Effective: June 12, 2018

This privacy policy applies to NovoEd.com, http://www.novoed.com and the course sites on the NovoEd platform (the “Site”), websites operated by NovoEd, Inc. (the “Company,” “us,” ”we,” or “our”).

The Site provides the “Service” as defined in the Terms of Use.

We respect and protect the privacy of our users.  This Privacy Policy explains how we collect and use your information and is part of our Terms of Use when you use our Site or Service.

 

WHAT DATA DO WE COLLECT?

Personal Data

“Personal Data” means any information relating to an identified or identifiable natural person.  We collect Personal Data from two (2) classes of users of the Services: Administrators and Instructors for entities that contract with us, that might be interested in contracting with us or we market to and answer our inquiries (“Customers”), and the persons that Customers desire to use the Services to provide information for learning and training them and who must register to do so either directly through our website or through Services we operate for our Customers (“Learners”, also referred to as “End Users”). When referred together, Learners and Customers are “Users”.

For Customers, we will collect Personal Data such as the names, customer ID, e-mail addresses, name of the entity they represent, phone numbers, and IP Address they access the Site or Service from.  We also will collect and post content for Customer in connection with the Service such as articles, checklists, courses (“Courses”).

For Learners we collect Personal Data such as names, user names, and email addresses.  We also collect End User IP addresses, name, email, location (country, state, city), school name or employer name; if applicable. We also collect a history of the Courses taken and completion of course activities and whether they logged in to view the courses (“Course History”).  Learners may also submit content to share with other students or with the Customers and their instructors. The courses have social tools such as discussions to allow learners to interact and learn from each other. These discussions are logged.

If NovoEd offers courses under its own name, then we serve the same role and have the same responsibilities as our Customers do to Learners.

Tracking Data

We and our third-party service providers may collect certain tracking information about your use of our Site and Service.  For example, we collect:

  • Google Analytics:  as user uses the app; tracking user clicking behavior; session length, device used,and estimation of country of origin based on IP address.  
  • Log information (including your IP address, browser type, Internet service provider, referring and exit pages, operating system, dates/time of access, pages visited and time spent on those pages and related data)
  • Information collected by cookies
  • Web beacons (also called “Internet tags” or “clear gifs”; used to count visitors to our Site and which pages were viewed and links clicked)
  • Embedded scripts (code temporarily downloaded onto your device to collect information about your interactions with the Service and thereafter deleted or deactivated)

Cookies

When you visit our Site we use cookies, or similar technologies like single-pixel gifs to record log data.  Session information is stored in Cookie in order to remember users sign-in on the browser.

We use both session-based and persistent cookies.  Session-based cookies last only while your browser is open and are automatically deleted when you close your browser.  Session cookies are used to track the session and remember Users sign-in the browser so the user does not need to sign in every time if the session is active. Persistent cookies last until you or your browser delete them or until they expire.  They are unique and allow us to do site analytics and customization, among other things. If you access our Site through your browser, you can manage your cookie settings.

Here are some of the cookies services we use:

Google Analytics collects information about the use of the Services on our website. Google Analytics collects information such as how often Users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site.

We use the information we get from Google Analytics only to improve this site, but in anonymous form.  Google Analytics collects only the IP address assigned to you on the date you visit this site and assigns a user ID code, rather than your name or other identifying information and we will anonymize IP addresses collected through Google Analytics so that we can collect the same information without storing exact IP addresses.  We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google uses this information to analyze your use of the website, to generate reports about website activities for website operators and to provide further services related to website and internet use. Google may also share such information with third parties to the extent it is legally required to do so and/or to the extent third parties process data on behalf of Google. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google.  Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy and Data Processing Amendment. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser.

You may block Google Analytics on some browsers with the help of a browser add-on if you do not want us to use this Analytics tool.  This add-on can be downloaded at: Google Analytics Opt-out Browser Add on at: ‘http://tools.google.com/dlpage/gaoptout?hl=en. For more information on Google Analytics and Google’s privacy practices, please review the Google Privacy and Terms policy at https://www.google.com/policies/privacy/

New Relic:  New Relic is used for performance monitoring; anonymized data only. Please refer to New Relic’s Privacy Statement for more information.  

ZenDesk. ZenDesk drops cookies to track interaction with its customer support tools on our behalf.  For more information go to their privacy policy.

For more information please check out our full cookie policy.

How Do We Use Your Data?

Analytics:

We utilize Tracking Information to access anonymous data to help us understand how our Services are used.  We use Tracking Information to customize content for you and improve our Services. Google Analytics provides reports to us regarding website trends without identifying individual visitors.

Providing the Services:

We use your Personal Data to provide the Services, provide Customer service/support and communicate with you regarding the Services and new features.  If you are a Customer or Learner, it enables us to track your use for customer service purposes. We use the Courses created by Customers and their instructors to provide the Services to Learners.  If you are a Learner, we use your Personal Data and history of access to identify you, enable you to establish feedback using comments, and track your use of the Services for Customers.

Validating Access to Content:

For Customers, we use the Personal Data of customers tied to Courses and Course History to validate your right to use our Services.

Learners must authenticate to the application with a username/password through NovoEd’s sign in or via single sign on integrations via SAML 2.0, or Google, or Facebook.

We use the Course History and history of access by Learners tied to their Personal Data to validate the identities of Learners and track their use to report to Customers as a part of our Services.  As an learning content delivery platform, these are essential components of our Services.

Direct Marketing

We use Customer Personal Data to communicate with Customers regarding the provision of the Services, but also to let you know about additional features and services we provide that may be of interest to you.  If you do not wish to receive marketing communications, you may opt out at any time by following the unsubscribe link at the bottom of each email.

How Do We Share Your Data?

We will not sell, rent, or share Personal Data with third parties outside of our company without your consent, except in the following ways:

Customers and Instructors and other Learners

Our service involves providing a platform to present materials and course content from Customers to Learners.  This involves presenting the content and ensuring that certain Learners have accessed and reviewed the content for the benefit of both the Customer and the Learners.  As such, we share End User contact information and applicable End User search history; End User Program/Course Information access history with Customers to confirm End User attendance and review of the content.

When you register through the Site and submit your Personal Information to create an account, Learners, and Customers (including course instructor) will see your “Screen Name”.  Learners and Customers and staff may also see the month and year you first registered with NovoEd, answers to profile questions you provide when you create an Account or register for a Course as well as your Course activity, Course assignments and other submissions, postings in forums and communications with other Account holders, Course instructors and staff.     

We may share Personal Information, and Tracking Data with Customers for the purpose of providing the Services.  They use this information mainly to provide, administer and improve Courses and the Services, to respond to your inquiries, and to analyze and conduct research on the Services.  We may also provide Learners Personal Information to Course Providers of the courses you have been enrolled in for the purpose of their providing you with Direct Marketing information on goods or services they believe will be of interest to you.  You can, at any time, opt out of receiving such communications from a Customer using the opt out method provided by the Customer in the communication since they are the controllers of the data.

Comments

If you post a comment or communicate with other Learners, it will be shared with other Learners accessing the Course Information or to the specific Learner to which you directed you message. Users can edit or delete a post/comment they create.

Charging for Services

The Company does not store any credit card data associated with any purchases processed on the Site.  

Law Enforcement and Internal Operations

Personal Data may be provided where we are required to do so by law, or if we believe in good faith that it is reasonably necessary (i) to respond to claims asserted against Company or to comply with the legal process (for example, discovery requests, subpoenas or warrants); (ii) to enforce or administer our policies and agreements with users; (iii) for fraud prevention, risk assessment, investigation, customer support, product development and debugging purposes; or (iv) to protect the rights, property or safety of Company, its users or members of the general public.  We will use commercially reasonable efforts to notify users about law enforcement or court ordered requests for data unless otherwise prohibited by law. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to any third party request to compel disclosure of your information.

Business Transfer

Company may sell, transfer or otherwise share some or all of its assets, including your Personal Data, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.  Under such circumstances, Company will use commercially reasonable efforts to notify its users if their personal information is to be disclosed or transferred and/or becomes subject to a different privacy policy.

Third Parties

We sometimes contract with other companies and individuals to perform functions or services on our behalf.  Our categories of service providers include: software maintenance, data hosting, sending email messages, project management and customer service.  We necessarily have to share your Personal Data with such third parties as may be required to perform their functions. We take steps to ensure that these parties take protecting your privacy as seriously as we do, including entering into Data Processing Addendum(s), EU Model Clauses and/or ensuring they have EU-U.S. and Swiss-US Privacy Shield certification since all of our service providers are in the United States.

Third Party Service Providers

Third Parties that collect and share Personal Data with us regarding Learners or Customers:

Braintree. Braintree processes payments on our behalf using credit card and other payment transactions. Braintree collects payment information and contact information to validate and process payments since we do not store credit card information. Braintree, which is owned by PayPal, is self-certified under the US-EU Privacy shield and we have entered into a Data Processing Addendum with them to familiarize yourself with Braintree’s privacy practices and that of its parent company PayPal, go to https://www.paypal.com/us/webapps/mpp/ua/privacy-full

ZenDesk. We use ZenDesk to provide customer support and maintenance ticketing processes, including chat for support.  ZenDesk is self-certified under the EU-U.S. and Swiss-US Privacy Shield and data transfers and protection are subject to a Data Processing Addendum and Binding Corporate Rules. Processing takes place in the United States.  For more information check out ZenDesk’s privacy policy and other policy documents.

Google Analytics collects information about the use of the Services on our website. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site.

We use the information we get from Google Analytics only to improve this site, but in anonymous form.  Google Analytics collects only the IP address assigned to you on the date you visit this site and assigns a user ID code, rather than your name or other identifying information and we will anonymize IP addresses collected through Google Analytics so that we can collect the same information without storing exact IP addresses.  We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google uses this information to analyze your use of the website, to generate reports about website activities for website operators and to provide further services related to website and internet use. Google may also share such information with third parties to the extent it is legally required to do so and/or to the extent third parties process data on behalf of Google. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google.  Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy and Data Processing Amendment. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser.

You may block Google Analytics on some browsers with the help of a browser add-on if you do not want us to use this Analytics tool.  This add-on can be downloaded at: Google Analytics Opt-out Browser Add on at: ‘http://tools.google.com/dlpage/gaoptout?hl=en. For more information on Google Analytics and Google’s privacy practices, please review the Google Privacy and Terms policy at https://www.google.com/policies/privacy/

New Relic:  New Relic is used for performance monitoring; anonymized data only. Please refer to New Relic’s Privacy Statement for more information.  

How is My Data Protected?

We have implemented reasonable administrative, technical and physical security measures to protect your personal information against unauthorized access, destruction, or alteration. For example:

  • Passwords are saved encrypted in the database.
  • Data is kept on secure located in the US.  Access to this data is controlled using RSA key pairs and AWS security groups; and limited to only a few Company employees.
  • All data is encrypted in transit
  • Restricting staff access to Personal Data on a need to know basis with access monitored by logs.
  • Regular staff privacy and security training.

However, because no security system can be 100% effective, we cannot completely guarantee the security of any information we store, process or transmit.

Your Choices:

Data Subject Rights for Learners: NovoEd is only a processor of your personal data.

NovoEd provides learning platforms for our Customers.  As such we process data at their direction and the Customers are the controllers of the Personal Data of Learners who enroll in their courses.  Customers use our tools to decide what Learner behaviors are tracked and determine the purpose for which Learner Personal Data is collected on their behalf.  If you are a Learner accessing the Services to take Courses with a Customer, are located in the European Economic Area or Switzerland and would like to exercise any of your Data Subject Rights listed below, please contact the Customer whose Course you enrolled in directly.

Right to Review and Rectify Your Personal Data.

Customers can see a history of what articles and courses Learners have viewed or complete on their account as well as your Account Information.

You can update most of your Account Information by logging on to your account.  However, if additional assistance is required to change or delete inaccuracies within other Personal Data or would like to know what other information about you was collected, please contact us at privacy@novoed.com.

Right to Remove or Withdraw Consent.

If you are located in the European Economic Area or Switzerland you may have the right to withdraw consent where such consent is required to share or use data and you may request that we delete your Personal Data through your account or if you can not, by emailing us at privacy@novoed.com.

However, if you have included Personal Information in Course content, social activities, or in Course assignments or information or communications shared with other Account holders or with Course instructors or staff, you may not be able to update, correct or delete this information from the Site. Please contact the Customer directly.

We only email Customers and do not contact Learners with marketing opportunities. If you are a Customer and receive newsletter or marketing communications from us and no longer wish to receive them, please follow the removal instructions in the email or change your account settings. Customers can delete their Account Information by contacting NovoEd to remove their account.  However, since Personal Data and Customer Course History is required for us to provide the Services to you, deleting it will also terminate your access to the services. Learners and Customers should know that deleting your Personal Data does not mean that all of it will be removed if you have sent any of it to other Learners.

We take steps to delete Personal Data is no longer necessary in relation to provide the Services by deleting it within 120 days of your terminating your account.  We may be required by law, to retain it to exercise or defend legal claims, or contractual obligations with our Customers to retain some information in connection with our obligation to provide the Services.  We may de-identify and anonymize some data for purposes of retaining it.

Data Portability

If you would like us to transmit your Personal Data to another company providing similar services, we will work with them to do so upon request and verification of such request with both the requestor and the company receiving the Personal Data.

Right to Redress

If you are a subject of the European Union or European Economic Area and Switzerland and you believe we have violated any data protection laws that apply to you, you have a right to file a complaint with your Data Protection Authority office.  

Processing Learner Data for Customers

Our Services may involve the processing of Personal Data on behalf of our customers.  When we do so, we are acting as processors for the controllers of such data. As such, we take steps to ensure that Personal Data subject to GDPR is processed in accordance with controller instructions and GDPR such as entering into a Data Processing Addendum(s) incorporating EU Standard Contractual Clauses governing the processing, transmission and use of such End User Personal Data.  If you wish to exercise your data subject rights to review, rectify, delete or port your End User Personal Data please contact the controller to make such request. If you make the request to us, we will work with the controller to process and evaluate such request to confirm whether deletion is required by GDPR.

Transnational Transfer of Data

If you are providing your Personal Data to us directly to use our Site or Services, we will transmit your data, including your Personal Data, to the United States in order to fulfill our contractual obligations to you.  

Your California Privacy Rights

California residents who have an established business relationship with NovoEd may make a written request to Company about whether Company has disclosed any Personal Information to any third parties for the third parties’ direct marketing purposes during the prior calendar year.  To make such a request, please send an email at info@novoed.com or write us:

NovoEd, Inc.

854 Folsom St.

San Francisco, CA

(415) 789-3062

Third Party Websites

We may link to other websites.  When you click on one of these links, you are ‘clicking’ to another website.  Company does not control the data collection or privacy practices of such third party sites.  We encourage you to read the privacy policies of any third party sites, as their collection, use, and storage practices and policies may differ from ours.

Minors Under 16 Years of Age

Company does not knowingly collect or store any personal information from or about children under the age of 16.

If you believe a child under the age of 16 has under any circumstances provided us with personal information and data, a parent or legal guardian can email us at Privacy@Novoed.com  to request that their children’s information be deleted from our records.

Do Not Track

Do Not Track” or DNT is a feature enabled on some browsers that sends a signal to request that a web application disable its tracking or cross-site user tracking.  At present, our Site does not respond to or alter its practices when a DNT signal is received.

Changes to Privacy Policy

Company reserves the right to amend this Privacy Policy at any time. If Company makes material changes to its Privacy Policy, we will notify you by (1) changing the Effective Date on our Privacy Policy and provide additional notification either (1) via email or other means as we may deem commercially reasonable.

Questions?

If you ever have any questions about our online Privacy Policy, please contact us.  We respect your rights and privacy; and will be happy to answer any questions or concerns you might have. You may direct any such questions to our data protection contact at Privacy@Novoed.com