OER PROJECT PRIVACY POLICY

Effective Date: September 3, 2020

ABOUT OER PROJECT

The OER Project is operated as a non-commercial venture by Big History Project, LLC (referred to herein as “OER Project,” “we,” “us,” or “our”) for the purpose of offering a family of free, online courses to teachers and their students on behalf of their associated Schools. Our course materials, including the Big History Project and World History Project social studies courses, and related teaching resources are accessible to participating Schools at http://www.oerproject.com, and any mobile applications, other channels or mobile feature that we operate (the “Site”). All course material, teaching resources and supporting services available on the Site (the “Services”) are designed to be used by participating schools, school districts, and related entities and organizations, including but not limited to school personnel, such as classroom teachers or administrators, who access the Services on behalf of their school (each a “School”).

This Privacy Policy describes the privacy practices we follow when collecting and using information about you, a visitor or registered user (“you” or “your”) on the Site. We ask that you please read it carefully before using or registering for an account on the Site. When you access or register for an account on the Site, certain information, including personal information, may be collected, transferred, processed, stored, and in certain circumstances, shared with others as described in this Privacy Policy. We understand that online privacy is important and are committed to protecting, and to helping Schools protect, the privacy of their Student Users.

Capitalized terms used but not defined in this Privacy Policy have the definitions provided in the Terms of Use. Parts of the Terms of Use affect this Privacy Policy, so unless you have already done so, please be sure that you also review the Terms of Use prior to beginning your use of the Site, Services or instructing others to use them.

IF YOU DO NOT AGREE WITH THE PRIVACY PRACTICES STATED IN THIS PRIVACY POLICY, PLEASE DO NOT USE, OR REGISTER FOR AN ACCOUNT ON, THE SITE. IF YOU CHOOSE TO REGISTER FOR AN ACCOUNT ON, OR DIRECT OTHERS TO USE THIS SITE, YOU EXPRESSLY CONSENT TO THE INFORMATION HANDLING PRACTICES DESCRIBED IN THIS PRIVACY POLICY ON BEHALF OF YOURSELF AND ANYONE USING THE SITE AT YOUR DIRECTION.

IF YOU ARE A SCHOOL OR TEACHER USER, PLEASE NOTE THAT ALL USE OF THE SITE OR THE SERVICES BY YOUR STUDENT USERS MUST BE FOR SCHOOL PURPOSES ONLY AND AS DIRECTED BY YOU. BEFORE INVITING STUDENTS TO REGISTER FOR ACCOUNTS ON THE SITE, PLEASE BE AWARE THAT YOU ARE RESPONSIBLE FOR PROVIDING ANY NECESSARY NOTICES TO PARENTS AND OBTAINING AND PROVIDING TO US ALL REQUIRED CONSENTS TO OUR COLLECTION AND USE OF INFORMATION PERTAINING TO STUDENT USERS, INCLUDING STUDENT USERS WHO ARE UNDER THE AGE OF 13.

GUIDING PRINCIPLES REGARDING STUDENT PRIVACY

The practices stated in this Privacy Policy are guided by the following principles:

1. Our commitment to creating a safe and secure online learning experience for student learners.

2. Our commitment to using the personal information of students only to enable and enhance the Services we provide for, and on behalf of, Schools, rather than using that information to gain a commercial profit.

3. Our commitment to giving Schools access and control over the information that their Student Users provide to us.

4. Our commitment to creating extra precautions to protect the privacy of students, including those under the age of 13, such as limiting our collection of their personal information and restricting their ability to share personal information with others on the Site.

5. Our commitment to offering world-class educational content on the Site that is both free of charge to all users and free of commercial content, such as third-party advertising.

TABLE OF CONTENTS

1. Our Collection and Use of Information.

2. Children’s Privacy.

3. Your Choices About Your Information.

4. Our Handling of Educational Records for Schools.

5. How We Store and Protect Your Information.

6. Our Information Sharing Practices.

7. Links to Other Websites.

8. California Residents.

9. International Visitors.

10. Changes to this Privacy Policy.

11. Privacy Questions.

1. OUR COLLECTION AND USE OF INFORMATION

We collect the following information, including personal information, from users of the Site, which is used to enable, support and improve the Services we provide for and on behalf of Schools.

Schools: When a School’s teacher, administrator or other personnel (“School Personnel”) communicates an interest in using the Services as part of the School’s educational curriculum for its students, we gather information about the School, such as its name, school district, the city and state in which it is located, the name and email address of the School Personnel contacting us on the School’s behalf, and any message content, or other information provided about how the School intends to use our Services to educate its students. We collect and retain information about each School’s use of the Site and Services, such as the content of any messages, feedback or information posted by Teacher Users (defined below). We use this information to help us operate, manage, and improve the Site and Services. We may combine the information we collect from Schools and their associated School Personnel, including Teacher Users, with demographic data available from sources such as greatschools.org. This information is used to facilitate academic research pertaining to the Site and Services.

Teacher Users: Teacher User accounts are the primary means by which Schools define the scope of, and direct our provision of, the Services to their Student Users on their behalf. These accounts are created and managed by classroom teachers at participating Schools acting on behalf of, and as directed by, their affiliated School (“Teacher Users”) and are used to set up and manage virtual classroom learning environments for its Student Users. At registration, Teacher Users are asked to supply information about their School (to the extent not yet received), the grade level and subjects they teach, and other information we require to establish and operate Teacher User accounts, such as school email address, account name, and user-generated password. Once registered, Teacher Users can begin setting up and managing virtual classrooms as directed by their School, including directly supporting the registration of students assigned to them by their School. We collect and retain information regarding the School’s content selections and use specifications for each virtual classroom in order to tailor the educational experience we provide to Student Users on behalf of each School. As the School’s Teacher Users manage their virtual classrooms on the Site, we gather information about their ongoing use of the Site and Services for the purpose of providing, maintaining, and promoting the Site and Services, including the selected features, functionality and content chosen for each virtual classroom. We may use the information we collect from Schools and Teacher Users to communicate with them and occasionally to request feedback and survey responses, all of which is optional. We collect and use the feedback we receive from Teacher Users, as well as classroom usage data, to continually analyze and improve our Services and the functionality of the Site.

Student Users: Students cannot create accounts on the Site or otherwise use the Services without being authorized to do so by a School. We use unique classroom codes, provided to Teacher Users who then share them with their Student Users, to accomplish this purpose. We collect Student Data (defined below) only as requested or provided by each student’s School solely for the purpose of performing educational services on behalf of each student’s School and to tailor Student Users’ learning experience to the content, features and functionality specified by their respective School. “Student Data” is information provided to us by a Student User or collected from that Student Users’ School about such Student User, and may include personally identifiable information. For example, at registration, we collect limited information from Student Users to establish and operate their Student User account, such as a username, email address and user-generated password in addition to a valid unique classroom code authorizing their use of the Site and Services by their School, and linking their account to that of a Teacher User employed by their School. Once registered, Student Users may only gain access to the educational content and features pre-selected for them by their School. Depending on the Site or Services features selected by the School, a School may direct us to receive Student Data on its behalf through integrated learning applications required by the School. For the purpose of supporting educational research regarding our Services, we may ask Schools (at their option) to allow their students to participate in surveys regarding their learning experience on the Site or Services, which may be used by us to improve the educational value we offer Student Users on behalf of their Schools. Any survey responses we receive from consenting Schools are received in an anonymous fashion, and without any link or connection to individual students.

Student Users can log in with their student user accounts to access lesson content but will not be able access assignments once the student is not part of a participating classroom.

Automatically Collected Usage and Device Information: Like most other websites, we and our third-party partners (See the “Third-Party Analytics Tools” section below) automatically collect technical usage and related data when our account users access the Site, read our emails, or otherwise engage with us and our Services. This information is collected through tracking technologies like cookies, pixels, web beacons and similar technologies, which identify data about your device or its software, such as your IP address, browser type, Internet Service Provider (ISP), device type, operating system, platform type and other such information. If you access our Site or the Services from a mobile device, we may collect unique identification numbers associated with your device, mobile carrier, device type, model and manufacturer, mobile device operating system brand and model. We also collect data about the way you use our Site and Services, for example, the pages you visit, the links you click, and how frequently you visit the Site. We use the information we gather through these technologies to improve our ability to diagnose and fix technical problems, continuously improve the Services, to provide a better user experience to you, and in the case of Schools and Teacher Users promote the Site and Services. For example, it allows us to ‘remember’ information so a user will not have to re-enter it during subsequent visits and to keep track of your course progress so that the page content displayed upon your return remains consistent with your progression through the material selected by the Teacher User associated with your account. Data associated with Student User use of the Site and Services is never used by us or shared with others for targeted advertising purposes.

Third-Party Analytics Tools: We collect analytics data using third-party analytics tools such as Adobe Analytics and Google Analytics, to help us measure traffic and usage trends on the site. You can learn more about Adobe’s privacy practices at https://www.adobe.com/in/privacy/policy.html and view its currently available opt-out options at https://www.adobe.com/in/privacy/opt-out.html. You can learn more about Google’s privacy practices at https://policies.google.com/privacy?hl=en and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.

Limits On Third-Party Tracking; Do Not Track Signals: We DO NOT use Student Data for targeted advertising. However, the data that we receive through pixels and other tracking technologies allows us to effectively promote the Site and Services to various populations of teachers, and to optimize external advertisements about the Site and Services that appear on third-party websites, which are directed at teachers. Although we do our best to honor the privacy preferences of our users, we are not able to respond to ‘Do Not Track’ signals from your browser at this time.

Information We DO NOT Collect: We do not allow Student Users to add photos or other content to customize their user profiles and have safeguards in place to prevent Student Users from sharing or posting information on the Site or Services in a way that would be visible to anyone besides the Teacher User with whom such Student’s account is associated. We do not seek or collect highly sensitive information, like health or biomedical information from our users. We do not seek or have access to sensitive information used for identification purposes, such as social security numbers. While we may gather demographic information in the aggregate with respect to individual Schools or School Districts, we do not seek nor do we collect information on an individual basis. Similarly, we do not seek or collect free or reduced lunch status with respect to individual Student Users. We do not operate the Services or the Site with the goal of making a profit. We do not collect or store payment information of any kind from our users or make any commercial use whatsoever of the information we collect from or about our users, including Student Users.

See “How We Share Your Information” below for more information on the limited ways in which we share School and Student Data. See “Children’s Privacy” below for more information on how we collect and use the personal information of children under 13.

2. CHILDREN’S PRIVACY

Protecting the privacy of Student Users who are under the age of 13 (a “Child” or “Children”) is especially important to us. For that reason, OER Project strictly limits the registration of Student Users to only those students who are directed to register for an account on the Site by their associated School. We use unique classroom codes given to students by a currently registered Teacher User from their School to accomplish this purpose. When Schools require Children to register for Student User accounts on the Site for School purposes, we require them to provide any required notice to parents of the School’s use of third party service providers like us, and to obtain and provide to us consent and authorization for our limited collection of Student Data relating to its Student Users who are Children, as permitted by the Children’s Online Privacy Protection Act (“COPPA”).

We consider all Student Data (including Student Data relating to Children) to be confidential and do not use such data for any purpose other than to provide educational services to Student Users on behalf of their associated Schools. Our collection, use, and disclosure of Student Data is governed by this Privacy Policy, and/or any other agreement we may have with a School or School District, by the provisions of the Family Educational Rights and Privacy Act (FERPA), the Children’s Online Privacy Protection Act (COPPA), and certain applicable state laws concerning to the collection of Student Data. We do not knowingly collect any information from Children unless and until a School provides its consent for us to do so for School purposes and on its behalf. Please contact us at help@oerproject.com if you believe we have inadvertently collected personal information of a Child without first receiving proper consent so that we may delete such data as soon as possible. If you are a Student User, or a parent of a Student User, please contact your School if you have questions about the School’s use of educational service providers like us.

3. YOUR CHOICES ABOUT YOUR INFORMATION

Account Information and Settings: Schools may update account information and modify the Services available to Student Users, through their participating Teacher Users, by signing into the pertinent Teacher User account(s). Schools and Teacher Users can opt-out of receiving promotional emails from us by clicking on the “unsubscribe” feature at the bottom of each email. (Student Users do not receive promotional emails.) Please note that all users receive Service-related messaging, which are required to operate their respective user accounts and related Services, which cannot be opted out of without deleting the user account.

You May Decline Optional Requests: We may request that Schools provide or consent to our collection of additional information that is optional for use of the Services, such as Student User or Teacher User educational surveys about the Site and Services. Schools are free to decline these requests.

Optional Forums: We may, from time-to-time, make available to Schools, through their Teacher Users, optional community forums. While community forums on the Site and Services are designed to enhance collaboration among participating Teacher Users, Schools and their Teacher Users are free to choose not to engage in the sharing or posting of information through such forums. Technical safeguards exist to prevent Student User accounts from participating in community forums.

Teacher User Account Information: Schools and Teacher Users may update, correct, or delete their associated Teacher User account information. Most changes can be made on the Teacher User account settings page. Teacher Users can also go to their classroom’s “Manage Classroom” tab to update most common settings or to access a Student User’s login information, for instance if they need to reset the password of any Student User in their classroom.

Access to Student Data: If you have any questions about reviewing, modifying, or deleting Student Data, please contact your School directly. The School may then direct us to delete the pertinent Student User account or Student Data. All requests to delete Student User accounts or specific Student Data will be promptly addressed in accordance with this Privacy Policy, the Terms, any contractual agreement we may have with such School or related School District, and pursuant to applicable law.

Requests from Students: We ask that Student Users direct all questions and concerns regarding their account or the Services to their associated Teacher User, who will assist them on behalf of their School. If a Student User contacts us with a question about their account or our Services, we will forward the request on to their associated Teacher User and/or School.

4. OUR HANDLING OF EDUCATIONAL RECORDS FOR SCHOOLS

Our Site and Services are designed to be used by Schools, as part of the Schools’ educational curriculum. Information related to a participating School’s Student Users, including Student Data and information collected by us during the provision of our Services and the Site, may include “educational records” as that term is defined under the Family Educational Rights and Privacy Act, otherwise known as “FERPA” (“Educational Records”).

To help Schools meet their obligations to protect Educational Records we:

  • Collect, maintain, use and share Educational Records only for an authorized purpose as described in this Privacy Policy and as directed by the School.
  • Do not disclose any Educational Records for targeted advertising purposes.
  • Do not build a personal profile of Student Users other than in furtherance of a School’s educational purposes and as authorized by a School.
  • Maintain a comprehensive data security program designed to protect the Educational Records we may encounter in connection with our provisions of the Services to Schools.
  • Clearly and transparently disclose our data policies and practices to our users.
  • Will never sell Educational Records. We may transfer Educational Records to an affiliated or separate legal entity as part of a corporate merger or reorganization, in which case we would require the new owner to continue to honor the terms provided in our Privacy Policy or provide notice to Schools with an opportunity for them to opt-out of such transfer by deleting Educational Records associated with its Student Users before the transfer occurs.
  • Will not make any material changes to our Privacy Policy that relate to the collection or use of Educational Records without first giving notice to a School. We will, at all times, act in accordance with any separate agreement we may have with a School or School District as such agreement relates to Educational Records.

How we share and disclose Educational Records: We share Student User Educational Records with such Student User’s associated Teacher User or School and any third-party applications the School specifically designates for the purpose of monitoring a Student User’s progress and activity on the Site and Services, as well as to evaluate the effectiveness of the School’s use of the Site and Services.

How we retain and delete Educational Records: We will not knowingly retain Educational Records beyond the time required to provide Services to a School as requested by such School.

Each School is responsible for managing any applicable Educational Records. If a School no longer needs specific Educational Records for an educational purpose it must submit a deletion request to us. Schools should contact us at help@oerproject.com to request such deletion.

Questions about Educational Records: If you have questions about specific practices relating to Educational Records, please direct your questions to your Teacher User and/or School.

5. HOW WE STORE AND PROTECT YOUR INFORMATION

How Long We Keep User Information: Except for Student Data, including Educational Records, which is retained in accordance with the preceding sections of this Privacy Policy, we may retain or dispose of any information we collect, at our discretion and without notice, subject to applicable law and any written agreement we may have with your School. We may maintain anonymized or aggregated data, including usage data, for analytics purposes. If you have any questions about data retention or deletion, please contact us at help@oerproject.com.

Keeping Information Safe: We use certain physical, managerial, and technical safeguards designed to preserve the security of the personal and other information we maintain in connection with your use of the Site and Services. For example, access to your Student Data is limited (through user/password credentials and two-factor authentication) to those employees who require it to perform their job functions. When you enter personally identifiable information, we encrypt the transmission of that information using secure socket layer technology (SSL) or similar technologies. Other security safeguards include, but are not limited to, data encryption, firewalls, and physical access controls to our buildings and files. While these measures are helpful to safeguard your personal information after we receive it, no transmission of data over the internet can be guaranteed to be 100% secure.

Unauthorized Disclosure: If there is any disclosure or access to any personally identifiable student information or Student Data by an unauthorized party, we will promptly notify the affected School(s) and will use reasonable efforts to cooperate with their investigation of the incident. If there is any disclosure or access to any personally identifiable information of Teacher Users by an unauthorized party, we will promptly notify the affected Teacher Users as required under applicable data breach statues and otherwise respond in accordance with those statutory requirements.

6. OUR INFORMATION SHARING PRACTICES

No Sharing for Commercial Purposes: As a non-commercial venture, OER Project does not seek to profit in any way from your use of the Site or Services, or by sharing your information with others. We do not sell or rent Student Data with anyone for marketing purposes. The limited instances in which we share user information, including any personal information, are for the purposes of providing, improving, and promoting the Site and Services as described herein.

Sharing of Student Data with Teachers: An essential function of the Site and Services is to permit Schools, through their Teacher User accounts, to access and oversee information submitted by, or gathered relating to, their associated Student Users. Accordingly, we disclose personally identifiable information collected from Student Users to their respective Teacher Users and Schools in connection with their use of virtual classrooms via the Services on the Site, which is a central feature of the Services. This allows Teacher Users to receive any Student User-submitted coursework, monitor course progress, and help their respective Student Users access and use the Site and Services, including to reset forgotten passwords. We otherwise restrict sharing of personal information by Student Users on the Site and Services as otherwise described herein.

Sharing with Third Party Applications: Some features on our Site or Services may enable Schools to “turn on” third party applications, such as Clever or Google Classroom, for the benefit of their Student User’s education. We do not facilitate the sharing of any Student Data with third parties on the Site or via the Services except on behalf of a School after such School has authorized the third-party application to access Student Data. Please remember that this Privacy Policy applies to our Site and Services only, and not to other services or third-party applications, which may have their own privacy policies. Schools should carefully read the privacy practices of each third-party application before agreeing to engage with the application through the Site or Services.

Sharing of Student Writing Submissions: Some third party applications selected by Schools may use the Services to allow Student Users to comply with any School requirements to submit completed essays. Schools directing Student Users to utilize these features are required to affirmatively “turn on” this sharing of information option. By using these third party applications ad this function, Schools understand that the information shared may include unique identifiers for their Student Users in addition to the Student Users’ submitted writings. Material submitted in this manner is subject to the information practices employed by the third party integrated service to which a School expressly consents when choosing to implement such third party integrated service.

Sharing with Service Providers: We may share information with our trusted third-party service providers strictly for the purpose of carrying out their work for us. Contractors and service providers who may have access to Student Data when performing their services are subject to confidentiality and data security requirements.

Aggregated or Anonymous Sharing: We may share information in an aggregated and/or anonymous form that does not reasonably identify an individual or School. For example, we may use and share aggregate or anonymized survey response information with educational researchers to study and improve our Site, user functionality, and Services offerings.

Legal Requirements: We may be required to share information with law enforcement or other third parties when compelled to do so by court order or other legal process, to comply with statutes or regulations, to enforce our Terms of Use, or if we believe in good faith that the disclosure is necessary to protect the rights, property or personal safety of our users. We will notify affected parties (e.g., Teacher Users or Schools) in the event of a government or legal request for their information, unless otherwise prohibited by law or court order.

Change of Control: If we should ever transfer or restructure the operational ownership of the Site, we will not transfer the personal information of our Student Users unless the new owner intends to maintain and provide the Services as a going concern and has agreed to data privacy standards no less stringent than our own. In such case we will provide you with notice and an opportunity to opt-out of the transfer of personally identifiable Student Data.

7. LINKS TO OTHER WEBSITES

The Site and Services contain links to other websites. Any links to third-party external websites that we may provide on the Site or Services are vetted for age appropriate content. However, we are not responsible for any of the content of such linked third-party websites. We are also not responsible for the privacy practices and the terms and conditions of use for any external websites. The linked sites may collect personally identifiable information from you, which is not subject to our control. The data collection practices of linked sites will be governed by each site’s privacy policy.

8. CALIFORNIA RESIDENTS

California Minors: Should we provide you the ability to publicly post information on the Site or Services, and you are a California resident who is under 18, you may request removal of your content that you are unable to delete by using the contact information provided in the “Privacy Questions” section at the bottom of this Privacy Policy. When requesting removal please be specific about the information or content you want removed and provide the URL for each page on the Site or Services where it is located. We are not required to remove any content or information if: (a) federal or state law requires us or a third party to maintain the content or information; (b) the content or information was not posted by you; (c) we anonymize the content or information so that you cannot be identified; (d) you don’t follow our instructions for removing or requesting removal; or (e) you received compensation or other consideration for providing the content or information. REMOVAL OF YOUR POSTED CONTENT OR INFORMATION FROM THE SITE OR SERVICES DOES NOT ENSURE COMPLETE OR COMPREHENSIVE REMOVAL OF THAT CONTENT OR INFORMATION FROM OUR SYSTEMS OR THE SYSTEMS OF OUR SERVICE PROVIDERS. We are not required to delete the content or information posted by you; our obligations under California law are satisfied so long as we anonymize the content or information or render it invisible to other users and the public. Also, some content and information you post that has been copied or reposted by a third party is outside of our control and will not be removed.

California Shine the Light Law: California Civil Code Section 1798.83 permits California residents to request and obtain from companies once a year, free of charge, a list of the third parties to whom they have disclosed personal information (as defined under that statute) of that California resident, for direct marketing purposes in the preceding calendar year and the categories of personal information that was disclosed to them. We do not disclose the personal information of any of our users for direct marketing purposes.

California Consumer Privacy Act (“CCPA”): The OER Project is a non-commercial venture that provides data privacy protection in compliance with all applicable laws and with its contractual obligations to Schools and School Districts. Under the CCPA, we collect, retain, use, and disclose Student Data as a service provider to our School customers. If you have a question regarding any rights you might have as a California resident under the CCPA, please contact your School directly.

9. INTERNATIONAL VISITORS

If you are accessing the Site or Services from a location outside of the United States, please be aware that this Site and our Services are housed on servers located in the United States, and the information we collect (including through cookies) is processed and stored in the United States, which may not offer the same level of privacy protection as the country where you reside or are a citizen. BY USING THIS SITE AND PROVIDING INFORMATION TO US, YOU CONSENT TO THE TRANSFER TO, AND PROCESSING OF, ALL INFORMATION IN THE UNITED STATES ASSOCIATED WITH YOUR USE OF THE SITE.

10. CHANGES TO THIS PRIVACY POLICY

We may modify or update this Privacy Policy from time-to-time, so you should review this Privacy Policy periodically. If we change this Privacy Policy in a material manner, for example if we seek to use personal information in a materially different way than we had previously, we will provide notice to participating Schools such that they will have sufficient time to evaluate the change. Of course, you or your School can always opt-out of the change by deleting your account. Your continued use of the Site or Services after the Effective Date of any new changes to the Privacy Policy will constitute your consent to the updated Privacy Policy.

11. PRIVACY QUESTIONS

If you have any questions about this Privacy Policy or other matters that relate to it, you may contact us by sending an email to: help@oerproject.com.