Effective as of Aug 6, 2021
Disclose (Disclosure) means any act that makes Personal Information available or accessible to a third party, either by physically transferring the Personal Information to the recipient or by allowing the recipient to view or access the Personal Information remotely.
Personal information means any information that can be used to identify, locate or contact an individual. Personal Information includes identifying information (such as a person's name or email address). It also includes other data elements, such as Internet Protocol (IP) addresses, Adapta Globally Unique Identifiers or GUIDs, device identifiers or school-issued IDs, if such data can be associated with an individual and content captured and recorded when taking a course, such as for a languages course. If we can tie the data to an individual (either by itself or using other information that we have), then the data is PI.
Adapta Student means an individual studying in any preschool, elementary, middle or secondary school and using an Adapta Education platform.
Adapta Student Data means (with respect to Adapta Students) any Personal Information that, alone or in combination, identifies an individual student or the student's parent or family, and that is collected, maintained, generated, or inferred by a public education entity, either directly or through a school service, or by a school service contract provider or school service on-demand provider. Adapta Student Data encompasses all Personal Information pertaining to Adapta Students (including all persistent identifiers, geolocation data, images and photographs) collected via rosters, directly from Adapta Students or from other sources.
The following rules are designed to enable Adapta to comply with FERPA, COPPA and state student privacy laws.
Collection, Use, and Disclosure
Adapta shall not collect, maintain, use or disclose Adapta Student Data beyond that needed for authorized educational/school purposes, or as appropriately authorized by a school, parent, or student.
Adapta shall protect Adapta Student Data using appropriate security measures, including encryption, and disclosing the information only to third parties that are capable of and contractually obligated to maintaining its confidentiality and security.
Adapta shall not retain Adapta Student Data longer than needed to fulfill the educational purposes for which it was collected. Adapta will also delete Adapta Student Data upon request of the applicable Client (school or school district) or (if feasible) the applicable parent or Student.
De-Identified and Aggregated Data
Adapta shall not use any Adapta Student Data for product development, testing or innovation unless the Adapta Student Data has been de-identified (anonymized) and aggregated. (Adapta may use de-identified data for product development, research and other purposes. This data will have all direct and indirect identifiers removed, including name, student ID numbers, GUIDs, dates of birth, demographic information location data and school ID. Adapta shall not attempt to re-identify any de-identified data and shall prohibit any recipients of the de-identified data from trying to re-identify individuals.)
Children Under 13 years old
To the extent that Adapta’s websites and online services (including mobile apps) are directed towards (or are actually used by) children under 13 years old, Adapta must either obtain verifiable parental consent from the Student’s parent or be authorized to collect the Personal Information by the Student’s school.
Services provided to a School
To the extent that Adapta is collecting Personal Information from children under 13 in connection with website and mobile apps provided to a school, Adapta may rely on the school to authorize the collection of the Personal Information. In this case:
(b) Adapta shall obtain consent from the school prior to collecting Personal Information from the children.
(c) The Personal Information may only be used for educational purposes that benefit the school and not for any commercial purposes;
(d) To the extent feasible, Adapta shall provide parents with access to their child's Personal Information to review and/or have the information deleted;
(e) To the extent feasible, Adapta shall give parents the opportunity to prevent further use or online collection of a child's Personal Information; and
(f) The Personal Information shall only be retained for only as long as is necessary to fulfill the educational purpose for which it was collected.