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VISTA HIGHER LEARNING PRIVACY POLICY

This Policy was last updated on June 28, 2017.

Vista Higher Learning, Inc. (“Vista Higher Learning”, “we”, “us”, or “our”) is committed to protecting your privacy through compliance with this privacy policy (this “Privacy Policy”). This Privacy Policy explains our policies and practices with respect to the information you entrust to us when you use the VHL Digital Products (defined below). Throughout this Privacy Policy, “user”, “you”, or “your” refers to instructors or students who have registered for and are using VHL Digital Products or, if students are under the age of 13, to the parents or legal guardians of those students.

What this Policy Covers

This Privacy Policy applies solely to our use of information collected online by or through our Supersite, Portales, VHL Central, and Mobile Application products and support services (collectively, the "VHL Digital Products”). It does not apply to any information we may collect offline or through any other means. This Privacy Policy does not address, and we are not responsible for, information collected by or through third parties, even if their products or services may be linked to or from the VHL Digital Products. For more information, see “Links to Other Sites” below. Please read the terms of any privacy policies that you enter into with other parties, including your educational institution, as those policies may explain how certain of your information is used by those parties.

Information We Collect

When you register for or use a VHL Digital Product, we may collect certain information from or about you or your students. The first type of information we may collect includes certain personal or identifying information, such as first and last name (or, at your option, a pseudonym or substitute identifier), email address, birth year, school affiliation including country, state or province, time zone, school type, and full institutional name (optional), and username. When you provide us with this information, which is collected on an individual basis, you knowingly choose to disclose it to us.

Additionally, subject to compliance with the Family Educational Rights and Privacy Act (“FERPA”) and other federal, state or local laws governing the privacy of educational records, your school, school district, or educational institution may provide Vista Higher Learning with certain information for your account, such as your name, email address, and course and section enrollment information. This is discussed further in the section titled “Student Information” below.

Another type of information we collect is user-generated content, which may include profile information, enrollment and login history, audio and video recordings, and scores for practice activities. In addition, some VHL Digital Products offer instructors and students the ability to complete substantive course work, including the ability to upload documents and submit communications. Some VHL Digital Products also offer instructors the ability to store student grade information on or through such products.

Finally, as you use the VHL Digital Products, we may automatically collect certain information about your use of and activity on the VHL Digital Products, including time spent using the VHL Digital Products, as more fully described below in the section titled “Use of Cookies and Website Information”.

You may choose not to provide us with some or all of the information described above. However, in some cases, if you choose not to provide us with the required information, you will not be able to access or use some or all of the content or services of the VHL Digital Products.

Use of Cookies and Website Information

Like many commercial websites, we use standard "cookie" technology and web server logs to collect information about how the VHL Digital Products are used. Cookies are small pieces of data that are stored by your web browser on your hard drive. Cookies allow our web servers to recognize the computers used to access the VHL Digital Products. Cookies allow you to move from page to page within the VHL Digital Products by remembering the information about the entire session.

Information gathered through cookies and by our web server logs may include your IP address, the date and time of your visit, the pages viewed, time spent on the VHL Digital Products, and the websites visited immediately before and after using the VHL Digital Products. This information is collected automatically and contains no personally identifiable information. However, we may tie this information to other information about you that we collect from you or other sources. For instance, we expressly reserve the right to analyze anonymous demographic information and to correlate it to particular individuals in order to investigate potentially unlawful conduct and/or breaches of this Privacy Policy or the VHL Terms of Use.

You can configure your web-browser to disable cookies, but doing so may impair your use of the VHL Digital Products.

How We Use the Information We Collect

We may use the information and user-generated content we collect for any business purposes not prohibited by law or this Privacy Policy, including, but not limited to, improving our products and services. For example, information we collect may be used in the following ways:

  • To facilitate and enable the registration, access, and operation of VHL Digital Products;
  • To respond to your requests for product support or customer service;
  • To personalize your use of and experience with VHL Digital Products; and
  • To monitor and improve the overall performance and quality of VHL Digital Products.

We may also use the information we collect through the VHL Digital Products to communicate with you in connection with your use of the VHL Digital Products. You may opt-out of receiving these communications at any time. The following options are available to opt-out of receiving these messages:

  • Send email to info@vistahigherlearning.com
  • Send written correspondence to:
  • Vista Higher Learning
    500 Boylston Street
    Suite 620, Boston, MA 02116
  • Call 800-618-7375 or 617-426-4910
  • Fax (617) 426-5215
  • By using the "unsubscribe" link on any emailed correspondence from Vista Higher Learning

Disclosure of Your Information

Vista Higher Learning does not sell, trade, or otherwise transfer your personally identifiable information to outside parties except under the following circumstances:

  • To our trusted affiliates and third party service providers, as further described below, who assist us in operating our business, servicing our website, or supporting you with your product experience;
  • When we believe in good faith that disclosing such information is necessary or advisable, including, for instance, to comply with any law, court order, or legal process, including responding to any government or regulatory request;
  • To enforce our site policies or protect our or other’s rights, property, or safety;
  • To a buyer or other successor or assignee in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Vista Higher Learning’s assets; and
  • Otherwise as permitted or required by law.

User information and user-generated content may also be made available to school officials, including instructors, who Vista Higher Learning reasonably believes to have a legitimate educational interest in such information and materials. Such information and materials may include a student's first and last name, username, e-mail address, student ID (if provided), the student's substantive course work, any student recorded and submitted communications, uploaded documents, product usage information (including time on site, time spent on each course-related activity, submission dates and times for course activities), score and grade information, login history, account creation date and time, and enrollment history. Additionally, if Vista Higher Learning makes chat rooms, forums, or message boards available by or trough the VHL Digital Services, it is important to remember that information you choose to disclose in these areas will become public information, and you should exercise caution in deciding whether to disclose your personal information publicly on such forums.

For the avoidance of doubt, Vista Higher Learning will not provide any third party with any personally identifiable information for purposes of engaging in targeted advertising. However, Vista Higher Learning may disclose aggregated user information or statistics in order to describe the VHL Digital Products to prospective partners, advertisers, and other third parties, and for other lawful business purposes.

Third Parties Who May Receive Your Information

Vista Higher Learning may share your information with affiliates and third party service providers who assist us in operating our business, servicing our website, or supporting you with your product experience. For example, Vista Higher Learning has engaged AltaVista (“AltaVista”) and OneLink (“OneLink”) to provide technical support for our VHL Digital Products. At your request or the request of your instructor or educational institution, AltaVista or OneLink may request information from or about you in order to provide technical support. AltaVista and OneLink have agreed to abide by Vista Higher Learning’s Privacy Policy. However, Vista Higher Learning is not responsible for AltaVista, OneLink or any third party’s implementation of its privacy and security practices.

How We Protect Your Information

We have implemented reasonable technical, physical and administrative safeguards to help protect your personally identifiable information against unauthorized access or loss. For instance, Vista Higher Learning provides privacy and information security training to our employees. While Vista Higher Learning strives to protect the personal information of users and takes reasonable steps to ensure the security, integrity and confidentiality of such information disclosed to us, we cannot guarantee the security, integrity or confidentiality of any information disclosed, and you do so at your own risk.

Username and Passcodes

When you create a password using a VHL Digital Product, you are responsible for keeping this password confidential. Please make every effort to ensure it remains private. Do not share your password with anyone, even on a temporary basis. Vista Higher Learning is not responsible for unauthorized access to accounts gained through the sharing of passwords. If you suspect your password has been compromised, contact Vista Higher Leaning Technical Support immediately.

If you lose or forget your login information, you may contact us and ask us to change your password to a temporary password. You authorize us to, upon request, send your login information to your email address of record. Further, we may provide secondary school instructors with a method of resetting a student's password for students who have indicated to us that they are enrolled at the instructor's school. This means that, if you are a secondary school student, it is possible for instructors at your school to view your VHL Central Site account. We will not knowingly provide instructor login information to any student.

Changes to Your Personal Information

You or your parent or legal guardian may review, correct or delete your personally identifiable information maintained by us. You may also ask us to stop collecting or using some or all of your personally identifiable information. However, please be aware that this may limit or prevent your future use of the VHL Digital Services.

To do this, please contact Vista Higher Learning Technical Support using the contact information provided at the end of this Privacy Policy. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make any corrections.

If your school, school district, or educational institution has provided Vista Higher Learning with your user information, the school, school district, or educational institution is responsible for providing the means by which parents, legal guardians, and eligible pupils may review and correct erroneous personally identifiable information in accordance with applicable law. See the section titled “Student Information” below for more information.

Links to Other Sites

Vista Higher Learning may provide links to other websites by or through the VHL Digital Products. Vista Higher Learning does not endorse and is not responsible for any third party websites, products, services or business practices. Vista Higher Learning assumes no responsibility for the privacy or security of information you provide to any third party through linked websites or any other means. We urge you to review the privacy policy of any website that you visit.

Student Information

We may collect certain legally protected information from or about students, such as students’ personally identifiable information, in the course of providing the VHL Digital Products and related services (“Student Information”). In general, we consider Student Information to be confidential and do not use such Student Information for any purpose other than to provide and improve the VHL Digital Products or behalf of our users and customers. Our collection, use and sharing of Student Information is governed by federal, state and local laws, as applicable, and not by any conflicting provisions contained in this Privacy Policy. This Privacy Policy does not supersede the terms of any agreements between us and any other party.

If you have any questions about reviewing, modifying, or deleting Student Information provided to us by your school or educational institution, please contact your school or educational institution directly.

Use of VHL Websites by Children under the Age of 13

The VHL Digital Products are not generally intended for children under the age of 13, but in some instances children under the age of 13 may be eligible users of certain VHL Digital Products. If that is the case, the child’s parent or legal guardian or school must assist the child in registering the product or service for use. Any information that may be needed for delivery of the product or service which may not be legally collected from a child under the age of 13 must be provided by the child’s parent, legal guardian or school with the consent of a parent or legal guardian or school, in each case as may be required by law. If you have reason to believe that we have collected personal information from someone under 13 years of age without having obtained the authorizations described above, please contact Vista Higher Learning Technical Support.

We encourage parents and teachers to spend time online with children and to monitor their online activities. Please protect your child's privacy by instructing them to never provide personal information via the internet without your permission.

Changes to Our Privacy Policy

Vista Higher Learning reserves the right, in its sole discretion, to change, modify, add or remove this Privacy Policy in whole or in part, at any time. Changes will be effective when notice of such change is posted at http://www.vhlcentral.com/privacy_policy. Your continued use of any VHL Digital Products after any changes are posted will be considered acceptance of those changes. By using the VHL Digital Products, you agree that you have reviewed, understand and accept this Privacy Policy, and that Vista Higher Learning may collect and use your information as set forth in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use any of the VHL Digital Products. Unless otherwise required by law or agreed in writing by Vista Higher Learning, the data collected via the VHL Digital Products belongs exclusively to Vista Higher Learning. Vista Higher Learning is solely responsible for creating and maintaining this policy.

Contact Vista Higher Learning

If you have any questions or concerns about Vista Higher Learning's use of non-public personal information or about this Privacy Policy, please contact Vista Higher Learning at:

Vista Higher Learning:
500 Boylston Street
Suite 620
Boston, MA 02116
USA
Phone:
(800) 618-7375
(617) 426-4910
Fax:
(617) 426-5215
E-mail:
info@vistahigherlearning.com

Vista Higher Learning takes concerns about privacy and use of personal information seriously, and will reply as quickly as reasonably possible to any report of concern.

Last Updated 6/28/2017