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).
This Policy applies to all users of the 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.
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.
You are accessing, using or receiving our Services when you:
Personal Information we collect from you or from your School may include:
b. Information we collect from third parties
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. These technologies help 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. These technologies may include:
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 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.
For further information on your choices regarding how we use your Personal Information, see the “Personal Information Preferences & Control” section below.
In accordance with how we use your Personal Information, we may share your Personal Information with the following:
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.
Please note: As explained further below, we do not disclose Student Data for targeted advertising purposes. For more information about our third-party tracking and online advertising in other contexts, please see below.
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.
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.
You can opt-out of certain behavioral advertising activities by doing one or more of the following. Please note that you will need to opt-out of each browser and device for which you desire to apply these opt-out features.
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. Some of these Advertising Service Providers, and links to their opt-out tools, are:
Industry Opt-Out Tools:
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.
Web Browser Controls:
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:
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, visithttps://play.google.com/store/apps/details?id=com.DAA.appchoices&hl=en ). For more information, please visithttp://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 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.
Below are some ways you can control the collection and use of your information in connection with the Services.
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.
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 email@example.com for any questions or concerns about the Personal Information we have about you.
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 firstname.lastname@example.org.
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.
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 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 individual.
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. However, 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. If you have reason to believe that your information is no longer secure, please let us know by contacting us at email@example.com.
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.
We welcome your comments or questions about this Policy. Feel free to email us at firstname.lastname@example.org. You may also contact us at our address: Newsela Inc., Attn: Legal, 500 5th Ave, 28th Floor, New York, NY 10110.
These Privacy Disclosures for Children and Students describes 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.
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.
Student Data we collect Includes:
Student Data may include “educational records” as defined by the Family Educational Rights and Privacy Act (“FERPA”), 20 U.S.C. § 1232(g).
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:
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.
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.
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.
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 email@example.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. We will also not delete any Student Data that has been transferred or stored in a personal account except at the request of the parent or student.
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.
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.