Last Updated January 6, 2020
1. The Personal Information We Collect from Children, How We Use It, And How and When We Seek Parental Consent
We market and sell our products to adults who purchase or otherwise subscribe to our Services, which can then be used by children at the direction and under the supervision of these adults. Certain of our Services—Raz-Plus, Raz-Kids, Headsprout, Science A-Z, ReadyTest A-Z, Writing A-Z, and Vocabulary A-Z—offer online learning tools that children may access and that may collect Personal Information from children, as defined by COPPA. We identify below potential instances of such collection and describe how and when we will provide parental notice and seek prior verifiable parental consent.
We do not knowingly collect, use, disclose or store any Personal Information from children unless we have obtained prior verifiable parental consent. In any instance where we collect Personal Information from a child, we will not collect more Personal information than is reasonably necessary for the child to participate in the Service, and we will retain that information only as long as reasonably necessary to fulfill the request or allow the child to participate in the Service, ensure the security of our users and Services, or as required by law. In the event that we discover that we have inadvertently collected information from a child in a manner inconsistent with COPPA’s requirements, we will delete that information and attempt to notify the child’s parent. If you believe that we might have collected Personal Information from your child without consent, please contact us.
Account Creation and Student Login Credentials
An adult teacher or parent purchaser of any Service may open an account for a child by creating the child’s student login credentials. We collect student user credentials each time a child log in to the student portal to access the Services. In addition, the student’s user credentials are collected and displayed on the online classroom roster in the teacher portal. We will not use this information for any purposes other than authenticating the student’s login and facilitating student access to the Services. Our staff is not authorized to disclose student login information; information regarding student login credentials is strictly controlled by the teacher.
Correspondence With Us
Nevertheless, if a child corresponds with us, we will collect the child’s Personal Information to directly respond to the child’s request for assistance on a one-time basis, and we will delete the child’s Personal Information after responding.
We automatically receive and record certain technical information from a child’s browser, including the child’s IP address, for internal purposes only. When we collect an IP address, we combine it with other information submitted by the user’s browser, such as requests for files from the web server. We compile this information to create access logs, which we analyze to determine trends, such as which pages are used the most, which browsers are most frequently used by visitors to access the site, and which areas of the world site users are accessing our products from most frequently. Our access logs do not contain any information which can be uniquely associated with any particular IP address or Personal Information about any individual user.
Student Account Activity
Certain activities on certain Services allow children to create or manipulate content and save it on our Services. Some of these activities do not require children to provide any Personal Information. If a Service requests or allows a child to provide Personal Information in their created content, we will seek prior verifiable parental consent in order to collect that information. Examples of created content that constitute or may include Personal Information include the following:
Student voice recordings (Raz-Plus, Raz-Kids, Headsprout, and Science A-Z only): Children may record themselves reading texts, they may play the recordings back, and they may send the recordings to their teachers.
Open-text fields (Raz-Plus, Raz-Kids, Headsprout, Science A-Z, ReadyTest A-Z, Writing A-Z, and Vocabulary A-Z only): Children may draft and submit written responses to various prompts.
We do not use student voice recordings or the information provided by children in open-text fields for any internal purpose; we only transmit the voice recordings and the content provided in open-text fields to the child’s teacher, where it can be reviewed or downloaded. Students may not share student voice recordings or the information provided in open-text fields with anyone else, and they cannot privately communicate with anyone using the Service.
Additional educational information is collected as the child progresses through the Service, such as amount of time logged in, reading rate, and assessment scores. This information allows the Service to adapt to the child and inform the teacher on the child’s progress.
For parent purchasers, in the event we wish to collect the Personal Information outlined above from a child, we provide parental notice and seek verifiable parental consent via the email address provided during account creation. In our initial email, we describe what Personal Information we collect from children, how we collect it, how we use it, how we disclose it, how the parent can consent to collection of such information, and your parental rights over such information. This email contains an activation link you must click. We send another email message to confirm we have obtained consent after a reasonable time delay. In this confirmatory message, we indicate how the parent can revoke consent to our collection of Personal Information.
Consent—Schools As Agents of Parents
Where a school or school district contracts with us to offer the Services solely for the benefit of their students and for the school system and for no other commercial purpose, the school or school district may consent to the collection of children’s Personal Information on parents’ behalf. We encourage schools and school districts using our Services to notify parents that our Services are being used in their schools.
We provide the schools and school districts using our Services with the notices required under COPPA, including a description of the Personal Information we collect from children, how we collect it, how we use it, how we disclose it, how the school or school district can consent to collection of such information, and all other rights over such information.
2. How We Share Personal Information Collected From Children
We do not provide any child’s Personal Information to third parties—we use this information for internal purposes only.
3. Parental and School Access and Control Over Personal Information Collected From Children
At any time, parents or schools operating as the agent of parents can request to review any Personal Information collected about a child, have such information deleted, and/or request that there be no further collection or use of a child’s Personal Information. Adults with teacher access may remove children by deleting them from their classroom roster. Parents may do this by contacting the account holder associated with their child and requesting deletion. We take steps to confirm that anyone requesting Personal Information about a child is in fact the child’s parent or authorized school agent. Please keep in mind that a request to delete Personal Information about a child or a request that there no there be no further collection or use of their child’s Personal Information may lead to the termination of an account, membership or other service. Upon written request by a school, we will delete any Personal Information collected from students, and we will provide written verification that the information has been destroyed as requested.
If you no longer wish to have Personal Information of a child collected by an application installed on a mobile device, you may uninstall the application by using the standard uninstall processes available on the mobile device or via the mobile application marketplace or network.
4. How We Protect Children’s Personal Information
Attn: Customer Service Manager
1840 E RIVER RD STE 220
TUCSON AZ 85718-5997