SkillsBuild for Students Data Privacy Policy

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This Policy was last updated on September 4, 2020

SkillsBuild for Students, an IBM initiative (IBM) and formerly P-TECH or Open P-TECH (sometimes, "we", "us" or "our") is committed to protecting your privacy. This Data Privacy Policy is important, and we encourage you to carefully read it.

This Data Privacy Policy discloses how we collect, use, and disclose information that we gather related to your engagement with our online learning channels (the "Services"). The Services do not include websites, mobile applications, or other services that link to another Data Privacy Policy. This Data Privacy Policy also describes the choices you have regarding our use of and your ability to access, correct, or delete your personal information. We may seek your consent by other means such as by asking you to click on a button or to change a setting. Where we do so, we will also offer you a way to revoke your consent.

1. How and Why We Collect and Use Personal and Other Information

In order to operate the Services and to maximize your experience, we may collect and use information, some of which may be considered your personal information. In general, we use your personal information to serve you best, including to create your account, to maintain, operate, and improve the Services, to personalize your experience, and to administer the Services. Please note that you may choose not to provide us with certain information; by doing so, however, you may not be able to receive the full range of Services from us. We collect information in the following ways:

  • A. Information Provided By You. You may provide us with information, some of which may be personal information, when you interact with the Services in the following ways:

    • Account Registration—For example, students must provide us with the following information to register for the Services: name, profile picture (students may select to either have their initials appear or upload a profile photo), email address, country of residence, and the name of the student’s school. We also require users to create a member name and password. We may request additional information from users (such as your grades and your parent’s emails when applicable), but this information is optional. We specify whether information is required or optional when we request it. If your school or SkillsBuild for Students Administrator registers your account on your behalf, then the school or SkillsBuild for Students Administrator may view or edit the account registration information; view the content of your Submissions; and view data related to the use of the Services such as badges, courses completed, and credentials.
    • Account Transfer—You will be notified if a school you attend wants to include your existing individual account under the school’s account. After your account is transferred to a school, it allows your school, SkillsBuild for Students Administrator or teachers to view and edit your registration information, view the content of your Submissions (as defined below), and view data related to the use of the Services such as badges, courses completed, and credentials. If you do not want to have your individual account registered your school, you may refuse. Likewise, if you have a school-registered account and your school is no longer affiliated with the Services, then you will have the option of transferring your account to an individual registration (and the school will no longer have the ability to view or edit your registration information, view the content of your Submissions (as defined below), or view data related to the use of the Services such as badges, courses completed, and credentials). If you do not want to have your school account registered as an individual account, you may refuse.
    • Commenting & Submissions—The Services may from time to time offer areas where you and other users can post or otherwise submit comments (e.g. discussion boards), information, creative suggestions, ideas, notes, concepts, information, ratings or other materials on or to the Services (collectively, "Submissions"). Your profile photo will be associated with any Submission you make and will be available to other users of the Services, including your school, SkillsBuild for Students Administrator or teacher (if you have a school registered account). You agree that your Submissions will comply with our Terms of use We do not monitor or review this content before it is posted, and we cannot control and are not responsible for how others may use the information contained in your Submissions. We encourage parents and student administrators to educate their children about safe internet use and to monitor their children's Submissions.
    • Responding to Your Request for Information or Support—When you contact us (online or offline) in connection with a request for information, to provide you with support, or to participate in a forum, we collect information necessary to fulfill your request, to grant you access, to provide you with support, and to be able to contact you. For instance, we collect your name and contact information, details about your request and your agreement with us. We retain such information for administrative purposes, defending our rights, and in connection with our relationship with you. If you have a school registered account and wish to make any corrections or updates to the registration, you must contact your school or SkillsBuild for Students Administrator to have them make the corrections.
    • Surveys—We may occasionally invite you to fill out a survey in order to help us measure the effectiveness of our program and improve upon it. The surveys are not required for participation in the SkillsBuild for Students program. In these surveys we may ask you to provide personal information such as name or email address, as well as your personal opinions. The data you provide will be reported as aggregates, with your information removed. The companies who will have access to your answers are IBM administrators and a third-party survey platform which serves as our data processor.
    • Quizzes—YL may store answers of quizzes which are executed as part of some learning activities.
  • B. Information Provided By Your School or SkillsBuild for Students Administrator. Your school or SkillsBuild for Students Administrator may provide us with personal information about you (e.g., your name, name of your school, parental consent to use the Service) to help us register your account and to provide the Services. We will combine this with the information we collect from you. Your school or SkillsBuild for Students Administrator can only register an account for you with your consent and, if required by law, your parent’s consent. Your school or SkillsBuild for Students Administrator must collect your registration information in an appropriate manner and be responsible for properly entering the information into your account. If your school or SkillsBuild for Students Administrator registered your account and you wish to update your account registration information to correct any inaccuracies, then you must contact your school or SkillsBuild for Students Administrator to modify your account registration. If you do not approve of how your account is registered or modified by your school or SkillsBuild for Students Administrator, you can close your account.

  • C. Information Used By Your School. Whether you or your school registers your account, your school cannot disclose to third parties (except your parents or legal guardians) any data relating to your use of the Services. Where you are registered through your school, your school (i) must not use or view your account other than to register or edit the account information; view the content of your Submissions; and view data related to the use of the Services for the sole of monitoring of student performance; (ii) may enable up to two (2) SkillsBuild for Students Administrators or teachers to register, monitor or track groups or classes of students; (iii) is responsible for ensuring that SkillsBuild for Students Administrators and teachers access the Services in compliance with law and our Terms of use; and (iv) must inform us of any change in SkillsBuild for Students Administrators or teachers so that we can discontinue their access, as appropriate, and re-assign you to new SkillsBuild for Students Administrator or teacher. If you do not wish to be re-assigned, you can close your account.

  • D. Information Used By Your SkillsBuild for Students Administrator or Teacher.Whether you or your school registers your account, your SkillsBuild for Students Administrator or teacher cannot disclose to third parties (except your parents or legal guardians) any data relating to your use of the Services. Where you are registered through your school, your SkillsBuild for Students Administrator or teacher must (i) not use or view your account other than to register or edit the account information; view the content of your Submissions; and view data related to the use of the Services for the sole of monitoring of student performance (ii) accurately register students and update registrations to keep them current or as otherwise requested by students for accuracy; (iii) access the Services only in compliance with law and our Terms of use; and (iv) inform us of any change in their status in supporting the Services, so that we can discontinue their access, as appropriate, and re-assign you to new SkillsBuild for Students Administrator or teacher. If you do not wish to be re-assigned, you can close your account.

  • E. Automatic Collection.When entering one of our websites, or using an online service, we will record information necessary to provide you with access, for the operation of the website and for us to comply with security and legal requirements in relation to operating our site, such as passwords, IP address and browser settings. We also collect information about your activities during your visit in order to personalize your website experience, such as recording your preferences and settings, and to collect statistics to help us improve and further develop our websites, products and services.

  • F. Information from Social Media Networks and Other Third Parties.Our websites utilize a social media aggregation tool that crowdsources user-generated content from social media platforms. If you upload content to social media and use a hashtag (pound symbol) followed by string of words associated to a SkillsBuild for Students media campaign, you are authorizing us to share and display your content on our websites. You can choose to not have your information shared or displayed in our website by not posting content with hashtags related to SkillsBuild for Students media campaign.

2. Data Collection Technologies/ Form of processing

We may contract with analytics partners to track, analyze, and report data about the use of the Services and to analyze and optimize the performance of the Services ("Analytics Partners").

Information that we collect via the data collection technologies described in this section may be linked to other information about you and may be considered personal information. We use the technologies described in this section, alone or in combination, to understand user behavior, help diagnose problems, recognize repeat visitors, and facilitate your access to and use of the Services.

  • A. Use of Cookies, Web Beacons, and Information Saved by Other Technologies

    Third parties may use cookies and other technologies through use of our Services to support or deliver online services. The data collection technologies we and third parties use on web include but are not limited to:

    1. Cookies: Cookies are text files containing small amounts of information that are downloaded to your computer or mobile device when you visit a website and stored within your browser. Cookies are then sent back to the originating website on each subsequent visit to that website or to another website that recognizes those cookies. Some cookies on our Services collect IP and MAC addresses, which may be considered personal information in some jurisdictions. Cookies are useful because they allow a website to recognize a user’s device. You can find more information about cookies at www.allaboutcookies.org The cookies used on this website can be categorized in the following ways:

      Category 1: Strictly Necessary Cookies These cookies are essential in order to enable you to use the Services and its features.

      Category 2: Performance Cookies These cookies collect information about how you use the Services (such as which pages you go to most often and if you receive error messages). In general, these cookies do not collect information that directly identifies you. However, some such cookies may collect GeoIP or other identifiers that may be considered personal information in some jurisdictions.

      Category 3: Functionality Cookies These cookies allow Services to remember choices you make such as language or the region you are in. These cookies can also be used to remember changes you have made to customize the Services.

    2. Web beacons: Certain pages on the Services may contain web beacons. Web beacons allow third parties to obtain information, such as the IP address of the computer that accessed the page on which the web beacon appears, the URL of the page on which the web beacon appears, the time the page containing the web beacon was viewed, the type of browser used to view the page, and the information in cookies sent by the third party.

    3. Web Storage: We may use local storage, such as HTML5 localStorage and indexedDB, to enhance user experience by, for example, storing your user preferences and settings (e.g., volume/mute) in connection with animated content on the Services. Local storage is similar to browser cookies but can store data more complex than simple text. By itself, local storage cannot do anything to or with the data stored on your device.

  • B. Web-Related Opt Outs
    Your browser, such as Internet Explorer, Chrome, Firefox, or Safari, may allow you to manage your cookies and local storage. Because each browser is a little different, we encourage you to check your browsers’ "Help" feature to learn how to block cookies, how to receive notification of new cookies, and how to disable existing cookies. Please note, however, that without some cookies you may not be able to take full advantage of all the Services and some parts of the Services may not function properly. For more information about managing cookies, please visit www.allaboutcookies.org/manage-cookies/.

3. How We Share or Disclose Your Information with Others

As a global organization offering a wide range of products and services, with business processes, management structures and technical systems that cross borders, IBM has implemented global policies, along with standards and procedures, for consistent protection of personal information. As a global company, we may share information about you with our subsidiaries world-wide and transfer it to countries in the world where we do business in accordance with this Data Privacy Policy.

Where appropriate and reasonable, IBM may also share your personal information with selected partners to help us provide you, or the school you attend, products or services, or to fulfill your requests, or with your consent. When selecting our suppliers and partners, we take reasonable steps to ensure proper data handling processes.

If IBM decides to sell, buy, merge or otherwise reorganize businesses in some countries, such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or the receipt of such information from sellers. It is IBM's practice to require appropriate protection for personal information in these types of transactions.

Please be aware that in certain circumstances, personal information may be subject to disclosure to government agencies pursuant to judicial proceeding, court order, or legal process. We may also share your personal information to protect the rights or property of IBM, our business partners, suppliers or clients, and others when we have reasonable grounds to believe that such rights or property have been or could be affected.

We may share certain information with your school or SkillsBuild for Students Administrator, including but not limited to the content of your Submissions and data related to the use of the Services such as badges, courses completed, and credentials.

4. Information Security and Accuracy

We intend to protect your personal information and to maintain its accuracy. IBM implements reasonable physical, electronic, administrative, managerial and technical safeguards to help us protect your personal information from unauthorized access, use and disclosure. For example, we encrypt certain personal information when we transmit such information over the Internet. We also require that our suppliers protect such information from unauthorized access, use and disclosure. Of course, we cannot guarantee that your communications with the Services will never be unlawfully intercepted or that your data will never be unlawfully accessed by third parties. Any transmission of information is at your own risk.

From time to time we may update this Data Privacy Policy. When making changes to this Data Privacy Policy, we will add a new date at the top of this Data Privacy Policy. If we make material changes to the way we collect, use and disclose personal information, we will notify affected users through the Services.

5. Retention Period

We will not retain personal information longer than necessary to fulfill the purposes for which it is processed, including the security of our processing complying with legal and regulatory obligations (e.g. audit, accounting and statutory retention terms), handling disputes, and for the establishment, exercise or defense of legal claims in the countries where we do business.

For Brazilian Data Privacy ("LGPD") purposes we will retain your personal information for ten (10) years. However, you can request to delete your personal information at any time as Section 6 below.

6. Your Information and Data Rights

You may access and change some of your personal information by editing your profile at any time. At any time, you can review, change, or delete your personal information by sending us an email at [email protected]. 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.

You may have additional rights pursuant to your local law applicable to the processing. For example, if the processing of your personal information is subject to the EU General Data Protection Regulation ("GDPR"), and your personal information is processed based on legitimate interests, you have the right to object to the processing on grounds relating to your specific situation. Under GDPR you may also have the right to request to have your personal information deleted or restricted and ask for portability of your personal information.

If the processing of your personal information is subject to the LGPD, in addition, you have the right to request: (i) confirmation of the existence of the treatment; (ii) anonymizing, blocking or deleting; (iii) data portability to another service or product provider; (iv) elimination of personal data processed with your consent; (v) information about public and private entities with whom the controller shared your personal information; (vi) information about the possibility of not providing your consent and the consequences of the refusal; (vii) revocation of consent. Under the LGPD, you also have the right to object to the processing when it is not based on consent and when the data is processed illegally, as well as the right to petition the National Data Protection Authority.

In the event that you consider our processing of data related your use of the Services not to be compliant with the applicable data protection laws, you can contact us or lodge a complaint:

  • Directly with IBM by contacting [email protected]
  • With the competent data protection authority. The name and contact details of the Data Protection Authorities in the European Union can be found here.

7. Student Privacy

We are committed to protecting the safety and privacy of young people using the Internet. We do not knowingly collect personal information from children under the age required in the relevant jurisdiction (for example, in the United States, age 13) unless and until we have received consent and authorization from the proper authority to use the Services and for us to collect such information. If you become aware that we have collected personal information from a child without proper parental consent, please notify us promptly at [email protected] If we become aware that a child under the applicable age has provided us with personal information without proper consent, we will take steps to remove such personal information.

8. International Transfer

The international footprint of IBM involves a large number of transfers of personal information between different subsidiaries, as well as to third parties located in the countries where we do business. Some countries have implemented transfer restrictions for personal information, in connection with which IBM takes various measures, including:

  • Where required, IBM implements Standard Contractual Clauses approved by the EU Commission, or similar contractual clauses in other jurisdictions. This includes transfers to suppliers or other third parties. You can request a copy of the EU Standard Contractual Clauses here.
  • IBM complies to the APEC Cross Border Privacy Rules.
  • IBM certified to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks. More information can be found here.

9. How to Contact Us

If you have a question related to this Data Privacy Policy, please contact us at [email protected] or at:

IBM
Attn: Privacy Office (SkillsBuild for Students)
1 New Orchard Road
Armonk, NY 10504
U.S.A.

Please, consult the IBM Privacy Policy available at to learn https://www.ibm.com/privacy about the Controller of your personal data.

10. California Residents

If you are a California resident, you have rights under the California Consumer Privacy Act of 2018 (CCPA). This section of the Privacy Policy is an overview of the information required by the CCPA and provides instructions on how to exercise the rights granted by the CCPA.

    1. 1. Disclosures about your Personal Information

      Collection, Business Purposes and Disclosure of Personal Information
      As described above, to support your use of SkillsBuild for Students, we may have collected and disclosed, for a business purpose, information from the following categories in the last twelve months:

      this includes Personal Information defined by the CCPA as:

      • Identifiers such as IP address and cookies
      • Personal information under the Customer Records provision of the California Civil Code such as your name, postal address or email address that you provide to use the SkillsBuild for Students platform
      • Internet activity information relating to your interactions with the SkillsBuild for Students platform
      • Electronic and visual information
      • Inferences about your consumer preferences
      • Education information defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act such as a student’s first and last name.

      Sources and Sharing of Personal Information
      As explained above, we may collect Personal Information directly from you, automatically from your device, and/or from your school. We may share information about you with our subsidiaries, suppliers and, where appropriate, with selected partners to help us provide you, or your school, products or services, or to fulfill your requests, or with your consent.

      2. Rights Relating to Your Personal Information

      In addition to the data rights mentioned above, as a California resident, you have the right to:

      Know your Personal Information
      You can request specific pieces of Personal Information, or information about the categories of Personal Information that IBM holds about you by submitting a request to [email protected] or by calling 1-800-IBM-4YOU (1-800-426-4968).

      Request Deletion of your Personal Information
      You can request the deletion of the Personal Information that IBM holds about you by submitting a request to [email protected] or by calling 1-800-IBM-4YOU.

      Non-Discrimination
      If you choose to exercise any of these rights, we will not deny goods or services to you or provide different quality of services.