Strut Learning Privacy Statement
Overview
Strut Learning is committed to the protection of users and partner privacy. Please review this Privacy Statement carefully to understand how the data and information you provide to us will be treated.
This Privacy Statement applies to Personally Identifiable Information (“PII”) collected (1) at the Strut Learning Web site and other sites that we own or control (“Strut Learning Web site”), including www.strutlearning.com, (2) for or by Strut Learning Platform enterprise offerings that may be hosted by Strut Learning or its third party service providers, or (3) for or by Strut Learning Platform software as a service (SaaS) consumer offerings. This Privacy Statement applies to this list of websites. There are two main classes of users of the Strut Learning Platform: enterprise users and consumer users. Enterprise users access the Strut Learning Platform by virtue of an agreement that we have with the user’s institution (educational or otherwise), employer or other organization (“Organization”). Consumer users are visitors to the Strut Learning Web site.
This Privacy Statement does not affect or control the enterprise client Organization’s information collection, use or disclosure of your information. You should contact your Organization and review its information collection and disclosure practices.
Consent to Strut Learning to Collect and Process Information about You
“Personally Identifiable information” is defined as all information related to an individual, either directly or indirectly identified by the information or which could be reasonably identified directly or indirectly. Personally Identifiable Information includes information that relates to an individual’s personal characteristics. Examples of Personally Identifiable information include gender, age, income, home address, personal phone number, identification number, location data, an online identifier, ethnic background, family status, and other data that belong to an individual such as health, religion, political activities or views. The collection of aggregate information without Personally Identifiable Information is exempt from this Privacy Statement.
By providing any Personally Identifiable Information to us or sharing Personally Identifiable Information (including sensitive information) with others using a Strut Learning Platform, other Strut Learning offering or the Strut Learning Website, you expressly and voluntarily consent to the storage and processing of that Personally Identifiable Information by us in accordance with the terms and conditions of this Privacy Statement and any applicable user agreement (including an end user license agreement or service agreement) that allows us to store and process Personally Identifiable Information about you. When you provide information, that information may reside on our or our service providers’ systems. You understand and agree that Personally Identifiable Information collected through Strut Learning Platform and Strut Learning Website may be stored and processed by us, our affiliates or our service providers in the United States, Canada, United Kingdom or other countries, including countries other than your country of residence; the laws of the jurisdiction in which the information is stored and processed will apply to its storage and processing. If you are a user of Strut Learning’s products and services, the location of your data and the laws that apply to its storage and processing may be subject to a contract between Strut Learning and your Organization.
Collection of Personally Identifiable Information
We may collect personally identifiable information from you in the following ways:
PROFESSIONAL SERVICES
In order to access the Strut Learning Platform, you may be asked to create an account which will require you to provide information that may include your name and email address and other Personally Identifiable Information. Select Strut Learning services and other Strut Learning offerings enable you to provide additional information voluntarily. Providing information beyond what is required at registration is up to you, but providing such information may enable you to derive more benefit from Strut Learning Platform.
Personally Identifiable Information about you may be collected if your Organization has contracted with Strut Learning for professional services or end-user support, or if you are an approved support contact under our agreement with your Organization. This information may include your name, email address or other Personally Identifiable Information. Information collected in connection with our provision of professional services to your Organization is collected for the purpose of providing such services to your Organization efficiently and effectively. Information collected through the use of our support service is intended to help resolve issues as quickly as possible, and to ensure that you can be notified of the progress of any issues that you describe.
We may collect Personally Identifiable Information about you if you contact us by email or for support for a Strut Learning Platform commercial or consumer offering.
ACTIVITIES RELATED TO THE STRUT LEARNING WEB SITE AND MARKETING
The Strut Learning Web site may ask you to provide Personally Identifiable Information, such as your email address, name, telephone phone or cellular number, employer name, and common mailing addresses. We may also collect demographic information, such as your postal or zip code, preferences, interests, etc.
We may collect Personally Identifiable Information from you such as your name, email address, telephone number and Organization information when you sign up for webinars, product trials, newsletters, the quarterly Strut Learning Platform Flexible Learning Advancement Committee (FLAC) event conference, contests or other marketing initiatives through the Strut Learning Web site.
COOKIES AND WEB BEACONS (pixels)
Strut Learning’s web site use technologies, such as cookies and web beacons (pixels), to collect information about the pages you view, the links you click and other actions you take on the Strut Learning Web site.
ANALYTICS
The Strut Learning Platform and the Strut Learning Web site use tools that help us develop and optimize our Strut Learning Platform and the Strut Learning Web site. We also use Google Analytics to improve our offerings and our Website. See http://www.google.com/analytics/terms/us.html for more information about Google Analytics.
HOW WE USE YOUR INFORMATION
If you are an enterprise user:
If your Organization is a school in the United States, our provision of services may involve us having access to student education records subject to the US Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. § 1232g, et seq. Under FERPA, Strut Learning and its personnel are deemed a “school official” to the extent we have access to student education records, and we will not use such student education records for any purpose other than to perform our agreements with you or as otherwise mandated by applicable regulations.
Beyond the Personally Identifiable Information that you directly provide to use Strut Learning products and services, we infer Personally Identifiable Information based on your usage. Monitoring information such as IP Addresses, the date/time of actions being taken, and what features are being used help us deliver great experiences. Strut Learning analyzes this type of data in aggregate and does not sell this information to third parties.
If you are a consumer user:
We may use your information to communicate with you. We may send certain service communications such as welcome letters, billing reminders, information on technical service issues, and security announcements. Some Strut Learning Services may send periodic member letters that are considered part of the service. We may also send you promotional information to inform you of other Strut Learning Platform, promotions and services.
We use your information to operate and improve the Strut Learning Platform and the Strut Learning Web site. These uses include providing you with more effective customer service, making the Strut Learning Platform easier to use by eliminating the need for you to repeatedly enter the same information, performing research and analysis aimed at improving the Strut Learning Platform and the Strut Learning Web site, and displaying content and advertising that are customized to your interests and preferences.
Some Strut Learning Platform services and functionality are accompanied by interactive features such as chat rooms, forums, messaging and other ways to share. If you are an enterprise user, permissions as to what features are enabled and who has access to those features are determined by your Organization.
When you receive newsletters or promotional emails from us, we may use web beacons, customized links or similar technologies to determine whether the email has been opened and which links you click in order to provide you more focused e-mail communications or other information.
COMMUNICATIONS WE SEND
We may communicate with you through email or other means available through a Strut Learning Platform or other Strut Learning offerings. We may send emails that help inform you about features of the Strut Learning Platform and we may also send you service messages related to the function of Strut Learning Platform. We may send you messages with promotional information directly or on behalf of our partners.
If you sign up for webinars, product trials, newsletters, attend conferences, contests, mailing lists or other marketing initiatives through the Strut Learning Web site, employees of
Strut Learning may contact you with information about the Strut Learning Platform and promotions that may be of interest to you. We may offer Webinars, product trials, conferences and events, contests or other marketing initiatives with certain partners; in such cases, the information you submit upon sign-up is shared with the relevant partner(s).
SHARING YOUR INFORMATION WITH THIRD PARTIES
We may share your information with third parties who are not our partners or service providers only in the following situations:
We have your consent through an opt-in option provided to you; or We have a good faith belief that access, use, preservation or disclosure of your Personally Identifiable Information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable terms and conditions of this Privacy Statement or any applicable user agreement, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of us, our users or the public as required or permitted by law.
As may be necessary in the course of providing our product offerings to you, we may disclose information to the payment processors, auditors, commercial partners, customer support providers, marketing and public relations companies, and operational services providers.
Mergers or Acquisitions: As with any other business, it is possible that in the future, Strut Learning could merge with, or be acquired by, another company. If such an acquisition occurs, you consent to the successor company having access to the information maintained by Strut Learning, and such successor company would continue to be bound by this Privacy Statement unless and until it is amended.
Except as part of the sale of all or substantially all of our assets, we will not sell, trade, or rent your Personally Identifiable Information to third parties who are not our partners or service providers unless we have your consent.
INFORMATION YOU SHARE WITH OTHER USERS
The Strut Learning Platform may enable you to share information with or send communications to other users or the general public. You (or, if you are an enterprise user, your Organization) may select the other users with whom you share or to whom you send this information. Once you share information with or send information to other users, however, those other users may share your information at their discretion.
Your Options for Your Personally Identifiable Information
CORRECT AND ACCESS YOUR PERSONALLY IDENTIFIABLE INFORMATION
We offer users the ability to access or correct information we collect during registration or which they have provided in using the Strut Learning Platform. Users may correct this information at any time and as often as necessary by using the features provided within the applicable Strut Learning Platform or other Strut Learning offering. To access or correct Personally Identifiable Information collected by us that is not available through a Strut Learning Platform or other Strut Learning offering, please contact us by email. We will respond within a reasonable timeframe of receiving your request or as otherwise required by law.
We may decline to provide you with access to, or to change, your Personally Identifiable Information if (a) your request is not provided in writing, (b) your request does not provide us with sufficient detail to identify the Personally Identifiable Information you seek to access or change, (c) we are unable to verify your identity to our satisfaction, (d) we deem, in our sole discretion, that it would be unreasonable in the circumstances to provide you with access to or to correct your Personally Identifiable Information, or (e) as otherwise provided by legislation.
If you are an enterprise user, you should contact your Organization for questions about access to the Personally Identifiable Information collected by your Organization.
USER OPT-OUT OPTION AND RETENTION OF YOUR INFORMATION
You may opt out of receiving promotional information from us by following the unsubscribe procedures indicated in promotional information you receive.
If you are an enterprise user, retention of your Personally Identifiable Information is governed by the privacy policies and is the responsibility of your Organization. If you wish to remove your account, please contact your Organization. If your Organization retains the information, it is subject to our contractual arrangement with your Organization and may be subject to our archival policies.
If you are a consumer user, we will retain your Personally Identifiable Information for so long as you maintain an active account or user profile, or as needed to provide you with the applicable Strut Learning Platform or other Strut Learning offering.
If you are a consumer user and you wish to remove or restrict the collection of data with an account you have with us, you may do so by contacting us at info@Strutlearning.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce this Privacy Statement and any applicable user agreements. We will take steps to ensure that your Personally Identifiable Information is destroyed, erased or made anonymous as soon as the purpose for which it was collected is no longer relevant, or as required by law.
Please be aware that, as long as you have access to the Strut Learning Platform, you cannot opt out of receiving service messages from us. Also, if we send communications to you via the carrier service with which you have a mobile communications subscription or otherwise have access, you understand you will pay any service fees associated with your receipt of messages on your mobile device (including text messaging charges).
Information Security
Strut Learning takes appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. We follow industry best practices, contract with third party vulnerability management services, and an independent third party review of all technology practices is conducted annually to identify security issues and assess the implementation and management of best practices. These include external and internal reviews of data acquisition, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store Personally Identifiable Information.
Access to Personally Identifiable Information is restricted to authorized Strut Learning employees who have a need to know specific information in order to perform their duties.
All employees are bound by written confidentiality agreements and subject to discipline, up to and including termination, as well as civil action and criminal prosecution, if they fail to meet these obligations.
While the complete elimination of all risk or misuse of, or unauthorized access to Personally Identifiable Information is not possible, Strut Learning does take all possible steps to ensure the security of all data. We cannot guarantee the security of any data (including Personally Identifiable Information) that we receive and store on our or our service providers’ systems.
Clients are responsible for the maintenance of any passwords and to prevent unauthorized access to and use of any Strut Learning Platform to which you have access.
Protection of Children’s Personal Identifiable Information
The Strut Learning Platform contains configurations intended to allow administrative personnel to manage and align the Strut Learning Platform with individual Organization policies.
Strut Learning does not knowingly collect any Personally Identifiable Information from clients under the age of 13.
Data Transfers
All Strut Learning Platform data stored by third party providers (e.g. AWS EC2) complies with the principles of Canada’s Personally Identifiable Information Protection and Electronic Documents Act (PIPEDA) and Federal Trade Commission and other applicable agencies. We ensure data transfers originating outside the U.S., (e.g., EU) will comply with that country’s governing laws and policies.
If you reside in the European Union, upon registration for any applicable Strut Learning Platform or other Strut Learning offering you consent that the Personally Identifiable Information you have provided may be transferred and stored in countries outside the EU. Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your personal information, in some of these countries may not be equivalent to those in your country of residence. However, we will take reasonable steps to protect your privacy and to provide a level of protection of personal information that is comparable to that of your country of residence.
GDPR The European Union’s General Data Protection Regulation (GDPR) protects European Union data subjects fundamental right to privacy and the protection of personal data.
Strut Learning complies with the GDPR. For an overview of the rights that are given to individuals and how it may affect Strut Learning customers using Strut Learning Platform, please consult the GDPR statement below.
Privacy Statement Updates/Changes
We routinely review our Data and Privacy Statements. We reserve the right to modify or supplement this Privacy Statement at any time. Changes to these policies will be posted on our website.