This site provides you with access to Kurzweil Education's Data Management System. This system is an integral component of Kurzweil Education's curriculum products and provides valuable reporting, instructional recommendations, and other resources used by teachers and other instructional leaders in conjunction with Kurzweil Education's curriculum with the goal of improving student performance.

This statement describes the privacy and security practices Kurzweil Education employs for this site. We have adopted these practices to protect you, the students, and the school district, and to enable each of us to comply with applicable legal requirements. Use of this site requires district acceptance of the practices outlined in this statement.

Two types of personally identifiable information are used on this site: your personal data and student data.

Your Personal Data

Collection: Kurzweil Education collects information from you as you use this site. For example, you must enter certain personally identifiable information, including your name, e-mail address, and phone number. We use this information to verify your identity and prevent unauthorized access to your account and to contact you in connection with your use of this site.

In addition to the information you provide, Kurzweil Education collects information about your use of this site through tracking, cookies, and log files, as described in our general Terms of Use statement.

Protection: Because you enter your personal data, you control its accuracy. If you discover that your personal data is inaccurate or if it changes, you may make corrections by notifying us at support@Kurzweil Education.com or 888-399-1995. We will not share your personal data collected through this site with third persons without your consent. However, your personal data will be available to authorized users from your school district who have permission from the school district to access it. We will not use your personal data collected through this site for any purpose other than providing you with access to this site and the associated services. We will use the same security to protect your personal data that we use to protect student data collected through this site.

Student Data

As you use this site, you will enter student data or interact with student data that has already been entered. Federal law (the Family Educational Rights and Privacy Act, "FERPA") allows a school district to release student records to an organization that is "conducting studies for, or on behalf of, educational agencies or institutions for the purpose of developing, validating, or administering predictive tests... [or] improving instruction."

However, FERPA requires limitations on disclosure of those records and implementation of appropriate security measures to protect those records. To help your school district comply with FERPA, Kurzweil Education has adopted certain practices, and requires that educators using this site fulfill certain responsibilities to safeguard student data. The following statement explains our practices and your responsibilities regarding the student data you enter on this site.

Additionally, Kurzweil Education operates in compliance with the Children's Online Privacy Protection Act ("COPPA"). Kurzweil Education will not knowingly collect or use personally identifiable information from anyone under 13 years of age.

Student Data Security and Confidentiality Statement

Purposes of Data Entry: You control what student data is entered on this site. Student data entered on this site should be limited to information that is relevant to the legitimate educational purpose of improving student performance. We will not ask you to enter, and you are instructed not to enter, data about students that is not relevant to this legitimate educational purpose.

Therefore, only a minimum amount of personally identifiable student data required for the setup of the system is requested. We require student first name, student last name, and student identification number. Additional data, not specific to the student, is also required to complete system setup, including the teacher first and last name, class name, grade level, and school name. Student demographic data, for the purposes of optional disaggregated reporting, is requested separately from the initial setup data and is obtained only with written permission from your district.

Use, Disclosure, and Storage: We will use the student data to provide the services to your school district. We will not keep the student data after you or the school district instructs us to delete it. You may not disclose or otherwise use the student data entered on this site for any unauthorized purposes.

We will only disclose student data to authorized employees or representatives of the school district, and will not knowingly disclose the student data to any third person without express written authorization. When, at the request of the district, we acquire assessment or other information, including personally identifiable student data, from a third party source we treat that information with the same confidentiality and security safeguards as though it were provided directly by the district. Additional agreements may be required by the third party to authorize transmission of data to Kurzweil Education.

Your district may from time to time request that Kurzweil Education provide student data to third parties of its choosing. We will do so with written authorization, which acknowledges that Kurzweil Education is providing that data as your district's agent and that once the data is received by the third party, Kurzweil Education no longer has any control over the use or disposition of the data.

We may also use aggregated data in our research and product development. That aggregated, non-personally identifiable data (e.g., summary or statistical data) may be shared with third parties. However, we do not use personally identifiable student data to market any products or services directly to students or their parents.

In the event that Kurzweil Education wishes, from time to time, to release aggregated data that identifies your school or school district by name, Kurzweil Education will enter into a separate agreement with you to authorize release and publication.

We may share Personal Information with our parent company and other affiliated companies. If we enter into a business transition such as a merger, consolidation, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, or dissolution, your Personal Information may be among the assets we transfer. You acknowledge and consent that such transfers are permitted by this Privacy Policy, and that any acquirer of ours or that acquirer's affiliates may continue to collect and use your Personal Information as set forth in this Privacy Policy.

Data Quality: You are responsible for keeping the student data that you enter accurate, complete and up-to-date. If you recognize that student data is inaccurate, incomplete, or out-of-date, you are responsible for correcting it. If you experience problems making corrections to student data, please notify us at support@KurzweilEducation.com and we will assist you with making corrections.

Security Safeguards: We are committed to protecting student data against unauthorized access, destruction, use, modification or disclosure. Protecting student data requires efforts from us and from you. We will implement reasonable and appropriate safeguards when collecting student data from you and when storing that student data in our database and you will observe our security safeguards and exercise reasonable caution when using this site.

Specific institutional and technological security safeguards include:

1. Only Kurzweil Education employees who are authorized to handle student data are able to access the Data Management System.
2. Only school district employees and representatives that the district authorizes as school officials are permitted to access the system. It has a hierarchical permissions system. This means:
   1. A teacher will only be able to see data for his/her class.
   2. A Principal, Coach, or other authorized School User will be able to view all data at a given school.
   3. An authorized district-level employee, such as an Instructional Coordinator or Superintendent, will be able to see all data across the district.
3. Each authorized school official is given a Userid and Password valid only for the duration of the academic year, including a summer program if applicable. You must safeguard your Userid and Password, and not permit any unauthorized access to student data entered or kept in Kurzweil Education's system.
4. Upon written request by the district, Kurzweil Education will destroy any student data for districts who no longer participate in an Kurzweil Education program. Kurzweil Education will provide written verification that the data has been destroyed as requested.
5. If a district has not used any Kurzweil Education product for a period of ten years, Kurzweil Education will provide written notice that the student data pertaining to their district will be destroyed, unless the district requests the records be kept. Upon destruction Kurzweil Education will provide written verification that the data has been destroyed.
6. Kurzweil Education uses industry standard server and network hardware and software to ensure that data is protected from unauthorized access or disclosure.

Although we make concerted good faith efforts to maintain the security of personal information, and we work hard to ensure the integrity and security of our systems, no practices are 100% immune, and we can't guarantee the security of information. Outages, attacks, human error, system failure, unauthorized use or other factors may compromise the security of user information at any time. If we learn of a security breach or other unauthorized disclosure of your PII, we will attempt to notify you so that you can take appropriate protective steps by posting a notice on our homepage (www.kurzweiledu.com) or elsewhere in our Service and we will send email to you at the email address you have provided to us. Additionally, we will notify the primary administrative contact at your school or district by email and telephone and assist with their efforts to ensure your notification.

Any such notice will include:

• The date of the breach.
• The type of information that was subject to breach.
• General description of what occurred.
• Steps we are taking to address the breach.
• The contact person with our Company who you can contact regarding the breach.

When you use this site, you consent to our privacy practices and agree to accept the responsibilities outlined in this statement.

Cookies and Log Files

A cookie is a piece of data stored on the user's hard drive containing information about the user. Cambium Learning uses cookies to assist users in the navigation of the site. Usage of a cookie is not linked to any personally identifiable information while on the site. Once the user closes their browser, the cookie simply terminates. Cambium Learning does not record IP addresses of users.

Links

This web site contains links to other sites. All of these sites have been reviewed by Cambium Learning for integrity and appropriate content. Cambium Learning is not responsible for the privacy practices of these other sites. Cambium Learning encourages its users to read the privacy statements of every web site that collects personally identifiable information. This Cambium Learning Privacy Policy statement applies solely to information which is collected by this web site, www.cambiumlearning.com.

Notification of Changes

The Privacy Policy is subject to change at Cambium Learning's sole discretion. If we decide to change our Privacy Policy, we will post those changes on our Homepage, www.cambiumlearning.com, so our users are always aware of what information we collect, how we use it, and under circumstances, if any, we disclose it. We will use information in accordance with the Privacy Policy in effect when the information was collected. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an e-mail. Users will have a choice as to whether or not we use their information in a different manner.

CONTACT

Kurzweil Education is the only operator collecting or maintain student data and PII. Kurzweil Education's contact information for questions or concerns about this data is as follows:

Kurzweil Education, Inc.
17855 Dallas Parkway, Suite 400
Dallas, TX 75287
support@KurzweilEducation.com
Privacy@cambiumlearning.com
888-399-1995