Privacy Policy for LightSail App

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LIGHTSAIL INC. – PRIVACY POLICY FOR LIGHTSAIL PLATFORM

LAST UPDATED: 08/21/2017

We know how important it is to understand how our users’ personal information is collected and shared, especially when that personal information belongs to children and students. We take privacy very seriously and have created this Privacy Policy (“Privacy Policy”) to explain how the personal information of our users, including children and students, is collected, used, stored and disclosed by LightSail Inc. (“LightSail” or “we” or “us”). This Privacy Policy applies to the LightSail software platform and related online services known as the LightSail® e-Reader Platform, which is a downloadable educational application and service offering for use on tablets and other devices (collectively, the “LightSail Platform”).

This Privacy Policy describes what information LightSail collects from and about users of the LightSail Platform, including children and students; how such information is used and stored; when such information may be disclosed to third parties; how users, parents and guardians can control the collection, use, accuracy and disclosure of such information; and how information is protected.

Our privacy practices comply with the United States’ Children’s Online Privacy Protection Act of 1998 (COPPA), which regulates how operators of commercial websites directed to children may collect, use and disclose personally identifiable information concerning children under the age of 13. Since the LightSail Platform is a school-based service, COPPA allows schools and school administrators to act in the stead of parents to provide consent for the collection of personal information from children. Schools should always notify parents about these activities. We also comply with other applicable data privacy laws in the United States. Schools and school districts must comply with the Family Educational Rights and Privacy Act (FERPA) when providing student information to LightSail from students’ education records. FERPA gives parents certain rights with respect to a school’s use and disclosure of their children’s education records. LightSail works with schools and school districts in order to provide its services in a manner that is consistent with FERPA. For more information on parental rights with respect to a child’s educational record under FERPA, please visit the FERPA site. In all circumstances, younger users should always check with their parents or guardians before entering information on any website, mobile or tablet-based application, and we encourage families to discuss their household guidelines regarding the online sharing of personal information.

I. INFORMATION COLLECTION AND USE.

 We request or collect user information in a variety of ways. We request — and schools or school districts provide — certain student-record information about students and certain information about teachers to enable such students and teachers to use the LightSail Platform. Teachers and students also provide information to us during the course of their use of the LightSail Platform voluntarily, either unsolicited or sometimes after a request within the LightSail Platform. In addition, certain information is collected automatically through technological capabilities within the LightSail Platform. All of these are described in more detail below. In all cases, we only collect and ask for the information that is reasonably necessary for students and teachers to properly and most efficiently and effectively use the LightSail Platform and for LightSail to enhance and maintain the LightSail Platform.

A. Information Provided by Schools:  Schools and school districts, through their representatives, provide us with information from school records that we need for students and teachers to use the LightSail Platform. The personal information provided by schools or districts may include:

 

  • first and last name;
  • gender;
  • date of birth;
  • ethnicity;
  • reading level;
  • user name and password;
  • a picture or image of the user;
  • an OSIS number or other student identification number; and
  • email addresses of students and their parents or guardians. 
  • We also may ask teachers, schools, administrators and school districts to provide (and then we collect) their names, addresses, email addresses, phone numbers and billing addresses.

B. Information Provided by Users: We collect information voluntarily provided by students and teachers via the LightSail Platform, whether unsolicited or in response to a request from LightSail within the LightSail Platform. Such information includes:

  • users’ activity on the LightSail Platform, including the content, answers and submissions provided in connection with the substantive use of the LightSail Platform;
  • written responses to assessments, tests, prompts and questions from teachers;
  • the books that a student reads and the types of books a student has expressed interest in;
  • the amount of time a user spends reading and otherwise using the service and other performance related information;
  • the number of pages read;
  • a user’s book annotations; and
  • communications with other users or teachers.

The LightSail Platform also offers messaging and/or chat features that permit LightSail, teachers and student users of the LightSail Platform to communicate and interact with each other, and LightSail also collects the content of these communications. Because of the foregoing nature of the voluntary submission of information by students and teachers within the LightSail Platform, for example in open-ended responses to assessments or via communication between teachers and students, it is possible that certain personal information of a student or teacher is voluntarily shared or disclosed at such times and then collected by LightSail.

C. Computer Information Collected by Us:  When users use the LightSail Platform, we may automatically collect certain information from their portable devices and tablets, such as the type of computer operating system they are using (e.g., Mac OS), the user’s IP address, device ID and/or UDID, users’ activity on the LightSail Platform, including the areas and functionality used, the amount of time a user spends reading and otherwise using the service and the number of pages read (collectively “Computer Information”). We may use certain technologies to obtain such Computer Information (collectively referred to as “Tracking Technologies”). The LightSail Platform and/or third parties on behalf of LightSail may use Tracking Technologies to collect Computer Information automatically during use of the LightSail Platform. These Tracking Technologies collect information regarding the individual use of the LightSail Platform such as visits to specific parts of the LightSail Platform and use of features and preferences, as set forth above. They may also collect user IP address or some other identifier unique to the device used to access the service (“Identifier”). An Identifier may be automatically assigned to any device used to access the LightSail Platform.

By using the LightSail Platform, users acknowledge, understand and hereby agree to LightSail collecting Computer Information and tracking activities and use of the LightSail Platform through Tracking Technologies and Identifiers, subject to the terms of this Privacy Policy.

D. Other Data Collection We allow users to submit search query information to search for certain information on the LightSail Platform but we do not track such searches. We also collect information voluntarily provided to us by users when they contact us with questions and comments within the LightSail Platform, such as to report a bug.

II. USE OF PERSONAL INFORMATION.

LightSail uses the personal information it collects from students and other users in connection with the LightSail Platform and otherwise only to support the educational purposes authorized by the schools and school districts that engage LightSail to provide the LightSail Platform, and for no other commercial purpose. LightSail does not use (or permit others to use) personal information to engage in targeted advertising, nor does LightSail use (or permit others to use) personal information to create a profile about students other than in connection with providing the LightSail Platform and for authorized educational purposes.

The personal information we collect is used as follows:

  • to create and maintain user accounts and to enable users to use the LightSail Platform and take advantage of the service offerings;
  • to understand students’ performance, including in relationship to others and to provide analysis and insight about student performance;
  • to respond to comments, questions and requests for services and information;
  • to develop and manage activities and track user progress;
  • to allow for user interactions;
  • to support the internal operations of the LightSail Platform;
  • to analyze, enhance, improve and customize the services and content users have access to when they use the LightSail Platform;
  • to prevent potentially prohibited activities;
  • to provide customer service, and send users information about the LightSail Platform; and
  • for any other purposes disclosed at the time we collect user information or pursuant to specific user consent, all as related to the use of the LightSail Platform.

Specifically with respect to Computer Information, we use it as follows:

  • to help tailor our services and content;
  • to enable the internal functioning of the LightSail Platform;
  • to understand usage, make assessments and improve or customize the content, offerings or services on the LightSail Platform;
  • to personalize user experience (for example, to recognize users by name when using the LightSail Platform);
  • to track messages originating from the LightSail Platform;
  • to save settings; and
  • to maintain and administer the LightSail Platform. 

III. DISCLOSURE TO THIRD PARTIES.

  1. Personal Information. We may disclose personal information to third parties only for the limited purposes described below. We also share student information with a student’s particular teachers, schools and administrators to assist such personnel in educating students and in using the LightSail Platform effectively and properly. Most of the personal information we collect about students comes from those same teachers, administrators, schools and school districts. 
    1. Law Enforcement and Safety. Users acknowledge, consent, and agree to the extent legally permissible in their jurisdiction to allow us to access, preserve, and/or disclose the information we collect and/or content or information users provide to us (including information posted in messages, chats, on bulletin boards or other internal communication systems) to a law enforcement agency or other third parties if required to do so by law or with a good faith belief that such access, preservation, or disclosure is reasonably necessary to: (a) comply with legal process; (b) respond to claims that any content you post violates the rights of third parties; or (c) protect the rights, property, or personal safety of the owners of the LightSail Platform, a third party or the general public.  We also may disclose user information to applicable third parties, if legally permissible, whenever we believe disclosure is necessary to limit our legal liability or to protect or defend our rights or property.
    2. LightSail Contractors. Certain information collected by LightSail may be transferred, disclosed or shared with third parties engaged by us to handle and deliver certain activities related to the LightSail Platform and its educational purpose, such as substantive activities within the service, order fulfillment, and to perform other technical and processing functions, such as maintaining data integrity, programming operations, user services or technology services.  For example, we may share a student’s OSIS number, certain reading test results and reading levels with third parties who help assess and track a student’s reading levels and reading progress. We may shares OSIS numbers, dates of birth and certain device IDs with third parties who provide services and products to our users for use within the LightSail Platform as part of its educational purpose, such as the provision of e-books. We may provide these third parties information collected as needed to perform their functions, but they are prohibited from using any personally identifiable information for any other purposes, and they may not disclose any personal information and must maintain reasonable security procedures and practices to keep such information secure.  Some of these third parties may request additional information from users directly, outside the user’s use of the LightSail Platform, but related to the provision of materials for use within the LightSail Platform.  For example, teachers may purchase e-books directly from third-party e-book providers (not through the LightSail Platform), but those e-books are meant for use on the LightSail Platform. Before providing additional information to such other or any third parties outside the LightSail Platform, we encourage visitors to review their privacy policies and information collection practices.
    3. Business Transfer.   In the event that assets of LightSail are transferred or sold to another entity as a result of, for example, a corporate sale, merger, consolidation, asset sale, or in the unlikely event of bankruptcy, information collected in connection with the LightSail Platform may be transferred to the acquiring company, provided the acquirer is also bound by the same privacy laws and requirements as are applicable to LightSail with respect to users’ personal information and agrees to be in compliance with such laws and requirements.
    4. With Your Consent. We will not disclose any user’s personally identifiable information to any third party for such party’s use in direct marketing to such user. Users do not need to take any action to ensure the foregoing. We may however disclose user information pursuant to user’s active consent.
  2. De-identified Information. We may create, use and disclose de-identified or anonymized data for our own purposes, however, we will not use any de-identified data for behaviorally targeted advertising or to create profiles of users for non-educational purposes.

IV. INTERNATIONAL USE OF LIGHTSAIL PLATFORM.

The LightSail Platform is currently designed for and targeted to U.S. users and is governed by and operated in accordance with the laws of the U.S. If users from countries other than the U.S. access the LightSail Platform, we make no representation that the LightSail Platform is operated in accordance with the laws or regulations of, or governed by, other nations. Continued use of the LightSail Platform indicates your consent and agreement to the collection, use, disclosure, management and storage of information as described in this Privacy Policy.

In addition, the user understands and agrees that: (1) personal information may be transferred to and stored on servers located outside user’s resident jurisdiction; (2) to the extent user is a resident of a country other than the United States, user consents to the transfer of such data to the United States for processing in accordance with this Privacy Policy and (3) the Privacy Policy and the collection of information pursuant to the Privacy Policy shall be governed by and construed in accordance with the laws of the United States, without giving effect to any principles of conflicts of law.

V. SECURITY, STORAGE AND RETENTION OF INFORMATION.

LightSail uses Amazon Web Services to house, store, and secure its data. In so doing, LightSail maintains reasonable technical and organizational procedures and policies to help protect the information collected in an effort to prevent loss, misuse and unauthorized access, disclosure, alteration and destruction, including limiting the number of people who have physical access to our database servers and use of electronic security systems and password protections that guard against unauthorized access. We limit access to user’s information to employees and contractors who are authorized for the proper handling of such information, and any employee found violating our standards of security and confidentiality will be subject to our disciplinary processes. We also take reasonable steps to help make sure our third-party contractors protect the security of your personal information. However, as with most Internet sites and services, it is possible that third parties may unlawfully access such personal information through a number of means despite our efforts, so please take note that no method of transmission or method of electronic storage is 100% secure. Therefore, although we take security very seriously and work very hard on behalf of student privacy, we cannot guarantee the security of all student information.

Information collected at the LightSail Platform will not be stored for longer than is necessary for the purposes described in this Privacy Policy, or to otherwise meet applicable legal requirements.

VI. ACCESSING AND CORRECTING INFORMATION.

  1. Reviewing, Editing and Deleting User Information and Parental Access. It is the schools’, districts’ and users’ responsibility to provide complete and accurate information via the LightSail Platform and to keep such information up to date. We are not responsible for any problem or liability arising from the failure to do so. However, a user or such user’s teacher, parent or guardian has the right to access, update and correct factual inaccuracies in personally identifiable information that we collect for use on the LightSail Platform, subject to certain exceptions.  Teachers and school administrators may log into their accounts to do so, and teachers, parents or guardians may e-mail us at privacy@lightsailed.com to update or correct any information. 

In the U.S., parents and guardians of children under the age of 13 have the right, upon request, to receive a description of the types of personal information collected from their child, to review the information collected from their child, to withdraw their consent to the further collection and use of such information or to direct the deletion of such information.   Parents or guardians may do any of the foregoing by contacting us at privacy@lightsailed.com. In addition, parents and guardians of children under the age of 13 have the right to consent to the collection and use of their child’s personal information without consenting to the disclosure of that information to certain third parties. However, in this particular instance, parents should know that the proper and effective use of the LightSail Platform may not be possible without sharing certain personal information with those third-party contractors who help provide the services via the LightSail Platform, as set forth above.

Students and parents of students may also contact their teachers and schools to review, modify or delete personal information about a student.

In all cases, to help protect user privacy and the security of personally identifiable information, we will take reasonable steps to verify a user’s identity before granting access, changes or deletion of personal information.

  1. Consent. Except as otherwise provided herein, use of the LightSail Platform means that the user has consented to the terms of this Privacy Policy. If a user does not consent to the terms of this Privacy Policy, please do not use the LightSail Platform.

VII.  LINKS TO THIRD PARTIES.

The LightSail Platform may or may not contain links to other sites. If so, these other websites are governed by their own privacy policies or information collection practices, which may be substantially different from ours. We encourage visitors to other websites to review the privacy policies and information collection practices of those websites.

VIII.  INTERPRETATION.

This document is the sole statement of the LightSail Platform Privacy Policy and no summary, restatement or other version thereof, or other privacy statement or policy, in any form, including, without limitation, machine-generated, is valid. In interpreting this Agreement, the English version governs the interpretation and meaning of the obligation set forth herein. To the extent there is an ambiguity or conflict with the Privacy Policy in other languages, the Privacy Policy in English governs.

IX. CONTACT US

If you have any other questions about our information handling practices, including our practices with respect to children’s personal information, please contact us at:

LIGHTSAIL INC., 159 West 25th Street, Floor 4, New York, NY 10001

Or email us at: privacy@lightsailed.com

Or call this number: 866.876.7323

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