Wellington Engagement Index Privacy Policy

Last modified: September 24, 2024

Introduction

The Wellington Initiative LLC ("Company" or "We") respects your privacy and is committed to protecting it through our compliance with this policy.

With the exception of information of children, this policy describes the types of information we may collect from you or that you may provide when you visit the website, www.wei.student.wellington.org, and www. wei.wellington.org, and the Wellington Engagement Index features, functionality and software available on or accessible through such websites (collectively, the "Website").

All capitalized terms used but not defined in this policy shall have the same meanings as defined in our Terms of Use available at: witools.org/documents.

Without limiting the forgoing, this policy applies to information we collect:

·         On or through this Website.

It does not apply to information collected from children or by:

·         Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or

·         Any third party (including our affiliates and subsidiaries), including through any application or
content (including advertising) that may link to or be accessible from or on the Website.

·         Provided however, the applicable rights set forth in this Policy available to children apply with respect to such children.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you acknowledge this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acknowledgement of those changes, so please check the policy periodically for updates.

All capitalized terms used but not defined in this policy shall have the same meanings as defined in our Terms of Use available at: witools.org/documents.

Children Under the Age of 13

Our practices for collecting, using, and disclosing personal information from children under the age of 13 ("children") are set forth in our children’s privacy policy available at: witools.org/documents. Children may only access and use the Website as Student Users and not as Administrator Users or Teacher Users. If we learn we have collected or received personal information from children in the capacity as an Administrator User or Teacher User or guest, without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at laughlin@wellington.org.

Certain consumers under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your State’s Privacy Rights section below, for more information.

 

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

·           By which you may be personally identified,

·           That is about you but individually does not identify you directly, by way of example such as unique ID number, grade level integer, gender, race/ethnicity, socio economic variables, class names, teacher IDs; and/or

·           About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

·           Directly from you when you provide it to us.

·           Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies.

·           From third parties, for example, our business partners, including your school, teachers, and administrators.

 

Information You Provide to Us

The information we collect on or through our Website may include:

·           Information that you, as an administrator or teacher provide by filling in forms on our Website or otherwise upload directly or indirectly on or to the Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.

·           Records and copies of your correspondence (including email addresses), if you contact us.

·           Your responses to surveys that we might ask you to complete for research purposes.

 

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

·           Details of your visits to our Website, including traffic data, logs, and other communication data and the resources that you access and use on the Website.

·           Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

·           Estimate our audience size and usage patterns.

·           Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include cookies.

 

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

·           To present our Website and its contents to you.

·           To provide you with information or services that you request from us.

·           To fulfill any other purpose for which you provide it.

·           To provide you with notices about your account, including expiration and renewal notices.

·           To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

·           To notify you about changes to our Website or any products or services we offer or provide though it.

·           To allow you to participate in interactive features on our Website, such as the Wellington Engagement Index.

·           In any other way we may describe when you provide the information.

·           For any other purpose with your consent.

 

Disclosure of Your Information

We may disclose personal information that we collect or you provide as described in this privacy policy:

·         To our subsidiaries, parents, and affiliates to the extent necessary for the purpose collected.

·         To contractors, service providers, and other parties we use to support our business.

·         To the extent permitted by applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s or our subsidiaries, parents, or affiliates assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company or such entity about our Website users is among the assets transferred.

·         To fulfill the purpose for which you provide it.

·         For any other purpose disclosed by us when you provide the information.

·         With your consent.

We may also disclose your personal information:

·         To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

·         To enforce or apply our Terms of Use available at: witools.org/document  and other agreements, including for billing and collection purposes.

·         If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

 

Your State’s Privacy Rights and Additional Disclosures

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. California's “Shine the Light” law (California Civil Code § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to laughlin@wellington.org or write us at: 3650 Reed Road, Columbus, OH 43220.

 

If you need to access this Policy in an alternative format due to having a disability, please send an email to laughlin@wellington.org or write us at: 3650 Reed Road, Columbus, OH 43220.

The information contained in this section of the Policy applies solely to Website users who meet the definition of the term “consumer” as defined under the California Consumer Privacy Act, as amended, and the then current regulations adopted by the California Attorney General and the California Privacy Protection Agency pursuant thereto (collectively, the “CCPA”) and to other individuals entitled to analogous rights and disclosures under applicable state law, including without limitation the Colorado Privacy Act and the rules adopted by the Colorado Attorney General, and Nevada Revised Statutes Chapter 603A, as amended, and the Virginia Consumer Data Protection Act, and the Connecticut Data Privacy Act, and the Utah Consumer Privacy Act, and all other applicable U.S. state and federal privacy laws (collectively, with the CCPA, as applicable “Privacy Laws”) Terms, and correlative terms, defined in the Privacy Laws contained in this section are intended to have the same meaning and effect as set forth in the Privacy Laws.

We collect personal information on and through the Website and process that personal information as set forth in this Policy. In particular, our Website collected the following categories of personal information from consumers within the last twelve (12) months:

 

Category	Examples	Collected
A. Identifiers.	unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	NO
C. Protected classification characteristics under California or federal law.	race, color, ancestry, national origin, citizenship, religion or creed, gender identity, gender expression, sexual orientation.	YES
D. Commercial information.	Records of products or services purchased.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a device or consumer's interaction with a website, application, or advertisement.	NO
G. Geolocation data.	Physical location or movements.	NO
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment related information.	Current or past job history or performance evaluations.	NO
J. Non-public	Education records directly related to a student maintained	YES
education information (per the Family Educational Rights and Privacy Act	by an educational institution or party acting on its behalf, class lists, student schedules, or student identification codes
(20 U.S.C. Section
1232g, 34 C.F.R.
Part 99)).
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

 

Use of Personal Information

We may use, or disclose the personal information we collect for purposes that are not materially different from those disclosed in this Policy and for one or more of the purposes set forth below, which may include:

·         To fulfill or meet the reason you provided the information.

·         To create, maintain, customize, and secure your account.

·         To process your requests and prevent fraud.

·         To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

·         To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.

·         For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.

·         To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

·         As described to you when collecting your personal information or as otherwise set forth in Privacy Law.

·         To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users, including without limitation consumers, is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

 

Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose.

We have disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

As defined by privacy laws, we do not Sell or Share personal information. We do not have actual knowledge that we Sell or otherwise Share personal information of consumers under 16 years.

In the preceding twelve (12) months, we have Sold or Shared the following categories of personal information to the categories of third parties indicated in the chart below.

 

Personal Information Category	Category of Third-Party Recipients
	Business Purpose Disclosures	Sales
A: Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.	None
B: California Customer Records personal information categories.	A name, signature, address, telephone number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.	None
C: Protected classification characteristics under California or federal law.	Age	None
D: Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	None
E: Biometric information.	None	None
F: Internet or other similar network activity.	Browsing history, search history, information on a device or device or consumer's interaction with a website, application, or advertisement.	None
G: Geolocation data.	Physical location or movements.	None
H: Sensory data.	None	None
I: Professional or employment-related information.	None	None
J: Non-public education information.	Class name, class title	None
K: Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	None

However, you or the Purchasing Organization may disclose or otherwise enable the processing of personal information, including without limitation the categories of personal information listed in rows A, C, J, and K of the table above through the use of APIs and otherwise through the Software. You, or the Purchasing Organization, as applicable, are the controllers with respect to such processing.

 

Sensitive Personal Data

We use and disclose Sensitive Personal Data as set forth in our Wellington Engagement Index Privacy Policy for Children Under the Age of 13 found available at: witools.org/documents, and with respect to Users 13 years of age and over as set forth below.

A User’s race, socio economic information, and gender may be Collected and used to provide the Software to the User and the applicable District Admin Users, School Admin Users, Teacher Users, and Purchasing Organizations. This information is Collected and used based on consent provided by the applicable Purchasing Organization for the applicable User, and is used to provide the Software requested.

We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

 

Right to Revoke Consent for Sensitive Personal Data Processing

You have the right to revoke consent for the processing of your or your Student Users’ Sensitive Personal Data.

You may revoke consent by sending us an email at laughlin@wellington.org

 

Your Additional Rights and Choices

The Privacy Laws provide consumers with specific rights regarding their personal information. This section describes consumer rights and explains how to exercise those rights.

 

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity, we will disclose to you:

·         The categories of personal information we collected about you.

·         The categories of sources for the personal information we collected about you.

·         Our business or commercial purpose for collecting or selling that personal information.

·         The categories of third parties with whom we share that personal information.

·         If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

·         sales, identifying the personal information categories that each category of recipient purchased; and

·         disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

·         The specific pieces of personal information we collected about you (also called a data portability request).

 

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity, we will verify the request and review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1.          Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

2.          Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3.          Debug products to identify and repair errors that impair existing intended functionality.

4.          Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5.          Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

6.          Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

7.          Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8.          Comply with a legal obligation.

9.          Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

 

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by emailing us at laughlin@wellington.org.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. To designate an authorized agent, submit a request by emailing us at laughlin@wellington.org.

You may also make a request to know or delete on behalf of your child by emailing us at laughlin@wellington.org.

You may only submit a request to know twice within a 12-month period.

 

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email us at laughlin@wellington.org.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

Personal Information Sales Opt-Out Right

We do not Sell or Share Personal Information and do not use Sensitive Personal Information for purposes other than those authorized by subdivision (a) of Section 1798.121 of the CCPA.

For the avoidance of doubt, Nevada consumers who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A, as amended, may submit a request by emailing us at laughlin@wellington.org.

 

 

Changes to Our Privacy Policy

It is our protocol to post any changes we make to the Policy on this page with a notice that the Policy has been updated send to the Purchasing Organization via email. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account and/or through a notice on the Website. The date the Policy was last revised is identified on the first page of this Policy.

 

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact The Wellington Initiative LLC at:

laughlin@wellington.org
Or

3650 Reed Road
Columbus, OH 43220

Wellington Engagement Index Privacy Policy for Children Under the Age of 13

Last modified: September 24, 2024

 

CHILDREN UNDER THE AGE OF 13

The Children's Online Privacy Protection Act of 1998 and its rules (collectively, "COPPA") require us to inform parents and legal guardians, and schools when consent is provided by such school (as used in this policy, "parents") about our practices for collecting, using, and disclosing personal information from children under the age of 13 ("children").

 

The Wellington Initiative, LLC ("Company" or "We") respects the privacy of children and we are committed to protecting it through our compliance with this this Wellington Engagement Index Privacy Policy for Children Under the Age of 13 (the “ Children’s Privacy Policy ”).

 

This Children’s Privacy Policy describes the types of information we may collect from children or that children may provide when they visit the website, www.wei.student.wellington.org, and www. wei.wellington.org, and the Wellington Engagement Index features, functionality and software available on or accessible through such websites (collectively, the "Website") whether as a guest or a registered Student User and our practices for collecting, using, maintaining, protecting, and disclosing that information.

 

All capitalized terms used but not defined in this policy shall have the same meanings as defined in our Terms of Use available at: witools.org/documents.

This policy notifies parents of:

·                      The types of information we may collect from children.

·                      How we use the information we collect from children.

·                      Our practices for disclosing that information.

·                      Our practices for notifying and obtaining parents' consent when we collect personal information from children, including how a parent may revoke consent.

·                      All operators that collect or maintain information from children through this Website.

This Children’s Privacy Policy only applies to children under the age of 13.

 

Information We Collect from Children

Children can access the log in page of the Website as a guest, and may access additional content as Student User. Children may only access the Website, beyond the log-in screen, as a registered Student User, not as a District Admin User, School Admin User, or Teacher User. We only collect as much information about a child as is reasonably necessary for the child to participate in the Wellington Engagement Index activity for the use and benefit of the child’s school, and we do not condition his or her participation on the disclosure of more personal information than is reasonably necessary.

 

Information Provided by the Administrator or Teacher

Some content and features are available only to registered District Admin Users, School Admin Users, or Teacher Users, or require us to collect certain information, including personal information of children, from the child’s school, through applicable Users. By way of example, the applicable District Admin User, School Admin User, or Teacher User provides the class roster and is instructed not to provide first or last names. The Website supports automatic data rostering using Clever and Veracross. If the child’s school uses Clever or Veracross, the applicable User may use the automatic data rostering tools available and we may receive information from Clever or Veracross on behalf of the school. This initial data, and data uploaded through periodic uploads and data syncs, as enabled, is uploaded to the Wellington Engagement Index tool and may include data such as the student ID, grade level, class, discipline, gender, race, socio-economic identifier, and custom identifiers, as applicable.

 

We Collect Directly

When a child utilizes the Wellington Engagement Index tool (by placing “dots” on the self-assessment engagement grid), reporting how challenging they find the class and how much they love the experience, inferences may be drawn from the location of the “dots” placed by the child.

 

Automatic Information Collection

We use technology to automatically collect information from our Student Users, including children and the browser used, when they access and navigate through the Website and use certain of its features, by way of example through the use of cookies. The information we collect through these technologies may include:

·                      One or more persistent identifiers that can be used to recognize a User over time and across different websites and online services, including IP address; and

·                      Browser type.

We may combine non-personal information we collect through these technologies with personal

information about the child that we collect online.

 

How We Use Your Child's Information

We use the personal information we collect from your child and the information provided by the other applicable Users to:

·                      register him or her with the Website;

·                      make the Wellington Engagement Index tool available to your child as a Student User, and self-assessment engagement information provided by your child to the applicable District Admin Users, School Admin Users, and Teacher Users.

We use the information we collect automatically through technology and other non-personal information we collect to improve our Website and to deliver a better and more personalized and secure experience by enabling us to:

·                      Estimate our audience size and usage patterns;

·                      Prevent fraud; and

·                      Determine the browser utilized, to help enable us to display the content on such browser.

All of the above uses are limited to the extent necessary to provide the Wellington Engagement Index tool to the applicable child’s school, for the use and benefit of the school, and for no other commercial purpose, and the personal information of children is deleted when such information is no longer needed for its educational purpose.

 

Our Practices for Disclosing Children's Information

We do not sell children's personal information.

We do not process children’s personal information other than as described in this Children’s Privacy Policy.

We may disclose children's personal information:

·                   To the following parties we use to support the internal operations of our Website, (i) Microsoft for the hosting of the Services through its Azure cloud solution.

·                   If we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request.

·                      To the child’s school, and applicable District Admin Users, School Admin Users, and Teacher Users.

·                      If we believe disclosure is necessary or appropriate to:

·                      protect the safety of a child;

·                      protect the safety and security of the Website; or

·                      enable us to take precautions against liability.

·                      To law enforcement agencies or for an investigation related to public safety.

 

Accessing and Correcting Your Child's Personal Information

At any time, you may review the child's personal information maintained by us, require us to correct or delete the personal information, and/or refuse to permit us from further collecting or using the child's information. You can review, change, or delete your child's personal information by sending us an email at laughlin@wellington.org . To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.

 

Schools and Parents

For the avoidance of doubt, the immediately preceding paragraph applies to both the parents of the child and the child’s school.Although each child’s school acts as the agent of each applicable child’s parent, and provides consent under COPPA, for the collection and use of such child’s personal information as provided in this Children’s Privacy Policy, this Children’s Privacy Policy is available to both the child’s school and parents, on the Website. And, if desired, the child’s parents or school may request additional information or revoke the consent provided by the school, for such child, by sending us an email at laughlin@wellington.org.

 

Operators That Collect or Maintain Information from Children

The following are all operators that may collect or maintain personal information from children through the Website:

The Wellington Initiative LLC

laughlin@wellington.org

614-754-4248

3650 Reed Road
Columbus, OH 43220