The Hab Lessons Privacy Policy
Effective: 1 March 2018
This website is developed and maintained by 10 Fathoms Down Limited, an Irish Limited Corporation, Registration No. 604274, trading as The Hab Lessons (hereinafter “The Hab Lessons,” “we” or “us”). This Privacy Policy communicates our Privacy practices to parents, teachers, and schools and school district administrators, collectively “you,” who license our products and services for either your own use or the use of your students. Please read this Privacy Policy carefully. By continuing to interact with our digital properties, you agree to the practices described in this Privacy Policy on behalf of yourself and your students.
When you visit our
This Privacy Policy applies to thehablessons.com, thehablessons.net, associated subdomains, our software and apps and covers information collected in connection with access and use of our digital properties. This Privacy Policy applies whether access or use of the digital properties is via
PLEASE NOTE: While most of thehablessons.com and the hablessons.net (hereinafter “the sites”) are general audience websites through which we do not knowingly collect information from children under 13 (“Children” and each, a “Child”), portions of the sites, certain subdomains, our software, and our apps are directed to children under 13. These subdomains, software, and apps contain teaching and learning resources designed for students in 6th through 12th grades. Students may access those digital properties directed to children only after their parent, teacher or school or school district administrator has entered into a license with The Hab Lessons and has provided the students with an access code. The subdomains, software, and apps that are directed to children will follow our Children’s Privacy Policy. In addition, our use of student information is described in Section 7. How
- Changes to this Privacy Policy
We ask that you periodically review our Privacy Policy to be sure you are familiar with the most current version. The Policy will state its effective date, which is the most recent date on which we revised the Policy. The Hab Lessons reserves the right to make immaterial changes to our Privacy Policy that will not affect The Hab Lesson’s use of a user’s personally identifiable information at any time without any notice to you other than posting any such changes in a revised Privacy Policy on our digital properties. If we make material changes to this Privacy Policy that increase our rights to use personal information we have previously collected about you, we will obtain your consent for those changes, as they relate both to your information, and to your students’ information, either through an email to your registered email address, or by prominent posting on our digital properties. If such changes occur, you will be asked to consent to these changes before continuing use of relevant digital properties.
- Information Collected by The Hab Lessons
The Hab Lessons collects information about you when you interact with our digital properties. Our digital properties are directed toward two audiences:
- Parents, Teachers or Administrators of a class, school or school district (collectively, “Non-Student Users”); and
- Students
Our privacy practices, including the type of data we collect, vary by digital property and audience. For detailed information on how we handle student information, please see Section 7. How
We may automatically collect information about the devices you and your students use to interact with our digital properties and how you interact with our digital properties. The information we automatically collect may include you and your students’ IP addresses, device identifiers, web browser types and versions, approximate locations based on IP addresses, search terms and results within the Site, date, time, and pages viewed, and your languages.
The Hab Lessons digital properties do not collect personal information about your online activities over time and across third-party websites or online services. Therefore, “do not track” signals transmitted from web browsers do not apply to our digital properties, and we do not alter any of our data collection and use practices upon receipt of such a signal.
Thehablessons.com provides information about our products, services, and resources for teachers or school or school district administrators. In addition, certain subdomains of thehablessons.com provide direct access to these products, services, and resources for Non-Student Users who have licensed these products. In order to use many of these features, tools
- How Does The Hab Lessons Use The Information Collected About Non-Student Users?
The Hab Lessons may use the information it collects about non-student users for a number of purposes, including:
- To manage The Hab
Lessons’s everyday business needs, such as administration and improvement of our digital properties; - To communicate with parents, teachers, and schools and school district administrators, and support customer communications;
- To offer you information and promotional material about the products and services you see on our digital properties;
- To analyze the performance and functioning of the digital properties, including to test, correct and improve our content, applications
and services; - To develop new applications, products
and services; - To research how users interact with the digital properties and to perform other market research;
- For investigation of information security and information asset protection-related incidents; and
- To prevent fraud or other potentially illegal activities, to enforce our Terms of Service, to comply with all applicable laws and The Hab Lessons’ corporate reporting obligations, and to enforce The Hab Lessons’ agreements.
- To analyze academic and learning outcomes and preferences
- For external academic research and scholarship
The Hab Lessons does not retain usage information from users of any demonstration or trial versions of its products after the conclusion of the trial period. If users of demonstration or trial versions of such products provide contact information, we may use that contact information to communicate with you to provide additional information and promotional materials.
For detailed information on how we handle student information, please see Section 7. How
- When does The Hab Lessons Share Your Information?
The Hab Lessons may share your information with third parties who perform services and functions on our behalf to support our interactions with you including, for example, by fulfilling information requests, administering surveys or contests, providing necessary technical services, or communicating with you. However, all such third parties have no independent rights to your information and are prohibited from using your information in any way that contradicts The Hab Lessons’ privacy policy.
The Hab Lessons may share your information with third parties, including law enforcement authorities, to:
- Enforce its Terms of Use;
- Protect The Hab Lessons’ property, services
and legal rights; - Prevent physical harm to the persons or property of others;
- Prevent fraud or potentially illegal activities against The Hab Lessons and others;
- Support auditing, compliance, and corporate governance functions;
- Test, correct, and improve our content, applications, and services;
- Develop new applications, products, and services;
- Analyze academic and learning outcomes and preferences;
- For external academic research and scholarship;
- Comply with subpoenas, court orders, or similar legal processes, including from law enforcement agencies, regulators and courts; and
- Comply with any and all applicable laws.
The Hab Lessons also may share any personally identifiable or other information about you that The Hab Lessons obtains with any or all of its subsidiaries and affiliates in order to accomplish these purposes.
The Hab Lessons also may provide to third parties, including other businesses and members of the public, aggregated statistical data showing general usage patterns and statistics about our digital properties, interactions, and transactions. This data does not personally identify you or provide specific information about individual usage.
- What If You Don’t Want The Hab Lessons to Automatically Collect Your Information?
The Hab Lessons may begin collecting information as soon as you or your students visit our digital properties. By using our digital properties, you permit The Hab lessons to collect and use your information in accordance with this Privacy Policy. By directing your students to our digital properties, you consent to our collection and use of their information in accordance with this Privacy Policy and, in particular, with Section 7. How
Many Internet browsers and mobile devices allow you to block the transmission of information, such as your IP address or geolocation information, or to block the installation of cookies. You may choose to enable these options. However, enabling these options may prevent you from using many of the core features and functions available on our digital properties.
You can review, modify, and delete certain information related to your use of our digital properties by accessing your Hab Lessons account. You can unsubscribe to email, text, or other messages in your account settings or by following the instructions contained within the message. You can also ask us to update your information by contacting us at contact@thehablessons.com.
- How does The Hab Lessons Use Cookies?
When you use our digital properties, The Hab Lessons may place pieces of code, commonly referred to as “cookies,” or similar technology on your devices. Carnegie Learning uses cookies to collect information about how you use our digital properties, to save your password so you don’t have to re-enter it each time you visit our digital properties, to deliver content specific to your interests, and to track the pages you’ve visited. These cookies allow us to use the information we collect to customize your Hab Lessons learning experience so that your visit to The Hab Lessons is as relevant and as valuable to you as possible. Certain browsers may allow you to disable such cookies. However, disabling cookies from The Hab Lessons may prevent you from using various features of our digital properties.
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7. How
The Hab Lessons is committed to protecting information about all of its customers. As part of this commitment, we work with educational institutions that must comply with the Family Educational Rights and Privacy Act (FERPA) to help ensure student education record data is handled in a manner consistent with the applicable educational institution’s FERPA policy.
The Hab Lessons collects and maintains information on students for the benefit of teachers, and schools and school district administrators who license our products and services. We collect student information through our digital properties that provide teaching and learning resources designed for students in 6th through 12th grades including, but not limited to thehablessons.com and thehablessons.net.
Students cannot independently access our teaching and learning resources. The parents, teachers, and schools and school district administrators who license our products and services provide students with an access code required to create an account at carnegielearning.com or to use our apps. Information collected about students may include:
- First and Last Name;
- Email address;
- The class and school where a student is enrolled;
- Photos through the students’ profiles;
- Information used to customize word problems including broad categories of interest, such as sports or music, and the first names of student’s friends; and
- Data on student activity within the digital properties, including answers provided, errors, hint requests, timing information, progress within the system, and inferences made from
the this data about student knowledge.
Schools, school districts, parents, and students may ask to review the information that The Hab Lessons has collected and retained about a particular student, as well as request its deletion by contacting us at privacy@thehablessons.com.
The Hab Lessons may use the information collected about students to:
- Help students reset their passwords;
- Investigate information security and information asset protection-related incidents;
- Test, correct and improve our content, applications
and services; - Develop new applications, products
and services; - Analyze academic and learning outcomes and preferences;
- Personalize the teaching and learning resources available across the digital properties to improve student instruction and meet individual student needs;
- Provide reports to parents, teachers or school or school district administrators at the family, class, school, or district level;
- Support parents, teachers or school or school district administrators implementing our products or using our services;
- Monitor the use of our products and performing such analyses as might be necessary or helpful in improving product performance, efficiency, and security;
- Research how students use the digital properties and analyze the educational effectiveness of our products and services to contribute to general knowledge about how students learn;
- Provide reports to parents;
- For external academic research and scholarship;
- Enforce our Terms of Use; and
- Use the information as may be required or permitted by legal, regulatory, industry self-regulatory, insurance, audit or security requirements.
In some cases, the parents, teachers, and schools and school district administrators who license our products and services enter into additional reporting or research agreements for the provision of reports that contain aggregate data by demographic categories (gender, ethnicity, free or reduced lunch status, etc.). In such cases, the teachers, schools and/or school district administrators may provide The Hab Lessons with the information required to provide these reports, which may personally identify students. When such agreements are in place, reports containing this information are provided only to the teachers, and schools and school district administrators authorized to receive that information. In such cases, data is held securely and only The Hab Lessons’ employees directly involved in producing these reports have access to students’ personally identifiable information.
The Hab Lessons does not collect or maintain any demographic, academic or other school record information about students, teachers or administrators unless it has a separate reporting or research agreement.
We may have different contractual terms and privacy policies in place with some of our customers. Those other terms and policies may amend this Policy for information collected or released under those terms, but they will never contradict the policy terms described here. If you have any questions as to what legal agreement or privacy policy
- Use of Data for Research
The Hab Lessons uses de-identified and aggregate data about students’ use of our digital properties for product development, research or other purposes. To de-identify data, we remove all direct and indirect personal identifiers. These identifiers include, but are not limited to, name, ID number, teacher name, class and school identifications. The Hab Lessons agrees not to attempt to re-identify any de-identified data. We may store de-identified data indefinitely.
Schools, school districts
In addition, for research and other purposes, The Hab Lessons may transfer de-identified data to third parties. For example, we may share information such as problems attempted, answers or hint requests for each step of the problem, and associated time stamps. We review all requests for such de-identified data sets, and we require all recipients of de-identified
In connection with research studies, The Hab Lessons and/or its partners may publish or discuss aggregate data about student performance and results. Such publications never reference individual information, only aggregate statistics. Research projects that make use of such aggregate data are reviewed by an Institutional Review Board (IRB) which is responsible for approving the goals and procedures of the study, including those related to maintaining
- How Does The Hab Lessons Protect My Information?
The Hab Lessons has implemented an information security program with numerous measures, including administrative, technical and physical controls that are designed to reasonably safeguard information that can individually identify you against the loss, misuse and alteration of the information under our control. We recommend that you do not share your password with anyone.
Data Retention, Access, and Security
The Hab Lessons requires that all information in its possession and in the possession of any subcontractors or agents to which we may have transferred the information, is destroyed or de-identified within 90 days of the termination of our contract(s) with the customer or at the request of the customer. Any information held by The Hab Lessons will be made available to the customer upon request.
- California Privacy Rights
The Hab Lessons does not share any personal information with third parties for the third parties’ direct marketing purposes. If this practice changes, we will notify you by prominent posting on our digital properties.
The portions of the digital properties directed to students and children under 13 do not enable or have a forum for the posting or sharing of content or information.
- CHILDREN’S PRIVACY POLICY
While most of carnegielearning.com is a general audience website that does not knowingly collect information from children under 13 (“Children” and each, a “Child”), portions of the digital properties, are directed to children under 13, and we may collect information directly from children under 13 in connection with those portions of the digital properties. Therefore, The Hab Lessons provides this Children’s Privacy Policy to explain our privacy practices with respect to children under 13 who access and use our digital properties.
The Hab Lessons collects personal information from children under 13 for the use and benefit of teachers or school or school district administrators, and for no other commercial purpose. We limit the use of information from children under 13 to the educational context authorized by the school or parent.
Through this Privacy Policy, we provide each school with all the notices required under COPPA, contained within this Privacy Policy. Parents also can request a copy of these notices and request access to their child’s personal information to review and/or have the information deleted by contacting privacy@thehablessons.com.
Collection & Use of Information from Children Under 13
The information we directly collect on children under 13 includes:
- First and Last Name;
- Email address;
- The class and school where a student is enrolled;
- Photos through our mobile apps;
- Information used to customize word problems including broad categories of interest, such as sports or music, and the first names of student’s friends; and
- Data on student activity within the digital properties, including answers provided, errors, hint requests, timing information, progress within the system, and inferences made from this data about student knowledge.
We do not enable children under 13 to make their personal information publicly available without the express consent of the administrator, teacher or parent of the student holding a licensed seat.
The Hab Lessons uses the information collected on children under 13 to:
- Help students reset their passwords;
- Personalize the teaching and learning resources available on our digital properties to improve student instruction and meet individual student needs;
- Provide reports to parents, teachers or school or school district administrators at the class, school, or district level;
- Support parents, teachers or school or school district administrators implementing our products or using our services;
- Monitor the use of our products and perform such analyses as might be necessary or helpful in improving product performance, efficiency, and security;
- Research how students use the digital properties and perform analysis directed at improving the educational effectiveness of our products and services and to contribute to general knowledge about how students learn; and
- Provide reports to parents.
We may automatically collect information about the devices children under 13 use to interact with our digital properties. The information we automatically collect may include IP address, device identifier, web browser type and version, photos added in our mobile apps, pages and activities viewed, and the date and time of use. Any usage information, device identifier, or other persistent identifier we collect is used for the sole purpose of providing support for the digital properties’ internal operations.
Disclosure of Information from Children Under 13
The Hab Lessons may rely on third party service providers who provide support for the internal operations of the digital properties, such as hosting the website, designing and/or operating our digital properties’ features, tracking analytics, or performing other administrative services. These third party service providers are held to the same obligations as The Hab Lessons with regard to information from children under 13, do not disclose or use information for any other purpose, and are subject to the terms of this agreement.
- Transfer of Assets
In the event of any acquisition, reorganization or merger of The Hab Lessons or its assets, your information may be transferred as part of the transaction to an assignee. The assignee will assume and be subject to the same obligations of the Terms of Service and this Privacy Policy as The Hab Lessons. You acknowledge that such transfers may occur, and that any acquirer of The Hab Lessons may continue to use the information you provide to us as set forth in this Privacy Policy and in our Terms of Use. In the unlikely event that the likelihood of us going out of business or entering bankruptcy is imminent, we will provide you with thirty (30) days’ notice to use the Service and after such 30 days all data will be transferred to the assignee.
- Contact Us
For any questions about The Hab Lessons, our privacy policies, or to request review and/or removal of information collected by The Hab Lessons, please contact us at:
10 Fathoms Down Limited
Ste 63, 20 Harcourt Street
Dublin 2 Ireland:
Email: contact@thehablessons.com
For questions about ongoing or potential research projects, please email research@thehablessons.com
To report technical issues with the Site or apps, or to submit feature requests, please Contact Us using the appropriate form.