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Publisher Learning Platform Privacy Policy

This is the privacy policy (“Privacy Policy”) for the Publisher Learning Platform powered by MassiveU and its affiliated sites. ("Publisher Learning Platform," “we,” or “us”). The Publisher Learning Platform is a custom version of the MassiveU Learning Platform used by PBL Global (“Publisher”) to offer its learning materials (Materials) in a web enabled way. MassiveU is MassiveU, Inc. Publisher works with various client organizations such as schools districts and schools (Customers) to provide the Materials to their students, teachers, employees or affiliates (Users). MassiveU, Publisher, and Customers may access and use the information retained by the Publisher Learning Platform as set forth below:

Your privacy is very important to Publisher Learning Platform and we are committed to protecting it. We understand that you need to be in control of your personal information. This Privacy Policy explains the manner in which Publisher Learning Platform collects personal information from you and the purpose for that collection. This Privacy Policy is designed to ensure that you are aware of how your personal information is being used and to provide you with choices about that use. By visiting Publisher Learning Platform or submitting your personal information, you accept the terms described in this Privacy Policy.

Publisher Learning Platform collects information that identifies you, such as names, telephone numbers, postal addresses, and email addresses (“personal information”), when voluntarily submitted by our visitors and Users. We receive and store any information that you choose to enter through Publisher Learning Platform, including any submissions that you make or content you provide on or through Publisher Learning Platform. For purposes of this Privacy Policy and Publisher Learning Platform’s Terms of Use, the term “Customer” means any entity, educational institution, school district or school that is offering Materials accessible on the Publisher Platform to its Users. These Materials are offered by Publisher. Customers must agree to be bound by this Privacy Policy and the Terms of Use of Publisher Learning Platform prior to offering Materials. The term “User” means any entity, educational institution, school, student, end user or individual that has accessed Publisher Learning Platform Materials.


Personal Information Collected by Publisher Learning Platform


Any User that accesses Publisher Learning Platform must register within Publisher Learning Platform. Publisher In addition to the personal information, if payment is required for the Materials, your credit card information, including your billing address, will be collected. Once you have registered, you may then sign up to be a User for the Materials. Publisher Learning Platform requires that all Users who will access the Materials either directly or through an entity, school or educational institution of any type must be identified in Publisher Learning Platform with the following information: the first and last name, gender, current educational level, and date of birth. We call this information “Registration Information.” We will also require a process to verify your consent to the registration and to the collection of your Registration Information. When you access the Materials, Publisher Learning Platform will automatically collect information about your patterns of usage, order history, participation in promotions, session data, and other information relating to usage, choices, and preferences. We call this information “Participation History.”


How Publisher Learning Platform will use the information collected from you


Email Address: Your email address may be used to send a confirmation email at registration, as well as information and updates around our Materials. For our Users, your name or other identifier set up at registration will serve as your login username. In addition, for Users, we will also email your progress information. For both Users and Customers, we may use the email address as an additional means of communicating with you about the Materials and Publisher Learning Platform, including notifying you of updates to Publisher Learning Platform or its related policies.


Name: The User’s name will be used to customize your participation in the Materials, as well as to personalize the reports and updates about your progress with the Materials. In addition, for our Users or parents or the legal guardian of a User, respectively, Publisher Learning Platform may send information to you using your name, at the mailing address that you provide.


Phone Number: The User and Customer’s phone number will serve as an alternate way of contacting you for the same purposes as the email address. It will only be used for support in connection with the Materials and will not be used for solicitation.


Credit Card Information: For our Users or parents or legal guardians of a User, respectively, in some cases, with your consent, Publisher Learning Platform on behalf of Publisher or Customers, may use your credit card information to bill you for access to Materials.


Date of Birth: If provided, we will use a User’s age to group Performance Data, as defined below, of Customer of similar age so we can assess performance by age, and improve the Materials. Such information will be aggregated with other Users and Customers in an anonymous manner and will not include any information that could be used to identify a specific User. It may also be used to determine if parental consent is necessary prior to a User accessing the Materials.

Educational Level: We will use a User’s educational level to group Performance Data of Users of similar educational levels so we can assess performance by educational level, and improve the Materials. Such information will be aggregated with other Users in an anonymous manner and will not include any information that could be used to identify a specific User.


Gender: We will use a User’s gender to personalize the Materials’ experience. In addition, we will use a User’s gender to group Performance Data of Users of the same gender so we can assess performance by gender, and improve the Materials.


Mailing Address: A User or Customer’s mailing address may be used to allow Publisher Learning Platform to mail you various materials and products related to the Materials.


Secondary Uses: Registration Information and other information may be used by Publisher Learning Platform for demographic profiling and targeted advertising, although, in such cases, the information will be aggregated as ANONYMOUS statistical information. Publisher Learning Platform will not sell, trade, or assign any unaggregated, personal information that it collects to third parties outside of Publisher Learning Platform, its affiliates and subsidiaries. If Publisher Learning Platform shares, sells, trades or assigns any such personal information with a third party, it will be in accordance with the terms of this Privacy Policy and for the purposes that are discussed below.


Participation History: Participation History will be collected for User and Customer care, development, marketing and other operational and business purposes, including improvements to the Materials by Publisher Learning Platform. Participation History will be available to Customers.


Other uses that Publisher Learning Platform may have for the personal information, Registration Information and Participation History collected include:

  • To respond to your inquiries and provide customer support
  • To administer promotions to the User;
  • For our internal marketing purposes, which include, but are not limited to, sending the User and Customer material about products, Materials, updates, etc. that we think may be of interest to the User and Customer;
  • For sharing with our affiliates and subsidiaries who may contact the User and Customer with respect to their educational or other Materials;
    • For investigation of information security and information asset protection-related incidents;
  • To test, correct and improve our content, applications and Materials;
  • To develop new applications, products and Materials;
  • To improve Publisher Learning Platform and Service performance and delivery;
  • To prevent potentially illegal activities (including illegal downloading of copyrighted materials in accordance with our Copyright Infringement policy included in our Terms of Use);
  • To investigate suspicious information that denotes illegal activity such as financial aid fraud;
  • To analyze academic and learning outcomes and preferences of the User and Customer;
  • To analyze risk and business results;
  • To obtain payment for Materials that we provide to the User and Customer;
  • To maintain business records for reasonable periods;
  • To enforce our Terms of Use;
  • To provide to affiliates and subsidiaries in connection with the contemplated or actual reorganization, merger, acquisition, financing, securitization, insuring, sale or other disposal of all or part of our business or assets, including for the purposes of determining whether to proceed with such transaction or fulfilling any records or other reporting requirements to such parties. In the event of any actual reorganization, merger or acquisition, such information may be transferred as part of the transaction to the acquirer; and/or
  • As may be required or permitted by legal, regulatory, industry self-regulatory, insurance, audit or security requirements applicable to Publisher Learning Platform, our affiliates and subsidiaries.

Information Publisher Learning Platform collects directly from the User


Publisher Learning Platform collects information directly from the User or Customer, over the Internet, in the form of the interactions that the User or the Customer makes when participating in the Materials. We refer to the data resulting from such participation, which includes but is not limited to data on when the User starts and stops a lesson, the responses the User makes to questions asked, the timing of the User’s responses, the User’s choice of character and customizations, and the choice of lessons to play as “Performance Data.” We will use Performance Data to:


(1) Measure the User’s performance in the Publisher Learning Platform Materials and to adapt the Materials to his or her learning needs;

(2) Analyze the User’s Performance Data, and provide the Users and Customers with periodic progress reports about the User’s performance in the Materials, and

(3) Improve the Materials.. In addition, we may aggregate the User’s Performance Data with the Performance Data of other Users and Customers participating in the Materials for marketing and other business related purposes. Aggregate information will be ANONYMOUS and will not identify the User or be combined with other information that would allow individual Users to be identified.


Opting-out of providing the information we request


Because the Publisher Learning Platform Materials are individualized and customized for each User, all the information we request from the User is required for the User to participate in the Materials, with the exception of certain information to be used for our marketing purposes to you only. At any time, the User may revoke the consent to participate in the Publisher Learning Platform Materials or refuse to allow Publisher Learning Platform to further use or collect the User’s personal information. Any ANONYMOUS Performance Data will be retained, but we will no longer use any identifiable information regarding the User that has been provided. However, if the User does any of the foregoing, the User will not be able to participate in the Materials.


Reviewing and changing your information


The User or Customer may review and modify your Registration Information at any time by accessing Publisher Learning Platform using your password.


Consent


In order to use and/or access the Materials, the User will be asked to submit certain personal information about the User and to authorize Publisher Learning Platform to use that information in a limited number of ways. For our Users under the age of 18, we will require that a Parent or Guardian review and submit a Parental Consent as part of the registration process, which will require the Parent or Guardian to consent to our collection and use of information directly from your child over the Internet as described above. We do not knowingly collect information from children under the age of 13. Should we learn that a child under 13 has provided us with personal information without appropriate consent from a parent or guardian we will delete that information from our database. Customers providing minor Users with access to the Materials are responsible for ensuring that appropriate consent has been obtained on behalf of all such Users.


Password Protection


The User will be asked to select a password to access the Materials through Publisher Learning Platform, and this password will be used to allow the User to access the Materials. The User’s password should be kept confidential. The User’s password will also allow the Customer to review and change the personal information we collect about the User. You are encouraged to use a strong password.


Protecting your information.


No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information the User, or Customer transmits to us. As such, the User or Customer does so at his/her own risk. Publisher Learning Platform has multiple security measures in place to protect the loss, misuse or alteration of information under our control.


The Materials are hosted in the United States. If the User or Customer is visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that the User or Customer are transferring their personal data to the United States, which does not have the same data protection laws as the EU or other regions; by providing the User or Customer’s personal data, the User, or Customer consent to the use of their personal data for the uses identified above in accordance with this Privacy Policy and the transfer of the User personal data to the United States as indicated above.


The User or Customer’s personal information and third parties


Except as provided in this Privacy Policy, Publisher Learning Platform WILL NOT disclose the personal information that it obtains from the User or Customer to third parties without the User, or Customer’s express written permission, or where we believe, in good faith, that the law requires us to disclose the information. A User’s information will be accessible by Publisher, MassiveU and the applicable Customer for the purpose of administering the Materials and monitoring progress and completion as they require. Additionally, the Materials may contain a social component that enables Instructor and fellow User interaction. Other Registered Users may see your first name as an identifier for any comments, questions or materials shared by you inside the Materials.


Publisher Learning Platform WILL NOT sell, trade, or assign any unaggregated personal information that it collects to third parties outside of Publisher Learning Platform. If Publisher Learning Platform shares, sells, trades or assigns any such personal information with a third party, it will be only be after it obtains the User or Customer’s express written permission. We, however, may aggregate the information that we collect from Users and Customers to create demographic profiles and performance profiles regarding the progress of Users and Customers who use the Materials. Publisher Learning Platform may share aggregated information with advertisers, marketing professionals, or potential investors. This aggregated information will be compiled and reported in the form of ANONYMOUS group statistics only in such a manner that makes individual Customers or Users unidentifiable. In addition, in order to offer and improve the Materials, Publisher Learning Platform may share Registration Information about the parents, legal guardians, and school officials that register to participate in the Materials, along with such Users or Customers’ Participation History, to contractual business partners of Publisher Learning Platform that are directly involved in the sale, distribution, operation, maintenance, and support of the Materials on behalf of Publisher Learning Platform.


Notwithstanding anything to the contrary, as Publisher Learning Platform continues to develop its business, it might sell some or all of its assets. In such transactions, User information is generally one of the transferred business assets. An acquiring company would be required to protect all information that Publisher Learning Platform collects from Users and Customers and Materials in accordance with the terms of this Privacy Policy.


Unsolicited third-party promotional emails


Publisher Learning Platform will not send the User or Customer unsolicited third-party promotional emails.


Use of cookies


As a standard practice, Publisher Learning Platform uses “cookies”. A cookie is a small amount of data sent to your browser from our web server and stored on your computer, then sent back to the server by your browser each time you access Publisher Learning Platform. Cookies are used solely for the required operations of Publisher Learning Platform and our Materials. We do not use cookies to collect any personal information, nor do we use them for behavioral advertising, to build a Customer profile unrelated to the use of Publisher Learning Platform, or for any other reason. Please note that if the User or Customer refuses the Publisher Learning Platform cookie (by turning cookies off in your browser or by clicking “don’t accept” if you have set your browser to warn you before accepting cookies), this may render Publisher Learning Platform and our Materials unusable to the User or Customer. Cookies as implemented by us cannot be used to gather personal information from the User, or Customer’s computer.


Children’s Online Privacy Protection Act


For the parents or legal guardians of Users that are under the age of 18: Congress has enacted a law called the Children’s Online Privacy Protection Act of 1998 (COPPA) that is designed to protect children’s privacy during use of the Internet. Publisher Learning Platform has implemented practices consistent with the guidelines provided by the Federal Trade Commission to date. Publisher Learning Platform will never knowingly request, obtain, use or disclose personally identifiable information or private content from anyone under the age of 13 without parental consent. You must be the parent or legal guardian to grant such consent. If we receive this parental consent, we may receive personal information from children under the age of 13 listed on your subscription account in order to provide our Materials to them. Publisher Learning Platform DOES NOT SHARE CHILDREN’S PERSONALLY IDENTIFIABLE INFORMATION WITH THIRD PARTIES. If you are a parent or legal guardian of a user under 13 you may, at any time, revoke your consent to allow your student to use the Materials under your subscription, refuse to allow Publisher Learning Platform to further use or collect your child’s personal information, or direct Publisher Learning Platform to delete all identifiable information regarding your child that you have provided. To do so, please contact our Privacy Officer at the contact information below. However, if you do any of the foregoing, your child will not be able to use the Materials.


To the extent that Publisher Learning Platform collects, uses, or discloses personal information from children under the age of 13, it is done in strict accordance with this Privacy Policy and for the sole purpose of providing Materials to the Customer and User.


If you would like more information about COPPA, please go to http://www.ftc.gov/ogc/coppa1.htm.


The Children’s Internet Protection Act


The Children’s Internet Protection Act (CIPA) is a federal law enacted by Congress in December 2000 to address concerns about access to offensive content over the Internet on school and library computers. CIPA imposes certain types of requirements on any school or library that receives funding support for Internet access or internal connections from the “E-rate” Course — a course that makes certain technology more affordable for eligible schools and libraries. Our Materials do not provide links to external resources or chat rooms, and do not contain any offensive or inappropriate material. If you would like more information about CIPA, please go to http://www.fcc.gov/cgb/consumerfacts/cipa.html.

Publisher Learning Platform does not share information with any third parties that could be used to personally identify Customers or Users. If a Customer that is an entity, educational institution or school requests that a User’s or student’s data be sent to a third party, with parental consent, Publisher Learning Platform will send the data to the Customer and never directly to the third party.


Amendments


Publisher Learning Platform may amend this Privacy Policy from time to time. We will notify the User and Customer by email regarding any material changes to our privacy and security practices. Please review all revisions to the Privacy Policy. The User and Customer’s continued use of Publisher Learning Platform and the Materials after the date Publisher Learning Platform has emailed such notices will be deemed to be the User and the Customer’s agreement to the changed terms.


Contact Us

If you have any questions about our Privacy Policy and/or your privacy or security measures at Publisher Learning Platform, please contact our Privacy Officer:

http://massiveu.com

Publisher Learning Platform

Attn: Angelo Biasi

Email us at: abiasi@massiveu.com