1. What Information do we collect?
K12 Insight collects information about both you, our clients (“clients” or “you”) and the individuals who participate in, or are invited to participate in, any of our Services (“Service Participants”). Collectively, the information collected about you (“Client Information”) and Service Participants (“Participant Information”) are referred to as “Information”.
Client Information: When Clients register for our Services, we ask them for personal information including, but not limited to, name and contact information, company name, name of business representative, title of business representatives, company address, telephone number, email address, user name and password, and billing information which may include credit card numbers. Clients also provide us with Information regarding the Services they have ordered.
Service Participant Information: We receive Participant Information from both Clients and directly from Service Participants. This may include any of the following categories of information relating to a Service Participant: personal data and the personal data of others, which may include first and last name, student ID number, grade level, ethnicity, address, phone number, and email, or any combination of the same (“Personally Identifying Information” or “PII”), and Lets Talk! “Dialogue Information”, which contains questions, comments, concerns, suggestions, compliments, and similar communications by any stakeholder in a school system.
Before receiving such Information, we contractually require that you warrant that you have a pre-existing relationship with the Service Participant or the Service Participant’s permission to receive electronic messages through the Service. Service Participants provide us with Information that you may request when using the Services, for example, their gender or zip code, as well as answers to survey questions and feedback in the form of comments and concerns relating to the Client. Clients are solely responsible for the content of the surveys they develop and we do not control the theme or questions asked in any survey developed independently by Clients or without our consultation. In order to enhance survey response rates, we log: (i) if and when a Service Participant has responded to a survey and (ii) if and when a Service Participant has received a reminder. In addition, we may also receive other information communicated by Service Participant directly to K12 Insight through the Service.
We also log Client and Service Participant Internet Protocol addresses to ensure the accuracy of the survey data and for system administration purposes, including tracking a web session so that we know when, how often and what web-pages of our websites and Let’s Talk! are visited. We also use Service Participant’s Internet Protocol address to analyze and develop reports on the number and frequency of Participant’s use of our Services. To prevent the need to re-insert user-name and password as you and your Service Participants move from one page of our websites to the next, we use “cookies” – short pieces of information used by web browsers to temporarily remember information provided by a user. But, cookies are generally deleted once the web browser used to access a web-site is closed.
2. How do we use information?
K12 Insight owns all questionnaires that it develops for its Clients and owns all of the reports and analyses that it develops for its Clients. Clients own all Dialogue Information from Let’s Talk! and responses from surveys. K12 Insight does not use or disclose any individual Participant Information for any purposes, except to develop these analytical reports for the Client’s benefit. K12 Insight may use Participant Information on an anonymous basis (i.e., without identifying any individual or school district) to establish aggregate benchmarks on issues covered by certain surveys. Client participation in benchmark studies is limited to only those Clients who agree to use specific K12 Insight survey instruments.
3. With whom do we share information?
We never sell Information, and we do not share the Information with any third parties except under the following very limited circumstances:
3.2. As You Explicitly Allow: We may share or otherwise use your Client Information as you explicitly allow us to and we may share Participant Information as both you and the Service Participant expressly allow. For example, you are given the opportunity to either hide or make available to Service Participants certain Client contact information in connection with any survey.
3.3. Agents Acting on Our Behalf: We may share some of your Information with other companies who provide us with technical, billing, and other type of essential supporting services. They will be contractually granted access to only that Information which is necessary for them to do their jobs and they will be prohibited from using the Information for any other purpose including sharing the Information with any other party.
However, electronic communications made through the Let’s Talk! service may be deemed an “electronic communication” by K12 Insight. As such, K12 Insight reserves the right to protect Information that it believes is protected from compelled disclosure pursuant to the Electronic Communications Privacy Act, 18 U.S.C. § 2510, et seq., (“ECPA”) and the Stored Communications Act, 18 U.S.C. § 2701, et seq., (“SCA”), in addition to protections afforded by state law. The protections provided under the SCA and ECPA enable K12 Insight to prevent governmental authorities from seeking compelled disclosure of certain electronic communications.
3.6. We acknowledge that the use and dissemination of student education records and PII are governed by state and federal laws, including, but not limited to the Family Educational Rights and Privacy Act (“FERPA”), 20 U.S.C. § 1232g, and the Children’s Online Privacy Protection Act (“COPPA”), 15 U.S.C.A § 6502, and strive to comply with these mandates at all times.
4. Can the information be changed?
Your Client Information may be viewed and modified in our active database in real-time, at any time. The changed Information may remain in archives and records for some period of time. Once a Service Participant has submitted a survey, the Service Participant will not be able to access his or her Participant Information. Service Participants may contact you and you, in turn, will be able to view the Service Participant’s collected Participant Information and, where appropriate, work with us in modifying Participant Information.
We permanently delete all PII within 30-days of discontinuing support for an active Service term.
5. How is the information protected?
Our Site has substantial and elaborate security measures in place to protect your Information. Unique user names and passwords must be entered each time a person logs on. Our Service web-sites are hosted in a secure server environment that uses a firewall and other technology to prevent access from outside intruders, in line with prevailing industry standards. Internally, we use security-logs, train our employees, and limit access to K12 Insight personnel who need to know the Information to deliver the Services. When transmitting sensitive Information, we use encryption technology. All of our technology and processes are not, however, guarantees of absolution security. Clients must actively protect their Information by maintaining the confidentiality of all usernames and passwords and by adequately installing the appropriate anti-virus programs and security measures on their own systems. You must immediately notify K12 Insight if any information security breach is suspected.
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