1. Information We Collect and How We Collect It
2. How We Use Your Information
3. How We Protect Your Information
We implement a variety of security measures and provide training to responsible individuals to maintain the safety of your personal information when you enter, submit, or access your personal information, and to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted via the Internet to our Website. CPM servers are physically located within the continental United States.
Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information regarding your visit to the Website such as: your IP address; the domain from which you accessed the Website; the date, time and duration of your visit; and the pages you visited.
We use this information to understand and save your preferences for future visits and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may contract with third-party service providers to assist us in better understanding our site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.
5. Disclosure of Your Information
We do not sell, trade, or otherwise transfer to outside parties your personal information except that we may disclose your personal information under the following limited circumstances:
- To trusted third parties, described below, who assist us in operating our Website, conducting our business, or providing services to you, so long as those parties agree to keep this information confidential and use such information only for the purpose of providing the contracted-for services;
- To comply with any law, court order or legal process, including responding to any government or, regulatory request;
- To enforce our Website policies, or protect our or other’s rights, property, or safety; and
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of CPM’s assets.
For the avoidance of doubt, CPM will not provide or sell to any third party any personal information in a Student Record (defined below), or engage in targeted marketing.
6. Categories of Third Parties Who May Receive Your Information
- Professional Development/Workshop Online Scheduling Software Services
- Accounting and Administrative Software
- Printer and Shipping Companies
- Specialized Consulting Service Companies
This policy does not apply to information collected by CPM offline or through any other means, including on any other website operated by any third party or information collected by any third party.
8. Your Choices Regarding Data Collection and Use
CPM uses personal information as needed for the purpose for which it was collected or where you have consented to the use of your personal information. You can always decline to provide your personal information to CPM. Registration is not required to access our Website, however if you decline to create or use a school or user account, CPM will not be able to provide certain features and functionalities found on our Website. You may later enable or access those features by providing CPM with the necessary personal information.
You may unsubscribe from receiving promotional email communications from CPM at any time by clicking the unsubscribe link in any e-mail.
California Children’s Privacy Rights. If you are a California resident under the age of 18, you may request removal of content or information you have posted publicly on our Website. To request deletion or de-identification of a post publicly displayed on the Website, please contact us directly at the address below in the “Contacting Us” section. Please understand that there may be de-identified or recoverable elements of your content or information on our servers in some form, and we will not remove content or information that we may be required to retain under applicable federal or state laws. Please see the “Retention and Deletion of Student Records” section below for more information.
9. Student Records
Control of Student Records. Student records obtained by CPM from a “local education agency” (or its equivalent as defined by applicable law, and referred to as “school” in this section) are, and will continue to be, property of and under the control of the school. Such “Student Records” include any information directly related to a student that is maintained by the school or acquired directly from the student through the use of instructional software or applications assigned to the student by a teacher or other school employees. Student Records do not include de-identified information (i.e., information that cannot be used to identify an individual student) collected or used by CPM: (1) to improve educational products for adaptive learning purposes and for customized student learning; (2) to demonstrate the effectiveness of CPM’s products in the marketing of those products; or (3) to develop and improve CPM’s educational websites, services, or applications.
Control and Transfer of Student-Generated Student Records. Students can generate Student Records through the use of eWorkspace via the Website. The student’s legal guardian or parent (referred to as “parent”), or the student, or the school can opt-in to the use of this functionality – the person/entity making the opt-in decision will depend on the age of the student and whether the school or parent has licensed CPM’s Licensed Content for the student’s use. Student-generated Student Records will only be retained by CPM for the duration of the applicable semester, class or program. After such time, the school will control and retain all Student Records related to the student’s use of the Website.
Ability to Correct or Access Student Records. Because the school enters and maintains the accuracy of the student roster, the school is responsible for providing the means by which parents and eligible students may review and correct erroneous information contained in a Student Record. To review, correct, update, or delete any personal information contained in a Student Record provided by the school, a parent, or eligible student should contact the school directly. If you have any questions about specific practices relating to Student Records provided to CPM by a school, please direct your questions to your school.
How CPM Ensures Security and Confidentiality of Student Records. Please see the “How We Protect Your Information” section above.
Notice of Unauthorized Access or Disclosure of Student Records. Please see the “Unauthorized Access or Disclosure” section below.
CPM’s Use of Student Records. Please see the “How We Use Your Information” section above.
Use or Disclosure of Student Records for Targeted Marketing. CPM does not use or disclose Student Records for targeting marketing. Please see the “How We Use Your Information” and “Disclosure of Your Information” sections above.
Retention and Deletion of Student Records. CPM certifies that Student Records shall not be retained or available to CPM upon completion of the terms of the applicable license agreement or Purchase Agreement with the school. Such certification will be enforced through the following procedure: within one (1) week following the expiration of the semester, class, or program covered by the applicable license agreement or Purchase Agreement, all data related to that class, including but not limited to personal information of a student, shall be deleted from CPM’s servers using industry best practices.
The school is responsible for managing Student Records which the school no longer needs by submitting a deletion request when the data is no longer needed. Schools should contact us at the address below in the “Contacting Us” section to request deletion of Student Records if deletion is needed before the end of the semester, class, or program. Please note that CPM can only comply with a school’s request to delete personal information connected with the student’s school user account (where the student uses a school email address or account login provided by the school pursuant to a license or Purchase Agreement between the school and CPM). Parents may submit deletion requests directly to us at the address below in the “Contacting Us” section.
Family Educational Rights and Privacy Act Compliance (“FERPA”). A student’s school will work with CPM to ensure compliance with FERPA by the following procedure: prior to the transmission of any Student Records, the parties will execute a license agreement or Purchase Agreement in accordance with FERPA unless the school demonstrates that the information to be provided to CPM has been designated by the school as “directory information” under FERPA.
10. Data Retention
CPM will securely maintain personal information, other than Student Records, for only as long as required to satisfy applicable federal and state record retention requirements. Upon the expiration of such period of time requiring retention, the data will be securely de-identified or destroyed.
11. Unauthorized Access or Disclosure
In the event of an unauthorized disclosure of a user’s personal information or Student Records (collectively, “Records”), CPM shall report such disclosure to the affected user(s) (or parent if applicable) within twenty-four (24) hours of learning the security, confidentiality, or integrity of such Records was, or is reasonably believed to have been, compromised. If applicable, CPM and the school or school district shall work together to provide notice to the affected individuals.
12. Accessing and Correcting Your Information
At any time, you may review your personal information (or your student’s personal information) maintained by us, require us to correct or delete such information and/or refuse to permit us from further collecting or using the information. Please submit an e-mail to the address below in the “Contacting Us” section. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make any corrections.
CPM does not permit children under the age of 13 (“child” or “children”) to create an account without the consent and at the direction of a parent or school. Please contact us at the address below in the “Contacting Us” section if you believe we have inadvertently collected information from a child under age 13 without the appropriate consent so that we may delete the information as soon as possible.
This section hereby notifies parents of: (1) the types of information we may collect from and about children; (2) how we use the information we collect; (3) our practices for disclosing that information; (4) our practices for notifying and obtaining parental consent when we collect personal information from children, including how parents may revoke consent; and (5) all operators that collect or maintain children’s information through this Website.
Information We Collect from Children. Children can access many parts of the Website and its content and use many of its features without providing us with personal information. However, some Licensed Content eWorkspace and features are available only to registered users (which may include children) which requires us to collect certain information, including personal information, from them. In addition, we use certain technologies, such as cookies (described above), to automatically collect information from users (including children) when they visit or use the Website. We only collect as much information about a child as is reasonably necessary for the child to access and use the Website, and we do not condition a child’s participation on the disclosure of more personal information than is reasonably necessary.
Information We Collect Directly. If a school contracts with CPM to make CPM’s Licensed Content and Website available to its students, the school will provide CPM with certain Student Records (defined above) for the creation of user accounts or the school will create user accounts for its students.
How We Use Your Child’s Information. We may use the personal information we collect from your child to register the child for the Licensed Content for his/her grade level or class, and provide the Licensed Content and Website for your child’s use.
Our Practices for Disclosing Children’s Information. Please see the “Disclosure of Your Information” section above.
Accessing and Correcting Your Child’s Personal Information. Please see the “Ability to Correct or Access Student Records” and “Accessing and Correcting Your Information” sections above.
Operators that Collect or Maintain Information from Children. CPM does not use any third party providers who collect or maintain any information from children.
14. International Users
15. Contacting Us
This policy was last modified on October 15, 2020.