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Last updated December 12, 2022
This Privacy Policy (the “Policy”) applies to your use of the HOW2 web-application (the “HOW2 Application”) and related website, teachinghow2s.com (collectively, the “Services”) provided by TeachingHOW2s, LLC (the “Company,” “we,” “us” or “our”).
The HOW2 Application is a is a collaborative learning platform that enables educators to learn evidence-based teaching techniques for purposes of enhancing their teaching practices.
We respect your privacy and are committed to protecting any information that identifies, relates to, describes, references, or may be reasonably associated with or linked to you or your household, such as your name, date of birth, mailing address, and other similar information that you may provide us or we may receive through your use the Services (collectively, “Personal Data”).
By using the Services, you acknowledge you have read and understood the terms and conditions of this Policy. If you do not agree to the terms and conditions of this Policy, please do not use the Services.
All capitalized terms not otherwise defined in this Policy shall have the meaning ascribed thereto in that certain End User License Agreement (“EULA”) by and between you and the Company. Authorized Users of the Services shall be referred to herein collectively as “Users” and individually as, a “User.”
PURPOSE OF THE PRIVACY POLICY
The purpose of this Policy is to describe the collection, use and disclosure of Personal Data that is collected in your use of the Services.
This Policy may be updated from time to time, at the discretion of the Company, in accordance with the terms herein.
DATA WE COLLECT ABOUT YOU
Information we must always collect in order to provide you with the Services includes:
Other types of information we may collect in our provision of the Services includes:
Additionally, from time to time and in our sole discretion, we may collect certain data points to ensure the Services are working as intended or to enhance the Services, such as:
We will collect, or have collected, the following Personal Data from Users of our Services in the last 12 months:
| Category of Personal Data | Source(s) of Personal Data | Business Purpose(s) for Collection / Disclosure | Third Parties Personal Data Has Been Disclosed to in Last 12 Months |
|---|---|---|---|
|
Identifiers
|
Directly from Users Indirectly from Users (e.g., from using our Services) From a User’s Educational Institution |
To fulfill or meet the reason the Personal Data was provided:
To troubleshoot technical issues or conduct other testing, analysis, systems support and maintenance, and the like To notify a User about changes to our Policy To send marketing communications to a User or make suggestions or recommendations as to other services which may be of interest to a User To comply with a legal obligation To fulfil another legitimate business purpose |
Please refer to Section 4 for further details |
|
Private, Non-Public Personal Data
|
Directly from Users Indirectly from Users (e.g., from using our Services) From a User’s Educational Institution |
To fulfill or meet the reason the Personal Data was provided:
To troubleshoot technical issues or conduct other testing, analysis, systems support and maintenance, and the like To notify a Users about changes to our Policy To send marketing communications to a Users or make suggestions or recommendations as to other services which may be of interest to a Users To comply with a legal obligation To fulfil another legitimate business purpose |
Please refer to Section 4 for further details |
|
Internet or Similar Network Activity
|
Indirectly from Users (e.g., from your use of our Services) |
To fulfill or meet the reason the Personal Data was provided To troubleshoot technical issues or conduct other testing, analysis, systems support and maintenance, and the like To comply with a legal obligation To fulfil another legitimate business purpose |
Please refer to Section 4 for further details |
|
Geolocation Data
|
Indirectly from Users (e.g., from your use of our Services) Indirectly from a third party provider (such as Google Analytics) |
To fulfill or meet the reason the Personal Data was provided To troubleshoot technical issues or conduct other testing, analysis, systems support and maintenance, and the like To comply with a legal obligation To fulfil another legitimate business purpose |
Please refer to Section 4 for further details |
|
Professional or Employment-Related Information
|
Directly from Users Indirectly from Users (e.g., from using our Services) From a User’s Educational Institution |
To fulfill or meet the reason the Personal Data was provided To notify a Users about changes to our Policy To send marketing communications to a Users or make suggestions or recommendations as to other services which may be of interest to a Users To comply with a legal obligation To fulfil another legitimate business purpose |
Please refer to Section 4 for further details |
Data Retention Policy: We retain and store your Personal Data only for as long as we have a legitimate business purpose to do so and in accordance with our data retention policies or as required by applicable law, and then we will delete it.
Subject to applicable law, unless otherwise agreed between you and the Company or the Company and your Educational Institution, we will only retain your Personal Data for a period of twelve (12) months from the date in which you cease to be a registered Users of the Services.
Failure to Provide Personal Data; Updating Personal Data: Where use of the Services is dependent upon our collecting certain Personal Data, or the collection of such Personal Data is required by law or the terms of a contract we have with you or your Educational Institution, and you fail to provide that data when requested, we may not be able to provide you with the Services. In this case, we may have to cancel a service you have with us, provided, however, that we will notify you in advance of doing so. Additionally, it is important that the Personal Data we collect from you is accurate and current. Please keep us informed of changes to your Personal data during your relationship with us.
HOW WE COLLECT YOUR PERSONAL DATA
We may receive your Personal Data from:
Direct Interactions. You may give us your Identity Data and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:
Your Educational Institution. Your Educational Institution may provide your name and email address to us for purposes of registering you with the Services.
Other Third Parties or Publicly Available Sources. We may receive Personal Data about you from various third parties and public sources, including analytics providers such as Google.
Automated Technologies or Interactions. As you interact with our website, we may automatically collect Technical Data about your Device or equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and other similar technologies. See Section 8 for further details on the tracking technologies we use.
USE OF INFORMATION
We use the Personal Data we collect from you as permitted by applicable law and for the following purposes:
We will only use your Personal Data as described in this Policy. We will not use your Personal Data for other purposes without updating this Policy in accordance with the terms herein or by otherwise providing you with notice.
SHARING AND DISCLOSURE OF INFORMATION
We do not disclose your Personal Data, except as provided in this Privacy Policy and for the legitimate business purposes set forth herein. If we disclose Personal Data for a legitimate business purpose, we will ensure that any third party receiving Personal Data is obligated to keep such Personal Data confidential and not use or it for any purpose except for the business purpose for which it was disclosed.
We may share or disclose information to the following categories of third parties and for the reasons set forth below:
Aggregated Data. We do not sell your Personal Data, except for aggregated, de-identified information and data (i.e., statistical or demographic data and information which does not identify you or your household, hereinafter “Aggregated Data”). For example, we may aggregate data pertaining to your usage of the Services to calculate the percentage of Users accessing a specific website feature where such information does not specifically identify a User.
SUBJECT TO APPLICABLE STATE AND FEDERAL LAW, WE MAY LICENSE, SELL, OR OTHERWISE SHARE DEIDENTIFIED INFORMATION WITH OUR SUBSIDIARIES, AFFILIATES, PARTNERS, CUSTOMERS, INVESTORS, SERVICE PROVIDERS AND CONTRACTORS FOR ANY PURPOSE. YOU AGREE AND ACKNOWLEDGE THAT THE COMPANY IS THE SOLE AND EXCLUSIVE OWNER OF ANY DEIDENTIFIED INFORMATION (INCLUDING THE DEIDENTIFIED ANALYTICS) CREATED BY THE COMPANY AND THAT YOU HAVE NO OWNERSHIP OR OTHER INTELLECTUAL PROPERTY RIGHTS IN OR TO SUCH DEIDENTIFIED INFORMATION.
COLLECTION AND USE OF INFORMATION FROM CHILDREN
Our Services are not intended for children under the age of eighteen (18). We do not knowingly collect Personal Data from children, and our Services are not designed to attract children under the age of eighteen (18). In the event that we learn that a child under the age of eighteen (18) has provided Personal Data to us, we will delete such Personal Data as soon as possible.
THIRD PARTY LINKS
When you use our Services, the Services may include links which may direct you to third party websites, plug-ins, or applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and we are not responsible for the privacy practices or content of such other sites. If you are redirected from the Services to a third party website, plug-in, or application, we strongly encourage you to review such third party’s policies and contact them directly with any questions you may have regarding their data collection practices.
Except as set forth in this Policy, the Company will never provide any third party with your Personal Data without your prior written consent.
HOW WE USE COOKIES AND SIMILAR TECHNOLOGIES
In providing the Services we may use cookies, web beacons, and other similar technologies in connection with the Services.
Cookies (or “Browser Cookies”). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
We use first-party cookies to help secure and maintain the Services, as well as to authenticate registered Users of the Services and maintain User login sessions. We use third-party service providers that may use cookies or other tracking technologies for providing certain functionality and security purposes with respect to the Services. Our third-party providers may use cookies to enable multimedia content plays and collect multimedia viewing usage statistics, as well as to collect general usage data in order to understand how its websites and web apps are used in order to inform their improvement.
Web Beacons. Pages of our Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count Users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Flash Cookies. Certain features of our Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with the following control over your information:
Tracking Technologies. There are several ways to manage cookies. Please check your browser and browser settings to determine where these types of cookies are stored and whether and how they may be deleted. The help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable most cookies altogether. Please note that if cookies are disabled or removed, certain parts of the services you intend to use may not be accessible or certain features of the services you intend to use may not operate as intended.
Disclosure of Your Information for Third-Party Advertising or Targeted Advertising. If you do not want us to share your information that we collect or that you provide to us with unaffiliated or non-agent third parties for promotional purposes or to serve interest-based advertising, you can opt-out by following the opt-out links on any marketing message sent to you. You can also always opt-out by sending us an email with your request to the contact information below.
We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.
SECURITY
We have implemented reasonable security measures to ensure the security of your Personal Data. Please understand, however, that no data transmissions over the internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk. If we learn of a breach of our security systems, we will attempt to notify you electronically so that you can take appropriate protective steps. Additionally, your User Contributions are posted and submitted at your own risk. We cannot control the actions of other Users who choose to share or to whom you choose to share User Contributions.
By using our Services or otherwise providing information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Services. We may post a notice via our Services if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
ASSIGNMENT
In the event that all or part of our assets are sold or acquired by another party, or in the event of a merger, you grant us the right to assign any of your Personal Data collected via the Services.
YOUR CALIFORNIA PRIVACY RIGHTS
From January 1, 2020, many California consumers now have the following rights:
If you would like to exercise one or more of the rights above, please contact us using the contact information provided below. If you are emailing, please write “Data Subject Request” as your subject line, and explicitly state which right you are exercising in the body of the email. You may designate an authorized agent to make a request on your behalf. Such authorized agent must be registered with the California Secretary of State. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.
Additionally, California Civil Code Section 1798.83 permits Users who are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please email us using the contact information provided below and put “Shine the Light” in the subject line of your request.
When submitting a request, we may need to take certain steps to ensure that we are receiving a verifiable consumer request before completing your request, and, for example, may ask for you to confirm data points we already have about you. We will only use Personal Data provided in a verifiable consumer request to verify the requester’s identity or authority to make the request. Whenever feasible for verification, we will match the identifying information provided by you to the Personal Data already maintained by us. If, however, we cannot verify your identity from the information already maintained by us, we may request additional information.
CHANGES TO THIS PRIVACY POLICY
We reserve the right to change this Privacy Policy from time to time in our sole discretion. When we do, we will also revise the “Last Updated” date at the top. If we make material changes, we will notify you by placing a prominent notice on our Services. We encourage you to periodically review this Policy to keep up to date on how we are handling your Personal Data.
CONTACT US
If you have any questions, comments or concerns about our privacy practices or this Privacy Policy, or to exercise any of your rights, please contact us at the contact information below:
4600 140th Avenue N., Suite 180
Clearwater, FL 33762
info@teachinghow2s.com
Attention: Nicky Dyer, Data Privacy Manager