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 websites, 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 registering 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, household or device. 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
  • Enable Software integrations to deliver the Services
  • Analyze, report, improve, and deliver the Services
  • Comply with legal obligations
  • Make other internal, lawful uses of the Personal Information

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’s participation in the Services
  • Comply with legal obligations
  • Make other internal, lawful uses of the Personal Information

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

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 manage your cookie preferences on our Manage Cookies Preferences page; however, it is 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, referring URL, and cookies that may uniquely identify your browser or your Services account.

2. HOW YOUR PERSONAL INFORMATION IS COLLECTED

Personal Information is obtained directly or indirectly 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 consent required by the Children’s Online Privacy Protection Act of the United States (“COPPA”) from the 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 who attends a school where 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 13 (Contact Us).  If you revoke your consent or refuse to allow further collection of Personal Information, you must also contact the applicable school where 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. We will need to verify the identity of anyone requesting information about a child under the age of 13 to ensure that the person is in fact the child’s parent or legal guardian.

Any collection of Personal Information from Students under the age of 13 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 who 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 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 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 such disclosure is part of the service offered.

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

New Classrooms National Office
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. We provide support services to school partners, who may be educational institutions subject to the Family Educational Rights and Privacy Act (“FERPA”). Our school partners may have additional information on their compliance with FERPA in their own privacy policies.

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, a 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. For New York City Schools Public Schools, please see Section 15.

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. SUB-PROCESSORS

We may engage Sub-Processors to process Personal Information on your behalf, and we do so in two ways. First, we may engage Sub-Processors to assist us with hosting and infrastructure. Second, we may engage with Sub-Processors to support product features and integrations.

Where we engage Sub-Processors, we will endeavor to impose data protection terms on the Sub-Processors that provide at least the same level of protection for Personal Information as provided in this Notice, to the extent applicable to the nature of the services provided by such Sub-Processors. We will remain responsible for each Sub-Processor’s compliance with the obligations of this Notice and for any acts or omissions of such Sub-Processor that cause us to breach any of our obligations under this Notice.

The following explains how New Classrooms engages with Sub-Processors.

  • Infrastructure Sub-Processor
  • Feature Specific Sub-Processor



1. Infrastructure Sub-Processor

To help New Classrooms deliver the Services, we engage Sub-Processors to support our infrastructure. By agreeing to this Notice, you agree all of these Sub-Processors may have access to your Personal Information. Below are some of these current Sub-Processors:



2. Feature Specific Sub-Processor

Some of our features and integrations require the use of additional Sub-Processors. Below are some of these current Sub-Processors:



3. Updates to this page

Due to the nature of our business, our business needs and service providers, including Sub-Processors, may change from time to time. For example, we may deprecate a service provider to consolidate or minimize our use of service providers. Similarly, we may add a service provider if we believe that doing so will enhance our ability to deliver the Services.

10. HOW WE PROTECT YOUR PERSONAL INFORMATION

We have implemented reasonable and appropriate steps to protect Personal Information from unauthorized access or disclosure, improper use, unauthorized modification, unlawful destructions and accidental loss. 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 collected, held, or processed 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 with respect to the security of your Personal Information, 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 we are legally required to do so.

11. 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. 

12. 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 choose to provide will be used as described in the privacy policy and terms of use provided by such 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.

For example, the Services are hosted by and support services are offered by Amazon Web Services, Akamai, 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 its privacy policy. We encourage you to read Classify Learning’s privacy policy before providing it with your information.

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

13. AUTHORIZATION

To protect your Personal Information and to comply with U.S. state data privacy laws, we will use an authentication process to confirm your identity before we act on your requests seeking any Personal Information from us. You or your authorized agent may make an authenticated consumer request related to your Personal Information. If you use an authorized agent to submit a request on your behalf, we may require that you (1) provide the authorized agent written permission to do so and (2) provide us a copy of the authorization or a copy of a power of attorney. If we suspect fraudulent or malicious activity on or from the password-protected account, we may decline a request or request that you provide further authenticating information.

14. CONTACT US

If you have any questions about your privacy or 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@newclassrooms.org, or by mailing us at:

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

15. YOUR PRIVACY RIGHTS

YOUR STATE PRIVACY RIGHTS

We value your privacy rights and will comply with data privacy laws, which generally state that the Personal Information we collect about you must be:

  • Used lawfully, fairly, and in a transparent way,
  • Accurate,
  • Collected only for valid purposes that we have told you about and used in accordance with those purposes, and
  • Kept in a secure manner and only as long as needed for the valid purposes.

Colorado, Connecticut, Utah, [Texas, Montana, Oregon,] and Virginia residents have the right to request:

  • Confirmation of whether we have processed, used, disclosed, shared, or sold Personal Information about you and access to see such Personal Information,
  • Deletion of your Personal Information, with certain exceptions,
  • Obtain a portable copy of your Personal Information that we possess in an easily accessible and transportable format, and
  • To opt out of certain sale or sharing of your Personal Information and processing of Personal Information for the purposes of targeted advertising.

Colorado, Connecticut, [Texas, Montana, Oregon,] and Virginia residents also have the right to request:

  • Correction of inaccurate Personal Information we have about you, with certain exceptions,
  • Opt out of having your Personal Information processed for the purpose of profiling in the furtherance of decisions that produce legal or similarly significant effects concerning you, and previously submitted privacy right request, and may submit an appeal using the contact information below.
  • Appeal our denial to act within a reasonable time on a previously submitted privacy right request, and may submit an appeal using the contact information below.

If you have questions regarding our handling of your Personal Information or require assistance in exercising your applicable rights, please contact us at 212-920-6130, via email at privacy@newclassrooms.org, or by mailing us at:

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

We may need to confirm your identity before acting on any request. Please learn more about our authentication process under Section 13 (Authorization), above. We will not discriminate against you for exercising any of your privacy rights described above.

YOUR NEW YORK CITY PUBLIC SCHOOLS PRIVACY RIGHTS

Students, Parents, and Users who are part of the New York City Public School System also have the following rights as established by the New York City Department of Education.

De-identified data may be used and maintained by New Classrooms for the analytical purposes as requested by New York City Public Schools for the purpose of supporting and/or improving the products and services being provided. At the conclusion or termination of the contracted agreement, New Classrooms shall promptly destroy all Personal Information processed for the User, school or office with respect to Services provided.

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”), as amended and expanded by the as amended by the California Privacy Rights Act of 2020 (“CPRA”) regarding your Personal Information.

A. Right to Know

California Shine the Light Law: While we do not provide your Personal Information to third parties for their use in marketing, under California law, California residents have the right to opt out of such use of your Personal Information if it occurred. California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of Personal Information to third parties for their direct marketing purposes in the preceding calendar year. To obtain this information, please send an email to privacy@newclassrooms.org with the phrase “California Privacy Request” in the subject line and in the body of your message.

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 interest 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

C. 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 your 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@newclassrooms.org, 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.

YOUR ADDITIONAL RIGHTS FOR THE EUROPEAN ECONOMIC AREA(EEA), UK, AND SWITZERLAND

Students, Parents, and Users in the European Union (EU), the United Kingdom (UK) and Switzerland whose Personal Information we receive in the United States have the following additional rights:

  • 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 Information.
  • Access: You have the right to access your Personal Information.
  • Rectification: You have the right to rectify inaccurate Personal Information.
  • Erasure: You have the right to have your Personal Information 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 ground for processing it or you consider that it has been unlawfully processed.
  • Restriction: You have the right to have the processing of your Personal Information 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 Information 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 Information for certain purposes.

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 Information. Please note that the right to erasure is not absolute and it may not always be possible to erase Personal Information on request, including for example where the Personal Information must be retained to comply with a legal obligation.

If you have questions or require assistance in exercising your available rights, please contact us at please contact us at 212-920-6130, via email at privacy@newclassrooms.org, 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. You also have the right (where applicable) to withdraw any consent given in relation to the processing of your Personal Information.

New Classrooms Innovation Partners, Inc. is the controller of Personal Information under this Notice. Although we hope we can help you in the first instance, if you are unhappy with the way we collect and use your Personal Information, you may lodge a complaint with a supervisory authority that has authority in your country or region. Contact information for EEA authorities can be found here and for authorities in the UK here and Switzerland here.