Last Updated: January 8, 2021
1. Who We Are
We respect the privacy of our customers and visitors of our websites (identified below); users of our online subscription services and digital lessons; participants of our surveys; educators who attend training or Professional Development, and have developed this Policy to demonstrate our commitment to protecting your privacy. For the purposes of this Policy, the term “Websites” shall refer collectively to www.inthefootsteps.org as well as any other websites that we operate and that link to this Policy.
In order to deliver our Websites and Services to you, from time to time we collect personal information. This Policy describes:
The types of personal information we may collect or that you may provide when you visit our Websites or use our Services; participate in a survey or provide feedback, communicate with us; register for Professional Development;
Our practices for collecting, using, maintaining, protecting, and disclosing that personal information.
This policy DOES NOT apply to:
Personal information we collect offline or through any other means except as provided for herein.
Personal information we collect about job applicants, independent contractors, service providers, or current or former full-time, part-time and temporary employees and staff, officers, directors or owners of RTV.
Information that you provide to or is collected by any third party, including through any third-party application or content that may link to or be accessible from or on the Websites or Services. These third parties may have their own privacy policies, which we encourage you to read before providing information to them.
Our Websites and Services may contain links to third-party websites, which do not operate under this Policy. These third-party websites may independently solicit and collect personal information from you. While we strongly support the protection of privacy on the internet, we do not have control over, and cannot be responsible for, the actions of other third parties. We encourage you to review the privacy policies of all third-party websites you visit to understand their information practices before providing personal information directly to them.
In this Policy, “personal information” means information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, and online identifier or to one or more factors specific to his/her physical, physiological, genetic, mental, economic, cultural, or social identity. Personal information does not include aggregate information or de-identified information, meaning that the information can no longer be attributed to an identifiable natural person without the use of additional information. Additionally, personal information does not include publicly available information, which is information that is lawfully made available from federal, state, or local government records.
Personal information is required for us to be able to provide the Services to you. In addition, some of the Services we provide require that we disclose your personal information to third parties, such as to companies that help us to provide our Services. If you are not willing to provide your personal information and have it disclosed to third parties in accordance with this Policy, you will not be able to use our Services.
3. Information We Collect and How We Collect It
We may collect several categories of personal information from or about you, including information:
By which you may be personally identified, including your full name, email address, username, and/or image.
That is about you but individually does not identify you, including your grade in school, your age, what grade you teach, your feedback and survey responses on our Websites and Services, professional development, and training (e.g., how you feel about the quality and quantity of activities in the program, how likely you are to recommend the Websites or Services to others, or how you rate a particular digital lesson), and geographic location information (e.g., address, country, state, city and/or postcode).
About your internet connection, the equipment you use to access our Websites and Services and other usage details (e.g., session duration, number of actions per session, feature usage, and whether you complete videos or lessons).
We collect this information:
Directly from you when you provide it to us, such as when you register to use our Websites and Services; register for training, professional development; participate in a survey or provide feedback; sign up to receive marketing communication and newsletters from us; or when you contact us.
From your school district, school, or a services provider in order to provide you with access to the Websites and/or Services.
From a colleague who may refer you to us.
From our marketing and research partners who help us connect with educators or conduct research and surveys on our behalf.
Automatically from your device when you access or use our Websites and Services.
A. Information Provided by You
We collect the following types of personal information from you when you access our Websites and Services. The most common of these circumstances where you would provide personal information and the categories of personal information we collect in those circumstances include the following:
Purchasing a Subscription or Membership. When you purchase a subscription or membership to our Services, we may collect information necessary to process your transaction, including your name, email address, mailing address, phone number, payment information, such as a credit card number and/or other related information that may be required from you to complete your purchase (“Financial Information”). Unless we tell you otherwise at the time of your purchase, we do not collect, store or maintain your Financial Information; rather this information is handled by our Service Providers. For more information on how your information is shared in these instances, please see the “Third-Party Payment Processing” Section below.
Using Our Websites and Services. In order to use certain features of our Websites and Services, you (or your school) may be required to create a password-protected user account and provide us with personal information, including first name, middle initial, last name, username (Logon ID), password, teacher ID, teacher email, student ID, student grade, parent/guardian name, and parent/guardian email. We will store and use this information to administer the Websites and Services in which you choose to participate.
Contacting Customer Service. When you contact our customer service, we may ask you to provide, or confirm, personal information, including your first and last name, job title, email address, phone number, city, state, school or district, so that we can better serve you.
Newsletters. For non-student users of the Websites and Services, we may collect your email address, first and last name, and zip code if you sign up to receive our newsletters.
Participating in a Survey or Providing Feedback. We may contact you to participate in surveys or provide feedback. If you participate in a survey, we may ask you to provide personal information, including your name, session ID, job title, grade level you teach, your school name, and your school district for internal analysis, research studies, and to support product and services development.
Promotional or Marketing Communications. If you sign up to receive promotional communications or notifications from us, we may ask you to provide personal information, including name and email address, so that we can provide these to you.
Featured Questions. From time to time, we may want to feature questions and comments we receive from you and your students. To submit a Featured Question, we collect the email address of the teacher, and the first name of the student and their grade system (e.g., United States grades). If the question is selected to appear, we will send you a permission form to obtain appropriate consent from the student’s parent or legal guardian for the student to appear in any featured video. Participation in any recorded video is optional, and we will never proceed without a signed consent form.
Interactive Features. We may offer interactive features such as commenting functionalities, “likes,” chat services, review forums, tips, and social media pages. We may collect the information you submit or make available through these interactive features. Any information you share on the public sections of these channels will be considered “public” and is not subject to privacy protections referenced in this Policy. We may access and use any of your public reviews along with your member profile name for any purpose, including marketing.
Professional Development, Training Conferences, Trade Shows, and other Events. We may host professional development and training events, and may attend conferences, trade shows, and other events where we collect personal information from individuals who interact with or express an interest in us and/or the Services.
Registering for Events. When you register for an event, such as professional development, we may collect your name, job title, professional email address, phone number, mailing address, state, school district, and school name during the registration process.
Referrals. Some of our Services may allow you to refer other educators to use our Services by providing their names and email addresses. We will use the email addresses you provide to send an email inviting the recipient to use our Services. If the recipient does not respond to the invitation, we may send a single reminder email.
The above list provides examples of the personal information that may be collected when using our Websites and Services. If you do not want us to collect your personal information, please do not provide it to us.
B. Information that We Collect Automatically From You On Our Websites and Services, and the Technologies We Use to Collect It
We may automatically collect information from you when you visit or access our Websites and Services. We use this information to deliver our webpages to you upon request, to tailor our Services to the interests of our users, to learn how our Websites and Services are used, and to measure traffic and usages within our Websites and Services.
Usage Details. When you access and use our Websites and Services, we may automatically collect certain details of your access to and use of our Websites and Services, including, but not limited to, location data, time of visit, length of time your visit and of specific pages, page views, scroll depth, logs, scoring content that you are interested in, referring or exit website address, the content of any undeleted cookies that your browser previously accepted from us, and other communication data and the resources that you access and use on or through our Websites and Services.
We use various technologies to collect information from your computer or other device and about your activities on our Websites and Services, including:
C. Information Collected From Other Sources
We may also obtain both personal and non-personal information about you from the following categories of sources: your school, our marketing partners (including social media companies, and companies that license datasets of teachers, educators, and school administrators), our resellers or partners, advertising networks, and companies we work with to conduct research and surveys. We may combine this information with information we collect through our Websites, Services, or from other sources.
4. Purposes for Processing Personal Information
Purposes for using personal information. While the purposes for which we may process personal information will vary depending upon the circumstances, in general we use personal information for the purposes set forth below.
Provide and deliver the Services you request, license or purchase.
Personalize and improve our Websites and Services and your experiences when you use our Websites and Services, including to develop new products and services.
Process and complete a transaction or service requested by you.
Contact you in response to sign up forms such as Contact Us, and to provide you with customer support.
Communicate with you about programs, products, and Services that we think may interest you; offers (such as a free-trial of a product or services); updates on new or popular content, features and Services; training and professional development opportunities; connecting you with other educators; special events; educational programs; and news from us. (If you prefer that we not contact you in this manner, please follow the Opt-Out instructions in this Policy). We do not contact students for this purpose.
For marketing purposes, including helping us create and publish content most relevant and impactful to you; developing and displaying content and advertising tailored to your interests on our Websites and Services; measuring and improving the effectiveness of our advertising campaigns; and developing sales and business development leads.
To aggregate and/or de-identify information about users or to use suggestions, comments, and ideas that are not personally identifiable. We are free to use and disclose through any means and use for any purpose information that is not personally identifiable in our sole discretion.
Monitor and analyze trends, usage, and activities in connection with our Websites and Services.
For surveys, research and development, and analytics (including sales and marketing research).
Ensure that our own processes, procedures and systems are as efficient as possible.
Enforce our Terms of Service.
Manage our business operations and perform functions as otherwise described to you at the time of collection.
Keeping our Websites, Services, products and IT systems secure.
Protect against or identify possible fraudulent transactions, and otherwise as needed to manage our business.
For legal compliance purposes.
5. Sharing of Personal Information with Others
We share your personal information as necessary to provide the services you request, including sharing information with third party service providers; when required by law; to protect rights and safety; and with your consent.
We may share personal information with:
Authorized Service Providers: We may share your personal information, including name, unique personal identifier, IP address, email address, job title, other similar identifier, usage details, profile reflecting a consumer’s preferences, characteristics, behavior, abilities, and aptitudes and device details with our authorized service providers that perform certain services on our behalf. These services may include delivering our Websites or Services to you; providing customer service and support to you; providing marketing, advertising, and business development; performing marketing, business and sales research and analytics; supporting our Websites and Services functionality; conducting surveys and research for product development and improvement; processing payments through a third-party payment service provider; and supporting challenges, contests, promotions, sweepstakes, surveys and other features offered through our Websites and Services. The research reports and white papers do not contain personal information.
RTV. Between and among RTV, our affiliates, subsidiaries and the companies under our control and ownership, we may share personal information such as name and contact details of our customers’ primary point of contact and end users of the Services, users’ usage details of the Services, customer’s sales history and account information, and information collected through our Websites and Services by tracking technologies (as described above) for the following purposes: identifying business development opportunities, our marketing and advertising activities, conducting research and analytics, and improving our Websites, Services and product development.
Corporate and Non-Profit Education Partners. We partner and collaborate with corporate and non-profit education partners to provide teachers with professional development and training; introduce students to careers and educational experiences; develop educational websites for educators, children, and parents; integrate digital content provided by the corporate and non-profit education partners into the Services; underwrite and sponsor RTV Services for certain schools;
We share aggregate or de-identified information and statistical reports relating to usage of the Website and Services with our corporate and non-profit education partners (e.g., aggregate counts of schools with access to the Services, aggregate counts of students who have logged in and used the content in the Services, and aggregate counts of clicks on content in the Services). These reports do not contain personal information.
Referrals. If you choose to refer colleagues and other contacts to use our Services by providing their names and email addresses, we may share your name with your colleagues in the initial referral email and one-time follow-up email.
Other situations. We also may disclose your information:
In response to a subpoena, document request, or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to prosecute or defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our terms and conditions or other agreements or policies.
In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
When you provide us with your consent to share your information with third parties.
Aggregated and Non-personal Information:
We may share aggregated and non-personal information we collect under any of the circumstances set forth in this Policy. We may share aggregated information with third parties, including advisors, corporate and non-profit partners, and potential customers, for the purpose of conducting general business analysis. For example, we may tell future advertisers the number of visitors to our Websites and Services and the most popular features or services accessed. This information does not contain any personal information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.
6. How Long We Retain Your Personal Information
RTV will retain your personal information for as long as is needed to fulfill the purposes set forth in this Policy, unless a longer retention period is required or permitted by law (such as for tax, accounting, or other legal requirements).
Upon expiration or termination of any subscriber agreement, RTV destroys personal information previously received from the subscriber, customer, and/or user when the subscriber, customer, or user signed up for the Services along with information relating to the subscriber, customer, and/or user’s use of the Services no later than sixty (60) days following such termination, unless a reasonable written request is submitted by the subscriber or customer to us to hold such personal information.
RTV retains the information it collects for an unrestricted period of time subject to requests for deletion.
7. Your Privacy Rights
You may have certain rights in relation to your personal information. If you would like to exercise any of them, please contact us (contact details below).
We will consider all such requests and provide our response within a reasonable period (and in any event within any time period required by applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances.
If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
How You Can Access or Request to Delete Your Information
If you have an online account with us, you have the ability to review and update your personal information online by logging into your account. You can also review and update your personal information by contacting your school.
If you are a user of the Services, you may request to have your personal information that you provided when you subscribed along with the information relating to your use of the Services removed from our databases by submitting a request to our contact information set forth at the end of this Policy, and insert “Privacy Rights Request” in the subject line. We will remove such information as soon as practicable for us, however, we may still retain certain information associated with your account for analytical purposes and record keeping integrity, as well as to prevent fraud, collect any fees owed, enforce our terms and conditions, take actions we deem necessary to protect the integrity of our Websites or our users, or take other actions otherwise permitted by applicable law. In addition, if certain information has already been provided to third parties as described in this Policy, retention of that information may be subject to those third parties’ policies.
Your Choices About Collection and Use of Your Information
You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our Websites and Services because such information may be required in order for you to access features of our Websites, participate in a contest, survey, or sweepstake; ask a question; contact customer support; or otherwise initiate other transactions on our Websites and Services.
At any time you can choose to no longer receive commercial or promotional emails or newsletters from us by modifying your email preferences by selecting the “Opt-Out” link found in the footer of the communication or on our Websites and following the instructions or contacting us. Non- student users of the Services may be given a choice as to whether you want to receive email messages about products and services related to your interest. You may modify your choice at any time by using the “Opt-Out” link as described above.
You also will be given the opportunity, in any commercial email that we send to you, to opt out of receiving such messages in the future. It may take up to ten (10) days for us to process an opt-out request. We may send you other types of transactional and relationship email communications, such as service announcements, administrative notices, and surveys, without offering you the opportunity to opt out of receiving them. Please note that changing information in your account, or otherwise opting out of receipt of promotional email communications will only affect future activities or communications from us.
Even if you opt-out of receiving promotional or marketing communications, you may continue to receive emails and notifications relating to your subscription, service announcements, administrative notices, surveys, and/or other business-related communications.
8. Children’s Personal Information
RTV does not collect personal information from students at this time.
In most instances, RTV will only request the first name and email address of a child under 16 years old in order to complete an immediate request from the child. For students using the Services, any personal information that may be provided, which may include, but is not limited to, first and last name, grade and school, will be provided by the school district, individual school, or individual using the Services.
Use of Personal Information Collected from Children
When we collect personal information from children under 16 years old, we will only use that information for the express purpose for which it was collected. The personal information will not be used for any other purpose.
Sharing of Personal Information Collected from Children
Except as provided in this Section, we do not share personal information collected from children under 16 years old with any third parties. We may, however, share a child’s personal information that we have collected from the child’s school district, school or from the child in the following limited instances:
We may share such information with our authorized service providers who help us maintain our Websites and Services and provide other services to us. We seek to ensure that these service providers may not use the personal information for any other purpose. These service providers have agreed to maintain the confidentiality, security and integrity of the personal information.
Note to Parents and Legal Guardians
Please contact RTV at any time regarding privacy questions or concerns, or to request to review what personal information we have collected from a child. Parents may also contact us at any time to request that we delete the personal information of a child or a parent and/or refuse to permit further collection or use of a child’s information. We will take steps to verify that any person contacting us for a child’s information is that child’s parent or guardian.
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9. Other Important Information
Below, you will find additional privacy information you may find important.
The security of your personal information is important to us. We follow generally accepted standards (including by taking physical, electronic and procedural measures) to protect the personal information that we collect and process.
While we are focused on the security of your personal information and follow strict standards, processes and procedures that are designed to protect your personal information, you must remember that the internet is a global communications vehicle open to threats, viruses and intrusions from others and so we cannot promise, and you should not expect, that we will be able to protect your personal information at all times and in all circumstances.
You should also take care with how you handle and disclose your personal information and should avoid sending personal information through insecure email. Please refer to the Federal Trade Commission’s website at http://www.ftc.gov for information about how to protect yourself against identity theft.
No Rights of Third Parties
This Policy does not create rights enforceable by third parties.
Changes to this Policy
We will occasionally update this Policy to reflect material changes in our privacy practices. If we make any material changes in the way we collect, use, and/or share your personal information, we will notify you by posting the modified Policy on our Websites and Services and indicating at the top of the Policy the date it was last updated. We may also notify you by sending you an email. We encourage you to review the Policy each time you visit one of our Websites and Services to see if this Policy has been updated since your last visit to make sure you understand how your personal information will be processed.
10. Age Screening
If we become aware that we have inadvertently received personal information from a child under the age of thirteen other than in a legally permissible situation, we will delete the information from our records as soon as we discover it.
Do Not Track Disclosure
RTV does not support Do Not Track browser settings and does not currently participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your personal information.
A. United Kingdom/European Union/European Economic Area
If you are an individual located in the United Kingdom, European Union or European Economic Area, you may have the following rights regarding your personal information:
You have the right to request access to your personal information, and the rectification of inaccurate personal information concerning you and obtain a copy of the personal information held by us. You have the right to obtain the deletion or the restriction of processing of your personal information in certain circumstances, including when the data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, except when we are required by law to maintain or otherwise process your personal information, for the establishment, exercise, or defense of legal claims, or for the protection of the rights or another person. You may have the right to request that we stop processing your personal information and/or to stop sending you marketing communications. In certain circumstances, you may have the right to be provided with your personal information in a structured, machine readable and commonly used format and to request that we transfer the personal information to another data controller without hindrance. You also have the right to lodge a complaint with a supervisory authority, in particular in the country of your habitual residence, place of work, or place of an alleged infringement of the applicable data protection law.
If you would like to make such a request, please email: email@example.com and insert “Privacy Rights Request” in the subject line or call this number: 718-986-5104. To protect your privacy and security, we may take steps to verify your identity before taking action on your request.
Our Legal Basis for Processing Personal Information
Our legal basis for processing your personal information will depend on the personal information concerned and the specific context in which we collect it. We rely on the following lawful bases for processing personal information: necessary for the performance of a contract, your explicit consent, and our legitimate interests, and compliance with legal obligations.
When we have collected your personal data to provide you with Services that you have requested, our legal basis for the processing of that personal data is that it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract. If you refuse to provide us with your personal data, you may be unable to obtain the products and services from us that you requested.
We also collect and process personal data about you as necessary to operate our business, sales, account management, provide direct marketing, product development and improvement, product usage analytics, meet our contractual and legal obligations, comply with federal, state, and local laws, and/or fulfill our other legitimate interests (when not overridden by your data protection interests or fundamental rights and freedoms).
When you participate in a survey, challenge, competition, sweepstake, promotion, and/or contest, our legal basis for the processing of your personal data is your explicit consent. Where our processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. This does not affect the lawfulness of the processing based on consent before its withdrawal.
If you have any questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided below.
International Transfer of Information
Your personal information may be transferred to, stored, and processed within the United States. Additionally, we may transfer your personal information to other countries in certain circumstances, for example because a server or third party service provider is located there. BY
PROVIDING YOUR PERSONAL INFORMATION TO US, YOU ARE CONSENTING TO ANY TRANSFER, STORAGE, AND PROCESSING IN ACCORDANCE WITH THIS POLICY.
There are potential risks to you associated with transferring your information to the United States and other countries due to the absence of an adequacy decision and appropriate safeguards. These risks include the risk that you will not be able to exercise your data protection rights under applicable law to protect yourself from unlawful use or disclosure of your information. The data protection and privacy laws of certain countries, including the United States, may not afford you the same level of protection as those in your own country.
11. Contact Us
If you have any questions about this Policy or our privacy practices, please contact us by email or postal mail as follows:
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