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Privacy Policy

Privacy Policy of Growth Over Time Learning, Inc. (gotLearning), LearningPulse and gotFeedback. This Application collects some Personal Data from its Users.

gotFeedback Privacy Assurances

  • We never sell your data or student data.
  • We do not own the content you add to gotFeedback, you do.
  • We use the latest security best practices to protect you.
  • We are compliant with FERPA, COPPA, CCPA and GDPR.
  • We are transparent about our practices and will let you know if things change.
  • We will never advertise in gotFeedback.

Children’s Privacy — Children’s Online Privacy Protection Act (COPPA)

We do not knowingly collect any information from children under the age of 13 unless and until the relevant institution has provided consent and authorization for a student under 13 to use the products and services and for us to collect information from such student. Where a client institution instructs us to collect personal information from children under the age of 13, we collect, use, process and retain such information solely to provide the educational services on behalf of the client and for the purposes set forth in our agreement with the client. We collect only as much information as is necessary to provide the service and the client may access, delete or withdraw consent for continued processing of the child’s information at any time. If you have any questions about reviewing, modifying, or deleting personal information of a child under the age of 13, please contact your educational institution directly.

United States — FERPA and State Education Privacy Laws

We provide educational products and services to schools and other educational institutions. Through the provision of these products and services, we collect personally identifiable information from or about students (“Student Data”), which may include educational records governed by the Family Educational Rights and Privacy Act (FERPA). We consider such Student Data to be strictly confidential and in general do not use such data for any purpose other than improving and providing our products and services to the educational institution or on the educational institution’s behalf. Our collection, use, and sharing of Student Data is governed by our contracts with the educational institutions, the provisions of FERPA, the Children’s Online Privacy Protection Act (“COPPA”), and other applicable laws that relate to the collection and use of personal information of students, but not by the provisions contained in this Privacy Statement. If you have any questions about reviewing, modifying, or deleting personal information of a student, please contact your educational institution directly.

Owner and Data Processor

Growth Over Time Learning, Inc. (gotLearning)
741 Conestoga Road
Bryn Mawr, PA 19010

Owner Contact Email: support@gotlearning.com

Types of Data Collected

Data collected by Growth Over Time Learning may include personally identifiable information from education records that are subject to the Family Educational Rights Privacy Act, “FERPA” (FERPA Records). Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies; Usage Data; first name; last name; school/company name; address; state; email address; website.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.

Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies — or of other tracking tools — by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available. Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.

Mode and Place of Processing the Data

Methods of Processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, email carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal Basis of Processing

The Owner may process Personal Data relating to Users if one of the following applies: Users (or their Parents/Guardians in the event Users are also Minors) have given their consent for one or more specific purposes; provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof; processing is necessary for compliance with a legal obligation to which the Owner is subject; processing is related to a task carried out in the public interest or in the exercise of official authority vested in the Owner; or processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party. In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located. Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data. If broader protection standards are applicable, Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law, and about the security measures taken by the Owner to safeguard their Data.

Retention Time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed. Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The Purposes of Processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics and Contacting the User.

Detailed Information on the Processing of Personal Data

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior. Google Analytics (Google LLC) is a web analysis service provided by Google LLC. Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Personal Data processed: Cookies; Usage Data. Place of processing: United States. A version with anonymized IP is also used, which shortens Users’ IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area.

Contact Form

By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header. Personal Data processed: address; company name; email address; first name; last name; state; website.

The Rights of Users

Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to: withdraw their consent at any time; object to processing of their Data; access their Data; verify and seek rectification; restrict the processing of their Data; have their Personal Data deleted or otherwise removed; receive their Data and have it transferred to another controller; and lodge a complaint before their competent data protection authority.

Details About the Right to Object to Processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection. Should their Personal Data be processed for direct marketing purposes, Users can object to that processing at any time without providing any justification.

How to Exercise These Rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Applicability of Broader Protection Standards

While most provisions of this document concern all Users, some provisions expressly only apply if the processing of Personal Data is subject to broader protection standards. Such broader protection standards apply when the processing is performed by an Owner based within the EU; concerns the Personal Data of Users who are in the EU and is related to the offering of paid or unpaid goods or services to such Users; or concerns the Personal Data of Users who are in the EU and allows the Owner to monitor such Users’ behavior taking place in the EU.

Additional Information About Data Collection and Processing

Legal Action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

System Logs and Maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.

How “Do Not Track” Requests are Handled

This Application does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to This Privacy Policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or, as far as technically and legally feasible, sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often. Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Information for California Consumers

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and applies to all Users who are consumers residing in the state of California, according to the California Consumer Privacy Act of 2018 (CCPA). For such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

Categories of Personal Information We Collect

We have collected the following categories of personal information about you: identifiers, commercial information and internet information. We will not collect additional categories of personal information without notifying you.

How We Collect Information

We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use this Application. For example, you directly provide your personal information when you submit requests via any forms on this Application. You also provide personal information indirectly when you navigate this Application. We may also collect your personal information from third parties that work with us in connection with the Service.

Sharing and Disclosing of Your Personal Information for Educational or School Purposes

We may disclose the personal information we collect about you to a third party for Educational or School purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose other than those necessary for the performance of the agreement. We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so.

Sale of Your Personal Information

gotLearning does not sell your data or student data. You have the right to opt out of the sale of your personal information. Whenever you request us to stop selling your data, we will abide by your request. To exercise this right, you can contact us using the details provided in this document.

Your California Privacy Rights

You have the right to request that we disclose the categories and sources of the personal information we collect about you, the purposes for which we use your information, and with whom such information is shared, limited to the personal information collected or used over the past 12 months. You also have the right to request that we delete any of your personal information, subject to exceptions set forth by law. To exercise these rights, submit a verifiable request to us by contacting us via the details provided in this document. We will confirm receipt within 10 days and respond within 45 days of receipt; should we need more time, we may take up to 90 days. You can submit a maximum of 2 requests over a period of 12 months.

reCAPTCHA

This Application uses Google reCAPTCHA on its forms to protect against spam and abuse. reCAPTCHA collects hardware and software information, such as device and application data, and sends it to Google for analysis. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.

Definitions and Legal References

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through this Application (or third-party services employed in this Application), which can include the IP addresses or domain names of the computers utilized by the Users, the URI addresses, the time of the request, the method utilized to submit the request to the server, and other parameters about the device operating system and the User’s IT environment.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data. The Data Controller, unless otherwise specified, is the Owner of this Application.

Legal Information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation). This privacy policy relates solely to this Application, if not stated otherwise within this document.

Contact Us

If you have any questions or concerns about our Privacy Policy, please contact us at privacy@gotlearning.com.

Growth Over Time Learning, Inc.
741 Conestoga Road
Bryn Mawr, PA 19010

LearningPulse by gotLearning

Student Work Analysis for K-12. Know where every student is in their learning, right now.

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