Effective as of March 30, 2017
As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.
Information Collection and Use
Our primary goals in collecting information are to provide and improve our Site and Application, services, features and content (together, the “Service”) and to enable users to enjoy and easily navigate the Site and Application.
Children’s Personal Information
If you are a Minor Student, you may only use this Service and disclose personally identifiable information if you have been given access to the Services by your Teacher or your School. We collect only the minimal amount of personally identifiable information from such Students (including Minor Students) to create accounts on our Service: we ask Students to provide a unique username, their full name, a password, and the unique access code they have been given by their Teacher to connect with a class. In addition to the information entered by the Minor Student, we automatically collect some information from use of our Service as set forth in the “Information Collected Automatically” section below, some of which may be considered personally identifiable information. Any information collected from a user that is considered personally identifiable information of a Minor Student is hereinafter referred to as “Minor Student Personal Information”. If you are under the age of 13, please do not send any Minor Student Personal Information about yourself to us unless you are using the Service as instructed to do so by your Teacher or School or unless we request such information from you when you sign up for the Service. In the event that we learn that we have collected Minor Student Personal Information from a Minor Student without proper authorization of his or her Teacher, Parent or School Administrator, or if we learn that a Minor Student has provided us Minor Student Personal Information beyond what we request when he or she signs up for the Service, we will delete that information as quickly as possible. If you believe that a Minor Student may have provided us Minor Student Personal Information beyond what is requested when signing up for the Service, or that a Student is not properly authorized to use the Service, please contact us at email@example.com.
Hereinafter, references to “Personal Information” shall apply to personal information that is not Minor Student Personal Information. References to “Minor Student Personal Information” shall only apply to personal information of a Minor Student collected from use of the Service. General references to “information” shall apply to all users.
- Personally Identifiable Information
In the course of using the Service, we may ask you to provide us with, or grant us access to, or permission to obtain, certain personally identifiable information that can be used to contact or identify you; personally identifiable information may include, but is not limited to, your name, email address, and profile photograph (“Personal Information”).
- We may collect Personal Information and Minor Student Personal Information in connection with your registration to join our Service. You can register to join via the Site or Application, or in the future you may be able to register by logging into your online account with certain third party service providers (each such account, a “Third Party Account”) via our Site or Application. Such third party service providers may include but is not limited to Google. When you register by logging into a Third Party Account via our Site or Application, we may obtain the Personal Information and Minor Student Personal Information you have provided to the Third Party Account (such as your “real” name, profile picture, email address and other information you make publicly available via the applicable Third Party Account) and use that information to create your Writable account (“Account”) and you will become a Member; the information we obtain may depend on the privacy settings you have with the Third Party Account.
- We also collect the other information that you provide as part of registration and your use of the Service (e.g., without limitation, your school, number of classmates using the Service and individual preferences) (“Non-Identifying Information”).
- We use your Personal Information and Minor Student Personal Information (in some cases, in conjunction with your Non-Identifying Information) mainly to provide the Service, complete your transactions, if any, and administer your inquiries.
- Certain Non-Identifying Information would be considered a part of your Personal Information and Minor Student Personal Information if it were combined with other identifiers (for example, your email address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences). We may combine your Personal Information or Minor Student Personal Information, as applicable, with Non-Identifying Information and aggregate it with information collected from other Writable Users (defined below) to attempt to provide you with a better experience, to improve the quality and value of the Service and to analyze and understand how our Site, Application and Service are used. We may also use the combined information without aggregating it to serve you specifically, to customize the service for you according to your preferences or restrictions.
- We also use the Personal Information of Teachers to contact Teachers with Writable newsletters, marketing or promotional materials and other information that may be of interest to Teachers. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications. (See “Changing or Deleting Information” below.)
Information Collected Automatically
Cookies and Other Similar Technologies
Identity theft and the practice currently known as “phishing” are of great concern to Writable. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, login information, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.
Information Sharing and Disclosure
We neither rent nor sell your Personal Information or Minor Student Personal Information to anyone. However, we share your Personal Information and Minor Student Personal Information in personally identifiable form as described below.
Writable Users. When you register through the Site and Application and submit your Personal Information and Minor Student Personal Information to create a profile, only you and your Teacher and/or School Administrator may be able to see your username, your associated writing samples that you submit to the Service, and your associated reviews or comments that you make regarding other user’s writing samples. Other Students may be able to see your writing samples, and your reviews or comments, but they will not be see which Student provided such writing samples, reviews, or comments. Students should not include any personal information in their writing samples, reviews, or comments. The creation of a personal profile of a Student is not used for any reason except for supporting authorized educational/school purposes or as authorized by the parent/student. Please note that if you use the same mobile device or computer tablet as another Writable Member, Writable will associate the data, including personal information that Writable collects or obtains about you with the data, including personal information that Writable collects or obtains about such other Writable Member, and may analyze and collect this data internally at Writable for analytical purposes.
Aggregate Information and Non-Identifying Information. We may share and otherwise disclose aggregated information that does not include Personal Information and Minor Student Personal Information and Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling, and other purposes. Any aggregated information shared in these contexts will not contain your information.
Third Party On-Line Services. As a Member, you may link your Account with certain Third Party Accounts. In these instances, with your permission and on your behalf, we will share your Account information with the applicable online service for the Third Party Account. Other than what we may share with the applicable third party online service in connection with your linking of accounts, the Personal Information and Minor Student Personal Information the applicable third party online service has about you is obtained by the third party online service independent of our Service. We take reasonable steps to only share your Minor Student Personal Information with third party online services who are capable of maintaining the confidentiality, security and integrity of such information, and who provide assurances that they will maintain the information in such a manner consistent with our policies. However such online service providers follow different rules regarding the use or disclosure of the Personal Information and Minor Student Personal Information you submit to them. We encourage you to read the privacy policies or statements of the other services you use before you provide personal information to such third parties.
Service Providers. We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Site and Application-related services (e.g., without limitation, maintenance services, database management, web analytics, DRM management, and improvement of the Site and Application’s features) or to assist us in analyzing how our Site, Application and Service are used. These third parties have access to your Personal Information or Minor Student Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Compliance with Laws and Law Enforcement. Writable cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe to a warrant or subpoena), to protect the property and rights of Writable or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.
Changing or Deleting Your Information
As a parent, school or school district, you can request to review, correct, update or have deleted the Personal Information of your Students (including, for the avoidance of doubt, the Minor Student Personal Information of your Minor Students) from our database by writing to us at firstname.lastname@example.org. Please include your name, relationship to the Student, email address and a telephone number where we can reach you. To protect such Student’s privacy and security, we will take reasonable steps to verify your identity before granting you access to the personal information that we collect and maintain about such Student. Please see the “Student Data” section of our Terms of Service for more information regarding our warranties for Minor Student Personal Information.
We will retain Personal Information of a Student (including, for the avoidance of doubt, the Minor Student Personal Information of a Minor Student), including after the school term in which the Student uses the Service, for only as long as is reasonably necessary to fulfill the purpose for which the information was collected. Generally, Writable will delete the Personal Information of a Student (including, for the avoidance of doubt, the Minor Student Personal Information of a Minor Student) four (4) years after such Student’s last login to the Services, or a shorter period if the retention of such information is no longer reasonably necessary to fulfill the purpose for which such information was collected.
If you would like us to delete your account in our system, please contact us at email@example.com with a request that we delete your Personal Information or Minor Student Personal Information from our database. We will use commercially reasonable efforts to honor your request. However, your writing samples and any reviews or comments on other writings samples that you submit when you interact with the Service will remain stored with Writable and viewable through the Service, provided that your username and other personally identifiable information will not be associated with any such writing sample and/or reviews. Additionally, we may retain an archived copy of records we have about you as required by law or for legitimate business purposes.
Writable is very concerned with safeguarding your information. We employ reasonable security measures designed to protect the security, privacy, confidentiality, and integrity of personal information against risks through the use of administrative, technological, and physical safeguards, including encryption. Do not provide your personal information if you are concerned with its disclosure.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on this Site and Application in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Do Not Track
We do not behaviorally target advertising to users on our Sites using Personal Information or Children’s Personal Information.
Do Not Track
We do not behaviorally target advertising to users on our Sites using Personal Information or Minor Student Personal Information.
We do not track users over time and across third party websites to provide targeted advertising and therefore do not respond to Do Not Track (DNT) signals. For more information on “do not track”, please visit www.allaboutdnt.org.
Links to Other Websites and Services
Our Site and Application contain links to other websites, online services or applications (collectively, “Third Party Services”). If you click on a link to a Third Party Service, you will be directed to that third party’s website, online service or application. The fact that we link to a Third Party Service is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over Third Party Services. Such Third Party Services may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites, online services and applications follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other Third Party Services you visit.