Last modified: October 15, 2019
The Rosen Publishing Group, Inc. (“Rosen,” “we,” “us,” and “our”), operator of LevelUp, is committed to protecting your privacy. This policy describes our online data collection and use practices for LevelUp. By using the LevelUp website and services (“Service”), you are accepting the practices described in this statement as well as our Terms of Service.
We are devoted to safeguarding users’ personal information, especially that of minors. We handle customer data in a manner consistent with applicable United States laws and regulations, including the Family Educational Rights and Privacy Act (FERPA), the Children’s Online Privacy Protection Act (COPPA), California’s Student Online Personal Information Protection Act (SOPIPA), and California’s Online Privacy Protection Act (CalOPPA).
Rosen contracts with Schools (including private or public schools; local, county, district, state, provincial, or federal educational agencies; after-school service providers; libraries; or other educational organizations, hereafter referred to as “School” or “Schools”) to provide the Service. Adult users of the Service may include teachers, specialists, administrators, and others over age 18. Children, including those under age 13, may use the Service under the direction and supervision of these adult users.
Personal Data of Primary Account Holders and Trial Users
If you register for a free trial or ask for information about LevelUp, or you were involved with purchasing LevelUp for your School, we may ask for your name, email address, postal address, school or district affiliation, phone number, what role you serve at the School, and billing information if necessary. Personal information collected in these ways is added to our access control database and/or our customer databases, which are at Rosen premises and hosted by third-party hosting companies.
We may use information in our customer databases to send you information, electronically or otherwise, about us and our products which we think may be of interest to you. We may also send information on updates, features, functionality, system maintenance, and other communications relevant to using the Service. Unless you have informed us that you do not wish to receive further information about our products, we may send you direct mail. You may choose to opt out of receiving these communications.
Your personal information will also be used to enable us to verify you are a subscriber and to deliver LevelUp to you.
Upon request, LevelUp will provide you with information about whether we hold any of your personally identifiable information.
Personal Data of Rostered Adult Users
If you become a rostered (adult) user in our Service, we may collect information including name, email address, school or district affiliation, phone number, what role you serve at the School, and other identifiable information, such as ID numbers, required by the School to use the Service. We store this information in order to fulfill our contractual requirements to deliver LevelUp to you.
We will not contact you about marketing unless you have elected to receive such communication. We may send information on updates, features, functionality, system maintenance, and other communications relevant to using the Service. You may choose to opt out of receiving these communications.
Upon request, LevelUp will provide you with information about whether we hold any of your personally identifiable information.
We request personal information (such as your name, email address, and other contact details) when you contact us with subscription management queries, technical problems, to comment on LevelUp, or when you ask for information about how to use the service. Personal information submitted for these reasons will not be added to our customer database and we request it simply so that we can respond to you about your query. Statistics regarding the types of queries submitted to us may be collated by us in aggregate form so that we can effectively monitor the site and improve levels of service.
Personal Data of Child Users
LevelUp is a preK–2 education Service, and its users include children under age 13 (“Child,” “Children,” “Student,” or “Students”). LevelUp is marketed and sold to adults, who are then responsible for the supervision and direction of users under age 13. LevelUp does not collect personally identifying information on users under age 13 without proper consent, and we abide by the terms of FERPA regarding educational records and COPPA regarding the collection of information from users under age 13.
LevelUp student accounts are set up and maintained by Schools. Under the terms of our contracts with Schools, we agree to act as a “School Official” as defined by FERPA, meaning that we:
- perform an institutional service or function for which the school or district would otherwise use its own employees;
- have been determined to meet the criteria set forth in the school’s or district’s annual notification of FERPA rights for being a School Official with a legitimate educational interest in the education records;
- are under the direct control of the school or district with regard to the use and maintenance of education records; and
- use education records only for authorized purposes and will not re-disclose personally identifiable information from education records to other parties (unless we have specific authorization from the school or district to do so and it is otherwise permitted by FERPA).
Under the terms of COPPA, because a School has contracted with us to collect personal information from students solely for the use and benefit of the School and its students, and for no other commercial purpose, Schools may consent to our collection of students’ personal information on behalf of students’ parents or legal guardians (“Parent” or “Parents”). As required by COPPA, we provide Schools using our Services with notices explaining our data collection practices regarding users under age 13.
To create accounts, Schools may provide personally identifying information on students, such as first and last names and the class they are assigned to. Students are granted unique usernames and passwords in order to access LevelUp. As Students use the Service, we collect information regarding their use of books, activities, and games as well as performance data on quizzes, activities, and reading assessments. Under certain circumstances, LevelUp also allows Students to create content. This content may include brief, written responses to questions about the content of books just completed as well as audio recordings of Students reading aloud brief text passages (running record assessments). Such content is submitted only to the Student’s teacher for review and grading, and it is not used by LevelUp for any other purposes. Students may make use of such features without providing any personal information. Wherever we collect student information, we do so in support of the educational purposes for which LevelUp is designed, such as allowing teachers to review students’ work, monitor student performance and progress, and otherwise support instruction.
Schools maintain ownership of their Student Records, as defined by FERPA. School administrators are able to access and review student records at any time through an administrator dashboard. Schools are urged to safeguard administrator access information, keep it in strict confidence, and notify us of any unauthorized use of a password or account registered under their subscription. Teachers are able to monitor student activity through an educator dashboard that only displays data for students their “class.” Student accounts do not allow students to communicate with other student users.
Other than in the ways explicitly disclosed in this policy, we do not knowingly collect personally identifiable information directly from users under age 13. If we learn that we have inadvertently collected any personally identifiable information from such a user, we will take steps to delete it. If you believe we have inadvertently collected personally identifiable information from a user under age 13, please contact us.
Information Collected Automatically
LevelUp collects and use non-personally identifying information, including IP addresses and web server log files to track trends, administer the website, track user movement, and gather demographic information. We use this non-personally identifying information in the aggregate. We do not combine these types of non-personally identifying information with personally identifying information.
Cookies and other persistent identifiers may be paired with personally identifiable information solely for the purpose of providing support for the internal operations of LevelUp.
LevelUp does not collect precise geolocation information.
Online Tracking/Do Not Track
LevelUp does not track users across other websites. We honor Do Not Track signals from users’ Web browsers.
Sharing Collected Information
We do not share personally identifiable information for marketing or advertising purposes. We do not share, sell, or distribute your personal information or the personal information of child users. We do not use children’s information to target advertisements to users.
LevelUp has been developed by and is hosted by third parties, but we have agreed with those third parties that they will keep your information secure and not use it for other purposes. We share information with third-party service providers only if it is necessary for them to perform services on our behalf in order to support our internal operations.
We may use or share anonymous or aggregate and de-identified information for educational research purposes, to evaluate, inform, or show the efficacy of our services.
If we believe that your use of the LevelUp website is unlawful or damaging to others, we reserve the right to disclose the information we have obtained through the LevelUp website about you to the extent that it is reasonably necessary in our opinion to prevent, remedy, or take action in relation to such conduct.
We reserve the right to disclose personally identifiable information if we are required to do so by law, or if we believe that disclosure is necessary to protect our rights, protect your safety or others’ safety, investigate fraud, and/or comply with a judicial proceeding, court order, subpoena, or legal process.
We may link to non-Rosen websites on LevelUp. If you visit these sites, they may collect information, and such websites are not within our control and are not covered by this privacy statement.
If you close your account, we have no obligation to retain your information, and we may delete any or all of your information without liability. However, we may retain information related to you if we believe it may be necessary to prevent fraud or future abuse, if required by law, or for legitimate business purposes, such as analysis of aggregated, non-personally identifiable information, account recovery, auditing our records, and enforcing our rights and obligations under our agreements.
At the request of the School, we will ensure that all Data in its possession and in the possession of any subcontractors, or agents to which the Provider may have transferred data, are destroyed or transferred to the School under the direction of the School when the data are no longer needed for their specified purpose.
If a school requests data to be destroyed or transferred while a contractual obligation still exists between Rosen and the School, and said destruction or transfer changes Rosen’s ability to provide its contractual obligations, Rosen shall not be held accountable fiscally or legally for its inability to provide the Service.
Your personal information is stored in data centers controlled by third-party hosting companies and on Rosen premises. The data centers controlled by third-party hosting companies are specifically designed to be physically secure and to only admit authorized personnel who are contractually bound to keep all our data confidential. Access to our customer database is only given to those Rosen employees who need such access in order to carry out the necessary processing of your account.
All personal information submitted by you and entered by Rosen in the LevelUp account management system is encoded using SSL encryption before being sent over the Internet.
Rosen strives to keep to industry-standard security practices. In the unlikely event of a data breach, we will work to remedy said breach. All affected institutions will be notified, and Rosen will support the subscribing institution in their notifying affected individuals, students, and/or families, in compliance with applicable laws.
Despite our best efforts, no security measures are perfect. We cannot guarantee or warrant the security of any information you disclose or transmit to us on or through the Services and cannot be responsible for the theft, destruction, loss, or inadvertent disclosure of your information. If you have reason to believe the security of your account has been compromised, please contact us.
Changes to This Policy
Rosen Publishing Group, Inc.
29 East 21 Street
New York, NY 10010