;

  • To customize the user experience;

  • For adaptive learning or customized student learning, including generating personalized learning recommendations and suggesting educational content or activities;

  • For analytics purposes, to understand how our Services are accessed and used and how they perform, so that we may improve design and functionality. We also collect analytics on aggregate information that does not identify any individual user; and

  • To diagnose problems, troubleshoot issues and provide maintenance and support.

For clarity, we do not use Student Data to: (i) advertise or market to students on our Services or to direct targeted online advertising to students on our Services, (ii) develop a profile of a student other than for the purpose of providing educational services or as authorized by School, or (iii) for any other commercial purpose unless authorized by School or permitted by applicable law.

f. How We Share and Disclose Student Data

We disclose Student Data solely as needed to provide the Services on behalf of specific Schools in accordance with our contractual agreements with those Schools. Please note that Student Data and teacher account usage data may be disclosed to or accessible by users who are authorized to use the Services on behalf of the School. Student Data may also be accessible to anyone who accesses your account with your login credentials. To avoid unauthorized access to Student Data, please do not distribute your login credentials and keep all login information secure.

In addition, depending on the manner in which the Services is used by the School and the terms of the agreement between the School and Newsela, we may provide access to certain Student Data to the student and/or to the parent or guardian of the student about whom the records relate, for the purpose of monitoring student usage and activity and evaluating the effectiveness of the School’s use of the Services. We also disclose Student Data to our trusted service providers who have a legitimate need to access such information on our behalf, subject to appropriate contractual terms to protect such data. Furthermore, we may disclose Student Data in connection with a business transaction or to support our legal rights and obligations, as described under the section entitled “Recipients of Personal Information” above.

g. How We Use De-Identified Student Data

We may collect and use De-Identified Data to operate, analyze, improve, market or develop educational sites, services or applications, to recommend content or services relating to school or educational purposes, and to demonstrate the effectiveness of our products or services. De-Identified Data means data from which all personally identifiable information, including direct and indirect identifiers, has been permanently removed or obscured so that the remaining information does not reasonably identify an individual and there is no reasonable basis to believe that the information can be used to identify an individual. If we share or publicly disclose De-Identified Data, that data will be aggregated or anonymized to reasonably avoid identification of a specific School or individual student.

h. How We Retain Student Data

We do not knowingly retain Student Data beyond the time period necessary to support the School’s educational purpose. We do not delete or de-identify any Student Data from an active student user account associated with a School except at the direction of the School.

Please note: Schools are responsible for maintaining current student rosters and identifying Student Data which the School no longer needs for an educational purpose by submitting a deletion request. School users may contact us at privacy@newsela.com to request deletion of Student Data. Even if we do not receive a deletion request from a School, we may delete or de-identify Student Data after a period of inactivity in accordance with our standard data retention practices.

We may not be able to immediately or completely delete all data in all instances, such as information retained in technical support records, customer service records, backups, and other similar business records. We do not delete information which has been de-identified or disassociated with personal identifiers such that the remaining information cannot reasonably be used to identify a particular individual.

i. Access to Student Data

We provide a mechanism for Schools to allow parents and legal guardians to review Student Data upon request. If you are a student, or the parent or legal guardian of a student, please contact your School to submit a request to access, review or modify Student Data. We will work with the School upon the School’s request to help facilitate responses to these inquiries.

j. How we secure Student Data

We take our responsibility to protect your Personal Information seriously. We have implemented security measures designed to prevent your Personal Information from being lost, used, accessed, altered, or disclosed in an unauthorized or unlawful way. Additionally, Newsela implements required and optional data privacy and cybersecurity training for all employees upon onboarding and annually.

Please note, no method of transmission over the Internet, or method of electronic storage is 100% secure, and we cannot and do not guarantee that Personal Information is completely secure and safe from such risks. By using the Services, you understand and assume the risks associated with your activities on the Internet. We update our security practices upon advancements made in technology and enhancements to industry standards, for the most updated information on our security practices please contact us at privacy@newsela.com.

k. Changes and questions about Student Data

We may update the Policy from time to time. When we make material changes to this Policy, we will revise the “Last Revised” date above. All changes to this Policy are effective when they are posted on this page. If you have questions about specific practices relating to Student Data provided to Newsela by the applicable Schools, please direct your questions to your School or contact us at privacy@newsela.com