Last updated: February 24, 2019
- Information We Collect and How We Use It
- Sharing Information with Third Parties
- Information Security
- Your Rights and Access to Your Information
- Contact Us
Generally, software, services, and programs delivered and accessed through the Internet necessarily involve the transmission and processing of personal data, sometimes on an international basis, depending, for example, on where the user is located. When personal information is provided to Coursetune through websites or mobile applications, the information is processed and stored on servers located in the United States. By using the websites and mobile applications, you acknowledge and give Coursetune authorization to such transfer, processing and storage on behalf of yourself, your organization, and other users as applicable.
Coursetune complies with the applicable FERPA requirements governing the use and redisclosure of Personal Information from Education Records. Coursetune does not collect or retain any personal or identifiable STUDENT data in the education records. Coursetune acknowledges that its customers have a statutory duty to maintain the privacy of such records. Coursetune uses education data as agreed upon in the Service Level Agreement (“Contract”), meaning the customer has direct control over personal information from education records. Education data are not redisclosed without your permission.
Information We Collect and How We Use It
Coursetune users are administrative and faculty members, stakeholders, business professionals, and accrediting associations. Coursetune is not a student-facing application and therefore does not collect any personal or identifiable information of either adult learners nor children. We collect user personal information (first name, last name, organizational email) when accounts are created and invitations to login are distributed by either Coursetune or your organization. Accepting an email invitation link and proceeding through login completes a double opt-in to customer communications in the form of notifications requested by the user, product updates, and announcements. Users may unsubscribe at any time. See “4. Your Rights and Access to Your Information” for more on our opt-in policy.
Coursetune only collects information that is relevant and not excessive for the purposes for which it is to be processed. Required personal information includes full name and e-mail address; an optional title or organization department is available to assist in the customer’s organization and process. Only the required information is necessary for Coursetune to complete the service provided. Data generated by the website or mobile application from which personally identifiable information and attributes about any user may be used by Coursetune for lawful purposes, including, without limitation, product and service improvement or development, general product and service analysis, benchmarking, development of best practices, and/or educational research or statistical assessment. To provide customers with the best products and services possible, Coursetune applications do not honor CalOPPA Do Not Track requests while within the product. Usage of the product indicates consent to this exception.
When you use our applications, we automatically collect additional information such as the type of desktop or mobile device that is being used, operating system version, and the device identifier (or “UDID”).
Links to Third Party Sites:
Sharing Information with Third Parties
Coursetune does not release personal information collected or received in the websites or mobile applications to any unrelated third parties for promotional purposes. We may, however, share anonymous, aggregated product usage data with unrelated third parties, and share personal information as described below:
We may disclose information (including personal information) collected from our websites and mobile applications with our local authorized Coursetune representatives for sales and support purposes. We require these authorized representatives to comply with this policy. Coursetune will not share your contact information with other businesses except service providers and successors, as described below.
We may share your information with our service providers—that is, organizations providing services to support Coursetune functions, such as our hosting services provider, mail and email processing providers, payment processing providers, and research and support providers. All such service providers are bound by contract to refrain from using the personal information we collect from you for any purpose other than providing the specified service to Coursetune.
Laws and Legal Rights
When personal information is provided to Coursetune through websites or mobile applications, the information is processed and stored on servers located in the United States. These servers, like all authorized 3rd parties Coursetune uses, comply with the GDPR and DPA security requirements. In addition, Coursetune utilizes security measures appropriate to the sensitivity of the data and level of risk to secure personal data against loss or any form of unlawful processing. Access to your data is controlled by both physical and logical controls.
These measures include, but are not limited to
- Establishing and maintaining industry standard technical and organizational measures to help to protect against accidental damage to, or destruction, loss, or alteration of the materials;
- Establishing and maintaining industry standard technical and organizational measures to help to protect against unauthorized access to the Services and materials; and
- Establishing and maintaining network and internet security procedures, protocols, security gateways and firewalls. 3rd-party software and services are equipped and/or designed with systems intended to prevent industry known system attacks (e.g., hacker and virus attacks) and unauthorized access to confidential information.
If you have any questions about security contact us at firstname.lastname@example.org.
Cookies and other Tracking Technologies
User activity is stored in a relational database and used for reporting and analysis, aiding Coursetune in services and support. We do not give user information to third parties, except to service providers who engage in support and assistance of our websites and mobile application, or disassociated from your IP address or other personally-identifiable data, or as authorized or directed by the customer organization.
With respect to any complaints relating to this policy that cannot be resolved through our internal procedures, we will cooperate with appropriate regulatory authorities to resolve such complaints. If any of your concerns are not acknowledged within a reasonable time frame (30 days), or have not been addressed to your satisfaction, please contact us at email@example.com.
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Your Rights and Access to Your Information
Under the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA) you have a number of rights with regard to your personal data. You have the right to request from us access to and rectification or erasure of your personal data, the right to restrict processing, object to processing as well as in certain circumstances, the right to data portability.
If you have provided consent for the processing of your data, you have the right (in certain circumstances) to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn.
You have the right to lodge a complaint to the Information Commissioner’s Office if you believe that we have not complied with the requirements of the GDPR or DPA 18 regarding your personally identifiable data.
Coursetune offers customers who provide personal information, through a double opt-in process, with the opportunity to withdraw consent with respect to the information they submitted at any time (“unsubscribe”), in which case such personal information will not be further processed. Our email programs allow you to choose to receive or stop receiving communications from us. We honor a “once out – always out” policy. Each secondary email we send to our recipients contains ‘Unsubscribe’ instructions. Once you unsubscribe, you are unsubscribed from that type of communication until we are explicitly told in writing that you want to opt back in. You may unsubscribe from email programs at any time by following the Unsubscribe instructions provided in the link at the bottom of the email.
You may at any time view your personally identifiable information within your user profile and request information be updated through your institution’s Coursetune administrator for the purposes of correcting or updating your profile. We will respond within a reasonable timeframe to any requests from your administrator regarding your personal data. You may also request to remove your identity from institutional areas of the platform. However, we will retain your profile information for as long as your account is active or as needed to provide services to you or to the organization that provides your license. If you request to remove your profile from institutional areas, Coursetune will continue to retain and use your information as necessary to comply with any legal obligations, resolve disputes, or enforce our agreements. If personal information is removed, all your educational data contributions will be retained under an “anonymous” or “previous” user byline and may remain within Coursetune databases and archives subject to our data retention policies and any agreements with the organization that provides your license.
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