Effective Date: July 29, 2022
The Utah Compose platform collects Student Data: The Utah Compose platform is an internet-based writing assessment and communication platform for use in educational settings by Schools. Providers of educational services, such as schools, school districts, or teachers (collectively, “Schools”) may subscribe to the Utah Compose platform for educational purposes. When Measurement contracts with a School to provide the Utah Compose platform, we may collect or have access to Student Data (defined below) provided by the School or the student. We consider Student Data to be confidential. Our collection, use and sharing of Student Data is governed by our contracts with the School. If you have any questions about reviewing, modifying, or deleting Personal Information of a student, please contact your School directly.
The Personal Information We Collect and How We Use It
The Personal Information we collect and how we use it depends on the context of your interactions with us. We also collect certain information automatically when you interact with the Services.
Information you Provide to Us. You may provide certain Personal Information to us when you sign up for a Measurement account and use the Services, consult with our customer service team, send us an email, or communicate with us in any other way. This information may include the categories described below.
When a teacher, school administrator, or other authorized person associated with a School registers for an account on the Services or corresponds with us, we may collect Personal Information such as a name, e-mail address, payment information, username and password, and information about the School.
Once registered, a School may provide information about its students, such as student names or other identifiers, passwords, e-mail address for the student, and grade level. Personal Information collected from or about students, along with other information associated with that Personal Information is Student Data.
Troubleshooting and support data, which is data you provide, or we otherwise collect in connection with support queries we receive from you. This may include contact or authentication data, the content of your chats and other communications with us, and the product or service you are using related to your help inquiry.
Feedback and correspondence, such as information you provide in your responses to surveys, report a problem with the Services, receive customer support or otherwise correspond with us.
Payment information and other financial information that we/our payment processors need in order to provide the Services.
Marketing information, such as your preferences for receiving marketing communications and details about how you engage with them, except that we do not collect such information from students.
Other information that you choose to share in connection with your request or inquiry.
Information We Collect Automatically from Your Use of the Services. We also may collect certain other information automatically when you use or access the Services, such as the following:
Browser and Device Information.
Certain information may be automatically collected by most browsers or devices, such as information about user devices (such as IP addresses and MAC addresses), operating systems, and browsers.
Information Stored in Cookies and Web Beacons.
Pixel Tags and Log Files
The Services may also use other tracking systems such as log files and pixel tags. For example, pixel tags, sometimes called web beacons, are similar in function to a cookie and can tell us certain information like what content has been viewed.
Information Collected in Connection with Analytics Technology.
When you use the Services, we may collect information about your location, including general location information that may be associated with your device’s IP address, and, if you allow your device to share information about your location with the App, the geolocation of the device you use to access the App, which may indicate your precise geolocation.
How We Use Personal Information. We may use the Personal Information that we collect or receive through the Services for purposes that include:
- To provide and maintain the Services, such as arranging access to an account, providing Schools and students with information and reports about performance and use of the Services, responding to inquiries, and providing customer support.
- To respond to your inquiries and communicate with you about the Services.
- To manage and communicate with you regarding your Measurement account, if you have one, including by sending you service announcements, technical notices, updates, security alerts, and support and administrative messages.
- To bill and collect payment.
- To store information about your preferences and customize your experience on the Services.
- To analyze usage trends and patterns and measure the effectiveness of the Services.
- To promote our products and services including by sending you newsletters, special offers, and other information we think may be of interest to you; however, we do not use Student Data to send marketing communications, and we do not send marketing communications to students.
- To administer, evaluate, and improve our business and the Services, including developing new products and services; managing our communications; and performing accounting, auditing, reconciliation and collection activities.
- To comply with legal and regulatory requirements, judicial process, and our company policies, including due diligence and contracting activities.
- To secure the Services, including by protecting against and responding to fraud, illegal activity, such as incidents of hacking or misuse of the Services, and claims and other liabilities, including by enforcing our agreements.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceeding.
- To create aggregate or de-identified information.
- Such other purposes as you may authorize.
Information We Receive from Devices You Connect to the Services
If you choose to connect a third-party application to the Utah Compose platform, we may also receive Personal Information, including name and email address, from the device you connect to the Utah Compose platform.
How We Disclose Personal Information. We may share or disclose your Personal Information as needed to provide our Services or with your consent or permission. We may also share Personal Information as described below.
- To teachers and school administrators, when you include writing or other content in to the Utah Compose platform and as directed by the School;
- Others within the School; for example, students using the Utah Compose platform may choose to share writing or other content for assessment purposes through the Utah Compose platform; and messages between a teacher and students in a class are accessible by School administrators or other designated School users.
- To our vendors, service providers, and other third parties that provide services or products for us or on our behalf, such as analytics, hosting and billing.
- To an actual or potential buyer, successor, or other organization in the event of an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceedings.
- To our affiliates and business partners, such as partners involved in joint business transactions.
- Where Measurement has a good faith belief that access, use, preservation, or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process, or enforceable governmental request; (b) enforce our policies, Terms of Service, contracts or other legal rights, including investigation of potential violations thereof; (c) detect, prevent or otherwise address fraud, security or technical issues; (d) protect the rights, property, or personal safety of Measurement, its users, or the public; or (e) as required or permitted by law.
We may also share information in aggregate and/or de-identified form that cannot reasonably be used to identify an individual; for example, to describe our Services to current and prospective partners and other third parties, and for other lawful statistical and research purposes.
Your Rights and Choices
Other examples of your choices include:
- You can browse our website without registering or directly submitting any information to us (although we may still collect some limited information automatically, as described above);
- You may opt out of receiving our messages at any time by using the opt-out mechanism provided in the message; and
- You may change your browser settings or take other steps to block, manage, or delete cookies. Our Services do not currently respond to browser “do not track” signals, so you will need to use your browser settings to effectively manage cookies. In some cases, blocking or disabling cookies may cause the Services not to work as intended and some features may not be available.
For information about interest-based advertising, and to opt out of this type of advertising by third parties that participate in self-regulatory programs, please visit the Network Advertising Initiative (NAI) opt out tool (http://www.networkadvertising.org/choices) and/or the Digital Advertising Alliance (DAA) Self-Regulatory Program for Online Behavioral Advertising (https://youradchoices.com). Please note that any optout choice you exercise through these programs will apply to interest-based advertising by the third parties you select, but will still allow the collection of data for other purposes, including research, analytics, and internal operations. You may continue to receive advertising, but that advertising may be less relevant to your interests.
We do not knowingly collect Personal Information from a child under 13 unless a School has authorized us to collect such information through the provision of the Services on the School’s behalf. When a School uses our Services in the classroom or in an educational context, we rely on the School to provide appropriate consent and authorization for a student under 13 to use the Services, and for Measurement to collect Personal Information from such student. Upon request, we will provide the School the opportunity to review and delete the Personal Information collected from their students. If you are a parent and you have questions about your child's use of our Services and any information collected, you should discuss your questions with your child's School.
Student Data - FERPA
We provide the Utah Compose platform to Schools. Through the provision of the Utah Compose platform, we collect Personal Information from or about students, which may include educational records governed by the Family Educational Rights and Privacy Act (FERPA). We consider such data to be confidential, and our collection, use, and sharing of Student Data covered by FERPA is governed by our contracts with Schools that subscribe to the Utah Compose platform. If you have any questions about our collection and use of Student Data, please contact us at email@example.com. If you have any questions about reviewing, modifying, or deleting Personal Information of a student, please contact the School directly.
We are committed to protecting the security of your Personal Information. We maintain a variety of physical, administrative, and technological safeguards designed to protect Personal Information against loss, misuse, and unauthorized access or disclosure. Our measures consider the sensitivity of the information we collect, use, and store, and the current state of technology. Our security measures include data encryption, firewalls, and data use and access limitations. Please note, however, that we cannot and do not guarantee the security of your information, as no method of data storage or transmission is completely secure.
Changes to your Personal Information
It is important that the Personal Information we hold about you is accurate and current. Please let us know if your Personal Information changes during your relationship with us by updating your registration profile or emailing us at firstname.lastname@example.org.
How Long We Keep Information
We will keep your Personal Information for the time period necessary to achieve the purposes for which it was collected, including provision of the Services and to comply with law, resolve disputes, and enforce our agreements, and otherwise at the direction of the School, as applicable. For example, if you register on our Services, we will store your information for as long as needed to maintain your account, provide you the Services or other functionality as you request it, enforce any applicable terms that govern your use of the Services, and maintain appropriate records to reflect our delivery of Services to you.
Other Sites and Services
ADDITIONAL INFORMATION FOR RESIDENTS OF CALIFORNIA
- Personal information that is exempt from the CCPA;
- Personal information we collect in connection with communications or transactions with consumers who are acting as representatives of companies and other organizations that occur solely within the context of conducting due diligence regarding, or providing or receiving a product or service to or from such companies or organizations; or
- Personal Information we collect, use, and share on behalf of our customers as a “service provider” under the CCPA.
California Personal Information We Collect
We may have collected the following categories of California Personal Information regarding consumers within the last 12 months:
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, signature, address, telephone number, bank account number, credit card number, debit card number, or any other financial information. Some Personal Information included in this category may overlap with other categories;
- Identifiers such as your real name, alias, postal address, zip code, telephone number, email address and account name;
- Unique and online identifiers such as device identifiers, internet protocol addresses, cookie identifiers, beacon identifiers, pixel tags or mobile ad identifiers or similar technology, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device;
- Commercial information that identifies or could reasonably be linked to you, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
- Internet or other electronic network activity information identifies or could reasonably be linked to you, such as browsing history, search history and information regarding an individual’s interaction with an internet website, application, or advertisement;
- Professional or employment-related information, such as current or past job history;
- Sensory data, such as audio, electronic, visual, thermal, olfactory, or similar information;
- Protected classification characteristics under California or federal law, which includes age if 40 years or older, race, color, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, pregnancy or childbirth and related medical conditions), veteran or military status, genetic information (including familial genetic information);
- Inferences drawn from Personal Information, such as person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes;
- Geolocation data, such as precise location information from your device or rough location generated based on IP address;
- Other Personal Information that may be contained in online chat, document uploads, and user-generated content.
- Education information subject to the federal Family Educational Rights and Privacy Act, such as student records.
Sources of California Personal Information
Use of California Personal Information
We may use the categories of California Personal Information that we collect, as described above, for one or more of the business purposes and commercial purposes described in the “How We Use Personal Information” section above.
Disclosures of California Personal Information for a Business Purpose
We may disclose the categories of California Personal Information that we collect as indicated above to the categories of third parties described in the How We Disclose Information section above. In the preceding 12 months, we may have disclosed all of the categories of California Personal Information listed above to our service providers and other third parties when you direct us to do so, or when you use our Services to do so.
Sales of California Personal Information
In the preceding 12 months, we have not sold California Personal Information. We do not sell California Personal Information, and we do not have actual knowledge that we sell California Personal Information of consumers under 16 years of age.
California Personal Information Rights and Choices
The CCPA and other California laws provide consumers with specific rights regarding their California Personal Information. This section describes those rights and explains how to exercise those rights to the extent we direct the purposes and means of the processing of your California Personal Information processing and otherwise qualify as a “business” under the CCPA.
Access to Specific Information and Data Portability Rights
California residents have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale of your California Personal Information over the past 12 months. If we receive and confirm a verifiable consumer request from you pursuant to the “Exercising Access, Data Portability, and Deletion Rights” section below, we will disclose to you, depending on the scope of the request:
- The categories of California Personal Information we collected about you.
- The categories of sources for the California Personal Information we collected about you.
- Our business or commercial purpose for collecting California Personal Information about you.
- The categories of third parties with which we share your California Personal Information.
- The specific pieces of California Personal Information we collected about you.
- If we disclosed your California Personal Information for a business purpose, a list of the categories of third parties to whom we disclosed California Personal Information for a business purpose identifying the categories of California Personal Information disclosed to those parties in the preceding 12 months.
Deletion Request Rights
California residents have the right to request that we delete California Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request pursuant to the “Exercising Access, Data Portability, and Deletion Rights” section below, we will delete your California Personal Information from our records, unless an exception applies.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email@example.com or in writing at:
404 Hunt Street
Durham, NC 27701
You may designate an authorized agent to submit requests on your behalf through a signed written permission that authorizes the agent to act on your behalf. We may mandate additional requirements when submitted through an authorized agent, such as requiring you to verify your identity directly with us or to directly confirm the authorized agent’s permission to act on your behalf. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. Your request must provide information sufficient to permit us to reasonably verify you are the person about whom we collected California Personal Information, or an authorized agent of that person. To verify your request, we may require you to provide additional information, including account profile information such as your Services email address and other information elements necessary to verify your identity. Your request also must include sufficient detail for us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with California Personal Information if we cannot verify your identity or authority to make the request and confirm the California Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, if you have a password-protected account with us we consider requests made through that account sufficiently verified when the request relates to California Personal Information associated with that specific account.
Any disclosures we provide will only cover the 12-month period preceding our receipt of the verifiable request. If we cannot fulfill, or are permitted to decline, your request then we will alert you or your authorized agent. For data portability requests, we will select a format to provide your California Personal Information that is readily usable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision, and we reserve the right to either refuse to act on your request or charge you a reasonable fee to complete your request if it is excessive, repetitive, or manifestly unfounded.
Subject to certain exceptions, you have a right to not receive discriminatory treatment for exercising your access, data portability, and deletion rights described above.
Our Global Practices
Measurement is located in the United States. Personal Information collected through the Services may be stored and processed in the United States or any other country in which Measurement or its affiliates or service providers maintain facilities, and that your Personal Information may become accessible as permitted by law in those jurisdictions, including to law enforcement and/or national security authorities.
How to Contact Us
404 Hunt Street
Durham, NC 27701
Phone Number: 919-683-2413