Effective date: June 12, 2020
The ExQ Service is offered as a school-based service. The Children’s Online Privacy Protection Act of 1998 (COPPA) allows schools and school administrators to act in the place of parents to provide consent to the collection of personal information from children. Schools should always notify parents about these activities. Schools and school districts must comply with the Family Educational Rights and Privacy Act (FERPA) when providing student information to us from students’ records. FERPA gives parents certain rights with respect to a school’s use and disclosure of their children’s education records. We work with schools in order to provide services in a manner that is consistent with FERPA. For more information on parental rights with respect to a child’s educational record under FERPA, please visit the FERPA site. In all circumstances, children should always check with their parents or guardians before entering information on any website, and we encourage families to discuss their household guidelines regarding the online sharing of personal information.
Children under the age of 13 should not register for their own account with the ExQ Service. Setup of accounts for the ExQ Service for children under the age of 13 is coordinated with a child’s teachers, parent/guardian, or both. If you are a parent of a child participating through a school program, please coordinate with your child’s teacher to set up an account for your child.
ExQ values the trust you place in us regarding the handling of your information and that of your children. If you would like to review the information we have collected from your child, or if you would like to ask us to make no further use of or delete the information we have collected from your child, contact us as described in the “Contact Us” section below. In your request, please include your name and email and your child’s name, and specify the question or concern or the action you would like us to take. For your child’s protection, we may need to verify your identity before implementing your request.
If you ask us to remove your child’s information, your child will not be able to use the ExQ Service any longer.
In general, we don’t require a child to disclose more information than is reasonably necessary to participate in the ExQ Service. The categories of information we receive through our ExQ Service, including information which may be automatically collected via the Site or the ExQ Service, are the following:
The categories of sources of this information include the following:
Below is a further description of the information we receive and how we receive it:
We receive from the schools or other organization under which you are participating, or from the parent directly, the contact information from parents of minor participants, such as email addresses.
We receive the following information regarding students and teachers who participate in the ExQ service:
This information may be provided by your school to us, or you may provide it to us when you sign up with the ExQ Service (www.myexquest.com/sign_up) or if you subscribe to our newsletter or other communications.
We collect content voluntarily provided by students, faculty and administrator users via ExQ Service. Such content includes:
This content is shared with administrator and faculty users of the school, or the coaches or other instructors of the organization that you are participating with in using the ExQ Service.
If we would like to use your content (for example, a video) as part of our marketing, we will contact you separately and obtain your express consent. In the case of children we will contact the parents either directly or through the school for such permission.
Tools employed on our Site and through our ExQ Service may gather your IP address or similar computer or device information regarding when you access the Site or use the ExQ Service.
A cookie is a small file placed on your computer that stores information. Overall, cookies help us provide you with a better experience. Cookies help us verify your browser and maintain your login session . You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the Site or ExQ Service. If you opt out of using cookies, we may employ a cookie only to help us remember this preference.
If you would like further information on the cookies we employ on our Site or in the ExQ Service, please contact us as provided in the “Contact us” section below. The following are some online resources that provide some helpful information on how to change your cookie preferences:
http://www.aboutads.info/choices/ (if you are based in the US)
In general, we use the personal information collected from participants and other users of the ExQ Service only to perform the ExQ Service for you and support the educational purposes authorized by the schools we perform services for, and for no other commercial purpose. We do not use (or permit others to use) personal information to engage in targeted advertising, nor do we use (or permit others to use) personal information to create a profile about students other than in connection with providing the ExQ Service and for authorized educational purposes. Below is a further description of the business or commercial purposes for which we use your information:
The contact information we receive from parents is used to verify their identity as parents of children who are participating (including for purposes of required consents) and communicate with parents regarding the ExQ Service, including the progress and performance of their children. We do not sell this contact information to third parties.
The personal information of users that we collect is used
In addition, if you have provided contact information as part of subscribing to our newsletter or other communications on our Site, then we will use your contact information to provide those communications to you. You may elect to stop receiving these newsletters or other communications at any time by unsubscribing via the methods available in those communications.
We use the information as part of the ExQ Service to understand, track and evaluate the participant’s performance and progress both internally and with the appropriate school faculty and staff and to respond to participant regarding those including through the Evaluation Data (defined below). The content provided by teachers and students will be assessed and analyzed for research purposes using factors such as age, gender, and grade.
The scores and reports that result from the questionnaires, evaluations and games a user engages with as part of the ExQ Service (“Evaluation Data”) are able to be viewed and accessed by the student participants and their teachers and staff and by teacher participants and their administrators. Users should not access the Evaluation Data of others without proper permission. ExQ may use the Evaluation Data for any purpose, including to improve the ExQ Service and prepare statistical analyses, reports, and benchmarking statistics for ExQ’s own use and for marketing purposes; however, the information will be deidentified and anonymized prior to any disclosure. We will not use any Evaluation Data for behaviorally targeted advertising or to create profiles of users for non-educational purposes.
We do not use persistent unique identifiers to amass a profile about a student except in furtherance of school purposes. We do use IP addresses and tracking and other information we collect from cookies and other means in the following ways:
Certain of our third party service providers may use IP address and tracking information from cookies to provide their service to you through our ExQ Service (see the “Disclosures to third parties” section below).
We may aggregate and de-identify personal information and metadata regarding participant content for our own purposes, including to improve and analyze the ExQ Service and Site, to provide information to others regarding the effectiveness of the ExQ service and Site and in order for us to develop new products and services. However, we will not use any de-identified data for behaviorally targeted advertising or to create profiles of users for non-educational purposes.
We do not sell personally identifiable information collected via the Site or ExQ Service. The following are the categories of personal information that we disclose for business or commercial purposes:
The following are the categories of third parties to whom we disclose the categories of information above:
Below we describe further how we may disclose the information we collect from our users.
We disclose personal information, content, Evaluation Data of student participants to their teachers and school administrators, or their coaches or instructors of other organizations with which they may be participating in the ExQ Service, as part of the services we provide to such schools and similar participating organizations. We disclose personal information, content, Evaluation Data of teacher participants to school administrators as part of the services we provide to schools.
Third parties may operate or host the Site or the computers that operate the Site and ExQ Service, store or process data for us, and provide services part of or related to the ExQ Service. We have agreements with these third parties that contain protections regarding use of your information.
Below is further information on some of our third party providers and your personal information:
AWS. We currently use Amazon Web Services to host our Site and the ExQ Service.
Usabilla. We use Usabilla to help us manage our Site. We provide Usabilla with the service type, browser, username and training “location” (what lesson you may be on in the ExQ Service) for these purposes.
We may also disclose your information for the following reasons:
Our intent is only to use personal information in compliance with applicable law, and that includes giving you choice on how and if your personal information is used. We don’t discriminate against you because you choose to exercise your rights, such as to request removal of or changes to your information. However, some uses of your information are necessary for the ExQ Service we provide through the Site or for the reason you provided us with the information, and if you don’t want your information used in certain ways, it may prevent you from using the ExQ Service.
We need complete and updated information in order to properly provide the ExQ Service. You may request that we disclose what personal information we collect, use, disclose, and sell through the ExQ Service. We will let you update the personal information that you have provided to us through the methods available through the ExQ Service. In addition, you may contact us to review, update or remove your information via the email address in the “Contact us” section below. We will take steps to make sure that any updates or removal requests that you provide are processed in a timely and complete manner. If you request that we remove your personal information, that may impact your ability to access or receive our services. We will take reasonable steps to verify a user’s (or the user’s parent’s) identity before granting access, changes or deletion of that user’s personal information. For example, we may require you to provide your email address, user ID or similar information to verify that you are the user of the ExQ Service or the minor user’s parent/guardian. When we do this, we delete the information provided if the user or parent does not timely respond to the request for verification.
Once your subscription to the ExQ Service is over, you will have had a chance to download the reports containing your Evaluation Data. During your subscription to the ExQ Service, you may also request the videos you make as part of the ExQ Service. However, after your subscription we may delete any or all of the data we have regarding your use of the ExQ Service. For example, the videos and recordings you may have made as part of the ExQ Service will usually be deleted by us 45 days after the end of your use of the ExQ Service.
With respect to any websites or services that may be linked to in the ExQ Service or Site, these or other websites are governed by their own privacy policies or information collection practices, and we aren’t responsible for those policies or practices. We encourage you to review the privacy policies and information collection practices of those websites.