Privacy Policy

The following Privacy Policy summarizes the ways that Keyboarding Without Tears® (KWT) treats the information associated with the use of the KWT suite of digital products. Our goal is to protect your and your students’ privacy. Please read this policy carefully. Your and your students’ use of the KWT suite of digital products will constitute your agreement to this Privacy Policy.

We reserve the right to revise this Privacy Policy at any time, including to address new issues or reflect changes to our service or product offerings. Such revisions become effective immediately upon notice to you. Notice may be given by any means, including, but not limited to, posting of the revised Privacy Policy. The date of the most recent revisions will appear on this page, so check back often. Your continued access to or use of KWT constitutes your acceptance of changes or revisions to the Privacy Policy.

This Privacy Policy deems the procedures and practices that govern the access, use, retention, and deletion of the Personally Identifiable Information (PII) of students to be of paramount importance to respecting and protecting the privacy and security of students. In particular, KWT’s suite of digital products and services is used nationwide in the United States and our information and data use practices comply with the following federal regulatory frameworks enacted to protect and monitor the data privacy, security, integrity, retention, and deletion rights of students, parents, and schools who use KWT: Family Education Rights and Privacy Act (FERPA); Children’s Online Privacy Protection Act (COPPA); Children’s Internet Protection Act (CIPA); Protection of Pupil Rights Amendment Act (PPRA).

PII

In the course of providing educational products and services to you, we may at times request and temporarily store certain types of personally identifying information about students in order to enable student login and student license-based access to selected applications in our suite of digital products and services. We adopt the definition of personally identifiable information set forth under the FERPA regulations, pursuant to 34 CFR § 99.3 (“Personally identifiable information”). We will not require a student to disclose more personally identifiable information than is reasonably necessary to participate in online activities. To enable a student’s license-based access to our digital products and services, we collect basic account information (name, grade level) about the student. We may also collect basic account information (school, teacher name, teacher e-mail) of designated school officials to enable their management of the student licenses. In the scenario in which a student may enter personally identifying information, we ask parents and educators to help us protect the privacy of students by instructing them never to provide personally identifying information without getting parental/guardian or teacher permission first. Please note that we do not consider any information that is not associated with a student’s personally identifying information (de-identified, anonymized or aggregated information) to be personally identifying information.

FERPA

In compliance with the Family Education Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g; 34 CFR Part 99), and with regard to the availability of KWT in schools in the United States, we are first granted lawful access to directory information (specifically, student names) from student education records by school officials with legitimate educational interest in American public schools. We subsequently utilize students’ names for the specific purpose of delivering KWT’s suite of digital products and services to students with KWT licenses in those public schools. We also run reports associated with student names to indicate the number of KWT activities completed, days in use, and student performance reports based on KWT Spot Check metrics.

With regard to the rights that FERPA confers to parents or eligible students to inspect, review, correct, or otherwise access student education records maintained by public schools and shared with us by school officials with legitimate educational interest, we will cooperate with schools officials to ensure that the rights of parents and eligible students under FERPA, and the security of student education records are protected. KWT is fully compliant with FERPA. Specifically,

COPPA

In compliance with the Children’s Online Privacy Protection Act (COPPA) of 1998, KWT collects a limited set of personally identifiable information from users at different points in the website for internal use, enabling log-in of licensees, and monitoring program participation. Upon request, we provide access to a parent or school to review the child’s personally identifiable information, ask to have it deleted and refuse to allow any further collection or use of the child’s information. As part of our commitment to data privacy and security, we recognize that our student users under the age of 13 need special safeguards and privacy protection. To prevent unauthorized access, and maintain data accuracy, and ensure the correct and appropriate use of information, we have put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure the information we collect.

CIPA

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 or library computers. CIPA imposes certain types of on any school or library that receives funding for Internet access or internal connections from the E-rate program – a program that makes certain technology more affordable for eligible schools. In 2001, the Federal Communications Commission (FCC) issued rules implementing CIPA. KWT is in compliance with CIPA because KWT is self-contained and does not provide links to external resources or chat rooms. Moreover, KWT does not contain any offensive or inappropriate content or subject-matter. As a result, any school, library, or otherwise E-rate eligible educational facility that uses KWT will be fully compliant with CIPA.

PPRA

The Protection of Pupil Rights Amendment (PPRA) (20 U.S.C. 1232h; 34 CFR Part 98) was enacted in 1978, and applies to student surveys, instructional materials or evaluations funded by the federal government that deal with highly sensitive issues. The PPRA is inapplicable to KWT’s suite of digital products and services because KWT is not funded by the federal government.

In compliance with this federal regulatory framework enacted by Congress to protect the data privacy and security rights of students, parents, and schools in today’s digital marketplace as applied to online and cloud-based educational products and services, our information and data use practices include the following. We automatically collect and store: the name of the domain and host from which you access the Internet; the Internet protocol (IP) address of the computer you are using; the browser software you use and your operating system; the date and time you access our sites; and the Internet address of the site from which you linked directly to our sites. We use this information only as anonymous aggregate data to determine the number of visitors to different sections of our site, to ensure the site is working properly, and to help us make our site more useful. We do not use it to track or record information about individuals.


Keyboarding Without Tears (KWT): Data Use Policy in Public Schools FAQ


How Does Keyboarding Without Tears Store Data and Who Owns it?

The answer to this question is simplest if we first define what we mean by “data”. When Keyboarding Without Tears (KWT) is made available to students in public schools in the United States, two types of data are involved: (1) roster data (2) progress data. Roster data is personally identifiable information, either inputted by users online or pulled from student education records (SER) that public schools conditionally and temporarily share with us for the duration of our contractual relationship with those public schools. Our access to roster data helps us link our KWT licenses to students in your school and manage which students are in which classes. Progress data is contextual, transactional, non-identifiable, and generated when students complete KWT activities. We collect progress data for the purpose of monitoring student participation and progress in the KWT curriculum. Progress data does not include roster data.


Do We Sell the Roster Data We Collect and Use to Third-Party Vendors?

No, we do not.


What Happens to the Data After Public Schools Stop Using KWT?

If you choose to stop using our solution, our contractual relationship with your public school would terminate. At this point, as part of the retention and deletion aspects of our KWT data use policy, we would retain all roster data provided by your public school in our data warehouse for six months after the termination of our contractual relationship. Upon request during this period, this retention policy enables us to make reports of the relevant progress data for specific students available to you. When the six month period expires, we then expunge all roster data provided by your public school from our data warehouse.


What Information Do You Require for a Student Account?

In the separate contexts of in-school/class use and at-home use, we require the following identifiers to enable KWT log-in functionality. These identifiers are typically associated with the directory information of a public school’s student education record: