Privacy Policy
Privacy Policy for Blended Learning and Study Center (BLSC)
Blended Learning and Study Center Company (“BLSC,” “we” or “us“) provides educational services and related materials, via a set of platforms and locations. The following privacy policy governs our privacy practices for each platform and location that links to this policy.
Our Commitment to Privacy
We have created our centers and platforms to assist organizations, institutions, corporations, schools, instructors, facilitators, students, parents, and families to provide individualized, and competency-based experiential online and blended educational experiences to all.
Our Compliance With COPPA And FERPA
We recognize the sensitive nature of personal information concerning students under age 13, and concerning K–12 and all students in general, especially where the information is contained in a school’s educational records. This personal information is protected under either or both of the following federal statutes: the Children’s Online Privacy Protection Act (“COPPA”) and the Family Educational Rights and Privacy Act, including the Protection of Pupil Rights Amendment (“FERPA”). Our privacy practices comply with both COPPA and FERPA.
The Scope of Our Privacy Policy
This privacy policy governs our privacy practices with respect to all personal information that our users submit, or that we collect in connection with our learning platforms. This policy governs not only our practices with respect to students’ personal information, but also with respect to the personal information of all individuals who use our platforms and centers.
Consent from Schools regarding Students’ Personal Information
COPPA permits a school or educational organization or institution, acting in the role of “parent,” to provide required consents regarding personal information of students who are under the age of 13. Where a school or educational organization is the subscriber to our platform(s) or centers, we rely on this form of COPPA consent. We provide the school, educational organization, or institution with this privacy policy, to ensure that the school, educational organization, or institution (herein referred to as SEI, that is school, educational organization, and institution) in providing its COPPA consent, has full information and assurance that our practices comply with COPPA.
FERPA permits a SEI to provide educational records (including those that contain students’ personal information) to certain service providers without requiring the school to obtain specific parental consent. FERPA permits this where the service provider acts as a type of “SEI official” by performing services, for example, that would otherwise be performed by the SEI’s own employees. We fulfill FERPA requirements for qualifying as a SEI official by, among other steps, giving the SEI direct control with respect to the use and maintenance of the education records at issue (including associated personal information), and refraining from re-disclosing or using this personal information except for purposes of providing our platform(s) and centers to the SEI. We comply with FERPA by relying on this form of consent.
Consents from Other Users
We also obtain consents regarding personal information of users other than students (such as parents, teachers, instructors, facilitators, institutions, organizations, and school administrators). To obtain these consents we (a) notify the users of our privacy practices by including links to this privacy policy within our platforms, and (b) rely on their continued use of our platforms to indicate their consent to this privacy policy.
The Types of User Information We Collect
We limit our collection of personal information to no more than is reasonably necessary for the user at issue to participate in our platforms and centers. Specifically, we collect the following types of information:
Tutor/Facilitator/Instructor/Mentor/Volunteer/Presenter/Parent and User Information:we collect registration information from all the above individuals and all users when he/she apply, registers, opens, or activates a BLSC account, which may include the individual’s own first and last name, home and business address and phone number, date of birth, email address, and username;
SEI Administrator Information: we collect registration information from a SEI administrator when the SEI administrator activates the SEI subscription account, which may include the SEI administrator’s own first and last name, business address and phone number, date of birth, email address, and username;
Teacher Information: we collect registration information from a teacher or SEI administrator when the teacher (or SEI administrator) activates the teacher’s account, which may include the teacher’s first and last name, business address and phone number, date of birth, email address, and username; additionally, we may collect information that constitutes Performance Review Data;
Student Information: we collect registration information from a teacher or SEI administrator when the teacher (or SEI administrator) activates the account of an individual student, which may include the student’s first and last name, email address, username and other information which may include gender, race, and ethnicity;
Schoolwork Information: we collect information contained in student homework, class work, curricula, syllabus, assignments, student compositions and reports, tests, test results, grades, and other exchanges over our platforms and centers;
User-Generated Content: we collect information that students and other users provide in connection with submitting user-generated content, and participating in collaborative features of our learning platforms (where applicable). Examples of user-generated content that might contain personal information include stories, responses to student, facilitator, or teacher assignments (either in text, image, audio, or video format), drawings that allow text or free-hand entry of information, and other information provided in open-text and open-form fields; and
Usage Information: we collect usage, viewing, analytics, and technical data, including device identifiers and IP addresses, relating to users of our learning platforms and centers
If we discover that we have collected information in a manner inconsistent with the requirements of COPPA or FERPA, we will either (a) delete the information or (b) promptly seek requisite consents before taking further action concerning the information.
How We Collect Personal Information
Our platform collects personal information in three ways. First, users, including tutors, volunteers, mentors, facilitators, parents, students, SEI administrators, and teachers provide personal information during the registration process. Second, teachers, students, tutors, facilitators, and students submit personal information during the normal operation of our platform. They submit this information, for example, when creating and responding to teaching assignments, and otherwise engaging in educational and other activities available on our platform. Finally, we collect usage information through technology, such as cookies, flash cookies, web beacons, and persistent identifiers. This collection of usage information takes place, for example, when a student or other user visits our platform, and during the activities in which the user engages. Certain features (or all features) of our platform may be hosted on third party sites, and in those instances the collection activities described above are undertaken by this third party, under our direction and control and consistent with this privacy policy.
How We Use Personal Information
We use personal information for the following purposes:
To provide users with the content and features available through our platform;
To communicate with all users, including parents, students, SEI administrators, and teachers about the applicable subscription account or transactions with us, and to send information about our platform’s features and, where applicable, changes to these features;
To personalize our platform’s content and experiences for students, teachers, and all users of the platform; and
To detect, investigate and prevent activities that may violate our policies or be illegal.
We do not as a rule allow third-party operators to collect personal information or usage information through persistent identifiers on our learning platform for any purposes other than the internal operations of our platform. Further, we do not use personal information collected through our Platform for the purpose of targeted advertising.
Finally, we de-identify usage information in accordance with COPPA and FERPA, and use this de-identified information to develop, evaluate, and provide improved educational products and services, as permitted under COPPA and FERPA. To the extent we collect information that constitutes Performance Review Data, we protect such information as personal information in accordance with this Privacy Policy.
We Do Not Share Personal Information Beyond Our Platform Except In Specific, Limited Circumstances
We use personal information for our internal purposes only, with the following limited exceptions. First, we share information with our service providers if necessary for them to perform a business, professional, or technology support function for us. In instances where we engage service providers for these purposes, we require them to comply with this privacy policy. Second, we disclose personal information:
In response to the request of a law enforcement agency or other authorized public agency, including a request by a children’s services agency or by the school at issue;
To protect the security or integrity of our platform and associated applications and technology, as well as the technology of our service providers;
To enable us to take precautions against liability, enforce legal rights, and to detect, investigate and prevent activities that violate our policies or that are illegal;
If we are directed to do so by a subscribing school in connection with an investigation related to public safety, the safety of a student, or the violation of a school policy; and
In other cases if we believe in good faith that disclosure is required by law.
How We Protect Personal Information
We have implemented and maintain technical, administrative and physical security controls that are designed to protect the security, confidentiality and integrity of personal information collected through our platform from unauthorized access, disclosure, use or modification. Our information security controls comply with reasonable and accepted industry practice, as well as requirements under COPPA and FERPA. We diligently follow these information security controls and periodically review and test our information security controls to keep them current.
10.1 Information Security Procedures. We will:
Standard of Care. Keep and maintain all personal information in strict confidence, using such degree of care as is appropriate to avoid unauthorized access, use, modification, or disclosure;
Use for SEI Purposes Only. Collect, use, and disclose personal information solely and exclusively for the purposes for which you provided the personal information, or access to it to us, and not use, sell, rent, transfer, distribute, modify, data mine, or otherwise disclose or make available personal information for our own purposes or for the benefit of anyone other than the SEI, without the SEI prior written consent;
Non-Disclosure. Not, directly or indirectly, disclose personal information to any person other than our employees and service providers who have a need to know, without express written consent from the SEI;
No Commingling. Segregate (via logical, database, or physical segregation) personal information from our other information or our other customers so that a SEI users’ personal information is not commingled with any other types of information not related to the SEI;
Employee Training. Provide appropriate privacy and information security training to our employees.
Transport Security. Use Transport Layer Security (TLS) for the transmission of all user data to and from our platform; and
Secure Storage. Use industry standard file encryption for user data that is subject to protection under either COPPA, FERPA, or both. Where file encryption is not reasonably feasible, we employ other industry standard safeguards, protections, and countermeasures to protect such data, including authentication and access controls within media, applications, operating systems and equipment.
10.2 Data Location and Security. We use cloud service providers in the delivery and operation of our platform(s), and data (including personal information) is stored on the servers of our cloud service providers. Our contracts with our cloud service providers requires them to implement reasonable and appropriate measures designed to secure content against accidental or unlawful loss, access, or disclosure. Our cloud service providers have at least the following security measures in place for their networks and systems: (i) secure HTTP access (HTTPS) points for customer access, (ii) built-in firewalls, (iii) tested incident response program, (iv) resilient infrastructure and computing environments, (v) ITIL based patch management system, (vi) high physical security based on SSAE-16 standards, and (vii) documented change control processes. To the extent we store personal information internally on our servers, we comply with the information security controls set out in Section 10.1.
10.3 Data Breach Response. In the event of a security breach involving Personal Information, we will take prompt steps to mitigate the breach, evaluate and respond to the intrusion, and cooperate and assist SEI and other subscribers in efforts with respect to (i) responding to the breach, including the provision of notices to data subjects; and (ii) engaging mutually agreeable auditors or examiners in connection with the security breach, subject to reasonable notice, access and confidentiality limitations.
Access and Control of Personal Information
SEI administrators and (where applicable) teachers hold access to personal information of the students for whom they are responsible, and they are able to update this information in the manner permitted by our platform. SEI administrators and teachers are similarly able to access and update their own personal information. The parents of a student can obtain access to information concerning their child, and from an SEI, that is available on our platform. The parent should also follow the SEI’s procedures for access under FERPA. We cooperate with and facilitate an SEI response to these access requests. Where the SEI’s procedures do not apply to the parent’s access request (and the request is otherwise proper), we will ourselves fulfill the request if and as required by law. After fulfilling an access request, we will update and (where necessary) correct the personal information at issue, as requested by the SEI or individual entitled to such access. We limit access to personal information to only those employees (i) who have a need to know such information, and (ii) who use the information only for the educational purposes of operating our platform and delivering our services.
Our Retention and Deletion of Personal Information
We retain personal information of users of our platform (i) for so long as reasonably necessary (ii) to permit the user to participate in the platform, (iii) to ensure the security of our users and our services, or (iv) as required by law or contractual commitment. After this period has expired, we will delete the personal information from our systems. Please understand that these deletion periods apply to personal information and do not apply to de-identified information. We retain de-identified information in accordance with our standard practices for similar information, and do not retain or delete such information in accordance with this policy.
In addition, if requested by a SEI, we will delete from our platform the personal information of the SEI’s users, including its teachers and students, as the school directs. Deleting this information will prevent the SEI user from engaging in some or all features of our platform. Where required by local law, we will delete such information and provide a certification of such deletion.
Definitions
“De-identified information” means information that meets each of the following criteria: the information (i) does not identify a particular natural person; (ii) does not identify, by network Internet Protocol address, raw hardware serial number, or raw MAC address, a particular device or computer associated with or used by a person; (iii) does not identify the SEI at issue by name or address; and (iv) is not reasonably linkable to a particular natural person or SEI because of technical, legal, or other controls.
“Platform” means any BLSC platform that links to this privacy policy.
“Parent” means a parent or legal guardian of a student.
“Performance Review Data” means professional performance review data of teachers related to the teacher’s effectiveness in the classroom and other measurements based upon factors including, but not limited to, student achievement or growth on state assessments or examinations, classroom observations by peers, classroom observations by trained evaluators, evaluation of lesson plans and other indicia of teacher practices. Performance Review Data includes annual professional performance data, as defined under New York state law.
“Personal Information” means information that identifies a natural person, as specified in the Family Educational Rights and Privacy Act, 20 U.S.C. § 1232g, including the Protection of Pupil Rights Amendment (“FERPA”) and the Children’s Online Privacy Protection Act, 15 U.S.C. §§ 6501–6506 (“COPPA”), the California Student Online Personal Information Protection Act, Ch. 22.2, §§ 22584 et seq. of the California Business and Professions Code, and Section 49073.1 of the California Education Code.
“Student” means an individual receiving educational instruction via our platform. The term “student” includes individuals within the K–20 age group, and individuals who are children under the age of 13.
“Usage Information” means information that does not directly identify a particular person, but that may be linkable to a particular computer or device (via a unique device ID or otherwise).
“We” or “us” or “our” refers to BLSC.
Contact Us
You may contact us with questions or concerns with respect to this Privacy Policy at the following addresses and/or phone number: 203-872-7040, Trumbull, CT 0661.
Do Not Track
Our platform does not change its behavior when receiving the “Do Not Track” signal from browser software.
Effective Date
The effective date of this Privacy Policy is June 1, 2016.
CONSENT FOR THE COLLECTION AND PROCESSING OF PERSONAL DATA FROM THE EUROPEAN UNION
Pursuant to the European Union General Data Protection Regulation (“EU GDPR”), Blended Learning and Study Center, under the EU GDPR, must obtain your explicit, affirmative, and informed consent before it can collect or process any personal data for a lawful basis, including, but not limited to, employment, admission and enrollment, study abroad, internship abroad, online education, etc.
“Personal data” means any information relating to an identified or identifiable natural person (a “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
Any personal data that is collected from you will be:
Used for the evaluation of an individual’s participation in Blended Learning and Study Center programs and in the collection of data for general program evaluation by Blended Learning and Study Center and its programs and subsidiaries;
Used for notifying Blended Learning and Study Center participants of upcoming events and programs;
Notwithstanding anything to the contrary herein, Blended Learning and Study Center may process personal data without the data subject’s consent under certain other lawful bases, including when processing is necessary for the performance of a contract to which a data subject is a party; when processing is necessary for compliance with a legal obligation to which Blended Learning and Study Center is subject; or when processing is necessary to protect vital interests, such as the life of a data subject.
Personal data will be handled and processed only by the persons who are responsible for the necessary activities for the purpose above and may be transmitted from the EU to Blended Learning and Study Center’s Information Systems.
Refusal of consent may make it impossible for Blended Learning and Study Center to carry out its necessary activities for the purpose above and may preclude Blended Learning and Study Center’s ability to provide requested educational services, employment, participation in programs, or other services to you.
You have the right to withdraw your consent to the collection and processing of personal data. If you would like to withdraw consent, please contact the Data Protection Officer at blass@blendedlearningcenter.com
Blended Learning and Study Center is committed to ensuring the security of your information. We have put in place reasonable physical, technical, and administrative safeguards designed to prevent unauthorized access to your information.
The effective date of this Privacy Policy is June 1, 2019.