Writable’s Privacy Policy:

Effective as of August 7, 2021

Writable, Inc”. (“Writable” or “we”) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive from users of www.writable.com (the “Site”) and our application located at app.writable.com for mobile devices and tablet computers (the “Application”). This Privacy Policy applies only to information that you provide to us through the Site and Application. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Writable Terms of Service, accessible at www.writable.com/terms-of-service.

Our Commitment
Writable is committed to the privacy of educators and students. As a team of technologists and former teachers, our vision is to make writing easier for teachers and more successful and motivating for a new generation of writers. We respect writing and feedback as ultimate forms of personal expression and our aim goes beyond compliance. We never sell or share your personal data, and we collect as little data as possible to run the Writable service.

We abide by education policies in privacy-forward states like California and New York and support national educational privacy leaders such as the Student Data Privacy Consortium and the Student Data Privacy Pledge 2020. To see a growing list of districts and states where Writable has active SDPA agreements, click here. Contact us at privacy@writable.com with questions about customized privacy or data security needs.

This Privacy Policy may be updated from time to time. If we make material changes to this Privacy Policy, we send a notice to the email address we have on file for the account holder, which may include a Student’s Teacher or School. For material changes regarding use or collection of data, we will provide choices and additional information regarding the collection of such data before it is used in any manner inconsistent with the terms initially provided to users. Except as otherwise provided in this Privacy Policy, any changes to this Privacy Policy will be effective immediately for new users of the Service (as defined below). You are responsible at all times for providing to us your most current email address.
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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.  We do not sell your Personal Information.

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 or School District. We collect only the minimal amount of personally identifiable information from Students (including Minor Students) to create accounts on our Service: we ask Students to provide a unique username or similar login from a third-party site such as Google, their full name, a password, and the unique access code or roster access they have been given by their Teacher to connect with a class. In addition to the information entered by the Student, we automatically collect some information from their 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 requested when he or she signed 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 privacy@writable.com.
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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.
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If you are a Student who was given access to the Service by your Teacher or your School or School District, this Privacy Policy does not govern how your School might collect, use, or disclose your Personal Information or Minor Student Personal Information. We are not responsible for your School’s collection, use, or disclosure of your personal information or information shared at your School’s request. Please contact your school to better understand your School’s privacy practices.

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”).

What do we collect?

• We may collect Personal Information and Minor Student Personal Information in connection with your registration to join our Service. If you join through a third-party service provider such as Google, Microsoft, Schoology, Canvas, or HMH Ed, we may obtain the Personal Information and Minor Student Personal Information you have provided to that Third Party Account (such as your name, profile picture, email address and other information you make publicly available via the applicable Third Party Account).  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”).  Certain Non-Identifying Information would be considered your Personal Information or 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).
• Like most web-based services, when you visit the Site and Application, whether as a Writable Member or a non-Member just browsing (any of these, a “Writable User”), we may automatically receive and log information on our server logs from your browser or your device (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, your computer’s or mobile device’s MAC and hardware model, browser type or the webpage you were visiting before you came to our Site and Application, pages of our Site and Application that you visit, the time spent on those pages, information you search for on our Site and Application, access times and dates, and other statistics (“Site Usage Data”).

How do we use the information we collect?

• We use your information to create your Writable account (“Account”) if you become a Member.;
• We use your Personal Information or 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.
• 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.)
• We use Site Usage Data to monitor and analyze use of the Site, Application, and the Service and for the Site and Application’s technical administration, to increase our Site and Application’s functionality and user-friendliness, and to better tailor the Site and Application to our visitors’ needs. For example, this could include the frequency and duration of your visits to the Service. If you use the Service on different devices, we may link the information we collect from those different devices to help us provide a consistent service across your different devices. If we do combine any automatically-collected information with Personal Information, we will treat the combined information as Personal Information or Minor Student Personal Information (as applicable), and it will be protected as per this Privacy Policy.

Cookies and Other Similar Technologies
Like many websites, we may use various technologies to collect and store information when you visit our Service including, clear GIFs (also known as “web beacons”), “tags”, “scripts”, and “cookies”. Like many services, we use these technologies to tailor the Service for you, and to help the Service work better for you – for example, by remembering your language preferences. We use cookies for two purposes. First, we utilize persistent cookies to save your login information for future logins to the Site. Second, we utilize session ID cookies to enable certain features of the Site, to better understand how you interact with the Site and to monitor aggregate usage by Writable Users and web traffic routing on the Site. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Site and Service and then close your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Application or all functionality of the Service. A Web Beacon is an electronic image, often a single pixel, embedded on web pages. Web Beacons are ordinarily not visible to users. Web Beacons allow us to count the number of users who have visited certain pages of the Site and Application, to deliver branded services and to generate statistics about how our Site and Application used.

A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the site again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information. You can configure your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies.

Phishing
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 users’ writing samples. Other Students may be able to see your writing samples, and your reviews or comments, but they will not 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 Online 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, such as Google, Schoology, Canvas, or HMH Ed. 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.  Writable’s Service Providers are contractually required to protect Personal Information and Minor Student Personal Information in a manner substantially consistent with the terms of this Privacy Policy.  Additionally, Writable’s Service Providers are forbidden from selling your Personal Information or Minor Student Personal Information.

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 be required by 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.

Business Transfers. Writable may sell, transfer or otherwise share some or all of its assets, including your Personal Information and Minor Student Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case the company receiving the Personal Information and Minor Student Personal Information would be obligated to follow this Privacy Policy.

Reviewing, 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 privacy@writable.com. 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.
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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, unless a legal request has been made for a user’s personally identifiable information, we do not retain and will delete or anonymize personally identifiable information in a Member’s Account within a reasonable period after we are informed the Account will no longer be used or that these Terms of Service have been terminated by you, or if an Account becomes inactive and we are unable to contact the relevant user, their school or school district. We may use aggregated and anonymized information derived from your personally identifiable information after you update or delete it, but not in a manner that would identify you personally.
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If you would like us to delete your account in our system, please contact us at privacy@writable.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. To protect the account holder’s privacy and security, we will take reasonable steps to verify your identity before deleting your account.  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.

Security
Writable is very concerned with safeguarding your information. We employ commercially 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.
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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.
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Writable may rely on one or more subcontractors or subprocessors to perform the Service. Upon request, Writable agrees to share with any authorized Parent or School the names of subcontractors that have direct access to Student Data made available by you. All subcontractors and successor entities of Writable will be subject to the protections for Student Data set forth in this Privacy Policy and Writable’s Terms of Service.

International Transfer
Your information may be transferred to—and maintained on—computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, Writable transfers Personal Information or Minor Student Personal Information to the United States and processes it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

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.

Contacting Us
If you have any questions or concerns about this Privacy Policy, please contact Writable’s Chief Privacy Officer at privacy@writable.com or 2625 Middlefield Road, Ste 470, Palo Alto, CA 94306.