PRIVACY POLICY


Effective Date: August 31, 2015


Thank you for visiting this website, which you have reached from any of the affiliated websites of NEW PERSPECTIVES ON ASSESSMENT, LLC, a Delaware limited liability company (hereinafter “we”, “our” or “us”), namely http://newperspectivesonassessment.com/, or such other websites as we may own or operate in the future (the “Site”). We have created this Privacy Policy to demonstrate our firm commitment to your privacy. To better protect your privacy, we provide this notice explaining our online information practices and the choices you can make about the way your information is collected and used by us. This notice discloses our information gathering and dissemination practices for our Site.


Although our computer systems are currently based in the United States of America, we operate internationally. Your personal data will be processed by us in the United States where data protection and privacy regulations may or may not be to the same level of protection as in other parts of the world, such as in the European Union. By visiting the Site from outside the United States, you consent to the collection and processing in the United States of your identifiable information.


  1. THE INFORMATION WE COLLECT


    Our primary goal in collecting personal information is to provide a smooth, efficient, and personalized experience. This allows us to provide products and features that most likely meet your needs and to customize our service to provide an easier and quicker experience. We use the information that you provide to respond to your requests, sell our educational products and services to you, assist our sales team to reach an appropriate audience, improve our products and the Site, provide suggestions to you of appropriate learning experiences, help you reflect and monitor your progress through the site, self-reflect on your professional growth, and in general, to communicate with you. Here are the types of information we gather:


    1. Information You Give Us. You can enter certain information on the Site, including your name, email address, billing and shipping addresses, phone number, credit card information or other site registration data, and your URL. You can choose not to provide certain information, but then you might not be able to take advantage of some of the features and promotions within the Site.


    2. IP Addresses and Other Automatic Information. Certain data is automatically collected from you and all visitors whenever you visit our Site. This data includes your IP address and the type of browser used to surf the Internet. Your IP address tells us both your Internet Service Provider (ISP) and the general geographic location from where you are connecting (e.g., country, territory, etc.) and also enables us to identify the specific computer from which you are accessing the Site. Your IP address is a number that is used by computers on the network to identify your computer and to enable other computers to send data to your specific computer. We may also use your IP address to track the date and time you accessed our Site, how long you stayed at the Site, and what pages you visited. If you have configured your browser with your email address, this data may also be available to us. Finally, web analytics tools are also used to track site usage, how our users arrive at the Site and what they do on our Site; however, this analytics data, collected via a JavaScript tag in the pages of our Site, is not tied to personally identifiable information.


    3. Cookies. Like many websites, we may make use of “cookies” on the Site. If you do not know what cookies are, or how to control or delete them, then we recommend you visit http://www.aboutcookies.org for detailed guidance. A cookie is a file transferred from a website to the hard drive of your computer so that the website may track your activities. Cookies, by themselves, do not let a website know any personally identifying information about you, such as your real name, address, etc., unless you previously provided that information at the website or have set your

      preferences in your browser to provide that information. We do not collect personally identifiable information about any one person using cookies. Cookie technology allows us and our third party websites (like Vimeo, Google and affiliates and retargeting companies) to keep track of the sites you visit and store your preferences. Currently we operate under an “implied consent” policy which means that we assume that our cookie usage as described in this Agreement is acceptable to you. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies, please note that you may not be able to sign in or use some of the interactive features offered on our Site. Finally, our Site uses session cookies to track your log-in history. These cookies are necessary for the websites to work and various site functionality will break upon disabling them.


      Notice to California Residents and All Users of Our Site: California law, and possibly other state laws, requires us to inform you how we respond to web browser “Do Not Track” signals. Our Site does not currently support “Do Not Track” codes, meaning that we do not respond to, or take any action with respect to, “Do Not Track” requests.


    4. Surveys. Occasionally, we may request you to fill out a user survey. Such surveys will always be optional to you, the users, but these surveys allow us to better understand the demographics and interests of our users. Your responses in combination with the responses of our other users help us to improve our Site.


    5. Email. If you contact us through the regular mail or via email, we may keep a record of that correspondence. Any personally identifiable information contained within your communication will not be used for a commercial or unlawful purpose.


    6. Electronic Newsletter. We may produce an electronic newsletter distributed periodically to those who opt-in from time to time. If you choose to subscribe to this feature, you will be asked to provide your email address and first and last name. Your email address will be used only by us to distribute our electronic newsletter and any promotions or marketing that we feel may be on interest to you, or as otherwise provided herein. To no longer receive our electronic newsletters, please review how in this Privacy Policy.


    7. Web Pixels. Our Web pages contain electronic images known as Web pixels (sometimes called single-pixel gifs or beacons) and are used along with cookies to compile aggregated statistics to analyze how our site is used and may be used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our customer communications and marketing campaigns.


    8. Payment Processing. Our external payment provider, Payeezy, requires billing address information to process credit card and other types of financial payment transactions.


  2. HOW WE USE THE INFORMATION


    We put the information gathered whenever you visit our Site (both non-personally identifiable and personally identifiable), and the information volunteered by you to us, to several uses as described in greater detail below.


    1. Your IP address is used to assist us in diagnosing problems with our server and to administer our Site. As discussed above in Section 1(b), IP addresses are used by your computer every time you are connected to the Internet. IP addresses are automatically collected by our web server as part of demographic and profile data known as “traffic data” so that data (such as the web pages you request) can be sent to you. We will consider your IP address as a form of personally identifiable information and will safeguard it as such in the manner in which we handle other personally identifiable information described in this Privacy Policy.

    2. We may use the information provided to perform statistical analyses of the characteristics and behavior of the users and decide where to invest our resources. We may use this information to update our Site, to notify you about information that may be of interest to you, or display content for which you may have shown a preference.


    3. We may use personal contact information volunteered by you for promotional and/or marketing purposes.


    4. If you provide us with your telephone number, you will only receive a telephone call from us or our third party vendors with information in relation to a request from you or order of a product from our Site.


    5. There may be additional uses associated with our use of Google Analytics, Display Advertising, affiliates, and retargeting companies which are discussed herein.


    6. A “referrer” is the information passed along by a web browser that references the Web URL you linked from, and is automatically collected by our web server as “traffic data”. We reserve the right to use this information to identify broad demographic trends that may be used to provide information tailored to your interests. You will not be personally identified from this information.


    7. System information that we collect as part of “traffic data” includes time, the type of web browser being used, the operating system/platform, and CPU speed. This information is sent automatically by your web browser when you are connected to a web site. We reserve the right to use this information for purposes of identifying broad demographic trends and may be used to provide information appropriate for your computer system. You will not be personally identified from this information.


    8. We take online payments for purchases made on our Site. We currently use Payeezy, which is a brand representing a suite of solutions belonging to First Data Corporation (“Payeezy”), as our third-party payment processing provider. To view Payeezy’s privacy policy, which governs your payment transactions on our Site, please visit https://developer.payeezy.com/privacy-policy. We provide companies like Payeezy only with the information they need to perform their payment processing services. After you select “Check Out with Payeezy” or a similar option on our Site, you will be redirected to the Payeezy website to enter in various data about yourself, including your contact information, such as your name, address, phone, email and other similar information, financial information, such as the full bank account numbers and/or credit card numbers that you link to your Payeezy account, billing address of the credit card and other detailed personal information. Payeezy, or our current third-party party payment processing provider, will verify the address against the cardholder’s details for security purposes. After completing your transaction on the Payeezy site, you will be routed back to our Site to finalize your purchase. In accordance with Payeezy’s current privacy policy, if you open a Payeezy account directly on or through our Site, any information that you enter on our Site (and not directly on a Payeezy website) will be shared with us as the owner of the Site. We may also use the billing details in case we need to contact you regarding payments (e.g., for an outstanding invoice or failed transaction).


  3. WHAT INFORMATION DO WE SHARE WITH THIRD PARTIES?


    1. Unless required by law, user information provided by you, including, but not limited to, demographic information, will not knowingly be shared with third parties that are unaffiliated with us, except as otherwise provided herein.


    2. User information provided by you, including, but not limited to, demographic information, may be shared with our affiliates, contractors or partners (including, without limitation, New Perspectives Online, LLC and Catherine Fosnot and Associates, LLC d/b/a New Perspectives On Learning), and may be used for promotional and/or marketing purposes or to otherwise provide services to us and/or to you.

    3. We respond to subpoenas, warrants or other court orders regarding information that is contained within access logs concerning any user. We also reserve the right to release the information concerning a user who we believe is in violation of our content guidelines, even without a subpoena, warrant, or other court order. We cooperate with law enforcement agencies in identifying those who use our servers for illegal activities. We also reserve the right to report any suspected illegal activity to law enforcement for prosecution.


    4. We may at some point sell all or part of our business or assets to a third-party. User data is an asset that may be transferred as part of such a transaction.


  4. WHAT CHOICES DO I HAVE TO CONTROL MY INFORMATION?


    You have the opportunity to opt-out of receiving communications from us and/or to opt out of permitting us to share your information with affiliates and our third-party vendors by sending us an email at mbecerra@newperspectivesonassessment.com or sending us a letter at New Perspectives On Assessment, LLC, 3396 Meadowbrook Blvd., Cleveland Heights, OH 44118 USA and telling us that you do not want us to send you any communications and/or permit us to share your information with our affiliates or third-party vendors.


    If you have submitted personally identifiable information through our Site, or if someone else has submitted such information, and you would like to review, request changes or have that information deleted from our databases, please contact us via email or send a letter to our Web Manager at the address indicated above. We will then use reasonable efforts to change or remove such information from our files, unless we are entitled or required to retain it pursuant to other agreements or by law. You may also contact us through either of the above methods to request or review the personally identifiable information that we have collected about you. We will use reasonable efforts to supply you with this information and correct any factual inaccuracies in this information.


    Your California Privacy Rights

    If you are a resident of California, Section 1798.83 of the California Civil Code entitles you to request information from us regarding our disclosure of your personal information to third parties for direct marketing purposes. To make such a request, please contact at the email address or address noted at the beginning of this Section 4.


  5. THE PRIVACY OF MINORS


    1. We believe that it is particularly important to protect the privacy of minors online. We define a “minor” as any person less than eighteen (18) years of age. We do not knowingly collect, use or share personal information about minor users with third parties without a parent’s permission. IF YOU ARE UNDER THE AGE OF EIGHTEEN (18), YOU ARE NOT PERMITTED TO COMPLETE ANY PURCHASES OR OTHER TRANSACTIONS OR ENTER OR PROVIDE ANY PERSONALLY IDENTIFIABLE INFORMATION ABOUT YOURSELF WITHOUT THE PERMISSION OF YOUR PARENT OR LEGAL GUARDIAN.


    2. We recommend that parents review our Privacy Policy before allowing their children to access our Site. Children should always ask a parent for permission before sending personal information to anyone online. They should also be instructed not to fill out any forms or register at any domain without a parent’s knowledge and consent.


    3. Our Site is directed toward and designed for use by persons aged eighteen (18) years or older (or over the age of majority in the jurisdiction in which you reside), users that can form legally binding contracts under applicable law We do not solicit or knowingly collect personally identifiable information from children under the age of eighteen (18). If we nevertheless discover that we have received personally identifiable information from an individual who indicates that he or she is, or that we otherwise have reason to believe is, under the age of eighteen (18), we will promptly delete such information from our systems.

  6. HOW DO WE PROTECT THE USER DATA WE COLLECT?


    We employ several physical, electronic and managerial safeguards to protect collected user data. Such data is stored in secure operating environments that are not available to the public. Our employees are required by us to maintain and uphold your privacy and security and are aware of our privacy and security policies. Unfortunately, no data transmission over the Internet can be guaranteed 100% secure. As a result, while we strive to protect your personal information, WE CANNOT ENSURE OR WARRANT THE SECURITY OF ANY INFORMATION YOU

    TRANSMIT TO US, AND YOU DO SO AT YOUR OWN RISK. In particular, we have no liability for disclosure of information due to errors in transmission or unauthorized acts of third parties.


  7. DISCLAIMERS


    1. All users should be aware while using any service where you disclose personal information online voluntarily, including on message, blog, rant or bulletin boards, or through email, that such information can be collected and used by others. If you use these services on our Site and voluntarily provide any information on our user feedback areas, you do so at your own risk. We cannot make any representations regarding the security of such transfer of information.


    2. You should be aware that our Site contains links to outside sites. We are not responsible for the privacy practices or the content of such websites.


    3. We reserve the right to change or modify this Privacy Policy at any time by posting such change or modification on this page after providing you with prior notice by email, if you have provided us with your email. Your continued use after such notice and amendment, indicates your acceptance of the amended Privacy Policy. Users should check this page regularly for such updates by referencing the Effective Date posted above. However, we stand behind the promises we make and will never materially change our policies and practices to make them less protective of customer information collected in the past without the consent of the affected customers.


  8. CONTACTING US


If you have any questions about this Privacy Policy, the practices of our Site or your interactions with this Site, please send an email to mbecerra@newperspectivesonassessment.com.