Privacy Notice

New Classrooms Innovation Partners, Inc. (“New Classrooms,” “we,” “us,” and “our”) respects your privacy. As a result, we have created this privacy notice (this “Notice”) to let you know how we collect, use, and share information in connection with TTO360.org, TTORoadmaps.org, teachtoone.org, newclassrooms.org, the subdomains of those website, and any successor websites to the foregoing (collectively, the “Site”), in connection with any software downloaded from the Site or otherwise made available by us (collectively, the “Software”), or any other services provided by us in connection with the foregoing (collectively, the “Services”). This Notice lets you know how we process Personal Information in connection with the Services, including the Personal Information of students (“Students”), parents or legal guardians (“Parents”), and other users of the Services, including teachers and school administrators (“Users”). A Parent may also be a User.

By using the Site, Software, or any other Services, and in particular by registered for an account to use any Services, you are expressly consenting to the collection, use, and disclosure of your personal information as set forth in this Notice. This Notice is incorporated and subject to our Terms of Use, available here. If you do not agree to any of the provisions of this Notice, you should not use the Site, Software, or any other Services.

Please read this Notice, together with any other privacy notices or waivers we may provide when collecting Personal Information from you. We may update this Notice from time to time to reflect changes in our privacy practices. If we make significant changes to this Notice, we will make efforts to notify you through the Services or using the contact information you provide. Checking our Terms of Use is the best way to stay up-to-date on how we collect and use Personal Information in connection with the Services.

1. WHAT INFORMATION WE COLLECT AND WHY

“Personal Information” is information that identifies, relates to, describes, or can be reasonably linked to, directly or indirectly, a particular individual or household. We may use Personal Information of Students (“Student Personal Information”) and Personal Information of Parents (“Parent Personal Information”) as permitted by law and as described in this Notice. Personal Information does not include de-identified or aggregated information.

A. Student personal Information

We use Student Personal Information to:

• Assess Student understanding
• Create personalized learning plans for participating Students
• Track Student progress
• Software Integrations to deliver the Services
• Analyze, report, improve & deliver the Services
• Comply with legal obligations
• Make other internal, lawful uses of the Personal Information that are compatible for the context in which you provide it

We collect the following categories of Student Personal Information:

B. Parent Personal Information

We use Parent Personal Information to:

• Verify parental consent to use of Student Personal Information (other than in cases where we require schools and other partners to collect verified parental consent for our use of Student Personal Information)
• Provide access to the Parent dashboard to track your Student’s progress
• Obtain payment of fees and process credit card payments
• Contact you and inform you of news, events, offers, or other information related to your child or children’s participation in the Services
• Comply with legal obligations
• Make other internal, lawful uses of the Personal Information that are compatible for the context in which you provide it

C. User Personal Information

We use User Personal Information to:

• Help us improve the content and functionality of the Services
• Better understand our Users and their preferences
• Contact you about the Services
• Obtain payment of fees and process credit card payments
• Provide you with information you have requested or services you have signed up for, such as newsletters
• Communicate offers or other content that may be of interest to you
• Comply with legal obligations
• Make other internal, lawful uses of the Personal Information that are compatible for the context in which you provide it

D. Cookies and Analytics

We use various technologies to collect and store information when you use the Services, and this may include sending one or more cookies or anonymous identifiers to your device. We use information collected from cookies and other technologies, like pixel tags, to improve your user experience and the overall quality of the Services. When you use the Services, other companies also collect certain information on you using anonymous identifiers, cookies and the other tracking technologies mentioned above. In this regard, we use Google Analytics to better understand how our customers navigate to and through the Services, how long customers spend visiting our content items and how often they return to visit the Services. Google’s privacy policy is available at: http://www.google.com/privacypolicy.html.  You may set your browser to block all cookies; however, it’s important to remember that some aspects of the Services may not function properly if your cookies are disabled.

When you use the Services, we may automatically collect and store certain information in server logs. This may include details of how you used the Services, such as your event attendance; internet protocol addresses (IP addresses); system activity, browser type, the date and time of your request and referring URL; and cookies that may uniquely identify your browser or your Services account.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not want them to track your online activities. The Services does not currently support Do Not Track requests.

2. HOW YOUR PERSONAL INFORMATION IS COLLECTED

Personal Information is obtained directly from Students, Parents, and Users through the Services.

3. DATA REGARDING CHILDREN UNDER 13

We work with partners and schools that provide Services as part of their curriculums to Students under 13, and we sell the Services directly to schools that use the Services for the benefit of, and allow use of the Services by, Students under 13.  In such cases, we rely on these partners and/or schools to obtain verified parental consent required by the Children’s Online Privacy Protection Act of the United States (“COPPA”) from parents or guardians of such Students under 13 so that New Classrooms can either directly collect information from such Students or so that New Classrooms can receive such information from the applicable partner or school that collected such information.  We rely on such partners and/or schools to obtain this consent before New Classrooms directly collects Personal Information from such Students, or before the partner or school provides such information to New Classrooms (as applicable).  We collect only Personal Information set out in Section 1.A above (Student Personal Information) regarding Students under 13, whether collected directly or indirectly by New Classrooms. 

If you are a Parent of a child under 13 that attends a school whereby the Services will be provided to such child, you must provide verified parental consent for your child to use the Services, and you must be the actual Parent of the child in order to legally grant such consent under COPPA.  If you have additional questions on how this consent is obtained or can be withdrawn, please contact the school or partner directly.  Subject to certain limitations under law, you have the right to withdraw your consent to use of Student Personal Information or Parent Personal Information at any time by contacting us using the contact details in Section 14 (Contact Us).  If you revoke your consent or refuse to allow further collection of Personal Information, you must also contact the applicable school whereby the Services are being provided to your child as a Student.  Upon receipt of this request, we will delete any unaggregated, non-anonymized personal information we have in our possession regarding your child, and you and your child will not provide us with any more Personal Information thereafter (note, however, that we may suspend you and your child’s ability to use the Services indefinitely, until a new verified parental consent is received by the applicable school or partner).  As a Parent, you also have rights, as set forth in Section 4 below, to view, verify, and change or update any Student Personal Information collected by us about your child.

Any Personal Information from Students under the age of 13 that is collected by New Classrooms as described herein is done solely to provide the Services to partners and schools using the Services for such Students, as well as the individual Students themselves that are participating in the classes provided by such partners and schools.  We do not collect more Personal Information from Students under 13 than is necessary for us to do the foregoing.  New Classrooms requires such partners and schools to comply with COPPA.  Except as set forth in this Notice, New Classrooms does not otherwise knowingly solicit any Personal Information directly from, or otherwise knowingly use or disclose Personal Information of, Students under the age of 13.  In the event New Classrooms is made aware that it has collected Personal Information from a child under 13 years old in a manner that is inconsistent with COPPA, then we will delete this information as soon as practicable. 

4. YOUR PARENTAL RIGHTS UNDER COPPA

We will not require a Student to disclose more information than is reasonably necessary to participate in the Services. Under the COPPA, Parents have the right to:

• Review (and verify, change, or update) their child’s personal information, direct us to delete it, and refuse to allow any further collection or use of their child’s information, and
• Agree to the collection and use of their child’s information without allowing sharing with third parties, unless the disclosure is part of the service offered.

To exercise your rights under COPPA, please contact us at 212-920-6130, via email at privacy@tto2022stage.wpengine.com, or by mailing us at:

344 Grove Street
#65400
Jersey City, NJ 07302

5. AUTOMATED DECISION MAKING AND PROFILING

We do not foresee making any substantive decisions about Students, Parents or Users using automated means or profiling; however, we will notify you in writing if this position changes.

We may retain certain Personal Information as permitted by law.

6. PERFORMANCE DATA

New Classrooms collects information directly from Students, over the Internet, in the form of the interactions that Student makes when using Services. We refer to the resulting Personal Information as “Performance Data,” and it includes but is not limited to data on when a Student starts and stops a lesson, the responses a Student makes to questions asked, the timing of a Student’s responses, your Student’s choice of character and customizations, and the choice of lessons to play.

7. COLLECTION AND USE OF AGGREGATED DATA

We also collect and use anonymized data such as statistical or demographic data (“Aggregated Data”). Aggregated Data may be derived from or include data collected through the Services but is not considered Personal Information under applicable law because this data does not directly or indirectly reveal Student, Parent, or User identity. 

If we combine or connect Aggregated Data with Personal Information so that it can directly or indirectly identify a Student, Parent or User, we treat the combined data as Personal Information which will be used only in accordance with this Notice.

8. HOW WE SHARE YOUR PERSONAL INFORMATION

We do not sell your Student Personal Information, Parent Personal Information, or User Personal Information to third parties, whether for monetary or other valuable consideration without your consent. However, as part of the Services and our other business activities, we may share your Personal Information with others in the following circumstances:

9. HOW WE PROTECT YOUR PERSONAL INFORMATION

We have implemented reasonable and appropriate steps to protect Personal Information from unauthorized access, disclosure, improper use, unauthorized modification, and unlawful destructions or accidental loss of Personal Information. We train our employees on data handling practices. In addition, New Classrooms and its business partners enter into confidentiality agreements which require that care and precautions be taken to prevent loss, misuse, or disclosure of Personal Information.

While we attempt to ensure the integrity and security of all Personal Information held by us, please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, although New Classrooms complies with its legal obligations in respect of the security of your personal data we cannot guarantee its absolute security.

We have put in place procedures to deal with any suspected security breach that involves your Personal Information and will notify you and the applicable regulator of a suspected breach where legally required to do so.

10. HOW LONG WE RETAIN YOUR PERSONAL INFORMATION

New Classrooms retains Personal Information only as long as necessary to fulfill the purposes for which we have collected such information, including for the purposes of satisfying any legal, accounting or reporting requirements. We will destroy your data at any time upon request subject to certain lawful exceptions under applicable laws. Note that the destruction of your data will mean you may no longer be able to use the Services. 

11. YOUR CALIFORNIA PRIVACY RIGHTS

Students, Parents, and Users who are residents of California also have the following rights under the California Consumer Privacy Act (“CCPA”) regarding your Personal Information. 

A. Right to Know

You have the right to know and see what data we have collected about you over the past twelve months, including:

• The categories of Personal Information we have collected about you,
• The categories of sources from which the Personal Information is collected,
• The business or commercial purpose for collecting your Personal Information,
• The categories of third parties with whom we have shared your Personal Information, and
• The specific pieces of Personal Information we have collected about you.

B. Right to Delete

You have the right to request that we delete the Personal Information we have collected from you (and direct our service providers to do the same). There are a number of exceptions, however, that include, but are not limited to, when the information is necessary for us or a third party to do any of the following:

• Complete your transaction,
• Provide you a good or service,
• Perform a contract between us and you,
• Protect your security and prosecute those responsible for breaching it,
• Fix our system in the case of a bug,
• Protect the free speech rights of you or other Users,
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.),
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws,
• Comply with a legal obligation, or
• Make other internal and lawful uses of the information that are compatible with the context in which you provided it.

B. Exercising Your Rights

You may exercise your right to know or your right to delete at any time by logging in to your Services profile or you child’s Services profile and reviewing or deleting all provided Personal Information. 

However, please note that we may retain certain Personal Information as permitted by law.

If you have questions or require assistance in exercising your rights under the CCPA, please contact us at 212-920-6130, via email at privacy@tto2022stage.wpengine.com, or by mailing us at:

New Classrooms National Office
344 Grove Street
#65400
Jersey City, NJ 07302

Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information. We will not discriminate against you for exercising any of your CCPA rights described above.

12. YOUR ADDITIONAL RIGHTS IN THE EUROPEAN ECONOMIC AREA

• Withdrawal of Consent: If consent is the lawful basis of our processing, you have the right to withdraw any consent that you have provided to us to process your personal data.
• Access: You have the right to access your personal data.
• Rectification: You have the right to rectify inaccurate personal data.
• Erasure: You have the right to have your personal data erased if it is no longer necessary for the purposes for which it was processed, you have withdrawn your consent to, or object to, its processing and there is no other legitimate grounds for processing it or you consider that it has been unlawfully processed.
• Restriction: You have the right to have the processing of your personal data restricted if you contest its accuracy, its processing is unlawful, we no longer need it but you need it for a legal claim, or you have objected to its processing and await verification of our legitimate grounds for processing it.
• Data Portability: You have the right to have certain personal data you provide to us transferred to another company in a machine-readable format.
• Objection: You have the right to let us know that you object to the further use or disclosure of your personal data for certain purposes.

Students, Parents, and Users whose personal data has been collected in connection with our activities in the European Economic Area (“EEA”) have the following additional rights:

You may exercise your right to access and erasure at any time by logging in to your Services profile and reviewing or deleting all provided personal data. Please note that the right to erasure is not absolute and it may not always be possible to erase personal data on request, including for example where the personal data must be retained to comply with a legal obligation.

If you have questions or require assistance in exercising rights under the available in the EEA, please contact us at please contact us at 212-920-6130, via email at privacy@tto2022stage.wpengine.com, or by mailing us at:

New Classrooms National Office
344 Grove Street
#65400
Jersey City, NJ 07302

Only you, or someone legally authorized to act on your behalf, may make a request related to your personal data. You also have the right (where applicable) to withdraw any consent given in relation to the processing of your personal data.

New Classrooms Innovation Partners, Inc. is the controller of personal data under this Notice. If you are in the EEA, you may lodge a complaint with a supervisory authority that has authority in your country or region. Contact information for such authorities can be found here.

13. LINKS TO OTHER SERVICES AND SUPPORT SITES

The Services may contain links to other websites and online services. When you go to these other sites, the information you provide will be used as described in the privacy policy and terms of use on those other sites. We are not responsible for the privacy practices of any third party sites, and the fact that a link to a third party site exists on the Services does not mean that such site operates under the same or similar privacy practices as set forth in this Notice. We encourage you to be aware of this when you click on a link and leave the Services, and to read the privacy policies of every site that collects Personal Information from you. If you access a third party site using a link, then you do so at your own risk.  

The Services is hosted by and support services are offered by Amazon Web Services, Microsoft Azure, Classify Learning, and Learnosity. When you provide information in connection with support (for example, in a request for training or help), that information will be used by Classify Learning in accordance with their privacy policy. We encourage you to read that privacy policy before providing them with your information.

All credit card information is processed and stored by our processing partner, Stripe. Their privacy policy can be found here.

14. CONTACT US

If you have any questions about your privacy or about security measures at New Classrooms, if you have any disputes about our collection and use of Personal Information, or if you would like to opt-out of email messages and other promotional mailing provided by us, please contact us at 212-920-6130, via email at privacy@tto2022stage.wpengine.com, or by mailing us at:

New Classrooms National Office
344 Grove Street
#65400
Jersey City, NJ 07302