Privacy Notice
Overview
Embanet Compass Knowledge Group, Inc. (referred to herein as “Boundless Learning™”) presents this site to provide information about Boundless Learning™ products and services. It serves as a front door to many of our products and services offered in the United States and allows you to connect with us in a variety of ways.
This privacy policy provides an overview of our commitment to privacy and describes how we collect, protect, use and share personal information collected through this site. Please note that other Boundless Learning™ websites and online products and services have their own separate privacy policies.
Collection and use of information
To conduct business and deliver products and services, Boundless Learning™ collects and uses personal information in a variety of contexts, including:
Products and Services
Our online products and services post specific privacy policies. We collect personal information for the purpose of providing our online products and services. The privacy policy applicable to an online product or services is posted on that product or service.
Support
Our support sites provide resources to help users of our products and services. Users may also submit requests for assistance through the support portals on those sites. The privacy policy applicable to a support site is posted on that support site.
Questions and Inquiries
For inquiries and questions, we collect the inquiry or question, together with name, contact details (email address, phone number and mailing address) and any other additional information voluntarily submitted to us through a Contact Us form and email. We use this information to address the inquiry and respond to the question.
Online Store
For orders and purchases placed through our online store, we collect order details, name, institution name and address (if applicable), email address, phone number, shipping and billing addresses, credit/debit card information, shipping options and any instructions. We use this information to complete transactions, fulfill orders, communicate with individuals placing orders or visiting the online store, and for related purposes.
Surveys
Boundless Learning™ may offer opportunities to provide feedback or participate in surveys, including surveys evaluating Boundless Learning™ products, services or sites. Participation is voluntary. Boundless Learning™ collects information requested in the survey questions and uses the information to evaluate, support, maintain and improve products, services or sites, develop new products and services, conduct educational research and for other purposes specified in the survey.
Contests and Drawings
Occasionally, we may sponsor a contest or drawing. Participation is optional. Boundless Learning™ collects name, contact information and other information specified on the entry form for the contest or drawing to conduct the contest or drawing. Boundless Learning™ may collect additional personal information from the winners of a contest or drawing in order to award the prize and for tax reporting purposes, as required by law.
Employment
We collect personal information from individuals seeking employment. We use personal information submitted through our online employment application portals to evaluate applications for employment.
Contractors
We collect personal information from individuals, who are our contractors, for purposes of our contractual relationship and agreement. This information may include name, contact information, contractual details, banking information required to submit payment, and social security number or tax identification number and other information required to comply with applicable tax laws.
Other Collection and Use of Information
Application and System Logs
Boundless Learning™ automatically collects log data to help ensure the delivery, availability and security of this site. Log data may include technical information about how a user or visitor connected to this site, such as browser type, type of computer/device, operating system, internet service provider and IP address. We use this information for support purposes and to monitor the health of the site, identify problems, improve service, detect unauthorized access and fraudulent activity, prevent and respond to security incidents and appropriately scale computing resources.
Web Analytics
Boundless Learning™ may use third party web trend analytical services, including Google Analytics, to collect visitor information, such as IP addresses, browser types, referring pages, pages visited and time spent on a particular site. While these analytical services collect and report information on an anonymous basis, they may use cookies to gather web trend information. The information gathered may enable Boundless Learning™ (but not the third party web trend services) to link information with application and system log data. Boundless Learning™ uses this information for system administration and to identify problems, improve service, detect unauthorized access and fraudulent activity, prevent and respond to security incidents, appropriately scale computing resources and otherwise support and deliver the Services.
Cookies and Related Technologies
This site uses cookies and similar technologies, as further explained in our Cookies Policy. Browser controls and other tools may be used to control, block or delete cookies and these technologies. Disabling or blocking cookies and such technologies, however, may prevent or impair functionality and use of the site.
Do Not Track
This site currently does not respond to Do Not Track signals.
Security
Boundless Learning™ uses appropriate physical, administrative and technical security measures to protect personal information from unauthorized access, use and disclosure.
Children
This site is not directed to children under the age of 13.
Marketing
Pre-Kindergarten – 12th Grade Students and Minors
Boundless Learning™ will not knowingly send or direct marketing communications to students in pre-kindergarten through 12th grade or anyone under the age of 18.
Adults
Except as otherwise provided in privacy policies related to specific contexts, such as a product or service privacy policy, Boundless Learning™ may send or direct marketing communications to adults, provided that
Such marketing is consistent with applicable law and Boundless Learning™’s legal obligations.
Boundless Learning™ will not knowingly direct or send marketing communications to an individual who has expressed a preference not to receive marketing.
Where required by applicable law, express or implied consent to marketing exists and has not been withdrawn.
Boundless Learning™ may provide personal information to a third-party service provider on a restricted basis to provide marketing solely on behalf of Boundless Learning™ and affiliated Boundless Learning™ companies, but not for marketing of any third-party products or services. Boundless Learning™ does not permit third-party ad networks or similar services to access or collect Personal Information within this site.
Marketing preferences may be changed at any time.
Sale of personal information
Boundless Learning™ does not rent or sell personal information in exchange for any payment of money. While Boundless Learning™ does not sell personal information, as defined in Nevada law, Nevada residents may email a request for no sale of their personally identifiable information to dataprivacyUS@boundlesslearning.com.
Supplemental Privacy Statement
If you are a resident of California, Colorado or Virginia, please also read our Supplemental Privacy Statement, which provides information about your state-specific privacy rights and additional information required by the laws of these jurisdictions.
Sharing and Disclosure
Boundless Learning™ may disclose personal information, as follows:
- As required by law.
- With the consent of the individual (or their parent, if the individual is a minor)
- In response to a subpoena, court order or legal process, to the extent permitted or required by law
- To protect the security and safety of individuals, data, assets and systems, consistent with applicable law
- In connection the sale, joint venture or other transfer of some or all of its company or assets, subject to the provisions of this Privacy Policy
- To investigate or address actual or suspected fraud or other illegal activities
- To exercise its legal rights, including enforcement of the Terms of Use for this site or another contract
- To affiliated Boundless Learning™ companies and other companies and organizations who perform work for Boundless Learning™ and are obligated to protect the privacy of personal information consistent with this Privacy Policy
- To a school, organization, company or government agency, where Boundless Learning™ collects or processes the personal information in a school setting or on behalf of such organization, company or government agency.
Requests and Contact
Please Contact Us about this Privacy Policy or if you have any requests or questions relating to the privacy of your personal information.
Changes to this Privacy Policy
We may revise this Privacy Policy through an updated posting. We will identify the effective date of the revision in the posting. Often, updates are made to provide greater clarity or to comply with changes in regulatory requirements. If the updates involve material changes to the collection, protection, use or disclosure of Personal Information, Boundless Learning™ will provide notice of the change through a conspicuous notice on this site or other appropriate way. Continued use of the site after the effective date of a posted revision evidences acceptance.
Last Update: July 28, 2023
Introduction
Definitions
Personal Information Collected and Disclosed within the Last 12 Months
How long will Boundless Learning™ retain my personal information?
Sale or Sharing of Personal Information
Privacy Rights
How to Make a Request under the Right to Know and Right to Deletion
Changes to this Supplemental Privacy Statement
Contact Information
Introduction
This Privacy Statement explains Boundless Learning™’s commitment to comply with California, Colorado, and Virginia law and applies to personal information collected in connection with providing services referenced on this site (the Services). Please read this Supplemental Privacy Statement in conjunction with the Privacy Notice that that linked here.
Definitions
Business Purposes includes the following:
Audit means auditing compliance with this Privacy Statement and applicable law. It also means auditing current interaction with a User and concurrent interactions with others, such as auditing access to particular content or features.
Debugging means identifying and repairing errors that impair existing intended functionality.
Evaluation means undertaking internal research to assess the effectiveness of the Services and for technological development and demonstration.
Maintenance and Improvement means undertaking activities to verify or maintain the quality or safety of the Services, and to improve, upgrade or enhance the Services.
Provide the Services means delivering and providing the Services, including, but not limited to, providing educational content and learning services, maintaining accounts, providing customer service, fulfilling orders and verifying customer information.
Security means detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity and taking appropriate action for those responsible for that activity.
Short-Term Use means short-term, transient use related to a current interaction with a California resident, such as the contextual customization of ads shown as part of the same interaction. In Short-Term Use, the personal information is not disclosed to another third/ party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction.
Personal Information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or their household. Categories of Personal Information include the following:
Identifiers means information used to identify a particular user, such as name, email address, user name, IP address or other online identifier.
Customer Records means categories of customer personal information described in California Civil Code 1798.80, including name, address and education information.
Protected Class Characteristics means characteristics identified under California and/or federal law such as race, ethnicity, national origin, disability, veteran or military status.
Commercial Information means information about products or services purchased, used or considered by a User.
Biometric Information means genetic or biological characteristics, such as information derived from fingerprint, iris or retina scans.
Internet or Other Similar Network Activity means information generated from interaction with a website or the internet.
Geolocation Data means information about the geographic location from where a user accessed the Services.
Sensory Data includes audio, electronic and visual information.
Professional or Employment-Related Information means current or past job history.
Non-Public Education Information means personally identifiable Education Information that is not publicly available, as defined in the Family Educational Rights and Privacy Act (FERPA).
Inferences Drawn from Other Personal Information means inferences that create a profile about User’s preferences, characteristics, intelligence, abilities and aptitudes.
Sensitive Personal Information means Personal information that reveals certain information about a consumer that are generally considered to be sensitive in nature, including:
- Any communications you have with a third party (ie, somebody outside our business)
- Biometric data processed to identify an individual
- Data about sexual orientation or sex life
- Financial account details in a combination (for example card number and password) that gives access to an account
- Genetic data
- Government-issued numbers (such as a social security number or a number on a passport, or driver's license)
- Health data
- Philosophical or religious beliefs
- Precise geolocation
- Racial or ethnic origin
- Union membership
- Information from a known child
Personal Information Collected and Disclosed within the Last 12 Months
Within the last 12 months, Boundless Learning™ collected and disclosed categories of Personal Information through the Services, as follows:
Category: Identifiers
Source: Users, Educators, and Institutions
Purpose: Provide the Services
Disclosures to Third-Party Businesses: Service Providers, Educators, and Institutions for auditing, debugging, evaluation, maintenance and improvement, providing the services, security and short-term use. Law Enforcement in very limited circumstances, when required for security.
Category: Customer Records
Source: Users, Educators, and Institutions.
Purpose: Audits, Evaluation, Provide the Services, Security, and Short-Term Use.
Disclosures to Third-Party Businesses: Service Providers, Educators, and Institutions for auditing, debugging, evaluation, maintenance and improvement, providing the services, security and short-term use. Law Enforcement in very limited circumstances, when required for security.
Category: Protected Classes Characteristics
Source: Users (only certain Career Success products)
Purpose: Provide the Services
Disclosures to Third-Party Businesses: Service Providers in order to provide the Services.
Category: Commercial Information
Source: Users
Purpose: Audit, Evaluation, Maintenance and Improvement, Provide the Services, Security, Short-Term Use
Disclosures to Third-Party Businesses: Service Providers, Educators, and Institutions for auditing, debugging, evaluation, maintenance and improvement, providing the services, security and short-term use. Law Enforcement in very limited circumstances, when required for security.
Category: Biometric Information
Source: N/A
Purpose: N/A
Disclosures to Third-Party Businesses: N/A
Category: Internet or Other Similar Network Activity
Source: Users
Purpose: Audit, Debugging, Evaluation, Maintenance and Improvement, Provide the Services, Security, and Short-Term Use
Disclosures to Third-Party Businesses: Service Providers, Educators, and Institutions for auditing, debugging, evaluation, maintenance and improvement, providing the services, security and short-term use. Law Enforcement in very limited circumstances, when required for security.
Category: Geolocation Data
Source: Users (Country of location)
Purpose: Audit, Debugging, Evaluation, Maintenance and Improvement, Provide the Services, Security, and Short-Term Use
Disclosures to Third-Party Businesses: Service Providers for auditing, debugging, evaluation, maintenance and improvement, providing the services, security and short-term use.
Law Enforcement in very limited circumstances, when required for security.
Category: Sensory Data
Source: Users
Purpose: Debugging, Evaluation, Maintenance and Improvement, Provide the Services and Security
Disclosures to Third-Party Businesses: Service Providers for debugging, evaluation, maintenance and improvement, providing the services, and security.
Category: Professional or Employment-Related Information
Source: Users
Purpose: Provide the Services, Evaluation
Disclosures to Third-Party Businesses: Service providers. Educators and Institutions to provide the Services and for evaluation.
Category: Non-Public Education Records
Source: Users, Educators and Institutions
Purpose: Provide the Services, Evaluation
Disclosures to Third-Party Businesses: Service providers. Educators and Institutions to provide the Services
Category: Inferences
Source: Users, Student, Users’ Instructors and Educational Institutions
Purpose: Provide the Services, Security, Evaluation
Disclosures to Third-Party Businesses: Service Providers, Educators, and Institutions for providing the Services, security and evaluation. Law Enforcement in very limited circumstances, when required for security.
Category: Sensitive Personal Information
Source: Users, Student Users’ Instructors and Educational Institutions
Purpose: Provide the Services
Disclosures to Third-Party Businesses: Service Providers, Educators, and Institutions for providing the Services.
How long will Boundless Learning™ hold onto my personal information?
We will keep each category of your personal information, as identified in the table above, only for as long as necessary to fulfil the purposes for which we are processing that category of your personal information and to meet legal and audit requirements, or as long as you continue to engage with the Services, or longer with your consent.
Sale or Sharing of Personal Information
We do not sell or share, and have not sold or shared, any Personal Information collected through the Services within the last twelve (12) months.
Privacy Rights
Where Boundless Learning™ is a service provider to an educational institution, your request for access, deletion or correction of your education records or course data should be directed to your school or University. Boundless Learning™ cannot modify or delete education records or other records collected or processed by, or on behalf of, an educational institution unless directed to do so by the educational institution directly.
FERPA Privacy Rights. FERPA provides students with privacy rights and protection for educational personally identifiable information collected and processed on behalf of educational institutions receiving government funding from the U.S. Department of Education. FERPA provides students with rights to obtain from these educational institutions access to their educational records, as well as correction and amendment of their educational records, even though the CCPA does not apply to non-profit and public educational institutions.
Residents of California, Colorado and Virginia have certain rights related to their personal information collected by and on behalf of a business. Depending on where you live and POLS’s role in collecting and/or processing your personal information, you may have the following rights:
To request access to your information including a request to receive a written report of the categories and sources of information and/or the specific personal information held by POLS. Your request may be limited to information collected within the previous twelve (12) months;
to update or correct your personal information;
to ask that we remove or delete your personal information with some exceptions. For example your request for deletion of your personal information may not interfere with an in process transaction, investigation or legal obligation;
to appeal a decision in response to a request regarding your personal information;
to withdraw your consent to the processing of your personal information;
to ask that we limit or restrict the processing of your personal information;
to ask that we transfer your information to another service provider;
to object to our processing of your personal information;
to opt out of automated processing which has a significant impact (such as profiling);
To opt out of the sale or sharing of their Personal Information or to require affirmation authorization to sell or share personal information if you are under the age of 16;
To limit the use or disclosure of sensitive personal information which is not necessary for the Services provided;
to complain to a regulator about the handling of your personal information; and
To not be discriminated against for exercising any of your rights related to your data.
Boundless Learning™ will not use or disclose your Sensitive Personal Information, collected through the Services, without your consent. Boundless Learning™ does not use or disclose Sensitive Personal Information for any purpose other than that which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services, or as otherwise permitted by law.
How to make a request to exercise your rights
To request access to a report of your data or deletion of your personal information, please send an email here for additional information: dataprivacy@boundlesslearning.com
We will not require a California resident to set up an account in order to make a request or receive the requested information. In order to respond to a request, however, we must be able to reasonably verify, understand and fulfill the request. We will not be able to respond to the request if we are unable to verify identity or the authority to make the request. In conducting verification, we generally will use personal information previously collected by us. If the request is made on behalf of another individual, we may require additional verification and documentation of the individual’s authority to make the request. In responding to requests, we may limit the information provided for privacy and security reasons, as permitted by law.
We will process your request within the time required by the law or inform of the basis for any unexpected delays.
To request correction of incorrect information associated with you, please contact support@boundlesslearning.com.
For any other questions about your rights associated with your personal information or to appeal a decision in response to a request to exercise any of the above privacy rights, contact dataprivacy@boundlesslearning.com.
Changes to this Supplemental Privacy Statement
We may update this Privacy Statement from time to time in the same way that we update the Privacy Notice that is linked to it.
Contact Information
If you have any questions or comments about this Privacy Statement or your rights under any State law, please contact us at dataprivacyUS@boundlesslearning.com.