SERP Institute Privacy Policy

Effective Date: January 7, 2021

Introduction

This Privacy Policy (the “Policy”) outlines the practices of SERP Institute (“we”, “our”, or “SERP”) with respect to information collected from users who access our website and digital resources including our Licensed Digital Products (collectively, “SERP Digital Properties”), or otherwise share personal information with us (collectively, “Users”). 

SERP provides educators with access to resources developed in the context of research-practice partnerships. Our primary goals in collecting information are to provide and improve our SERP Digital Properties, to improve Users’ experience, and to enable Users to enjoy and easily navigate SERP Digital Properties. Reviewing this data is critical not only to improve User experiences, but also to understand how and where our resources are being accessed and to demonstrate demand and access to funders that may allow SERP to provide products at a lower cost or free of charge. However, we are aware that Users may have concerns regarding the use and disclosure of their personal information and the tracking, use, and sharing of their data. The following Policy informs you of our policies and practices regarding the collection, use and disclosure of personal information obtained from Users. It also provides transparency to students, parents, school districts and teachers as to how data is collected and used. The Policy, as it may be amended, governs access to and use of the SERP Digital Properties. 

Information and Data Collection and Use by SERP 

When you visit SERP Digital Properties, we may collect certain information about you. Some SERP Digital Properties require registration, and some SERP Digital Properties that provide access to the MathByExample Web Application and SERP Online Professional Learning Products (the “SERP Licensed Digital Products”) collect additional data as part of that service. Processing of your Personal Information (as defined below) is necessary for the performance of some of the SERP Digital Properties, especially pages that require registration for free access to materials and discussion forums, and pages that require a license for access.   

We encourage our Users to read this Policy carefully and use it to make informed decisions. 

How do we receive information about you?

We receive your Personal Information from various sources:

• When you voluntarily provide us your personal details in order to register for SERP Digital Products;
• When you use or access SERP Digital Properties;
• For student Users, from your educators at your Educational Institution;
• From third party providers, services, and public registers (e.g., traffic analytics vendors).

What information do we collect?

We collect two types of data and information from Users. The first type of information is information we collect automatically via your use of SERP Digital Properties. We are not aware of the identity of a User from which this information is collected, which may include technical information transmitted by your device such as geolocation data, IP address, unique identifiers (e.g., MAC address and UUID), certain software and hardware information (e.g., the type of browser and operating system your device uses, language preference, access time, etc.), and other information that relates to activity through SERP Digital Properties. We may also collect information on your activity on SERP Digital Properties (e.g., pages viewed, online browsing, clicks, actions, etc.) to inform improvements to the product or the design of new products.

The second type of information is information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). Such information includes: 

• Registration-related information: When non-student Users register for SERP Digital Properties or register for Licensed Digital Products on behalf of students, you will be asked to provide us certain details about yourself or such students, e.g., full name; e-mail address; username and password; name of class, school or other workplace;  professional position (teacher, researcher, administrator, etc.); ZIP or postal code; and country of residence. Certain areas of the SERP Digital Properties require registration and login. While a registered user is logged in, SERP can determine which assets are accessed by that user (i.e. document downloads and forum posts). Only registered users may view or post to online forums. 

• User responses on SERP Licensed Digital Products.
• When student Users access SERP Licensed Digital Products, we may collect information such as status of assignments (e.g., assigned, started, submitted, graded); time spent on a particular item; student responses to each item, including through text input, sketchpad drawing, or photo upload; and student attempts in answering questions in an assignment. 
• Teacher- or administrator-provided information may include data generated about which assignments the teacher assigns to each class, and as a result, to each student; and data generated about the scores and feedback teachers provide students on submissions.

How do we use the information we collect?

We do not rent or sell Users’ information under any circumstances. We do not share Users’ information with third parties except as described in this Policy.

We may use Users’ information for the following:

• Providing the SERP Licensed Digital Products or other services you request, including student User reports and implementation support to teachers, schools, or school district administrators;
• Communicating with you – sending you notices regarding our services, providing you with technical information, and responding to any customer service issue you may have;
• For non-student Users, communicating about our websites and products (see more under the Marketing section of this Policy); 
• Conducting statistical and analytical processing of information to personalize content and improve SERP Digital Properties;
• Using de-identified data for research purposes (e.g., to improve the educational effectiveness of SERP Digital Properties).

In addition to the purposes listed in this Policy, we may share Personal Information with our trusted third party providers, who may be located in different jurisdictions across the world, for any of the following purposes: 

• Hosting, operating, or providing you with our services on SERP Digital Properties; 
• Storing and processing such information on our behalf.

Third party service providers are subject to the same obligations as SERP not to use or disclose information for any purposes other than those stipulated in this agreement.

We may also use or disclose information if we have good faith to believe that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including this Policy and our Terms of Use), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our Users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.

Use of Data for Research

SERP may use data that is de-identified and aggregated data about use of SERP Digital Properties for research purposes. Data is de-identified by removing any and all personal identifiers, including name, school ID number, and teacher and school name, such that the individual from whom the information is collected is not reasonably identifiable. SERP-generated identification numbers may be assigned for research purposes. We will not attempt to re-identify any data that has been de-identified. De-identified data may be stored indefinitely. 

Any licensed User of a SERP Licensed Digital Products may request that their data be excluded from de-identified data sets. Requests for exclusion should be sent to privacy@serpinstitute.org.

SERP may transfer de-identified data to third party research collaborators. Research collaborators will be subject to these terms of the Policy which prohibit, among other things, any attempts to re-identify de-identified data, and any commercial use of these data.

Research projects conducted by SERP and SERP research collaborators are reviewed by an Institutional Review Board (IRB) which is responsible for approving the study, including procedures related to maintaining data privacy. Research projects may include field tests of new content or features in SERP Licensed Digital Products. The IRB may or may not require notification or approval of parents or students. School and school district Users provide prior consent to research that involves de-identified student data that has been approved for use by an IRB. SERP agrees to abide by IRB requirements. 

SERP and its research partners may publish or discuss analyses of de-identified aggregate student performance data. Such publications will not reference individual information, and will not identify schools or school districts. 

Receiving and Storing Student Personal Information

SERP works with educational institutions that must comply with the Family Educational Rights and Privacy Act (FERPA), as well as state laws that ensure student education record data is handled in a manner consistent with applicable educational institutions’ privacy policies. 

Within one hundred and twenty (120) days after the end of each school year or upon termination of a contract with SERP, all student Personal Information provided to SERP or its third party agents will be destroyed. School districts may request a copy of the data or ask that we retain the data on their behalf by emailing a request to privacy@serpinstitute.org. De-identified data may be retained indefinitely. 

Cookies

We and our trusted partners use “cookies” and other technologies in our related services, including when you visit SERP Digital Properties or access our services. 

A “cookie” is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various purposes. These purposes include allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences, and making the interaction between you and our services quicker and easier. Cookies are also used to help compile statistical data on your use of our services. 

SERP Digital Properties use the following types of cookies:

1. “Session cookies” which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; 
2. Persistent cookies” which are read only by SERP Digital Properties, saved on your computer for a fixed period, and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, e.g., to allow us to store your preferences for the next sign-in. 

You may remove cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of SERP Digital Properties may not operate properly and your online experience may be limited.

We use a tool called “Google Analytics” to collect information about your use of SERP Digital Properties. Google Analytics collects information such as how often Users access SERP Digital Properties, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve SERP Digital Properties. Google Analytics collects the IP address assigned to you on the date you visit SERP Digital Properties, rather than your name or other identifying information. Google’s ability to use and share information collected by Google Analytics about your visits to SERP Digital Properties is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Third party collection of information

Our Policy addresses the use and disclosure only of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party to which you choose to disclose information. 

This Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties to which we may disclose information as set forth in this Policy. 

How do we safeguard your information?

We take great care in implementing and maintaining the security of SERP Digital Properties and your information. We employ industry standard procedures and policies to protect the safety of the information we collect and retain, and prevent unauthorized use of any such information, and we require any third party to comply with similar security requirements, in accordance with this Policy. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse SERP Digital Properties, and we make no warranty, express, implied or otherwise, that we will prevent such access.

Marketing

We may use non-student Personal Information (such as name and email address) ourselves or by using our third party subcontractors for the purpose of providing non-student Users with promotional materials concerning our services, which we believe may be of interest. 

We provide within such marketing materials the means to decline receiving further marketing offers from us. If you unsubscribe, we will remove your email address from our marketing distribution lists.

Transfer of Assets

In the event of an acquisition, reorganization or merger of SERP or its assets, your information may be transferred to an assignee. In the event of such a transaction, the transferee or acquiring company will assume the rights and obligations as described in this Policy. You acknowledge that any acquirer of SERP or a SERP Digital Property may continue to use your information as set forth in this Policy. 

Updates or amendments to this Privacy Policy

We reserve the right to periodically amend or revise this Privacy Policy; material changes will be effective immediately upon notice of the revised Policy. The last revision will be reflected in the “Last modified” section. Your continued use of SERP Digital Properties following the notification of such amendments constitutes your acknowledgment of such amendments to the Policy and your agreement to be bound by the terms of such amendments. Clients who have purchased SERP Licensed Digital Products will be informed of any changes to this privacy policy. 

How to contact us 

If you have general questions about the website(s) or the information we collect about you and how we use it, you can contact us at privacy@serpinstitute.org or the address listed below.

Strategic Education Research Partnership (SERP) Institute

1100 Connecticut Ave. NW, Suite 1310

Washington, DC 20036

(202) 223-8555