Effective Date: April 1, 2020
AltSchool, PBC d/b/a Altitude Learning (“Altitude”) respects your concerns about privacy and values its relationship with you.
INFORMATION WE COLLECT & HOW WE USE IT
The ways that Altitude may collect your Personal Information include:
Information You Provide
You may provide certain information directly to Altitude depending on your relationship with Altitude and the purpose of your visit to the Sites.
Visitors to the Sites (including Educational Program applicants, job candidates, and others)
Information Request. If you request information about Altitude, including but not limited to information about our Educational Programs or our Services, we may ask you to provide Personal Information and details, such as your name, email address, and application information. We will use your details to send you the information you request and may use this information to communicate with you in the future about Altitude.
Newsletters and Other Communications. We may offer online or offline newsletters and other communications about Altitude, including our Educational Programs, Sites, Services, and promotions. To sign up, we ask you for Personal Information, such as your name, postal address, and email address. We may use the information to send you the communications you request and to communicate with you about Altitude.
Careers. You may search for open Altitude positions on the Sites and apply for positions by submitting your resume and other Personal Information, such as your name, contact information, and job history. We use the information you submit to evaluate your interest in employment and to contact you regarding possible employment.
Students or Parents of Students Applying to an Educational Program
Application Information: If you choose to apply to an Educational Program, you may provide Altitude with a variety of demographic and Personal Information, including but not limited to, full name, physical address, email address, username, password, phone number, birthday, gender, guardian information, prior educational records, and information regarding learning needs and medical conditions. We will use this information to provide our Educational Programs and Services.
Information Collected to Facilitate Educational Program Activities: Students in Educational Programs may create or provide a variety of information during their time as students. Such information may include, but is not limited to, media content generated by students and teachers (pictures and audio/video recordings), academic projects, written work, and assessments in connection with Educational Programs and through the use of our teaching and learning tools.
Financial Information: If you choose to register for an Educational Program, you may provide Altitude, or third parties selected by Altitude, to administer financial services, with a variety of financial information in order to apply for financial aid, pay tuition, and/or pay other fees. Such information may include name, address, and payment information, including payment card details. We and/or the third parties selected by Altitude to administer these financial services will use this information to make financial aid award determinations and/or process your payments.
Students or Parents of Students Participating In an Educational Program
Personal Information: If you are participating in an Educational Program, you may provide Altitude with a variety of student and parent demographic and Personal Information, including but not limited to, full name, physical address, email address, username, password, phone number, birth date, gender, prior educational records, information regarding learning needs and medical conditions, and guardian information (“Partner Information”). We will use this information to provide our Services.
Information Collected to Facilitate Teaching and Learning Activities: Students participating in Educational Programs may create or provide a variety of information during their time as students through the Altitude licensed teaching and learning tools. Such information may include media content generated by students and teachers (pictures and audio/video recordings), academic projects, written work, and assessments in connection with Educational Programs and through the use of our teaching and learning tools. (“ Student-Generated Content”)
Educational Program Administrators and Teachers
Registration and Enrollment Information: Educational Program administrators and teachers may provide Altitude with a variety of information regarding your student, including Student-Generated Content. We will use this information to provide our Services.
Information Collected to Facilitate Educational Program Activities: Administrators and Teachers in our Educational Programs may create or provide a variety of information while using our teaching and learning tools. Such information may include media content generated by teachers (pictures and audio/video recordings), academic projects, written work, assessments, and notes concerning students and families during Educational Program activities and through the use of our teaching and learning tools. We may provide you with the ability to share your student’s work on external social media websites or other third party websites or platforms; if you choose to share such material outside of our platform we are not responsible for any further use or disclosure of such materials by such third party websites or platforms or any users thereof.
Information We Automatically Collect
We may automatically collect information about the devices you use to interact with our Sites. The information we automatically collect may include device identifier, web browser, search terms and results, page or app views, date and time pages are viewed, language, telephone number, and browsing information collected through cookies and beacons on our Sites, and IP address. We may also automatically collect information about how you use the Sites, such as what you have searched for and viewed on the Sites. The information automatically collected may be associated with any Personal Information you have provided.
Our Purposes in Collecting and Processing the Data We Receive
Altitude may use Personal Information for purposes in which we have a legitimate interest. These may include the following purposes:
To Provide Products, Services, or Information Requested. Altitude may use Personal Information or other information about you to fulfill requests for products, Services, or information, including information about potential or future Educational Programs or Services, including:
- To manage accounts, and Educational Program applications;
- To generate reports regarding our Educational Programs to be used for internal product development, marketing and other internal business purposes;
- To build a model of student progress and learning in order to provide actionable insight;
- To serve the functions of the Sites;
- To personalize the Sites for your use;
- To personalize teaching and learning tools for individual students;
- To communicate with you about our products;
- To facilitate your interaction through our Sites with other consumers, including through social networking;
- To respond to questions, comments, and other requests;
- To provide access to and personalize certain areas, functionalities, and features of Altitude’s Educational Programs and Services; and
- To contact you to answer requests for customer support or technical support.
Administrative Purposes. Altitude may use Personal Information about you for its administrative purposes, including to:
- To verify users’ identity and accounts;
- To measure interest in Altitude’s Educational Programs and Services;
- To process applications;
- To process payment;
- To manage everyday business needs, such as administration and improvement of the Sites;
- To analyze the Sites’ performance and functioning;
- To analyze how you use the Sites and to perform other user research; and
- To develop new products.
Marketing Purposes. Solely as to information collected from visitors to www.altitudelearning.com, but not users of the teaching and learning tools, to send to parents or legal guardians (but not students) further notices, promotions, solicitations, brochures, or other marketing materials regarding our Sites, our Educational Programs or Services, and the products and services of our affiliates.
Altitude uses Web Technologies and Mobile IDs to collect information about how you use our Sites, Educational Programs and Services. Many Internet browsers allow you to block the transmission of information, such as your IP address or location information, or to block the installation of cookies. The Apple iOS and Google Android mobile operating systems also allow you to reset your Mobile IDs or to limit tracking of your Mobile IDs. You may choose to enable these options. However, enabling these options may prevent you from using many or all of the core features and functions available on our Sites.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/.
Altitude has implemented Google Analytics to collect analytics about how you use our general audience Sites (but not on the teaching and learning tools). Altitude uses the Google Analytics cookie and Google advertising cookies together for retargeting campaigns, to track site behavior, demographic information, and browser and device information, and to personalize content. You can opt-out of Google Analytics using Google’s Ads Settings, or by using the Google Analytics Opt-out Browser Add-on. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
INFORMATION WE SHARE
- We Use Vendors and Service Providers. We may share your information with third-party service providers who perform services and functions on our behalf to support our interactions with you. The types of service providers to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Educational Programs and Services. Altitude has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
- Displaying to Other Users. We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is necessary to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Altitude policies or contracts; (v) to collect amounts owed to Altitude; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary.
- Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may be required to provide your Personal Information as required by a valid legal order to provide information. Before doing so, we will endeavor to confirm that the legal process requesting your Personal Information is valid and enforceable. We may disclose your information if we reasonably believe it is necessary.
BUSINESS TRANSFERS AND CORPORATE CHANGES
We reserve the right to disclose and transfer all information related to the Sites, including Personal Information:
To a subsequent owner, co-owner or operator of one or more of our Educational Programs or Services.
In connection with a corporate merger, consolidation, or restructuring, the sale of substantially all of our stock and/or assets, or other corporate change, including, without limitation, during the course of any due diligence process.
RIGHTS OF ACCESS, RECTIFICATION, ERASURE, RESTRICTION, AND OPT-OUT
In accordance with applicable law, you may have the right to access, update, correct inaccuracies, restrict processing of or delete your Personal Information subject to certain exceptions in applicable law.
In order to stop receiving electronic communications from us, you may unsubscribe to our communications by following the unsubscribe directions included at the end of each email we send.
You may contact us via e-mail at the address provided below. Please include your full name, email address associated with your account, and a detailed description of your data request.
By enrolling a student in our Educational Programs you are directly consenting to the collection and use of Personal Information from Children who are students in a manner consistent with the Children’s Online Privacy Protection Act (“COPPA”) and, to the extent applicable, the Family Educational Rights and Privacy Act (“FERPA”), but only for the use and benefit of our Educational Programs and Services and for no other commercial purpose. You may revoke at any time your consent to allow Children to use Altitude’s products.
Upon a parent’s or a legal guardian’s request, we will provide a description of the Personal Information we collect, give parents the opportunity to review their Child's Personal Information or have such information deleted, and provide the opportunity to prevent further collection or use of their Child's Personal Information. Parents and legal guardians may contact us via email at firstname.lastname@example.org, via mail to Privacy Team / Altitude Learning / 49 Stevenson Street / San Francisco, CA 94105, or via phone 866-664-2070.
Parents or legal guardians also can request a copy of these notices and request access to their Child's Personal Information to review and/or have the information deleted by contacting email@example.com.
Collection & Use of Information from Children
The information we may collect on Children, either directly from children using the Educational Programs Services, from parents or legal guardians of applicants to our Educational Programs, from parents or legal guardians of students participating in our Educational Programs, includes:
- Full name;
- Physical address;
- Email address;
- Username and password;
- Phone number;
- Birth date;
- Guardian information;
- Prior educational records;
- Media content generated by students and teachers (pictures and audio/video recordings) during Educational Program activities; and
- Academic projects, written work, notes, and assessments by students, teachers, administrators, and parents.
In addition, we may automatically collect information about one or more devices Children use to interact with our Sites, Educational Programs and Services such as a computer, mobile phone, or tablet. The information we automatically collect may include device identifier, web browser, browsing information collected through cookies and beacons, such as IP address, and activity on the Sites, including the date and time of use. Any usage information, device identifier, or other persistent identifier we collect is used for the sole purpose of providing support for the Sites’ internal operations.
Use of Collected Information
Our tools do not enable Children to make their Personal Information publicly available. We use the information collected on Children to:
- Share students’ progress and Educational Program work with teachers and parents or legal guardians;
- Provide reports to teachers or Educational Program administrators at the class, or Educational Program level;
- Support teachers or Educational Program administrators implementing or using our Educational Programs or Services;
- Monitor the use of our products and perform such analyses as might be necessary or helpful in improving product performance, efficiency, and security; and
- Research how students use the Sites and Services and perform analysis directed at improving the educational effectiveness of our products and services.
We will not use any information collected about children under 13 to directly advertise or market to students or their parents.
Disclosure of Information from Children
Altitude may rely on third-party service providers who provide support for the internal operations of the Sites, Educational Programs and Services, such as hosting the Sites, designing and/or operating our Educational Programs, Services, tracking analytics, or performing other administrative functions. These third party service providers are held to the same obligations as Altitude with regard to information from Children, do not disclose or use information for any other purpose, and are subject to the terms of this agreement. You may contact us via the email address provided below to obtain information about our third-party service providers.
We do not provide links to external resources or chat rooms except for external resources designed for use in our Educational Programs or Services, such as links to curriculum or teaching tools. Nor do our Services contain any offensive or inappropriate content. As a result, Altitude’s products are fully compliant with the Children's Internet Protection Act.
CALIFORNIA PRIVACY RIGHTS
Pursuant to California Civil Code Section 1798.83(c)(2), Altitude does not share your Personal Information with third parties for those third parties’ direct marketing use.
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user for device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity.
Browsing history, search history, information on a user’s interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information.
Current or past job history or performance evaluations.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other personal information.
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA's scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources
- Directly and indirectly from activity on the Sites.
Use of Personal Information
We may use or disclose the personal information we collect for one or more purposes listed above under “Our Purposes in Collecting and Processing the Data We Receive”. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category J: Non-public education information.
We may disclose your personal information for a business purpose as set forth above under “INFORMATION WE SHARE”
In the preceding twelve (12) months, we have not sold any personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at 866-664-2070
- Emailing firstname.lastname@example.org
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
LINKS TO OTHER WEBSITES
HOW WE PROTECT PERSONAL INFORMATION
We maintain administrative, technical and physical safeguards to protect against loss, misuse or unauthorized access, disclosure, alteration or destruction of the information you provide when visiting or using the Sites.
HOW TO CONTACT US
AltSchool PBC d/b/a Altitude Learning
1245 Folsom Street
San Francisco, CA 94103