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.
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,
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.
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.
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.