Last Updated Date: 01/07/2021
SWYE360 Learning, Inc (referred to in this policy as “SWYE360”, “us”, “we”, or “our”) has adopted the following Privacy Policy to explain how we collect, use, and share information from and about you.
Your privacy and security are very important to us at SWYE360. We’re committed to transparency when it comes to our privacy practices and how we safeguard your information. This Privacy Policy (“Policy”) outlines what kinds of information we may ask you for and gather from you as you visit and use SWYE360, how that information may be used, and under what circumstances certain information might be shared with others.
This Policy applies to the data you share when you use our “Services” which includes our website at SWYE360.com and any affiliated web pages or forms we may create or host (“Site”), our mobile applications (“Apps”), or when you communicate with us.
INFORMATION YOU TELL US
Some information collected when you use our services is considered “Personal Information” (or PI). This is information that can be used to identify you personally and includes things like your full name, your street address, your phone number, and your email address. Other than as provided for in this Policy, we won’t share or disclose this kind of information unless we get your permission. Other information that we collect may not identify you personally. This kind of information may be shared or disclosed in an aggregate form, used to personalize and improve your user experience, and so on.
For Tutors, Coaches, and Parents:
Registration: The following Personal Information is collected from Tutors, Coaches, and Parents when they register for a free account: First Name, Last Name, Email.
Additional Information: The following Personal Information can be optionally entered by Tutors, Coaches, and Parents after registration: Bio, Gender, Birthday, Phone, Address
For Students:
Registration: The following Personal Information is collected from Students when they register for a free account: First Name, and Last Name.
Additional Information: The following Personal Information may be required, district, school, can be optionally entered by Students after registration: Bio, Gender, Birthday, Phone.
All Members. To use many aspects of our Services, you’re required to create a SWYE360 account and become a Member. To become a Member, we require that you provide us with your email address so we can contact you. We also ask you to tell us your full name as you may or will interact with learners that include students under the age of 13 that are protected under the FERPA Act.
Finally, we’ll ask you to share information about your user type (teacher, tutor, professional development coach, parent, student), your geographic location, what and where you teach, and information about your interests to help us personalize your experience using our services.
SWYE360 requires schools, districts, or teachers (on behalf of the parents or legal guardians of students under the age of 13) to provide consent for the online collection of personal information of the student under the age of 13 through SWYE360. In order to register to use SWYE360, students must use an access code provided to them by their teacher or autogenerated by SWYE360.
SWYE360 collects limited personal information from minor students only where that student’s school, district, or teacher has contracted with SWYE360 to collect personal information for the use and benefit of the learning environment. This information is not shared outside of the school or with any third parties except those needed for the provision of the service as outlined in this policy. Students of any age cannot share their profiles publicly outside of their classroom or school.
Teachers can give students grades, attendance marks, and provide comments to students. Students can submit assignments, make comments, and take online tests, assessments, and quizzes, Teachers or students can record audio or video and attach these recordings to content or other items in our system. None of this information is shared with any third parties without the Teachers, district, or school's consent.
Teachers accessing SWYE360 on behalf of a School or District or using a free account must ensure that they provide parents with access to SWYE360.
Service Providers. Members who register for one of our Provider Memberships (“Providers”), will be required to provide additional contact information and payment information to receive Earnings. To comply with applicable laws, we may collect federal tax identification information from Providers, including your social security number or employer identification number, to verify your identity and issue tax documents.
PURCHASE INFORMATION
When you provide or receive online tutoring and or job-embedded coaching through our Services, you’ll need to provide billing and payment information. We’ve carefully chosen Service Providers who use Payment Card Industry Data Security Standard (PCI DSS) compliant practices to process payments (“Payment Processors”). Whether you check out using a credit or debit card, or any other payment method we may support, your payment will be processed directly by our Payment Processor and we’ll never have access to or store your full payment details.
When you use a credit or debit card to pay for your purchases or services, you’ll be asked to enter your credit or debit card number, CVV, and billing contact information. When you submit your order, this information will be sent directly to our Payment Processor. After your payment is processed, the Payment Processor will send SWYE360 some details about the transaction so that we can record the transaction in our database and provide access to the materials that you purchased.
You have the option to save a credit or debit card record with our Payment Processor to re-use those details for future purchases on SWYE360 without having to re-enter them at checkout. You can edit or remove this information at any time by navigating to the checkout page or by contacting us for assistance.
If you choose to pay using Stripe, you’ll log in to your Stripe account to complete your order. When Stripe processes your payment, they’ll send us a confirmation with transaction details so we can record your order and provide access to the Resources or services you’ve purchased. We do not collect information about or have access to the specific payment or funding sources or any other financial account details associated with your Stripe account.
OTHER INFORMATION
When you use our platform, we receive and collect certain information from your browser and your devices such as your Internet Protocol address (IP address), device information, operating system, browser type and version, and browser country location. This information helps us defend against fraudulent activity or attacks, maintain the security of our Services, and improve and personalize your experience.
We also log data related to how Members use our Services, including cookies that may uniquely identify your visit or account. This log data includes details such as what pages of our Site or App you visit and when, how users navigate through the Site and visit referral URLs. This information allows us to better understand how our Services are being used, helps us make improvements, and enables us to personalize your experience with our Services. (Please refer to the Cookies section below for more information about how we use cookies.)
OUR COMMITMENT TO CHILDREN’S PRIVACY
At SWYE360, we take children’s privacy very seriously. SWYE360’s Services are directed at and intended for use by both adults and children. We do not knowingly collect Personal Information from children under the age of 13 without the approval of the School, District, Guardian, or Parent. If we discover that we have collected information from a child under the age of 13 without the appropriate approvals, we will take the appropriate measures to promptly remove that information from our Services.
SWYE360 is committed to compliance with all other federal and state laws and regulations governing student data privacy, including the federal Family Educational Rights and Privacy Act (“FERPA”), the California Student Online Personal Information Protections Act (“SOPIPA”), the Connecticut Student Data Privacy laws (C.G.S. §§ 10-234aa through 10-234dd), the Illinois (105 ILCS 85/) Student Online Personal Protection Act (SOPPA) and other similar state laws.
If you are a parent or guardian and believe that SWYE360 may have collected Personal Information about your child, please contact us at partners@swye360.com to let us know. We’ll work with you to make sure that information is removed from our Site.
Parents have the right to refuse the site further contact with their child and to have access to their child's information and to have it deleted by contacting the school administrator.
Parents have the right to consent to the site's use of the child's personal information without having to consent to its disclosure of that information to third parties by contacting the school administrator.
If you are the parent and guardian of a student using SWYE360, and cease to agree with SWYE360's terms of use and privacy policy at some point in the future, you may opt-out by contacting (a) your Subscriber (typically your school) SWYE360 Concierge if you are a Member using our Service Providers.
If your or your child's personally identifiable information changes, or if you no longer desire our service, you may correct, update or delete it by contacting Partners Support at partners@swye360.com We will respond to your access request within 30 days.
We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at partners@swye360.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
SWYE360 and your school work together to protect the online privacy of all of your school community members that use SWYE360, including students, parents, teachers, and administrators. This privacy policy and SWYE360’s information collection and security practices have been authorized by your school or teacher, and SWYE360 strives to manage your school's internet services in a secure manner. For example, SWYE360 uses industry-standard technology called SSL (Secure Socket Layer). SSL encrypts information transmitted across the internet to and from SWYE360. You will know that SSL is working when you see the presence of an image of a closed lock or solid key in the bottom bar of your browser window. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure and “hacker-proof,” and SWYE360 cannot ensure or warrant the security of any information managed by the site, whether transmitted to SWYE360 by you, your school, or your teacher. SWYE360 shall not be liable if a security breach occurs, if the site malfunctions, or if the information is misused or mismanaged in any way to your detriment or the detriment of a third party, whether by SWYE360, your school, your teacher, or an unauthorized third party.
DEFINITIONS
Data breach: when personal information held by SWYE360 is lost or subjected to unauthorized access, modification, disclosure, or other misuse or interference. Examples of a data breach are when a device containing personal information of a student is lost or stolen, SWYE360’s database containing personal information is hacked or SWYE360 mistakenly provides personal information to the wrong person. Data breaches are not limited to malicious actions, such as theft or ‘hacking’, but may arise from internal errors or failure to follow information handling policies that cause accidental loss or disclosure.
Loss: accidental or inadvertent loss of personal information held by SWYE360, in circumstances where it is likely to result in unauthorized access or disclosure.
Unauthorized access: when personal information that SWYE360 holds is accessed by someone who is not permitted to have access. This includes unauthorized access by an external third party (such as by hacking).
Unauthorized disclosure: when SWYE360 makes personal information accessible or visible to others outside SWYE360, and releases that information from its effective control in a way that is not permitted by FERPA, SOPIPA, and SOPPA.
Validate the data breach
• Examine the initial information and available logs to confirm that a breach has occurred.
• The date, time, duration, and location of the breach
• The type of personal information involved in the breach
• The cause and extent of the breach
• A list of the affected individuals, or possible affected individuals
• The risk of serious harm to the affected individuals
• The risk of other harms
Assemble an incident response team
• Team includes representatives from management, information technology, legal, media relations, and risk management.
• Immediately determine the status of the breach (on-going, active, or post-breach).
• If the breach is active or on-going, take action to prevent further data loss by securing and blocking unauthorized access to systems or data and preserving evidence for the investigation.
• Document all mitigation efforts for later analysis.
• Advise staff who are informed of the breach to keep breach details in confidence until notified otherwise.
Determine the scope of the breach
• If criminal activity is suspected, notify law enforcement and follow any applicable federal, state, or local legal requirements relating to the notification of law enforcement.
Notify the data owners
• Reach out to data owners as soon as possible to notify them about the breach.
• Foster a cooperative relationship between the incident response team and data owners.
• Work collaboratively with data owners to secure sensitive data, mitigate the damage that may arise from the breach, and determine the root cause(s) of the breach to devise mitigating strategies and prevent future occurrences.
Prevent Future Breaches
• Full investigation of the cause of the breach
• Report to the Leadership Team and make a recommendation:
• Update security and response plan if necessary
• Make appropriate changes to policies and procedures if necessary
• Revise and update SWYE360 staff training practices if necessary
IN GENERAL
Your privacy is very important to us. Other than as provided for in this Policy, we don’t share your Personally Identifiable Information with third parties without your consent.
We use the information we collect about you and the information that you tell us about yourself for the following general purposes:
To create your SWYE360 account and profile
To identify you in connection with your account activity (In some cases, this information may be shared or displayed publicly or only to certain other Members in a full or modified form as described in sections B, C, and D below.)
To communicate with you about our Services and your account
To facilitate transactions between you and our Sellers
To provide customer support
To personalize your experience with our Services
To track usage of our Service and run tests to improve our Services
To identify and understand trends in user activity so that we can make improvements to our Services
To ensure the proper operation and security of our Services
Other purposes to deliver and improve our Services for you
INFORMATION SHARED BETWEEN BUYERS AND SERVICE PROVIDERS
When you receive or provide tutoring and or coaching, your full name, city, state, and zip code will be visible to the Service Provider.
WHEN YOU CONNECT, SHARE, OR COMMUNICATE WITH OTHERS There may be features of our Services which allow you to:
Post Content (resources you upload, and communications you post such as comments, reviews, questions, or other public messages)
Connect, communicate, and share information about yourself with other Members
Link your account to an organization using SWYE360 for Schools
Submit requests for resources
Display a profile public, and so on
By using any of these features, you’re choosing to share information about yourself and your SWYE360 account activity with the public or with other Members. If you connect with another Member, for example by joining a group or organization, or by accessing a Resource shared with you by another Member, the Members you interact with may be able to view certain information and activity associated with your account and that interaction.
THIRD-PARTY SERVICE PROVIDERS
SWYE360 engages the services of third-party companies (“TPSP”) to support and help provide certain features of our Services such as payment processing, customer support, data storage and analysis, visitor tracking and user testing, email messaging, advertising, surveys, Site security, and other services. SWYE360 shares data with these Service Providers so that they can perform their services which help deliver our Services more securely, efficiently, and effectively.
TPSP may have access to certain Personal Information in the course of providing their service. TPSP’s access to your Personal Information is limited to the purpose of providing the services contracted for. TPSPs are not permitted to disclose information to other parties or use your Personal Information for any other purpose.
From time to time, we may partner with other companies or organizations (“Partners’) to offer additional products and services (“Partner Content”). When you buy or use Partner Content, we may share information with our Partners about your order and your account for the purposes of facilitating your use of Partner Content and ensuring delivery of Partner Content to you.
SWYE360 may from time to time share aggregate user data with business partners, TPSP, or other third parties to identify or share trends, usage statistics, and so on. Sharing data in an aggregate form means that no Personal Information, which would allow the recipient of the data to identify you personally, will be shared.
MERGER OR ACQUISITION
As part of a merger or an acquisition of SWYE360, we may transfer the data we have collected, including Personal Information, to the purchasing company. In such an event, we’ll notify you of that change. In addition, any purchasing company would have to adhere to the terms of this Policy including notifying you before making material changes and giving you the opportunity to opt-out.
LEGAL OBLIGATION
Finally, we respect and comply with legal obligations and may release information (including Personal Information and information about your account activities) in cooperation with a law enforcement investigation, in response to a valid legal request such as a court order or legal subpoena, as part of the process outlined by the Digital Millennium Copyright Act (DMCA), or to defend, protect, or exercise our legal rights.
At SWYE360, it’s important to us that you have the ability to make choices about your personal information, so we provide you with options for managing your account and the information you give us and if you choose to have a public or private profile.
ACCOUNT INFORMATION
You can view, update, and correct the information you’ve provided about yourself by visiting your Profile page from the Dashboard. You can also remove any of the optional information you’ve provided. Information that is required will be indicated as such and can be updated but cannot be removed.
SAVED PAYMENT SOURCE
If you’ve saved your credit or debit card for future purchases, you can edit or delete your saved card information when you go to the checkout page.
EMAIL PREFERENCES
SWYE360 uses your contact information to communicate with you about our services and to provide notifications related to your account or activity. Certain communications related to your account or your activity are required and you can’t opt-out of receiving them. These include, but aren’t limited to, scheduled sessions-related notifications, notifications related to changes that have been made to your login credentials or account details, and legal notifications. Other communications may not be required such as announcements about our Services, newsletters and messages with information you might be interested in, and other marketing and promotional messages (“Optional Communications”). You can manage your preferences related to Optional Communications in the Email Preferences section of your account, or by using the “unsubscribe” link at the bottom of any Optional Communication you receive.
OTHER
If you choose to create a public profile or post communications, any information you post will be visible to other Users and the public. You can edit and update communications you’ve posted and information provided in your public profile. You can change your public profile at any time.
ACCOUNT SECURITY
Access to your SWYE360 account is secured by the password you choose. To prevent unauthorized access to your account, choose a password that can’t be easily guessed and don’t share your password with anyone else. Whenever you use a shared computer or other shared devices to access your SWYE360 account (for example, a school computer), be sure to log out of your account completely before you leave your workstation, uncheck the “remember me” option at login, and select “no” if the web browser prompts you to save your login credentials. You’re responsible for keeping your password confidential, and for all activity that occurs under your account, whether or not authorized by you. You can change or update your password anytime by visiting your My Account page. If you forget your password, you can request a reset password link.
COOKIES
Cookies are small pieces of data that are stored on your computer browser. When you visit websites like ours, some information about your visit is stored in cookies which are used to tailor your experience, surface relevant information, products, and advertisements, and to allow you to pick up where you left off the next time you visit.
By using our Services as a Member, you agree to our use of cookies in the following ways, as well as other similar purposes:
Analytics
Marketing
Preserving your preferences
Personalizing your experience
Understanding where our website traffic is coming from
To ensure the security and availability of our Site and our Services
You have the right to decide whether a website can store cookies on your computer. Depending on the internet browser you use, you can view, manage, delete, and disable cookies through your browser preferences. Some features may not work properly if you choose not to allow us to use cookies. To learn more about how to do this, check out instructions from these browsers:
The Content uploaded or posted to our Services is made available at the direction of our Members. We are not responsible for the Content, including any disclosures of Personal Information by our Members. If you believe that any Content posted on our Services violates your personal privacy rights, please notify us at partners@Swye360.com or by using our Contact Us form.
SWYE360 will use your information for the reasons detailed in this Policy in order to deliver our Services to you while your account is active. If you no longer wish to be a Member of our Services, you can close your account with us at any time. If you close your account, your account is placed in an inactive state. We retain a record of your account information and only use your account information to provide sales data to Sellers you’ve transacted with, to continue to make Resources available to Members who have purchased licenses from you, to comply with a valid legal request, or resolve a dispute, or to meet any legal requirements or obligations. We may also continue to include your data as part of ongoing aggregate data and usage analysis. We’ll no longer send you marketing or other communications about your account or our Services. You can restore your account at any time by logging in with your email or username and your password.
SWYE360 for Schools enables increased collaboration and communication between and among teachers, administrators, coaches, tutors, and students.
If you’ve linked your SWYE360 account to an Organization using SWYE360 for Schools, your interactions with and activity related to SWYE360 for Schools may be shared with and be visible to other Organization Members and Managers (Organization Users). Your personal purchases, purchase history, billing information, and personal account details such as your street address and phone number will not be shared.
Linking your Account. When you link your SWYE360 account to an Organization, your name and role will be shared with your organization, and you’ll be added to your Organization’s roster which is visible to other Organization Users.
Requesting Resources. When you submit a request for Resources, your request will be visible to Organization Users as part of the Organization’s list of pending requests. SWYE360 may enable your Organization Manager to communicate directly with you about your requests and send notifications via the email address associated with your SWYE360 account. When you reply via your personal email account, your email address will be visible to the Organization Manager you’re communicating with, but when you reply within the SWYE360 platform your email is not visible to the organization.
Receiving Resources. When a Resource License is shared with you, Organization Users can see that a Resource License has been shared with you, whether you’ve claimed or downloaded that Resource License, and may be able to see other activity related to your use of that Resource.
Purchases. When your Organization makes a purchase, those Resources will be added to the Organization’s shared library which is visible to all other Organization Users.
Communicating. SWYE360 will use the email address associated with your SWYE360 account to send you notifications about your SWYE360 for School activity, including communications from your Organization. By communicating with your Organization by email, you’re sharing your email address with your Organization.
From time to time, we’ll update this Policy in accordance with the process and rules in our Terms of Service.
For any questions, you have about this policy or if you need assistance with your account, you can reach us anytime using the following methods:
Submit a question using our Contact Us form
Email us at partners@swye360.com
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