Effective Date of Last Update: July 31, 2017
Knewton, Inc. (“Knewton”, “we”, “us”) is founded on the principle that every student in the world should be able to receive a high-quality education tailored to his or her needs. We understand that data collected from individuals, especially students and children, is a sensitive issue and that it is incumbent upon us to be as transparent as possible about our privacy practices.
Note that if you are using the Enterprise Service through an Enterprise Partner product, this policy does not apply to our Enterprise Partners; their privacy policies that you have agreed to, not ours, govern their practices regarding information they may collect from you.
“Direct Identifiers” means information that directly identifies and can be used communicate with an individual, including: (1) a first and last name (or first initial and last name); (2) a home or other physical address including street name and name of a city or town; (3) online contact information such as an email address; (4) a screen name or username that functions in the same manner as online contact Information; (5) an educational institution-issued student identifier or other government-issued identifier; (6) a telephone number; and/or (7) a photograph, video, or audio file where such file contains an image or voice.
“Indirect Identifiers” means information about an individual that is not a Direct Identifier, such as a unique indirect identifier assigned to that individual, birth date, payment information or IP address, which is used to single out an individual over time, but standing alone, cannot be used to contact that individual.
“Personally Identifiable Information” or “PII” means information about an individual that contains Direct Identifiers (by itself or combined with Usage Data) and Indirect Identifiers when combined with Usage Data.
“Usage Data” means the data we collect from a user’s interactions with the Enterprise Service and analytical representations of such Usage Data. This data may include, but is not limited to, descriptions of content and problems you have viewed and attempted, problems you have answered correctly or incorrectly, the amount of time spent viewing content, etc. Standing alone, this information is not personally identifiable information.
From whom do we collect information?
Where an Enterprise User of any age accesses and interacts with the Enterprise Service through our Enterprise Partners’ digital course materials and online learning applications, we only collect or receive Indirect Identifiers and Usage Data from our Enterprise Partners (as further detailed in the next section). We do not knowingly collect or receive from Enterprise Users or our Enterprise Partners any Direct Identifiers of Enterprise Users.
What information do we collect/receive?
To support Enterprise User privacy, Enterprise Partners assign and share with us a unique Indirect Identifier for each Enterprise User. We also assign a unique Indirect Identifier to Enterprise Users who do not have an account with Knewton. Usage Data is automatically generated and sent to our Platform as users interact with our Enterprise Partners’ digital course materials and their online learning applications and we combine such Usage Data with those Indirect Identifiers. We only collect Usage Data that we believe is necessary to provide personalized learning through our Online Courseware.
When we combine Usage Data with Indirect Identifiers, we treat that information as PII, which means we put in place what we view as necessary physical, managerial, and technical safeguards to protect that PII from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.
We will never link a Direct Identifier with Usage Data received through your interactions with the Enterprise Service unless you have both created an account with Knewton at www.knewton.com and also authorized us to link any such Usage Data to that account to allow you to carry a learning profile across various products and subject domains.
How do we use and share collected information?
As part of the Enterprise Service, Knewton creates and maintains a personalized learning profile for each user based on his/her Usage Data.
Knewton provides Enterprise Partners with recommendations and analytics data that are personalized to users based on this Usage Data, that our Enterprise Partners may in turn render to users and/or instructors or other authorized personnel of a school or other institution.
Knewton also uses Usage Data to improve and inform Knewton’s internal platform technologies, including maintenance and debugging, data analysis, testing and research in connection with providing the Enterprise Services to users.
What access and control do you have over collected information?
If you are an Enterprise User and do not have an account with Knewton, please note that we do not collect or receive any Direct Identifiers about you from our Enterprise Partners and therefore have no way to identify or contact you personally. As such, we are not able to provide you access or control to any Usage Data we may have collected from you through your use of an Enterprise Partners’ digital course materials and online learning applications. You should reach out directly to the Enterprise Partner through whom you purchased the product that uses the Enterprise Service.
Changes to this policy
Any such posted changes will be effective upon the date indicated by the posting, but in any event not sooner than 14 days after posting.
If any changes materially change the type of information we collect or how we use the information we collect, we will work with the Enterprise Partner to also provide you notice through the Enterprise Partner’s product.
Postal mail to: Privacy Administrator, Knewton, Inc., 440 Park Avenue South, 14th Floor, New York, NY 10016; or
Telephone: +1 212-563-9866 (request “Privacy Administrator”)