Last Modified: August 22, 2017
At TenMarks Education LLC, we understand how important privacy is to our customers, and we are committed to providing a safe and secure learning experience for students, educators, and parents who use our websites, services, and software (collectively, our "Programs"). As a subsidiary of Amazon.com, Inc., the information we receive is subject to the Amazon.com Privacy Notice at http://www.amazon.com/privacy (as supplemented by this policy).
We provide additional privacy safeguards to the students who use our Programs, and we have signed the Student Privacy Pledge.
This policy describes our privacy practices for Student Information we receive about a student's use of our Programs. We use the term "Student Information" in this policy to refer to information that personally identifies a student and other information we receive about a student that is linked to information that personally identifies a student. Student Information does not include de-identified or aggregated information that does not personally identify an individual student.
What Types of Student Information Does TenMarks Receive?
We receive Student Information for educational or school purposes, or as authorized by an educator, parent, or student. This includes, for example, the following types of Student Information:
- Student Information Provided by Educators or Parents: We receive information that an educator or parent gives us about a student. This may include, for example, a student's name or identifier and grade level provided by an educator or parent when they register a student for our Programs. Student Information we receive from a school or a district continues to be the property of and under the control of the school or district.
- Student Information Provided by Students: Student interactions with our Programs generate data we refer to as "Performance Data." Performance Data may include, for example, the lessons a student chooses to play, when a student starts and stops a lesson, and student responses in the lesson.
- Student Information We Automatically Receive From the Student's Device: We receive technical information from the computer or mobile device a student uses to interact with our Programs. This technical information may include, for example, the device operating system, web browser type, and IP address.
How Does TenMarks Use the Student Information It Receives?
We use Student Information for educational or school purposes, or as authorized by a parent or student. In general, we use Student Information to provide students the best possible educational experience on our Programs. For example, we use Student Information:
- To Customize and Personalize Our Programs: We use Student Information to provide access to and to customize and personalize our Programs. For example, we may use a student's Performance Data to adapt our Programs to a student's unique needs, make adaptive learning recommendations, and to personalize the reports and updates about a student's progress we send to educators and parents.
- To Assess Student Performance: We use Student Information to assess student performance and provide updates and reports about a student's progress to educators and parents. For example, we may group Performance Data of similar students to assess performance by level.
- To Support, Provide, and Improve Our Programs and Offerings: We use Student Information to support, provide, and improve our Programs and offerings. For example, we may use Student Information to provide technical and customer support.
Does TenMarks Share Student Information?
We do not sell Student Information to third parties. We will share Student Information only as described below.
- Educational Institutions, Educators, and Parents: We provide educational institutions, educators, and parents with progress reports, updates, and other information about their students. These reports and updates may be personalized about an individual student and may include Student Information.
- Third-Party Service Providers: We employ other companies and individuals to perform functions on our behalf. Examples include analyzing data and providing customer service. They may have access to Student Information needed to perform their functions, but may not use it for any other purposes.
- Business Transfers: As we continue to develop our business, we might merge with other businesses or sell substantially all of our assets. In such transactions, Student Information would be one of the transferred business assets, but will remain subject to the promises made in this policy.
- Affiliated Businesses: To provide you the best possible educational experience, we may work closely with Amazon.com, Inc. and the subsidiaries it controls. We may share Student Information with these affiliated businesses, but their use of the Student Information will be subject to the restrictions of this policy.
- As Authorized: We may share Student Information with additional third parties for authorized educational or school purposes, or as authorized by the educator, parent, or by the student as permitted by applicable laws and regulations.
Can a Student, Educator, or Parent Opt-Out of Providing Student Information?
Our Programs are individualized and customized for each student, so the Student Information we receive is required for a student to use our Programs. At any time, a student, educator, or parent may revoke consent to allowing a student to use our Programs. At a student's, educator's, or parent's request, we will remove, de-identify, or anonymize the Student Information in our Programs, and the student will no longer be able to use our Programs.
Is TenMarks Compliant with FERPA?
Additional Frequently Asked Questions Related to Student Data Privacy
Can a student retain control of any student-generated content, including
transferring it to a personal account?
Yes, students using TenMarks Writing may download the final version of student-generated essays. TenMarks Math does not involve the creation of student-generated content.
Can parents, legal guardians, or students review Student Information in the
student's records and correct erroneous information?
A parent, legal guardian, or student may review Student Information in the applicable student's records by viewing their TenMarks account. To correct any erroneous information, the parent, legal guardian, or student can ask the applicable student's teacher or TenMarks customer support to make the changes.
What does TenMarks do to ensure the security and confidentiality of
We take a number of steps to protect the security and confidentiality of Student Information. We leverage industry-standard software, encryption, and the leading infrastructure of Amazon Web Services to ensure the security of that information. All team members with access to Student Information are required to take regular training on their responsibilities in protecting that information against technical and social engineering threats. Access to sensitive Student Information is provided only to employees with a business need, and is immediately removed upon the termination of the employee.
What does TenMarks do if there is an unauthorized disclosure of Student
Within 48 hours of learning about a data breach, or longer reasonable time as may be required by the legitimate needs of applicable law enforcement or as to take measures necessary to determine the scope of the breach and restore reasonable integrity of its systems, TenMarks will notify all teachers, parents, principals, and district administrators whose information may have been improperly disclosed, via email communication to the email address on file for each user. Since TenMarks does not maintain any contact information for students, TenMarks will inform any users who oversee those students (i.e. relevant teachers, parents, principals, and district administrators) if any Student Information is involved. This email notification will describe the nature of the data breach and steps that are being taken to protect their TenMarks accounts going forward.
Can a school, district or teacher request that TenMarks delete Student
Yes. Following the termination of a license, a school or district may request that TenMarks delete or de-identify Student Information and TenMarks will do so. A teacher who purchases a TenMarks license may also request that TenMarks delete or de-identify Student Information after termination of that license.