Last Modified: May 25, 2018
1. What is CommonLit?
Note about Children: As required by applicable law and our Terms of Service, children under the age of 13 in the U.S. (and a higher age if required by the applicable law in another country) may only use our Services with the express prior consent of a parent or legal guardian. If you are a Teacher or Administrator, you must obtain all necessary parental consents before allowing students to create an account or use the Services.
2. What is this policy?
Information Sharing: Remember that if you create a Profile (as defined below) or share personal information with other users on the Services, your information may be visible to others. However, student data will only be visible to their teachers, and students cannot share data with other students. Note that we do not share your Personal Information with third parties for their marketing purposes; however, we may share your Personal Information under certain limited circumstances. For more details, please review the section below entitled "Will CommonLit share any of the information it collects?"
Third party analytics providers: We work with analytics service providers and other vendors to provide us with information regarding traffic on the Services, including the pages viewed and the actions users take when visiting the Services and to provide us with information regarding the use of the Services.
CommonLit never conducts advertising or marketing activities on the Services or using Personal Information. Please review "Third Party Analytics Providers” for additional information.
Information Shared With Us
1. Registration and Other Information You Provide
The Services may collect "Personal Information" (which is information that can reasonably be used, alone or in combination with other reasonably available information, to identify or contact a specific individual). Personal Information includes, but is not limited to, student data, metadata, and user content. This may include a name, email address, username, password, or assessment results. Any information combined with Personal Information will be treated as Personal Information.
2. Your Account Page and Community Forums
Your Account Page: Teachers must create an Account that contains the teacher’s name, password, email, role, and school. Students or teachers may create student accounts which contain their names, passwords, grade level, and may contain emails. Teachers cannot view students’ Account pages; however, teachers are able to view the name, email, and grade level of each of their students. Teachers may be able to view the name and email address of other teachers at their same school, but cannot view another teacher’s Account Page.
Community Communications: The Services may provide teachers the opportunity to participate and post content that would be visible to other teachers, through interactive features and through other communication functionality ("Community Communications").
Note that anything you post to a Community Communication may be visible to others.
3. Third Party Services, Social Media Platforms, and Information Third Parties Provide About You
Third parties may provide us with information about you. For example, if you are on a third party web site, and you opt-in to receive information from us, that third party will forward information about you to us so that we may contact you as requested.
Information We Collect Automatically
Like other web sites and online services, we and our analytics providers, vendors and other third party service providers may automatically collect certain "Usage Information" whenever you access and use the Services. For example, we may collect information regarding when a user downloads resources such as pdfs or the pages a user accesses.
Usage Information may include the browser and operating system you are using, the URL that referred you to our Services (if applicable), the search terms you entered into a search engine that lead you to our Services (if applicable), all of the areas within our Services that you visit (including information about any ads you may view), and the time of day you used the Services, among other information. We may use Usage Information for a variety of purposes, including to select appropriate content to display to you and to enhance or otherwise improve the Services and our products.
In addition, we automatically collect your IP address or other unique identifier ("Device Identifier") for any computer, mobile phone or other device (any, a "Device") you may use to access the Services. A Device Identifier is a number that is automatically assigned to your Device used to access a Service, and our servers identify your Device by its Device Identifier. Some mobile service providers may also provide us or our third party service providers with information regarding the physical location of the Device used to access a Service, internet service provider (ISP), date and time of your visit, browser language, browser type, referring and exit pages and URLs, amount of time spent on particular pages, which parts of our Services you use, which links you click, search terms, operating system, traffic and related statistics, keywords, and/or other general browsing or usage data. Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as Personal Information.
Usage Information is collected via tracking technologies, including:
1. Cookies: Our Services utilize Cookies to improve your current and future experience by allowing us to understand your usage of our Services. For example, cookies help our systems recognize you if you return to our Services shortly after exiting them. Cookies are small text files stored on your computer that allow us to personalize the content of our Services. Cookies can be turned off via your browser settings if you so choose. However, if you turn your cookies off, some features of our Services may not function properly.
2. An Embedded Script: is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your computer or other device from our server or a third party service provider and is deactivated or deleted when you disconnect from the Services.
In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.
3. HTML5: We use Local Storage Objects (LSOs) such as HTML5 to store content, information and preferences. Third parties with whom we partner to provide certain features on our site use LSOs such as HTML 5 & Flash to collect and store information.
Various browsers may offer their own management tools for removing HTML5 LSOs.
How We Respond To Do Not Track Signals:
Please note that your browser setting may allow you to automatically transmit a "Do Not Track" (DNT) signal to websites and online service you visit. DNT is a privacy preference that users can set in certain web browsers to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. However, we do not recognize or respond to browser-initiated DNT signals, as the internet industry is still working to determine what DNT means, how to comply with DNT, and how to create a common approach to responding to DNT. To find out more about "Do Not Track", please visit http://www.allaboutdnt.com.
We may use information about you, including Personal Information, the information you provide in your Profile, User Content, and Usage Information to:
1. Allow you to participate in features we offer or to provide related customer service, including, without limitation, to respond to your questions, complaints or comments;
2. Tailor content, recommendations and offers we display to you, both on the Services and elsewhere online;
4. Process your registration with our Services, including verifying your e-mail address is active and valid;
5. Improve the Services and for internal business purposes, including the measurement of ad effectiveness;
6. Contact you with regard to your use of the Services and, in our discretion, changes to our policies; and
7. Permit other CommonLit users to contact you, and vice versa; and
Please note that information submitted on the Services via a "Contact Us" or other similar function may not receive a response. We will not use the information provided via these functions to contact you for marketing purposes unrelated to your request unless you agree otherwise.
CommonLit does not share your Personal Information with third parties for their marketing purposes in compliance with all applicable laws (including California Business & Professions Code section 22584 ("SOPIPA"), and California Education Code section 49073.1). CommonLit may share non-Personal Information, such as aggregate or de-identified user statistics, demographic information and Usage Information with third parties.
1. Service Providers
We will share your Personal Information with third parties to provide services to us or you in connection with the Services, but subject to confidentiality obligations which limit their use and disclosure of such information. For example, we may provide your Personal Information to companies that provide services to help us with our business activities, sending our emails, or offering customer service. If you purchase any merchandise, our billing partner will receive billing, shipping and financial information (e.g., credit card numbers) necessary to process your charges, including your postal and e-mail addresses, depending on your payment method.
2. Administrative, Legal Reasons & Academic Integrity Investigations
We may also use Device Identifiers, including IP addresses, to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies in our discretion. These disclosures may be carried out without your consent or without notice to you.
3. Business Transitions
We display personal testimonials of satisfied adult users on our Services in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us via email by clicking here.
6. How does CommonLit work with third parties?
No Third Party Advertising
CommonLit will never use any Student Data to advertise or market to students or their parents. We will not mine Student Data for any purposes other than those agreed to by the parties. Data mining or scanning of user content for the purpose of advertising or marketing to students or their parents is prohibited.
We work with analytics service providers and other vendors to provide us with information regarding traffic on the Services, including the pages viewed and the actions users take when visiting the Services and to provide us with information regarding the use of the Services.
Third Party Content, Links to Other Sites, and CommonLit Content Found Outside of the Services
Certain content provided through the Services may be hosted and served by third parties. In addition, the Services may link to third party web sites or content over which CommonLit has no control and which are governed by the privacy policies and business practices of those third parties. In addition, third-parties may have different privacy policies which apply to such third party use of your information.
Please also note that CommonLit content may be included on web pages and web sites that are not associated with us and over which we have no control. These third parties may independently collect data. CommonLit is not responsible or liable for the privacy practices or business practices of any third party.
7. What happens if I access CommonLit’s services through a mobile device?
If you use the Services through a mobile device or one of our mobile applications, you agree that CommonLit may store and use that information for security purposes (for example, for user verification or authentication and to ensure that our APIs are being used appropriately).
8. How does CommonLit protect children’s information?
Protecting the privacy of young children is especially important to CommonLit. For that reason, we created certain features designed to help protect Personal Information relating to children who are less than 13 years of age, or higher age if required by applicable law (“Child Users”).
CommonLit does not knowingly permit Child Users to use our Services without prior, express consent from a parent or legal guardian, except through agreements with schools or districts or as otherwise permitted under the Children’s Online Privacy Protection Rule (COPPA) and the Family Educational Rights and Privacy Act (FERPA). If we learn that Personal Information of a Child User has been collected on our Services without prior parental consent, then we will take appropriate steps to delete this information. If you are a parent or guardian (“Parent”) and discover that your child under the age of 13 (or a higher age if required by applicable law) has a registered account with our Services without your consent, please contact your child’s school and alert CommonLit at email@example.com and request that we delete that child’s personal information from our systems.
How does a child register and use the services?
Child Users cannot obtain a User Account without first receiving a prompt from their school. CommonLit obligates schools and teachers (or other authorized individuals) to first obtain any necessary parental consents before permitting children to register for a User Account or use the Services.
What children’s information is visible to others?
No student’s profile is made available or visible to the public through CommonLit. If a teacher utilizes certain features on a device in the classroom, other students may be able to view information that is displayed by the teacher in the classroom, but students can’t view each other’s individual student profiles.
Parents: To review your child’s User data you must request the information from your child’s teacher.
9. How does CommonLit protect and store my information?
CommonLit takes data security very seriously. CommonLit takes commercially reasonable technical, physical, and administrative security measures designed to protect the Personal Information submitted to us, both during transmission and once we receive it. Such measures vary depending on the sensitivity of the information at issue. Measures taken to protect your data include:
- We continually test CommonLit’s security practices for vulnerabilities
- We periodically review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems
- We continually develop and implement features to keep your personal information safe - for example, all traffic to and from our application is over secure, encrypted protocols (SSL/TLS).
- We ensure passwords are stored securely using encryption and salted one-way hashing
- We also operate a ‘bug bounty’ security program to encourage an active community of third party security researchers to report any security bugs to us. More information on this is available by contacting us at firstname.lastname@example.org.
- Every CommonLit employee participates in training on the importance of and methods for protecting Personal Information. Training consists of how to remain compliant with federal and state regulations (e.g . FERPA, COPPA, and SOPIPA), CommonLit policies, and general security posturing to protect student data (including techniques such as Two Factor Authentication, Drive Encryption, creating and managing strong passwords, etc).
- All CommonLit employees are trained in security practices and procedures designed to keep Your Data under strict internal controls.
- Developers peer-review code to make sure changes adhere to best practices for security.
- Administrators are knowledgeable of security practices and harden the infrastructure with necessary patches, monitor security resources for advisories and vulnerabilities, and scan the environment and application to ensure that student information remains secure.
Please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security.
How will CommonLit handle a data breach or security incident?
In the event that CommonLit becomes aware of a data breach impacting your Personal Information, we will provide notification in compliance with all applicable laws. For example, we may post a notice on our homepage (www.CommonLit.org) or elsewhere on the Service, and may send email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
CommonLit has procedures in place that are designed to stop threats that may expose personally identifiable information, restore Services to full functionality, and document and take proactive steps to ensure the incident cannot be repeated. CommonLit will also preserve necessary evidence for investigation by security professionals and law enforcement as appropriate. In the unlikely event of an unauthorized disclosure of records, CommonLit will follow its internal procedures, which articulates how to report the problem to internal and external stakeholders. The notification process includes any information that can identify which customers and students may have been impacted, the data that may have been accessed, CommonLit’s process to inform affected customers, and steps to prevent the incident from happening again as appropriate.
In the unlikely event of an unauthorized disclosure of Data, CommonLit has implemented a process for responding to incidents and notifying affected individuals and, if applicable, law enforcement personnel.
If you have any questions about security on our Services, you can email us by clicking here.
10. How can I opt-out of sharing, providing, or receiving certain information?
Providing Personal Information: You can always decline to share personal information with us, or even block all cookies. However, it’s important to remember that many of CommonLit’s features may not be accessible, or may not function properly - for example, we may not be able to remember your language preferences for you.
Email Communication: You can opt-out of receiving further communications by clicking the unsubscribe button at the bottom of an email.
11. How can I access and manage my personal information?
You may be able to review the information you provided to us on a Service and make any desired changes to the information, or to the settings for your account on that Service, by logging in to your account for that Service and editing or deleting the information.
12. What communications will I receive from CommonLit and how do I limit them?
CommonLit may send you information by email or may post notices on the CommonLit homepage (www.commonlit.org).
You may choose to stop receiving certain emails from CommonLit by using the unsubscribe button at the bottom of the CommonLit email. However, we reserve the right to send you information on our behalf and on behalf of third parties in connection with providing the Services. If you no longer want to receive information from us, you will need to close your account for that Service.
13. How do I close my account?
If you wish to close your account with one of our Services, please send your request via email by clicking here and we will remove your Personal Information and Profile, if applicable, from the active databases for the Service(s) you request. Please let us know which Service(s) you wish to close and, if applicable, send your request using an email account that you have registered with CommonLit under your name. You typically will receive a response to a request sent to this account within five business days of our receiving it. Requests to change your email preferences or unsubscribe from all emails may not be made through this email address, but rather must be submitted through one of the channels set out in the previous section.
14. How long does CommonLit keep my information?
Upon termination of your Account, CommonLit will take commercially reasonable steps to delete any Sensitive Information from its live databases in a reasonable amount of time not to exceed ninety (90) days. You understand and agree that CommonLit may continue to have Sensitive Information in archive files or similar databases. You further agree that CommonLit has no obligation to delete aggregated or de-identified information. CommonLit may retain and use aggregated and de-identified information for any purpose that is consistent with laws and regulations.
15. How will CommonLit notify me of changes to this policy?
16. What if I don’t live in the U.S.?
Consent to Transfer
The Services are operated in the United States. If you are located outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. By using the Services, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.
Important Information for Users in the European Economic Area
The following information only applies to users in the European Economic Area (EEA), provided that we are the controller of their personal information as described below.Controller
If you use the Services through your employer, school or another organization, that organization is the controller of your personal information and all questions or requests regarding your rights under European data protection legislation (including the rights described under Your rights below) or the processing of your personal information, should be directed to the organization. CommonLit is the organization’s processor and uses your personal information only as instructed by the organization.
If you do not use the Services through an organization, CommonLit is the controller of your personal information and can be reached using the contact details in “How can I contact CommonLit with questions” section.
References to “personal information” in this policy are equivalent to “personal data” governed by European data protection legislation.Legal bases for processing
We process your personal information on the following legal bases:
|Processing purpose (including sharing for such purposes as described above)||Legal basis|
|To provide the Services||Processing is necessary to provide the Services or to take steps that you request prior to requesting the Services.|
|To communicate with you about the ServicesTo send you marketing communicationsFor research and developmentTo create aggregated or anonymous data for analytics For security, compliance, fraud prevention and safetyBusiness transfers||These processing activities constitute our legitimate interests. We do not use your personal information for activities where your data protection interests override these legitimate interests (unless we have your consent or are otherwise required or permitted to by law).|
|To comply with law||Processing is necessary to comply with our legal obligations.|
|With your consent||Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated at the time consent is requested.|
Please note that we rely on legitimate interests as the basis for processing your data in the limited circumstances set out below:
- In situations where we obtain your personal data from a source other than you, we process your data on the basis of legitimate interests, until the earlier of either (a) the point at which you provide your consent; or (b) the point at which you ask us to stop processing your data on the basis of our legitimate interests;
- We will archive information about your use of our services, even after you withdraw your consent to our processing of your data. This information will only be used in very limited circumstances, such as for defending legal claims relating to contracts we have with you or a third party and retention for audit purposes relating to commercial contracts; and
- We will use information relating to your use of our services for statistical analysis and research purposes; however, we remove personally-identifying information such as name and email address before we do so.
In the event that we transfer your personal information out of the EEA to countries not deemed by the European Commission to provide an adequate level of protection for personal information, the transfer will be based on safeguards recognized by the European Commission as providing adequate protection, where required by EU data protection legislation. Please contact us to request further information on the specific mechanism used by us when transferring your personal information out of the EEA.Your rights
You may ask us to take the following actions in relation to your personal information that we hold:
Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information.
Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
Restrict. Restrict the processing of your personal information.
Object. Object to our reliance on our legitimate interests as the legal basis of our processing your personal information, where that processing adversely impacts your legal rights.
You may send us these requests by emailing us at email@example.com. We may request information from you to help us confirm your identity and process your request. Applicable law may require or permit us to reject part or all of your request. If we reject your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us at firstname.lastname@example.org or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.Retention
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.