Information We Collect
We do not collect personally identifiable information from Students, Teachers, Staff, or Other Representatives of educational organizations who use the Program, Platform and Other Services to learn and improve their study behaviors as part of a School or Educational Organizational Purchase. (collectively, “ School Users”)
We do collect personally identifiable information from individual purchasers, who access or use the Program, Platform and Other Services, ( collectively, “Individual Users”).
information that We collect includes:
- Purchase information
- Activity and usage information regarding access to and use of the platform by de-identified School Users
- Information about the Educational Organization or Individual Purchaser using the platform to ensure proper billing and payment
- De identified data and results from exercises to evaluate and improve the product’s performance.
- Any personal information that candidates volunteer unprompted when they use the Platform;
- Technical support records; and
- Service requests and inquiries
Cookies and Similar Tools
We may also automatically receive and store certain information when Individual Users access or use the Services, including browser type, and originating URL, date and time, and how Individual Users interact with Us. We use different types of technology to collect this information, such as log files, cookies, web beacons, and pixel tags.
We may also use these tools to provide relevant, requested information to Individual Users of the Services monitor traffic and identify behavior that violates the Terms of Service.
If Individual Users wish to disable cookies, You may do so through your individual browser options. More detailed information about cookie management with specific web browsers can be found at the browsers’ respective websites.
How do We use Personal Information?
The CTTL uses personal information for Individual Users of NTGS:
- to create and administer the Organization’s or Individual User’s account, including to authenticate Individual purchaser or Educational Organization Admin users on log-in, for the Platform;
- to provide administrative users access to the Platform;
- to establish and maintain responsible behaviors by administrators
- to communicate with the purchasing organization and Individual Users in order to provide Services;
- to respond to any correspondence users may direct to Us;
- to enforce Our Terms of Service;
- to provide You with Service or administrative messages;
- to meet legal and regulatory requirements; and
- for any other reasonable purposes with your consent or as otherwise required by law.
Disclosure of Personal Information
The CTTL shares personal information from Individual Users only with 3rd parties data processors as required for delivery of the NTGS program.
We allow access to the personal information of Individual Users to third party suppliers, contractors and agents (“Service Providers”) who are contracted by Us to assist it in providing and developing products and services, including content development, content and data hosting, data processing, analytics, and technical support. We require our Service Providers to only use any personal information for the purposes of providing these services to us.
We will disclose Information pursuant to a lawful order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of Your personal information. We may also disclose information if we receive a lawful request from a police officer or other law enforcement agency with authority to request access to Your personal information in the course of an actual or potential investigation into a breach of a law.
Legal Basis for Processing
In connection with Services provided to individuals outside of the European Economic Area (“EEA”), we process any personal information with consent except where otherwise permitted or required by law. For example, we may be permitted by law to collect, use or disclose personal information without consent to comply with a subpoena or court order, or to comply with the rules of court regarding the production of records. Your consent may be expressed or implied, depending on the circumstances and the sensitivity of the personal information in question.
In connection with Services provided to individuals in the EEA, we rely on one of the following legal grounds (as appropriate) to process personal information:
- To enter and perform a contract with you or to perform any steps you require from us before entering into a contract.
- To pursue our legitimate interests in establishing, managing or concluding our relationship with you.
- Where you have specifically consented to us processing your personal information.
- To comply with our legal obligations and establish, exercise or defend our legal rights.
Where personal information is processed with consent, you may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. In order to withdraw consent, You must provide notice to Us in writing.
Personal information is maintained electronically on the CTTL’s servers or those of its Service Providers. We will retain personal information for only as long as required to fulfill the identified purposes or as required by law. Personal information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by The CTTL.
Storage Outside of the United States
Your personal information may be processed by Us or Our Service Providers outside of your home jurisdiction. While outside of your home jurisdiction, personal information will be subject to the laws of the country in which it is processed, which may not be as protective as the laws of your home jurisdictions.
Links to Other Websites
Our program may contain links to other websites that may be subject to less stringent privacy standards. We do not assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. We are not responsible for how such third parties collect, use or disclose Your personal information. You should review the privacy policies of these websites before providing them with personal information.
You may request access to or correction of the personal information in our custody or control, or an account of how your personal information has been used or disclosed by Us by writing to Us (see the “Contact Us” section below). Please note that these rights are subject to certain restrictions. For example, We may not provide you with Your personal information if it contains information about other individuals, or if the information is subject to solicitor-client or litigation privilege.
If you are in the EEA you may also have the right, in specified circumstances, to object to our use of Your personal information, to request the deletion of Your personal information or restrict its use, to request a copy of the information You have provided to us to use for Your own purposes, or to lodge a complaint with the supervisory authority. If you have any questions about these rights, or you would like to exercise any of them, please contact our Privacy Officer using the contact information provided below.
We protect personal information by security safeguards appropriate to the sensitivity of the information, that are designed to protect against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.
Our methods of protection include:
- Physical measures, such as filing cabinets which are kept locked when not in use and restricted access, both to Our place of business in general and to internal offices as well;
- Organization measures, such as security access on a need to know basis; and
- Technological measures, such as the use of passwords, firewalls and encryption.
Please note that no security measures can offer absolute security and there is always a risk that personal information may be accessed or disclosed without authorization.
The Center for Transformative Teaching & Learning at St. Andrews Episcopal School
Attn: Glenn Whitman
8804 Postoak Rd
Potomac, MD 20854
Last Revised: January 19th, 2022