Updated as of: November 18, 2019
PLEASE SEE BELOW FOR OUR POLICY REGARDING OUR COLLECTION OF PERSONAL INFORMATION FROM CHILDREN UNDER AGE 13
WHAT IS ANNOTATE.NET?
The Service is intended for use by instructors, such as teachers, professors, corporate trainers or other presenters (“Instructors”) who wish to use the Service to provide instructional content, and tools such as digital white board tools, quiz and polling tools, screen sharing, streaming and recording tools, and discussion and collaboration tools for use with a group of students or participants in a class, course or other group (a “Group”), for use by the Group participants registered as users (“Students”). Group membership is managed by the Instructor.
Our use of information submitted through the Service may also be governed by additional agreements with the school or school district to which we provide the Service. Additional agreements with a school or school district may contain additional provisions regarding our collection, use, and disclosure of information collected pursuant to that agreement.
Personal Information We Collect
As described in more detail below, we may collect, use and disclose Personal Information from Instructors, as well as from Students. Students who are age 13 or older (“Older Students”) may be treated differently in certain ways than students who are under age 13 (“Child Students”). Please see below the section titled Personal Information from Children for an explanation of how our information policies differ for Child Students.
“Personal Information” is information that identifies an Instructor or a Student as an individual or that relates to an identifiable person, including:
- Email address
- Voice recordings
- Video recordings
- Student ID or registration ID
- Other information that you make visible from your screen when using certain sharing features
How We May Collect Personal Information
Except as described below with respect to Child Students, we may collect Personal Information in a variety of ways, including:
- Through the Service: We may collect Personal Information through the Service, such as when you create an account or upload or submit information, or when you or an Instructor uses voice or video recording features or screen sharing type features.
- From Integrated Services: If you decide to register for the Service through, or to otherwise grant access to, a third-party social networking or integrated service that we may make available (each, an “Integrated Service”), such as Facebook Connect or Google, we may have access to Personal Information that you have provided to the Integrated Service from the account you have with it. You may revoke our access to such information at any time by updating the appropriate settings in the account preferences of the relevant Integrated Service.
- From Other Sources: We may receive your Personal Information from other sources, such as public databases, joint marketing partners and other third parties.
How We May Use Personal Information
Except as described below with respect to Child Students, we may use Personal Information:
- To provide the Service.
- To respond to your inquiries and fulfill your requests, such as to send you newsletters.
- To send administrative information to you, such as information regarding the Service and changes to our terms, conditions and policies.
- To send you marketing communications that we believe may be of interest to you, if you are an Instructor.
- To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information. We suggest that you read any such rules carefully.
- For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying the Service, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
How Personal Information May Be Disclosed
Except as described below with respect to Child Students, Personal Information may be disclosed:
- To our third party service providers who provide services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.
- To your Instructor, if you are a Student. Your Instructor will also have access about your submissions and other activity through the Service, including, for example, notebook annotations, responses to quizzes or polls, written assignments, written discussion entries, audio captured (for example in class discussions or annotation clips), and information submitted through screen sharing features.
- To your Group, if you are a Student. For example, submissions made through the announcements, projects, or screen sharing type features are visible to both your Instructor and other Students in your Group, possibly along with your username and photo. By your Instructor, for example if your Instructor includes information or recordings within materials for another course or shared outside the Service.
- By you if you share publicly, for example on your public profile page or through other services to which you are able to post information and materials. Any information you share publicly may be available to other users and the general public. We urge you to be very careful when deciding to share any information outside the Service.
- To third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
- Company cannot guarantee how other users may use or share your information.
We may also use or disclose your Personal Information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; and (e) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
Other Information We May Collect
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:
- Browser and device information
- Information collected through cookies, pixel tags and other technologies
- Demographic information and other information provided by you
- Aggregated information
How We May Collect Other Information
We and our service providers may collect Other Information in a variety of ways, including:
Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language and Internet browser type and version. We use this information to ensure that the Service functions properly.
Using cookies: Cookies are pieces of information stored directly on your device. Cookies allow us to collect information such as browser type, time spent on the Service, pages visited, language preferences and other traffic data. We and our service providers use the information only to support the internal operations of the Service, such as for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while using the Service and to recognize your device to assist your use of the Service. We also gather statistical information about use of the Service in order to continually improve its design and functionality, understand how it is used and assist us with resolving questions regarding it.
We do not respond to browser do-not-track signals at this time.
Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with the Service to, among other things, track the actions of users (including in connection with the emails we send), measure the success of marketing campaigns and compile statistics about use of the Service and response rates.
IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet service provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Service, along with the time of the visit and the pages visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for the purposes of providing support for the internal operations of the Service, such as calculating usage levels, diagnosing server problems and administering the Service. We may also derive your approximate general location from your IP address.
From you: Information such as your communications preference may be collected.
By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Service.
How We May Use and Disclose Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your Personal Information
If you are an Instructor, you may opt out from receiving marketing-related emails from us on a going-forward basis by clicking the unsubscribe link in any such email. We will try to comply with your request as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.
How you can access, change or suppress your Personal Information
If you are registered using an email, you may update, correct or delete the Personal Information that you have provided to us by going to your account settings page. We will try to comply with your requests as soon as reasonably practicable. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed. Further, it may not be possible to locate or delete a recording of a screen share, or a given individual’s voice from recordings of class discussions.
PERSONAL INFORMATION FROM CHILDREN
The definition of Personal Information above applies also to Child Students (as defined above), except that for Child Students we may additionally collect information about the child’s parents (such as name and contact information), and about the child’s school.
Except as described below, we use the Personal Information of Child Students as set forth above, under “How We May Use Personal Information” and “How Personal Information May Be Disclosed.”
Except as described below, we and our service providers also collect from Child Students the information described above, under “Other Information.”
The rest of this section describes how our information practices are different with respect to Child Students.
A Child Student cannot obtain an account to use the Service unless either: (a) the Child Student has a qualifying course code that was issued to an Education Instructor, or (b) the account is created for the Child Student by an Education Instructor or otherwise on the Child Student’s behalf by the school or district, or (c) we have received verifiable parental consent, or (d) other arrangements have been made to comply with COPPA requirements.
Child Students do not have a public profile page.
Child Students do not have access to certain Integrated Services features that would result in sharing information from the Service through a social medial account.
Child Students may have access to sharing features that enable them to share information through email or through certain Integrated Services that are offered through their school (for example where students are provided a Google drive account through their school).
Limited Use of Information. Use of Personal Information of Child Students will be solely for the use and benefit of the school contracting with us (including through an Education Instructor), or for a program approved by parental consent, and for no other purpose. Our use of Personal Information of Child Students will be entirely limited to that educational or approved program context.
Process to Review, Delete, Terminate. If you would like to review the Personal Information we have collected from your child or student, or if you would like to ask us to make no further use of, or delete, the Personal Information we have collected from your child or Student, contact us using this form. In your request, please include your name and the child’s name, and specify the action you would like us to take. For your child’s protection, we may need to verify your identity before implementing your request.
Deletion of Information. Any Personal Information collected from or about Child Students will not be retained longer than it is reasonably required to provide the Service and will be deleted promptly upon request and when it is no longer reasonably required. Company generally intends to maintain information for a period after the Student last accessed the Service, to enable Students to return to earlier course work for later reference, however we make no guarantee that user information will be retained. Information may be permanently lost if a school, instructor or user terminates a course or an account.
Certain information may be retained solely for legal compliance recordkeeping.
There may be residual information that will remain within our archives and other records, which will not be removed. Further, it may not be possible to locate or delete a recording of a screen share or a given individual’s voice from recordings of class discussions.
THIRD PARTY SERVICES
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.
The Service is controlled and operated by us from the United States and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and, by using the Service, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service or otherwise to us.
Because email communications are not always secure, please do not include sensitive information in your emails to us.