Privacy

NEURON LEARNING PRIVACY NOTICE

Privacy Policy

Effective May 25, 2018

Neuron Learning LLC (“Neuron”, “we”, or “us”) recognizes the importance of privacy. We want you to feel confident using our services, and this privacy policy (“Policy”) is to help you understand and describe how we collect, use, and disclose information that we obtain about users of our websites, services, plug-ins, software or other Downloadable Tools (all of which we refer to as the “Platform”). This Policy describes the following:

  • What information we collect and how it is collected;
  • How we use the information;
  • With whom we may share information;
  • Legal basis for processing the information;
  • Your rights and choices;
  • Security and storage of the information;
  • Third party websites;
  • Users outside the United States  and
  • Changes to the Policy and Contact Information.

Throughout this document, we will use a few terms to describe various roles. Neuron students have been  signed up to use our service and have an account. Neuron authorized persons are people who take responsible for the students using our services in school, home, learning centers and other locations

Information We Collect

We collect information about you directly from you and automatically through your use of our Platform. We may combine information automatically collected with other information that we have collected about you including from publicly available sources.
The types of data that may be processed are listed below. As indicated below, not every item listed below is required to be entered for a student. Accordingly, the actual data collected in respect of a student varies depending on what a parent, instructor or educational administrator enters.

Student Information

We require the following information to to register a student on MySciLEARN:

First Name, Last Name
Date of Birth
Student Username
Student Password
Grade
Gender
English Language Learner (yes or no)
Special Education (yes or no)
School

The following information can be entered for a student while registering but is not required:

Middle initial
Student ID
Parent email
Race/Ethnicity
Title 1
Migrant Student
Dyslexia
Down Syndrome
Phonological Disorder
Autism
Asperger’s Syndrome
Expressive Communicative Disorder
Developmental Delay
Special Learning Disability
Attention Deficit
Rett’s Disorder
Childhood Disintegrative Disorder
Receptive Communication Disorder

Training & Progress Data:

Reading Progress Indicator assessment information (if used by the customer):
o Grade Equivalent Scores
o National Percentile Scores
o Reading Proficiency Levels – Struggling, Emerging, Proficient, Advanced
o Gain scores are reported in grade equivalent scores and percentile scores
(only for Fast ForWord as gains can only be calculated with both a pre- and post-test.)

Fast ForWord products
Individual exercise progress & results
Attendance (date and time that the student worked on the exercises)
Participation (amount of time per day working on the exercises)
Percentage of exercise content mastered (daily, weekly, monthly)
Exercise completion details level by level
Number of exercise trials
Student errors

Reading Assistant products
Participation
minutes on RA per week
number of reading selections completed per week
time usage per session activity
Think About It questions score
Comprehension quiz score
Fluency score – words correct per minute
Performance Level – a measure that evaluates both fluency and
comprehension performance on a reading selection
Reading Level High Score – highest reading level mastered by the student
Student Audio recordings
Student Errors – words to practice

The categories of Data Subject to whom the Company Personal Data relates

The categories of Data Subjects include students (pre-K and up) and may include parents, instructors and education administrators.

In order to help you protect yourself and your information, we encourage you to provide only that information that is necessary for using our Platform. For example, to set up as a participant you may only need to provide us with a name, email address, date and time.

Neuron is not directed to children under six (6) years or age and we do not knowingly collect personal information from children under 6.

Information You Provide Voluntarily

  • Participant Information. When a Neuron participant uses Neuron you as the responsible person voluntarily give us certain information. This can include your name, email address and phone number; email addresses of other people; participant’s information ; and any other information you provide us or as required by  Neuron Learning.
  • Account Information. We do not collect information from other sources
  • Billing Information. If you purchase a premium version of Neuron, our third-party payment processors will collect and store your billing address and credit card information. We do not store your credit card number, card type and the expiration date.

Information Collected Automatically

Like many websites, we and our service providers use cookies, web beacons and other technologies to receive and store certain types of information when you interact with us through your computer or mobile device subject to your opt-out preferences (see Your Rights and Choices section below). Using these technologies helps us customize your experience with our Services, improve your experience, and tailor marketing messages. Here are some of the types of information we collect:

  • Log & Device data. When you use Neuron, our servers automatically record information (“log data”), including information that your browser sends whenever you visit our Website. This log data may include your web address you came from or are going to, your device model, operating system, browser type, unique device identifier, IP address, mobile network carrier, and time zone or location. Whether we collect some or all of this information often depends on what type of device you’re using and its settings. For example, different types of information are available depending on whether you’re using a Mac or a PC, or an iPhone or an Android phone. To learn more about what information your device makes available to us, please check the policies of your device manufacturer or software provider.

Cookies and Other Tracking Mechanisms

  • Cookie data. Depending on how you’re accessing our products and subject to your opt-out preferences, we may use “cookies” (a small text file sent by your computer each time you visit our website, unique to your Neuron account or your browser) or similar technologies to record log data. When we use cookies, we may use “session” cookies (that last until you close your browser) or “persistent” cookies (that last until you or your browser delete them). For example, we may use cookies to keep you logged in to Neuron. Some of the cookies we use are associated with your Neuron account (including personal information about you, such as the email address you gave us), and other cookies are not. To help us make emails more useful and interesting, we often receive a confirmation when you open email from Neuron if your computer supports such capabilities. You can opt out of receiving emails from us. Please see the Your Rights and Choices section below.
  • Other Web Site Analytics Services. Subject to your opt-out preferences (see Your Rights and Choices below), we use third party service providers such as Google Analytics to provide certain analytics and user interactions services to Neuron in connection with our operation of our Platform, including the collection and tracking of certain data and information regarding the characteristics and activities of visitors to Neuron. You may opt-out of Google Analytics cookies using Opt-Out Features on their respective websites.

How We Use Your Information

We may use information that we collect about you, including personal information, to:

  • Provide the Neuron Service. We will use your information to provide our Platform and services to you; to facilitate scheduling; to manage your account; to respond to your inquiries; and for other customer service and support purposes. We use the payment information you provide to us in order to alert you of past, current, and upcoming charges, to allow us to present the billing history to you on your billing page in the platform, and to perform internal finance processes, such as looking the status of a credit card charge. In the event of a credit card dispute, we also share account information with your bank to verify the legitimacy of a charge.
  • Understand and improve our products. We will perform research and analysis about your use of, or interest in, our products, services, or content, or products, services or content offered by others. We do this to help make our products better and to develop new products.
  • Communicate with you.
  • Service related communications. We may send you service and administrative emails to ensure the service is working properly. We will also email you regarding your calendar appointments. These messages are considered part of the service and you may not opt out of these messages.
  • Promotional. Subject to your opt-out preference, we may send you emails about new product features or other news about Neuron or on topics we think would be relevant to you. You may opt out of receiving these communications at any time. Visit the Your Rights and Choices section below.
  • Responding to your requests. We will also use your information to respond to your questions or comments.
  • Administrative. We may contact you to inform you about changes in our services, our service offering and other important service related notices, such as changes to the Policy or about security or fraud notices.
  • Advertising. Subject to your opt-out preferences, we may develop and display content and advertising tailored to your interests on our services and other sites. See Your Rights and Choices below.
  • Protecting Rights and Interests. We will use your information to protect our rights and interests as well as the rights and interests of our users and any other person, as well as to enforce this Policy or our Terms of Service.
  • Legal Compliance. We may use your information to comply with applicable legal or regulatory obligations, including informal requests from law enforcement or other governmental authorities.
  • Other. We also may use your information to manage our business or perform functions as otherwise described to you at the time of collection subject to your consent. Please read all online agreements carefully before accepting them.

With Whom We May Share Your Information

We do not share your personal information with others except as indicated within this Policy or when we inform you and give you an opportunity to opt out of having your personal information shared.

We will share information we collect about you, including personal information, in the following ways:

  • With third party service providers, agents, or contractors. We use other companies, agents or contractors (“Service Providers”) to perform services on our behalf or to assist us with providing services to you. For example, we may engage Service Providers to process credit card transactions or other payment methods. Or, we may engage Service Providers to provide services such as marketing, advertising, communications, infrastructure and IT services, to provide customer service, to collect debts, and to analyze and enhance data (including data about users’ interactions with our service). These Service Providers may have access to your personal or other information in order to provide these functions. In addition, some of the information we request may be collected by third party providers on our behalf. We require our Service Providers to agree to take reasonable steps to keep the personal information that we provide to them secure. We do not authorize them to use or disclose your personal information except in connection with providing their services.
  • Affiliates. We may disclose your information to current or future affiliates or subsidiaries for research, marketing, and other purposes consistent with this Privacy Policy.
  • To comply with legal process or to protect Neuron and our users and students. We may share your data: if we believe that disclosure is reasonably necessary to comply with a law, regulation, legal or governmental request; to respond to a subpoena, court order, warrant, or other legal process; to enforce applicable terms of use or this Policy, including investigation of potential violations thereof; to protect the safety, rights, or property of the public, any person, or Neuron; to detect, prevent, or otherwise address, security, or technical issues or illegal or suspected illegal activities (including fraud); or as evidence in litigation in which we are involved, as part of a judicial or regulatory proceeding.
  • Business Transfers. We may engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding that involves the transfer of the information described in this Policy. In such transactions, customer information is typically one of the business assets that is transferred or acquired by a third party. If we are acquired by or merged with another company, if we sell or transfer a business unit or assets to another company, in the unlikely event of a bankruptcy proceeding, or as part of any other similar business transfer, you acknowledge that such transfers may occur.
  • Aggregate or De-identified Information. We may disclose aggregate, anonymous, or de-identified information about users for marketing, advertising, research, compliance, or other purposes.

Legal Basis for Processing Your Information

We rely on the following legal grounds to process your personal information:

  • Consent. We may use your personal information as described in this Policy subject to your consent. To withdraw your consent, please contact us at support@NeuronLearning.com. You may also refrain from providing, or withdraw, your consent for cookies. Please see Your Rights and Choices below for more information on opt-outs.
  • Performance of a contract. We may need to collect and use your personal information of Neuron students and Neuron Users, as applicable, to perform our contractual obligations.
  • Legitimate Interests. We may use your personal information for our legitimate interests to provide our Platform and services and to improve our services and the content on our Platform. We process information on behalf of our customers who have legitimate interests in operating their businesses. We may use technical information as described in this Policy and use personal information for our marketing purposes consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable law.

Your Rights and Choices

  • Account. In order to keep your personal information accurate and complete, you can log in to review and update your account information, including contact and billing information, via your account settings page. You may also contact us to request information about the personal data we have collected from you and to request the correction, modification or deletion of such personal information. We will do our best to honor your requests subject to any legal and contractual obligations. If you would like to make a request, cancel your account or request we delete or no longer use your account information to provide you Services, contact us at support@NeuronLearning.comor the address set forth at the end of this Policy. Subject to applicable law, we will retain and use your account information only as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
  • E-mail. As described above, if you do not wish to receive promotional emails from us, you may opt out at any time by following the opt-out link contained in the email itself. Please note that it may take up to ten (10) days to process your request. Please also note that if you opt out of receiving marketing communications from us, we may continue to send to you service-related emails which are not available for opt-out. If you do not wish to receive any service-related emails from us, you have the option to deactivate your account.
  • Cookies. You may also refrain from providing, or withdraw, your consent for cookies. Your browser’s help function should contain instructions on how to set your computer to accept all cookies, to notify you when a cookie is issued, or to not receive cookies at any time.
  • Third Party Analytics Services. Some of the services used provide the ability to opt-out. You may opt-out of Google Analytics’ and any other services using Opt-Out Features on their respective websites.
  • The Google Analytics service is provided by Google Inc. You can opt-out from Google Analytics service from using your information by installing the Google Analytics Opt-out Browser tool: tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: www.google.com/policies/privacy.
  • Additional Rights. Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal data, such as the right to complain to your local data protection authority.

Security and Storage of Information

We have taken reasonable steps to help protect the personal information we collect. These measures include using SSL encryption and two-factor authentication. Unfortunately, no measures can be guaranteed to provide 100% security. Accordingly, we cannot guarantee the security of your information in all circumstances.

You should take steps to protect against unauthorized access to your device and account by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

We retain the personal data we collect for so long as reasonably necessary to fulfill the purposes for which the data was collected, to perform our contractual and legal obligations, and for any applicable statute of limitations periods for the purposes of bringing and defending claims.

Third-Party Links

Our Platform may contain links to third-party websites and applications. Subject to your opt-out preferences (see Your Rights and Choices), we may also use third-party advertisers, ad networks, and other advertising, marketing, and promotional companies, to serve advertisements on our websites. Any access to and use of such linked websites and applications is not governed by this Policy but instead is governed by the privacy policies of those third parties. We do not endorse these parties, their content, or any products and services they offer, and we do not endorse these parties, their content, or any products and services they offer, and we are not responsible for the information practices of such third-party websites or applications.

Users Outside the USA

Our application and database servers are located with Amazon Cloud Services in the United States. Amazon Cloud Services has certified with the Department of Commerce that it adheres to the Privacy Shield Principles under the EU-U.S. and Swiss-U.S. Privacy Shield frameworks. If you are an individual located in the European Economic Area, the United Kingdom, Canada or another jurisdiction outside of the United States with laws and regulations governing personal data collection, use, and disclosure that differ from United States laws, please be aware that information we collect (including through the use of methods such as cookies and other web technologies) will be processed and stored in the United States or in other countries where we or our third-party services providers have operations. By submitting your personal information to Neuron and using Neuron, you expressly consent to having your personal data transferred to, processed, and stored in the United States or another jurisdiction which may not offer the same level of privacy protection as those in the country where you reside or are a citizen.

Changes to the Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, and if we do we’ll post any changes, including any material changes, on this page, so please be sure to check back periodically. If you continue to use Neuron after those changes are in effect, you agree to the revised Policy.

Contacting Us

If you have any questions or comments about this policy, please contact us at support@NeuronLearning.com or Granard Business Centre, Bunns Lane, Mill Hill, London, NW7 2DZ, United Kingdom.