Client Privacy Promise

Alef Education respects its client’s and their associated end user’s privacy and is committed to protecting their personal data when using Alef Education’s products and services (together the Alef Platform). This privacy promise informs our clients and associated end users of how we collect, look after and use their personal data. For the purposes of this privacy promise, end users are considered to include school administrators, teachers, parents/guardians and students.

The following summarises our promise to clients:

• We only process personal data for Education/School purposes (including, but not limited to use relating to instruction, administration and development and improvement of products and services intended for Education/School use).
• We do not use personal data for behavioral targeting of advertising.
• We do not sell personal data.
• We follow security best practices to protect our clients and their end users’ personal data.
• We are compliant with FERPA and COPPA.
• We are also signatories of the Student Privacy Pledge. Details of the Pledge can be found here.

This promise is provided in a layered format so you can click through to the specific areas set out below:

• Contact details
• Changes to the privacy promise
• The data we collect about our clients and their end users
• If a client fails to provide personal data
• How is the personal data collected?
• Purposes for which we use personal data
• Consent
• FERPA (this provision is only applicable for clients whose end users are located in the USA)
• Disclosures of personal data
• International transfers
• Data security
• Data retention and requests for deletion
• Client access to personal data and data portability

Contact details
If you have any questions of feedback about this privacy promise, please contact privacy@alefeducation.com.

Changes to the privacy promise
We keep our privacy promise under review. This version was last updated on 15 August 2019.

We will inform our clients prior to making any changes to our privacy promise which we believe will materially impact their rights. As a client, if you object to any changes you should notify us within 14 days by email: privacy@alefeducation.com. If a client continues to use the Alef Platform after you receive notice of changes to this privacy promise, they will be deemed to have accepted the changes.

The data we collect about our clients and their end users
Personal data, or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Alef Education may collect, use, store and transfer different kinds of personal data relating to its clients and their end users which we have grouped together as follows:

• Contact Data: We take contact first name, last name, job position, address, phone number and email address of our client’s account managers, administrators and any other representatives who we correspond with. Where our client requires us to contact parents/guardians of student end users, we will also take first name, last name, address, phone number and email address of the parents/guardians provided by the client. The client is responsible for ensuring the accuracy of Contact Data that it provides to us.

• End User Account Data: We create Alef Platform user accounts in accordance with our client’s instructions. Where end user accounts are created in accordance with client instructions, we collect personally identifiable information about them including their first names, middle names, surnames, gender, usernames, email addresses, password and school enrolled at. This information is normally provided by our clients for Alef Education to enter into the Alef Platform, but it may be entered by end users themselves or populated from the end user’s account with a third party sign-in service, such as their Google account.

• Profile Data: We collect end user’s data in respect of their use of the Alef Platform. This mainly comprises of information relating to student’s enrollment, participation and progression using the Alef Platform, such as school test results (where provided by the client), diagnostic tests and survey results, Alef Platform test results, and end user interests and preferences when using the Alef Platform. This data may also comprise information that is uploaded by the end user or made available by the client on their behalf (including but not limited to their avatar, photos, drawings, files, notes, hyperlinks, and other learning records). We regularly add types of information that can be uploaded, and these are all considered Profile Data under this privacy promise.  If an end user is permitted by the client to allow us to access microphone or video recordings on their device, we may also collect video and voice recordings. Profile Data that is uploaded by a student end user may be considered a student education record as defined by FERPA.

• Communications Data: We collect messages that are sent and received in the Alef Platform by end users, and we also collect any information that an individual send to us directly through communications, such as emails or phone logs.

• Log Data: When an end user uses the Alef Platform, we receive log data such as their internet protocol (IP) address, log-in data, browser type and version, time zone setting and location, browser plug-in type and version, operating system and platform, device information and other technology on the devices used to access the Alef Platform.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from personal data but is not considered personal data in law as this data will not directly or indirectly reveal an individual’s identity. For example, we may aggregate Log Data to calculate the percentage of users accessing a specific feature of the Alef Platform, and this Aggregated Data may be shared with third parties. However, if we combine or connect Aggregated Data with personal data so that it can directly or indirectly identify an individual, we treat the combined data as personal data which will be used in accordance with this privacy promise.

We do not knowingly collect any Special Categories of Personal Data about our users (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about user health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. We will not be held responsible in circumstances where the client or end users provide data which falls under a Special Category of Personal Data and, where discovered, we may take steps to delete such data.

If a client fails to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with a client, and that client fails to provide that data when requested, we may not be able to provide the client and their end users with access to the Alef Platform.

How is the personal data collected?We use different methods to collect data from and about our clients and end users including through:

• Direct interactions. Clients and their end users may give us identity and contact details by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data provided when a client or end user:
  • Creates or instructs us to create an end user account;
  • subscribes to our service or publications;
  • requests support or maintenance services;
  • enters a competition;
  • completes forms;
  • gives us feedback or contact us;
  • uploads data onto the Alef Platform including any direct communications via the Alef Platform; or
  • responds to surveys and questionnaires.
• Automated technologies or interactions. As Client end users interact with the Alef Platform, we will automatically collect Log Data and Profile Data about end user equipment, actions and patterns. We may collect this personal data by using cookies, cache and other similar technologies.
• Third parties or publicly available sources. We may receive information about student users from our clients and their parents/guardians through providing the Alef Platform. We may also receive personal data about users from various third parties and public sources including Log Data from analytics providers such as Google.

Purposes for which we use personal data

We will only use personal data when the law allows us to. Most commonly, we will use personal data in the following circumstances:

• Where we need it to ensure secure end user authentication.
• Where we need to perform the contract we are about to enter into or have entered into with our clients.
• Where it is necessary for our legitimate interests (or those of a third party) provided that user interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

We have set out below, in a table format, a description of all the ways we use personal data of users of the Alef Platform and related services, and which of the legal bases we rely on to do so.

We will only use personal data where such use is compatible with the purposes as outlined above. However, we may process personal data without client or end user knowledge or consent, in compliance with the above rules, where this is required by law.

Consent

We require that our clients obtain all necessary consents before allowing end users to access the Alef Platform. As a client, you are responsible for checking your local laws to determine the appropriate method of consent.

FERPA (this provision is only applicable for clients whose end users are located in the USA)

Data collected by Alef Education may include personal data from education records that are subject to the Family Educational Rights and Privacy Act (FERPA).  To the extent that student Profile Data includes FERPA records, as a client you hereby designate Alef Education as a “School Official” (as defined in FERPA) under the direct control of the school with regard to the use and maintenance of the FERPA Records and Alef Education agrees to comply with FERPA.

Disclosures of personal data

We will share with our clients their associated end user’s data, and we will also make student end user data available to their registered parents/guardians (as provided by the client).

We may share personal data for the purposes set out in the table above to third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use the personal data we have obtained in the same way as set out in this privacy promise.

We may also share personal data with our service providers to help enable us to provide our products/services to our Clients and users. A list of third-party services that obtain personal data we currently use is available upon request.

We require all third parties to respect the security of personal data we share and to treat it in accordance with the law. We do not allow our third-party service providers to use personal data for their own purposes and only permit them to process your personal data for specified purposes in accordance with this privacy promise and our instructions.

We may also disclose client and end user personal data to a third party to comply with applicable laws or regulations, or a valid legal request – including to meet national security or law enforcement requirements. If we are going to release personal data in this instance, we will do our best to provide the relevant client with notice in advance by email, unless we are prohibited from doing so by law.

International transfers

The Alef Platform is hosted and operated in Europe. By default, any personal information that our clients or their end users provide us will be hosted on servers in these locations except for our clients in the United States, where the Alef Platform is hosted and operated in the United States. By using the Alef Platform, you consent to the transfer to and processing of your personal information in the applicable location.

Some of our external third party service providers are also based in jurisdictions outside of those of our clients and so their processing of personal data will involve a transfer of data outside of our client’s country. Whenever we transfer personal data out of a client’s country, we ensure a similar degree of protection is afforded to it.

Data security

We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process personal data on our instructions and they are subject to a duty of confidentiality.

However, no security measures are perfect and we cannot ensure or warrant the security of any or all of the information that is shared to us by our clients.

Data retention and requests for deletion

We will delete an end user account when instructed to do so by a client. We will also delete end user accounts following termination or expiry of a client contract. Prior to deleting an account, we will notify the client associated with the account by email and provide an opportunity to download an archive copy of Platform Data. Generally, we will delete any personal data within 60 days following expiry or deletion of an end user account. This is in order to provide customer support and prevent accidental deletion.

Where we are required to do so by law, we will retain basic information about our clients after they cease to be clients. In limited circumstances we may also retain client and end user personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you as a client.

In some circumstances we will anonymise personal data (so that it can no longer be associated with the client and/or associated end users) for analytical purposes, in which case we may use this information indefinitely without further notice to you.

Client access to personal data and data portability

We provide clients with the ability to access personal data we hold about them and their associated end users. This information can be found directly through a client account on the Alef Platform. Our clients are also able to access and correct any personal data held about them and their associated end users via the Alef Platform.