1. NumberCoach’s Commitment to Privacy
Our commitment is guided by a few major principles:
We Empower Schools to Make Data Decisions
- Schools and districts can use NumberCoach without sharing any Personal Data from students. Or they can choose to set up student accounts and use NumberCoach to track their students’ progress.
- The school or district’s account manager can delete or correct Personal Data from students at any time.
NumberCoach is Committed to Maintaining a Safe and Compliant Platform
- We use industry standard security practices, such as TLS encryption.
- We’ve signed the Pledge to Safeguard Student Privacy. Learn more here.
- We’ve reaffirmed its commitment to privacy, by signing Pledge 2020.
2. Children’s Use of NumberCoach
Only parents/guardians, schools, or districts that have obtained licenses and provided consent on behalf of students can create student accounts. For all other types of subscriptions and trials, NumberCoach does not knowingly collect Personal Data from children under the age of 16.
If you are a child under the age of 16, you must get permission from your school, parent, or legal guardian to use this website. If you wish to sign up for a free trial or subscribe to NumberCoach, your school, parent, or legal guardian must register for a trial or paid subscription to grant you access to the website.
If we learn that we have inadvertently collected Personal Data from anyone younger than 16 without the appropriate consent, we will take the necessary steps to delete it.
3. Mobile Application
When a user with a Lite, School, or District subscription uses our mobile application, the information collected will be handled in the same way as described in this policy. When our mobile application is used in a standalone mode (meaning a user has downloaded the app but has NOT started a free trial through the Apple App Store or Google Play store), we will only collect information to identify the device used, which we will use solely to facilitate the internal operations of NumberCoach. If a free trial is started, a free trial is converted to a paid subscription, or a subscription is renewed by a parent or by a child 16 or older, we collect only the minimum information necessary (a transaction identifier and email address for the application store account holder) to verify that payment was made through the applicable application store. We will also automatically collect non-personal information in the manner described in this policy, and that non-personal information will be linkable to the transaction identifier and email address.
4. What Information Do We Collect and How Do We Use It?
a. Website Visitors.
If you are an individual who visits our front-end website (for example www.NumberCoach.com) only (a “Visitor”) and do not log into the site, we may collect certain information in furtherance of our legitimate interests in operating the NumberCoach services and business. Information collected automatically from Visitors may include the following:
- IP address associated with your computer;
- “clickstream data,” which includes information about your clicks on our website and which may also include information about your computer;
- web browser and operating system and information about the website you visited before coming to our site;
- mobile application information;
- identifiers such as an anonymized session identifier; and
- website traffic volume, frequency of visits, and type and time of transactions.
By collecting your IP address, which is necessary for the operation of this Site, we may indirectly collect information about your geographic location (which may be sufficient to identify the name of your city or town, and, in some cases, your street name)
b. Logged-In Users.
We will ask you to create a NumberCoach account to access certain portions of our site. When you create an account, we will ask for your consent to collect certain types of Personal Data. However, if you do not grant the requested consent to the processing of your Personal Data, the use of the NumberCoach website may not be possible. The Personal Data that we collect from logged-in users includes information that you voluntarily provide to us when you sign up for an account and information that is automatically collected when you are logged into the NumberCoach platform. The information collected depends on whether you are a teacher, school, parent or student. The provisions below describe what information we collect for each type of user.
(i) From teachers and administrators
1. Information you voluntarily provide.
- If you are a teacher or administrator signing up for an account on our website, we collect your first and last name, email address, role at your school, grade interests and subject interests. We’ll ask you to enter the state of your organization to select your school, and we remember the school you select so that we can properly give you access if your school has already purchased NumberCoach. Additionally, we ask you to set a password to keep your account secure. In districts that have enabled login through a third party account (such as a Google LLC or Clever Inc. account), you will connect using that account, we will use your email address registered with that third party as your username and you will not need to set a separate password.
- Your email address will be your username. We’ll use your email address, as well as your school, role, grade and subject interests, to customize the updates you get about NumberCoach via email. You can always opt out of emails that you have already opted in to receive from us by clicking “unsubscribe.” If you request a school trial or a consultation with our sales team, we will also ask for your phone number and job title so that a member of the NumberCoach team can get in touch with you to set up your trial or help you with a purchase.
- If you are purchasing a paid account, we will collect all the information necessary to process the order, including credit card information, billing information or shipping information (as applicable).
- Teachers and administrators with schoolwide or district accounts can invite other staff members at the school or district to create a NumberCoach account. To do this, they can enter the email addresses of the people they wish to invite or use other import mechanisms supported by NumberCoach. We only use these email addresses to send invitations, and will not send any other emails to these addresses.
- Information we automatically collect. If you are a teacher or administrator logged into NumberCoach, we will automatically collect the same information that we collect from Visitors.
(ii) From parents
1. Information you voluntarily provide.
- If you are a parent, you may access the website by (1) creating an account using our mobile app or (2) purchasing an individual subscription. If you activate a school subscription, we will collect the same information from you as if you were a teacher or administrator. If you are a parent signing up for an account through our mobile app or an individual subscription, we collect the information you voluntarily provide to create an account. Only parents who have activated school subscriptions may invite others to create a NumberCoach account.
- Information we automatically collect.
- If you are a parent logged into NumberCoach, we will automatically collect the same information that we collect from teachers or administrators.
(iii) From students
1. Students can’t create accounts on their own.
- Unless a school or district has obtained a license, provided consent on behalf of students and chosen to allow for student account creation, we collect no personally identifiable information or Personal Data from students (other than parent or teacher selected usernames for certain legacy accounts). In cases where a school or district purchases NumberCoach, the first step is for teachers or administrators to create classes. Students can only sign up for NumberCoach after their school or district imports student roster information into NumberCoach or their teacher enters class information and instructs students to create an account with a provided code. Students cannot sign up and create a NumberCoach account unaffiliated with a class or a schoolwide or district license.
- Student accounts created by teachers or administrators.
- NumberCoach is not offered directly to students on any basis, and school districts, teachers or parents must first sign up for primary accounts and then invite students to use NumberCoach through student accounts. When students create a student account on NumberCoach, they’ll enter a code which will associate them with their school and teacher. These codes may only be generated by teachers or administrators and no student may create an account without a valid class code. To the extent not already imported by teachers or administrators (either manually or using a third-party tool such as Google), we’ll then collect the student’s first and last name, and the student will set a username and password. In districts that have enabled login through a third party account (such as a Google or Clever account), the student will connect using that account, we will use the student’s email address registered with that third party as the username and the student will not have a separate password. We collect the first and last name so that teachers can identify students on their class roster in the My Classes section of NumberCoach.com and administrators can identify students in the school management section. We collect the username so students can easily log in, as well as have unique identification for the website. Because the first and last name are for teachers’ class management, they can instruct students to enter an initial or nickname instead of a first or last name, or another form of identification, if they’d prefer. The student’s username and first and last name will not be shared with any NumberCoach users or third parties other than their teacher(s) and the account manager(s) at their school or district.
- Student accounts created by parents.
- Only parents who activate a school subscription may invite students to use NumberCoach through the student account sign up process mentioned above. If a parent signs up for NumberCoach through the mobile app or an individual account, no additional sign up process is necessary. We may, however, ask for the grade level of a parent’s child and other general information to customize the user experience on the mobile app or individual account. If you are a parent who has created an account through our mobile app, you may also limit your child’s usage of the app by toggling “on” the Parental Controls. Toggling on the Parental Controls in the mobile app will hide all content dealing with mature subjects (including, but not limited to: violence, sex and tragedy) and restrict visible content to lessons deemed inappropriate for K-5 students.
- How student accounts are used.
- Limits on collection of Personal Data from student accounts.
- We do not ask or require students to provide Personal Data beyond that which is reasonably necessary to use NumberCoach. We do not share any student login information with any third party and information collected from students is never used or disclosed for any third-party advertising or any kind of behaviorally targeted advertising.
- Information we automatically collect.
- If a student is logged into NumberCoach, we will automatically collect the same information that we collect from Visitors.
- Deleting Student Accounts.
- NumberCoach will promptly correct or delete student information at the request of a parent or an authorized representative of the student’s school or district. You can send a deletion request to email@example.com.
- How we automatically collect information.
We use the following tools to collect and track the automatically collected information described above, including:
(i) Cookies and Similar Technologies.
- To learn more about browser cookies, including how to manage or delete them, look in the Tools, Help or similar section of your browser, or Click Here.
- Additionally, our video player may store local shared objects, also known as Flash cookies, on your computer. Local shared objects cannot be managed in the same way as browser cookies. Visit this link for information on managing Flash cookies.
- We may use the technologies described above in connection with the advertising of our services to parents, teachers and administrators on other websites and tracking the results from such advertising. We don’t allow these third parties to advertise directly on our website.
- We use third-party analytics service providers to assist us in collecting and understanding website usage information. We use information from these services to help us improve our website and the services we provide to our users.
- We place a tiny image, also known as a pixel tag, in the emails we send, and this tells us when you have opened the email. Our team uses this information to improve emails we send to you, and best tailor them to your needs.
By using our website, you agree to our use of these tracking technologies.
We do not track our users across third party websites. As a result, we do not currently honor “do not track” signals transmitted by users’ web browsers. To learn more, Click Here.
d. Anonymized Data.
5. How We Use Your Information
We use Personal Data and any other information collected through the website for the following reasons:
- administer the site;
- improve the quality and types of services that we deliver;
- communicate with parents, teachers and school districts by responding to your requests, comments and questions;
- diagnose technical problems;
- send users emails regarding service, technical and other administrative matters. These communications may also include information regarding changes in services, new service offerings and important service-related notices, such as security and fraud notices. Such communications will only be delivered to parents, teachers and school districts and will never be delivered to the site’s student users.
- send users alerts to notify them about upcoming assignments and NumberCoach services related to their activity on the site “Notification Alerts”. These Notification Alerts may be sent to all users of the site, excluding students.
- billing, account management and other administrative matters; and
- as required by applicable law or regulation.
We use this information to help us diagnose technical problems, administer the site and improve the quality and types of services that we deliver. We may also collect, track and analyze information in aggregate form that does not personally identify users.
6. How We Share Your Information
We will not sell or rent any of your or your students’ information to any third-party for any purpose, and we do not track users outside of our website. There is no third-party advertising on NumberCoach.com.
We share information that we collect in the following circumstances:
- as instructed by a school administrator, school or district in relation to information about their users, for example to let administrators know which teachers are using NumberCoach;
- with teachers who are the managers of a class so they can see information about the students in that class;
- with third party products specifically configured by schools or districts to interoperate with NumberCoach;
- if we believe in good faith that it is necessary to disclose the information under any applicable law or regulation, such as complying with a subpoena or legal process;
- if the information is Anonymized Data;
- with our corporate affiliates and/or parents; and
- other circumstances that you expressly consent to.
If there are changes to the Policy, you will have the opportunity to consent to them prior to additional information being collected or to cease using the NumberCoach site and content.
Please also note that our service providers may be able to combine the data we share with them with the data they collect on their own. For example, if we share information with Clever, Clever may combine such information with the data they have already collected about you through their website. We are not responsible for such combinations of data and we encourage you to learn about their privacy and security policies before you use this site or provide our service providers with your personal information.
7. Links to Third-Party Sites
8. How NumberCoach Protects and Secures Your Information
Each account created on the NumberCoach website is protected with a password. Make sure that you and any students associated with your account keep these passwords a secret at all times to prevent unauthorized access to your account. You are responsible for any activity that occurs while you or any students associated with your account are logged in to NumberCoach, whether or not that access is authorized by you. If you think that someone has gained unauthorized access to your account, please contact us immediately.
We have industry-standard security policies and procedures in place, and take reasonable measures to protect the confidentiality, security and integrity of Personal Data collected on our website. This includes the use of encryption to protect sensitive information transmitted online, firewalls and other security technologies to prevent access to the data from unauthorized parties. All connections between users and NumberCoach are secured via encryption communication technology (TLS). All NumberCoach passwords are salted and hashed using the practices recommended by NIST (National Institute of Standards and Technology). NumberCoach utilizes industry-standard application hosting providers who agree to perform frequent diagnostics, operating system updates, and network security monitoring. Our engineering team is committed to creating and maintaining systems to protect your Personal Data.
Our policy is that only employees who need to access user information in order to perform a specific job (for example, billing or customer service) are granted access to that information. Our partners, including our outside shipping company and our credit card processing company may only use the information to provide specific services. These companies do not retain, share, store or use personally identifiable information for any secondary purposes beyond filling your order.
While we have taken all steps to protect your information, and continuously work to keep our systems at or above industry standard security, no system is 100% fail proof and secure. If we believe that the security of your Personal Data may have been compromised, we will seek to notify you as soon as possible by email.
For information regarding our internal security audits, please contact us at privacy@NumberCoach.com.
9. Your Choices Related to Your Privacy
a. Withdraw Consent or Object.
- In order to process your Personal Data, we rely on your consent or our legitimate interests to process to process your data. You may withdraw your consent or object to the use of our Personal Data at any time, but you will no longer be able to access NumberCoach.
- You can edit your information.
(i) Editing your information.
- If you have an account on our website, you can edit your information in the account section of the website. If you are unable to do this on the website, you can contact us and we’ll help you make changes. We will ask you to verify your identity before we provide you with access to your information.
- You have the right to opt out of emails from us by clicking unsubscribe. You may still receive transactional emails from us related to purchases, account expiration, or other necessary communication.
(ii) Editing a student’s information.
- If you are the manager of a school or district subscription, you can add, edit or delete teacher and student users of your account. You may edit student usernames and passwords if your students provided them. If your students sign in with a third party product specifically configured by schools or districts to interoperate with NumberCoach, such as Google, Microsoft Inc.’s Office 365, Clever, or a learning management system that is integrated via Learning Tools Interoperability (LTI), you or the student will need to contact the third party or your School/District IT Administrator to change name, email address or password.
- If you are a parent who has purchased a school subscription, you may delete, edit or add accounts in the same manner as the manager of a school or district. If a parent joins a school subscription, they will have the same information editing rights as a teacher.
- If you are a parent, guardian or student, the law allows you access to certain information that may have been provided to NumberCoach by your school or district. If you would like to obtain such access, please contact your school or district.
- You have the right to delete your information.
- If you are a parent, teacher or administrator, you can contact us to delete your account. Parents, teachers and administrators can delete student accounts or contact us and we can delete them for you. After a parent, school or district account termination and subsequent removal of student data, we may retain securely stored backups in accordance with applicable law, our agreement with the school or district and our data retention policy, after which point it will be deleted.
- Please note that any information you share with others on the website or content other users may have copied, is not a part of your account and may not be deleted when you delete your account. If we share your data with one of our service providers, we will use our best efforts to cause such third party to delete such data when you delete your account.
- How we retain and delete your data.
- We will retain Personal Data collected in connection with free trial or subscription accounts only for as long as is necessary to provide the services to the account holder, as required by applicable laws or regulations or otherwise per the terms or a contract with a school or district.
- We may maintain Anonymized Data, including usage data, for analytics purposes.
- Certain Rights for EEA Persons.
- Individuals in certain countries, such as the European Economic Area (the “EEA”), have certain statutory rights in relation to their Personal Data. These rights include the right to request access to Personal Data, as well as to seek to update, delete or correct their Personal Data. You may exercise these rights by following the steps explained above, which for holders of student accounts means making such a request to a school, teacher or parent. If you have any problems exercising your rights or if you have any additional questions about our use of your Personal Data, please contact us at privacy@NumberCoach.com for additional information.
- You also have the right to (i) restrict NumberCoach’s use of information that constitutes your Personal Data, which will cause you to lose access to NumberCoach and (ii) lodge a complaint with your local data protection authority. Or you may contact the Office of the Data Protection Commissioner.
- Identifying the Data Controller and Processor
- We endeavor to be fully compliant with the General Data Protection Regulation (GDPR), effective as of May 25th, 2018. We may act, depending on the circumstances, as either or both a Controller and a Processor of Personal Data (as these terms are defined in the GDPR). We act as the Controller of information that we ask you to provide to create an account and information that we automatically collect when you use the site. When acting as the Data Controller, for purposes of Article 14(2) of the GDPR, NumberCoach relies on the following lawful basis for processing Personal Data: consent, compliance with law, and legitimate interest.
- Location of Data and Processing
13. Complaints/Contact Us
For California Residents Only:
California Consumer Privacy Act (CCPA)
a. Your Rights. California residents have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other California and Federal privacy and data protection laws, as applicable, to exercise free of charge:
- Disclosure of Personal Information We Collect About You. You have the right to know:
- The categories of personal information we have collected about you (as more particularly described in section b., below);
- The categories of sources from which the personal information is collected (as more particularly described in section b., below);
- Our business or commercial purpose for collecting or selling personal information (as more particularly described in section b., below);
- The categories of third parties with whom we share personal information, if any (as more particularly described in section b., below); and
- The specific pieces of personal information we have collected about you.
- Please note that we are not required to:
- Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
- Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
- Provide the personal information to you more than twice in a 12-month period.
- Disclosure of Personal Information Sold or Used for a Business Purpose. We do not sell your personal information.
- Right to Deletion. Subject to certain exceptions set out below, we will:
- Delete your personal information from our records; and
- Direct any service providers to delete your personal information from their records.
- In order to request deletion of your personal information, you must make the request from the email address associated with your NumberCoach account.
- Please note that we may not delete your personal information if it is necessary to:
- Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
- Comply with an existing legal obligation; or
- Enable solely internal uses that are reasonably aligned with your expectations based on the your relationship with us;
- 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
- Comply with the California Electronic Communications Privacy Act;
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
- Debug to identify and repair errors that impair existing intended functionality;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
- Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
- Protection Against Discrimination.
- You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. NumberCoach does not differentiate how we treat our users whether they exercise their rights under the CCPA. This means we do not, among other things:
- Deny goods or services to you;
- Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- Provide a different level or quality of goods or services to you; or
- Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
- Disclosure of Personal Information Collected.
- Information We Collect About You. We may collect and use the following personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
Categories of Personal Information Specific Types of Personal Information Collected
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers For Educator NumberCoach Users:
- First and Last Name, Email Address, IP Address
For Student NumberCoach Users:
- First name and first initial of last name OR Nickname, IP Address
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her 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 informationFor Educator NumberCoach Users:
- First and Last Name, District of employment and School assignment, title/position (e.g. admin or teacher);
- [If you are the account administrator]: Address where to send Invoices, Telephone number; and
- [If using a paid account]: to the extent applicable, the name and last four digits of the credit/debit card used to pay for the services.
For Student NumberCoach Users:
- First name and first initial of last name
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)For Educator NumberCoach Users:
- Prior NumberCoach Materials purchases and/or prior NumberCoach purchases
For Student NumberCoach Users:
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)For Educator NumberCoach Users:
- Click-stream data, IP address
For Student NumberCoach Users:
Audio, electronic, visual, thermal, olfactory, or similar informationFor Educator NumberCoach Users:
- To the extent the feature is used, voice recording.
For Student NumberCoach Users:
- To the extent enabled by the Educator NumberCoach User: student voice recording.
Professional or employment-related informationFor Educator NumberCoach Users:
- District of employment and School assignment, title/position (e.g. admin or teacher).
For Student NumberCoach Users:
- How Your Personal Information is Collected. We collect most of this personal information directly from you in person, by telephone or email and/or via our website and apps. However, we may also collect information:
- from publicly accessible sources (e.g., school websites);
- from a third party with your consent (e.g., your bank);
- from cookies on our website; and
- via our IT systems, including: communications systems, email and instant messaging systems.
- Why We Use Your Personal Information. We use your personal information for the following reasons:
- Providing access and services of the NumberCoach Materials;
- Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
- Debugging to identify and repair errors that impair existing intended functionality;
- Short-term, transient use, provided the personal information that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
- Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider;
- Undertaking internal research for technological development and demonstration; and
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.
- Who We Share Your Personal Information With. We routinely share personal information with:
- our affiliates, including companies within the NumberCoach group;
- service providers we use to help deliver our services to you, such as payment service providers, warehouses and delivery companies;
- other third parties we use to help us run our business, such as customer relationship managers or website hosts;
- third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
- credit reporting agencies;
- our insurers and brokers; and
- our banks.
e. Please note, NumberCoach does not sell, lease, or rent your data to any third-party.