Tennessee Book Company LLC Privacy Policy

Effective Date: 3/21/2022

This Privacy Policy (“Policy”) explains Tennessee Book Company LLC’s TBC(collectively, “TBC”TBC “we,” “our,” and “us”) information practices on our website(s), including any of our desktop applications, mobile applications, websites (such as TBC classgatherTBC.com), any TBC owned web retail store, including without limiting, our products known as ClassGather, and other products controlled. owned or licensed by TBC, and any other products or services that include a link to this Policy (collectively, the “Products”). 

You agree to the terms of this Policy when you access or use any of the Products, or take other actions described below. IF YOU DO NOT AGREE TO THIS POLICY, YOU ARE NOT PERMITTED TO USE THE PRODUCTS.

1. Information We Collect About You.

TBC provides its Products directly to schools and school districts (“Schools”) for their educational purposes and as allowed under applicable federal and state laws. The information that we collect depends on the Products and features within those Products that a School uses. We collect some information from School teachers, administrators, officials, and agents (collectively “School Users”) and some information from students (“Students”) and their parents/legal guardians (“Parents”) (Parents and Students together with School Users, “Users”).

TBC collects information when Users purchase, redeem, download, access or use any content or the Products; register a Product with TBC; create an account; take notes or participate in assessments in a Product; use collaboration features; submit requests; and access Products, including when you visit any of our websites; as described further below.

a. Information You Provide Directly to Us.

The types of information we collect depends on the User:

School Users:

The information that School Users may provide to us while using the Products, or that entities may provide us at the direction of the School, includes the following:

• Account Sign-Up and profile information
• Contact information such as full name and email address;
• School name;
• Username and password;
• Teacher information;
• School payment information collected and used by our third party payment processors such as credit or debit card numbers;
• Class and Student information;
• Class rosters (including teacher, Parent name, Student name and grade level;
• Student email address;
• Student identification numbers such as school identification number or school information system identification number;
• Course information and assessment information
• Coursework, including content, assigned and completed;
• Assessments, assessment scores, grades, and teacher feedback on coursework; and;
• Teacher curricula and notes and feedback to or about Students.
• Other
• Answers to surveys about the Products; and
• Feedback, suggestions, and questions provided to TBC and any other type of information submitted to us at the User’s discretion, such as by contacting us.

Students:

We collect information from Students to provide the Products to Students as directed by Schools. Schools have authorized us to collect the following information from Students necessary to use our Products:

• Coursework and activity, for example: content read, project submissions (including documents and other media), assessment responses;
• Notes and highlights in content;
• Communications with teachers and classroom discussions, for example: responses to teacher feedback and requests for guidance; and

Parents:

• Parent name associated with Student name;
• Username and password
• Answers to surveys about the Products; and
• Feedback, suggestions, and questions provided to TBC and any other type of information submitted to us at the User’s discretion, such as by contacting us.

Users can choose not to provide such information, but, in general, most of the information we request from you is required in order for us to provide the Products and the lack of such information will prevent us from doing so. We will collect, use, transfer and disclose this information as described in this Policy.

b. Information We Receive From Third-Parties

We receive information from third parties, such as Local Education Agencies, your School’s vendors or representatives third-party authentication services (if you interact with us through third-party sites or services) and the parties with whom we exchange Information as described here.

c. Information That Is Automatically Collected.

TBC automatically collects certain information as Users interact with the Products. We and our service providers (which are third party companies that work on our behalf), may use a variety of technologies, including cookies and similar tools, to assist in collecting the following information:

• technical data, such as domain name, and what browser type and langauge, and operating system you are using, Internet Protocol (IP) address, country and city, device types, mobile device identifier, the date and time of your request, if any, and the device you are using, referring and exit pages and URLs, platform type, landing pages, error logs, and other similar information; and
• usage data, such as the date and time of requests, the number of clicks, information you download, how and which Products you use; pages viewed and the order of those pages, the amount of time spent on particular pages, the terms you use in searches on our sites; information from interactive Products, including scores from assessments, engagement during study sessions and overall performance, and records of any contact we have with you by telephone, email or online.
• TBC may collect Information about you when you visit the TBC website through the use of “cookies.”
• We may use third-party web analytics services (such as those of Google Analytics, New Relic on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
• For Users that receive email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when the email message is opened message or which links or banners Users click. This data allows us to gauge the effectiveness of our communications.

2. Using your Information.

Depending on the User, we use Users’ information to:

• meet our contractual commitments to the School;
• administer accounts and respond to User requests;
• provide the Products;
• maintain and improve the Products;
• provide Users with information related to the Products, including changes to the Products;
• provide School Users with information we think is useful about our Products
• customize or curate content supplied to a School based on its use of the Products, subject matter, grade level, and needs of teachers or Students(e.g., content or study recommendations, supplemental content);
• to track, evaluate, and analyze individual and aggregate use of the Products and to share, publish, or otherwise publicize information, but not personal data, describing such use;
• prevent, investigate and deal with fraud, violation of intellectual property rights and other laws and unauthorized use of Products or Users’ accounts,
• as otherwise reasonable and appropriate to the legitimate business needs of TBC related to the Products, and;
• as otherwise described to you in this Privacy Policy, for example in the section describing how we share your information, including personal information with third parties.

TBC will not use the information we collect for behaviorally-targeted advertising purposes. We do not sell or rent any personal information to any third party for any purpose – including for advertising and marketing purposes. TBC will not use information collected from Students for any purposes other than Schools’ educational purposes unless we have de-identified the information so it cannot reasonably be linked to an identifiable Student.

3. Sharing Your Information.

We share information as follows:

• With trusted third parties performing certain tasks on our behalf. For example, this includes but is not limited to service providers providing customer support, operation and administration of the Products, processing information that you provide to us, and other tasks related to the Products. We allow these third parties to access only the information needed to perform those services.
• With other visitors to the Product or users of the Product. To the extent that a School User submits content to publicly accessible portions of the Product (e.g., reviews or comments), visitors and users may be able to view information that identifies you as the author.
• Legal Process and Protection of TBC and Others. We may share information if required to do so by law or in a good faith belief that such disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of TBC, its agents and affiliates, its users and/or the public.
• With a content distributor: TBC shares information related to identified Schools’ use of purchased or licensed content, but such information is de-identified as to specific Users. TBC does not share information related to identifiable Students with distributors or publishers. For example, we share information about a School that has, licensed content to provide access to content in that School’s learning management system.
• We share information with publishers as follows:
• For Schools that get desk copies, samples, or free access to publisher’s content we share the School’s contact name, and School name, in addition to the contact information that you specifically provide for purposes of sharing with the publisher.
• When we report sales to publishers, we include data identifying the School associated with such sales.
• When you ask us to convey to provide course and enrollment metrics so that a publisher can provide you with pricing or other special terms.
• We share de-identified data of usage and user-generated data associated with publisher’s content.
• With affiliates of TBC, or with potential successors in the event of or in contemplation of a merger, acquisition, divestiture or reorganization, in whole or part, for use consistent with this Privacy Policy.
• As otherwise described to you at the point of collection, pursuant to the User’s consent, or as otherwise permitted by law.

4. Your Rights and Choices.

Schools can review and delete information through the Products.  Schools may also request the review or deletion of information by contacting us. We will assist the School in facilitating requests as explained further in the “Retention” section below.

Parents can view their Student’s progress through their Parent account. Parents and Students may make a request for access, review, correction or deletion of personal information in the Products by contacting the appropriate official at the student’s School. If the School determines that the request should be implemented, the School may either make the change themselves or submit the request to TBC.

Parents can contact us to request deletion of their accounts.

• Schools can tell us not to contact them with promotional information regarding our Products and those of third parties either at the point information is requested on our website (by checking or un-ticking (as directed) the relevant box) or, by following the unsubscribe instructions on promotional communications sent. Schools can also exercise the right at any time by contacting us using the Contacting Us details at the end of this Policy.
• California Online Privacy Protection Act Notice Concerning Do Not Track Signals. We do not recognize or respond to browser-initiated Do Not Track (“DNT”) DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. To learn more about Do Not Track, you can do so here.
• YOUR CALIFORNIA PRIVACY RIGHTS: California Law permits visitors who are California residents to request once per year certain information regarding our disclosure of personal information to third parties for such third parties’ direct marketing purposes. However, we do not disclose Users’ personal information for third parties’ direct marketing purposes.

5. Data Retention.

We retain information, including personal information from Students and Users, for a limited time. If a School requests removal of personal information, we will promptly direct our team to delete, dispose of, or de-identify the personal information in a commercially reasonable amount of time unless, consistent with applicable law, there is a compelling reason or legal requirement to retain such information. For example, we may retain information if we have User consent to do so or if we are required to retain such information to comply with applicable law, law enforcement requests, to resolve disputes, to protect the safety and security of our Users or our Service, or enforce our Terms of Service. Please note that information may persist in copies made for backup and business continuity purposes for an additional period of time.

6. Security

TBC takes information security seriously and has taken various measures to help keep information secure from unauthorized access or disclosure. TBC has established administrative, technical, physical, electronic and managerial procedures to help prevent unauthorized access, maintain data security and use the information collected from you in accordance with this Policy.

7. Children’s Privacy

For Products offered to elementary and secondary Schools, we either provide that Product without collecting, using or disclosing “personal information” (as defined in the Children’s Online Privacy Protection Act (“COPPA”), except as permitted by COPPA, or we obtain consent from the School or parent or guardian. COPPA governs the collection of certain information from children under the age of 13 (“child” or “children”); for more information about COPPA and generally protecting children’s online privacy, please visit OnGuard Online. If we have reason to believe that any personal information has been submitted to us by a child under 13 in the United States without legally valid consent, we will take reasonable steps to delete that information as soon as possible. Prior to a Student accessing the Product, the School must facilitate the Student’s access to Products. The commitments we make regarding information collected from or about Students apply equally to all elementary and secondary Students regardless of their age.

We collect the information set forth in Section 1 from Students and use information collected from Students to provide the Products to Students and as described further in this Privacy Policy. The Products limit access to each Student’s account and the content thereon to the Student, the Student’s Parents, and School Users (depending on the choices made by the School’s administrator). The Products do not permit any Student’s account or the content and grades thereon to be viewed or accessed by the general public.

Please see the “Data Retention” section for how long we keep Student information. Please see “Your Rights and Choices” for Parental choices.

8. Links to Other Websites

You may find links to third-party websites from any of the Products. These websites may have their own privacy, cookies and/or other policies, which you should check. We do not accept any responsibility or liability for their policies because we have no control over them.

9. Changes to this Policy

The information practices described in this Policy are current as of the effective date at the end of this document. TBC reserves the right to periodically update this Policy at its discretion. Notice of any revisions will be posted to this page and are effective once posted. If you are concerned about how your Information is used, bookmark this page and check back periodically.

10. Contacting us

If you have any questions, comments, or requests regarding this Policy, please contact us by post or email using the following contact information:

Tennessee Book Company LLC
ATTN: Info Data Sec and Privacy Officer
1550 Heil Quaker Blvd
Suite 100 La Vergne TN, 37086
privacy@ingramcontent.com

Please allow up to 5 business days for us to reply.