Skill Struck Data Privacy Policy

Updated
May 20, 2020

Skill Struck LLC. (“Skill Struck”, “We”, “Us”, or “Our”) respects your privacy, and we strive constantly to earn and keep your trust. All personal information you share with us is treated with the utmost care. We have created this privacy policy to establish our commitment to the privacy of your data and the data of your students and children. It describes how Skill Struck collects, uses, shares and secures the personal information you provide. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. The use of information collected through our service shall be limited to the purpose of providing the service for which you (your school or school district), has engaged Skill Struck.

This privacy policy applies exclusively to the Skill Struck SaaS-based educational products and associated services, including the website skillstruck.com (the “Site”).

  1. Information We Collect and How We Use It
  2. Children’s Privacy
  3. Sharing Information with Third Parties
  4. Information Security
  5. Changes to This Privacy Policy
  6. Contact Us

If you have questions or complaints regarding our privacy policy or practices, please contact us at support@skillstruck.com.

Skill Struck receives and processes the personal data of the students, staff and other users of Skill Struck products and services through service agreements with school and district customers that purchase our products and services on behalf of those users. An individual (user or the user’s parent or legal guardian) who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct the query to the school or district or other Skill Struck customer through which the user receives access to the Skill Struck product (the data controller). If requested to remove data, we will respond within a reasonable timeframe.

We will retain personal data we process on behalf of our clients for as long as needed to provide services to our clients, to comply with our legal obligations, resolve disputes, and enforce our agreements.

Software, services, and programs delivered and accessed through the Internet necessarily involve the transmission and processing of personal data, sometimes on an international basis, depending, for example, on where the user is located. When personal information is provided to Skill Struck through the Site, the information will be processed and stored on servers located in the United States, and by using the Site, you acknowledge and give Skill Struck authorization to such transfer, processing and storage on behalf of yourself, your organization, and your students or other users as applicable.

Information We Collect and How We Use It

Skill Struck collects information, including personal information that you provide to us. We also collect personal information when your school, district, or organization creates accounts for administrators, teachers, and students. Skill Struck only collects information that is relevant and not excessive for the purposes for which it is to be processed. Personal information includes information that can identify you. For teachers or administrators, this includes full name, e-mail address, and school. For students, this includes full name, student ID, school, teacher name, and potentially parent email. If the school or district elects to do so, additional optional data may be entered for students that may include demographic data such as gender, birth date, ethnicity, special education, instructional language, participation in free lunch programs, and Title 1 status. This information is only used by Skill Struck for the purpose of completing the purpose for which provided. Data generated through the use of the Site from which personal information and attributes about any user has been removed (“de-identified data”), may be used by Skill Struck for lawful purposes, including, without limitation, product and service improvement or development, general product and service analysis, benchmarking, development of best practices, and/or educational research or statistical assessment.

Links to 3rd Party Sites

Our Site also includes links to other websites whose privacy practices may differ from those of Skill Struck. If you submit personal information to any of those websites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

Children's Privacy

What information is collected online from children under 13?

Children under 13 access Skill Struck using a student account. Typically these accounts are established by the student’s school or by Skill Struck using information provided by the school. The minimum information required to create a student account is:

  • First Name
  • Last Name
  • Student ID Number
  • Student Email

Do you obtain parental consent prior to collecting information from the child?

No. Student accounts are created by teachers or school administrators, or by Skill Struck using information provided by the school. COPPA and other laws authorize schools to act in place of the parent or guardian in deciding whether to give consent to the collection and use of student information for educational purposes. By creating the student account on the Site, teachers provide consent and authorization for Skill Struck to store and process personal data about those children for the purpose of providing the Skill Struck program. Children under 13 cannot create their own accounts and parents do not have access to the administrative portion of our Site where student accounts are created.

When we receive or access student personal data and education records from our school and district customers through their use of our products and services, we understand that we are acting in the capacity of a “school official” under FERPA, and are committed to complying with the limitations and requirements imposed on us as an educational service provider to our school and district customers under FERPA and other applicable state student records privacy laws. Student personal data is used only for the purpose of fulfilling our duties and provisioning our products and services under our services agreement with our school and district customer, and is not otherwise used or disclosed except as provided for in the service agreement, as required by law, or as authorized or directed in writing by our school or district customer.

Can a child enter personal information into your Site?

No. Personal information about children can only be entered by school personnel or by Skill Struck personnel acting on their behalf. There is no way for a student using the Skill Struck program to enter or store additional personal information on our Site. The Skill Struck program collects and stores data created by student use of the program (namely, coding level and progress data), which is linked to each student’s respective personal information.

Is a child’s personal information required for participation in the Skill Struck program?

Yes. Students need individual accounts to access the Skill Struck program and so that their progress in the software program can be monitored by the school or organization and its teachers.

Is children’s information shared with unrelated third parties?

No. Personal information obtained online from students is not released to any unrelated third party except as permitted by law or as expressly set forth in this policy (such as to certain Affiliated Businesses, as provided below), or at the direction of the school.

What are the choices of a parent or guardian?

Skill Struck collects information under the direction of its Clients (school or organization personnel or administrators of the Skill Struck product), and has no direct relationship with the students and children whose personal data it processes in working with schools or school districts. If you are a parent or guardian or otherwise a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. Service providers that we utilize to provision our products and services, and who may access or receive personal information to provide those services or functionality, are under contractual obligations with respect to the personal information and are covered by the service agreements with our Clients.

Parents and legal guardians can make choices regarding the personal information we store online for their children by contacting their child’s school or organization to review what personal information is being collected. Parents who experience difficulty or require additional information may contact Skill Struck directly, however, parents should start by contacting the school or organization first since the school/organization is the entity that contracted with Skill Struck for the services and authorized the information to be collected and stored. In addition, the child’s school or organization is best positioned to verify the parent’s identity and connection to the student, which would be necessary before Skill Struck could respond to this type of request.

Upon written request from the school or organization, or from a confirmed parent or legal guardian (as noted above), Skill Struck will provide an inventory of the personal information it holds on their behalf and take reasonable steps to allow such persons to review their information for the purposes of correction or removal, subject to the limitations (including disproportionate burdens) set forth in the US Department of Commerce's Privacy Shield Principles. We will respond to all inquiries within 30 days of receipt. Please see the contact information provided at the end of this privacy policy to contact us.

Sharing Information with Third Parties

Skill Struck does not release personal information collected or received in the Site to any unrelated third parties for promotional purposes. We may, however, share aggregated product usage data with unrelated third parties, and share personal information only as described below:

Affiliated Businesses

We may disclose information (including personal information) collected from our Site with our local authorized Skill Struck representatives for sales and support purposes. We require these representatives to comply with this policy. Skill Struck will not share your contact information with other businesses except service providers and successors, as described below.

Service Providers

We may share your information with our service providers—that is, organizations providing services to support Skill Struck functions, such as our hosting services provider, mail and email processing providers, payment processing providers, and research and support providers. All such service providers are bound by contract to refrain from using the personal information we collect from you for any purpose other than providing the specified service to Skill Struck.

Successors

In the event Skill Struck is sold to a new owner, whether by merger, stock sale, asset sale or other means, we retain the right to transfer personal information to the new owner, provided we notify you this is occurring (which may be by posting on our websites) and the new owner agrees to respect the privacy policy in effect with respect to this personal data.

Laws and Legal Rights

We also may release personal information at the request of law enforcement authorities, when ordered to do so where a formal request has been made such as in a court order, subpoena or judicial proceeding by a court or similar legal process, or when we have the right to do so and believe it is necessary to assert or protect our legal or intellectual property rights, or in protecting the physical safety of our employees, users and the general public.

Fraud Prevention

In order to protect our customers, users and ourselves from fraud or theft, we may provide personal information to law enforcement agencies or to other organizations that agree to respect the privacy policy in effect with respect to this personal data.

Information Security

Skill Struck utilizes standard security measures, such as firewall, limited access, and SSL encryption technology, designed to help protect against loss, misuse, and alteration of user information collected by Skill Struck during its transmission. Access to your data is controlled by both physical and logical controls. Only selected members of the Skill Struck staff can access the raw data or backups. All backups stored offsite are encrypted and deleted when they become obsolete. Our production systems are housed in a tier-1 hosting facility that is monitored 24 hours a day, 7 days a week. Access to these systems requires prior written approval from Skill Struck management and all access is logged and monitored. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Site, you can contact us at support@skillstruck.com.

Cookies and other Tracking Technologies

Skill Struck and our service providers use cookies or similar technologies. These technologies are used in administering the Site and maintaining user progress within the program, analyzing trends and user movements within the Site, and to gather general usage and demographic information about our user base as a whole. We may receive reports associated with these technologies by these providers on an individual as well as aggregated basis.

As is true of most websites, we gather certain information automatically and store it in log files. This information may include IP addresses, browser types, referring/exit pages, operating systems, date and time stamps, and “clickstream” data. We do not link this automatically collected data to other information we collect about you.

Teacher and student activity is stored in a relational database and used for reporting and analysis, including student user progress monitoring for teachers and administrators, and aiding Skill Struck in trend analysis and providing customer support.

We do not give log file information or student usage information to third parties, except (i) those service providers engaged to support and assist in administering our Site, or (ii) in a sanitized form disassociated from your IP address or other personal data, or (iii) as authorized or directed by the school.

Enforcement

Skill Struck periodically verifies that this privacy policy properly describes the information we collect and how we use it, and that we act in compliance with this policy. Please contact us if you have questions or concerns using the contact information below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this policy.

With respect to any complaints relating to this policy that cannot be resolved through our internal procedures, we will cooperate with appropriate regulatory authorities to resolve such complaints.

Testimonials

From time to time we may display personal testimonials of satisfied customers on our Site in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update your testimonial of request that it be removed, you can contact us at support@skillstruck.com.

Social Media Widgets

Our Site includes Social Media Features and Widgets, such as the Facebook button and Twitter button. These features may collect certain information, such as your IP address or which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with any of these features is governed by the privacy policy of the company providing it.

Changes to This Privacy Policy

Last updated: May 2020

We may amend this privacy policy at any time. If we make material changes in the way we collect, use, and/or share your personal information, we will notify you by prominently posting notice of the changes on the Site covered by this privacy policy for thirty (30) calendar days prior to the implementation of the material change and provide instructions on how to remove your information prior to the changes taking effect.

Your Choices and Access to Your Information

Skill Struck offers those who provide personal information the opportunity to withdraw consent with respect to the information they submitted at any time ("opt-out"), in which case such personal information will not be further processed. Our email programs allow you to choose to receive or stop receiving communications from us. We honor a “once out – always out” policy. Each secondary email we send to our recipients contains ‘Unsubscribe’ instructions. Once you opt out, you are opted out of that type of communication until we are explicitly told in writing that you want to opt back in. You may opt out of email programs at any time by following the Unsubscribe instructions provided in the email you receive from us. Upon request Skill Struck will provide you with information about whether we hold any of your personal information. For the Site and mobile application, you may access your personal information for the purposes of correcting, amending, or deleting it by logging into your account and reviewing and selecting your profile preferences. You may also contact us to request assistance for which we will respond to within a reasonable timeframe and as may be required by law.

Skill Struck acknowledges that you have the right to access your personal information. If you are a student or other end user receiving access to Skill Struck through a school or organization, you will need to contact the administrator that submitted your personal information to us, and we will support them as needed in responding to your request to access, change or delete the personal information submitted and associated with your account. Requests will be addressed within a reasonable timeframe and as may be required by law.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Contact Us

If you have questions or concerns regarding your privacy, please contact us as follows:

Privacy Officer
Skill Struck LLC
1555 N. Freedom Blvd. 200 W
Provo, UT 84604
E-mail: support@skillstruck.com
Telephone: (949) 491-2793

This privacy policy explains what information Skill Struck, LLC, collects on our services and how we use and share that information. By using our services, you accept the practices described in this privacy policy.

If we change this privacy policy, we will include the date when we last updated it. If we deem the changes significant, we may notify you either by prominently posting a notice prior to implementing the change or by sending you a notification directly. We encourage you to review this policy periodically.

What information do we collect?

We may collect data that alone or together with other data would reasonably allow us to determine the identity of a specific person (“Personal Information”). We may also collect data that, standing alone, tells us something about a person but does not reasonably allow us to identify a specific person (“Non-Identifiable Information”). We also may gather and store site-visitation data. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. The term “information” includes all of the above data.

How do we collect the information?

We use different methods to collect information, including:

  • When you provide information directly to us;
  • When you use our services; and
  • When third parties share information with us.

To collect information automatically, we may use cookies, web beacons, third-party services, or other data-collection tools.

We may use hashtags, keys, unique identifiers, or other encryption devices to anonymize Personal Information. We treat this modified Personal Information as Non-Identifiable Information for purposes of this privacy policy.

How will we use the information we collect?

We solely determine our purposes for collecting your information. Some of these purposes may include:

  • Improving, debugging, and maintaining our products and services;
  • Studying and personalizing user experiences;
  • Fulfilling legal requirements;
  • Conducting business analysis and research;
  • Conducting marketing campaigns;
  • Addressing fraud, security, or technical issues;
  • Personalizing your updates, upgrades, enhancements, and other relevant offers; and
  • Otherwise managing our business.

We also may use your Personal Information to:

  • Process payments for services;
  • Enroll you in select discounts, rebates, promotions, or other programs; and
  • Transfer to a buyer or other successor in the event of a corporate sale, merger, or similar event.

We reserve the right to use any student’s image or likeness, as well as any content your student may produce, whether through photographs, adaptations, displays, exhibits, or otherwise, in all markets, media, or technology now or later known. Any image or likeness will be used solely for the promotion, marketing, public education, and fundraising activities of Skill Struck, LLC, and will not include the name of any individuals therein unless otherwise agreed in writing by you. Neither you nor your child will receive any compensation for the use.

With whom do we share the information?

We may share your information with:

  • Government bodies or law enforcement agencies to comply with a court order or other legal process;
  • Third parties to enforce or defend our legal rights, including our terms and conditions, and investigate violations thereof;
  • Our service providers, business partners, or affiliates, if the entity first agrees to adhere to this privacy policy;
  • Third-party purchasers or sellers; and
  • Any other persons or entities as otherwise provided for by law.

If we share your Personal Information with third-party purchasers or sellers, we will first anonymize your Personal Information.

How do we protect the information?

While we at our sole discretion may choose to maintain methods to secure your information, we do not guarantee that your Personal Information, Non-Identifiable Information, or other data or communications will be secure. You are solely responsible for carefully handling and disclosing your Personal Information. Please refer to the Federal Trade Commission's website for more information.

We also do not guarantee that any third-party services you may access from our services provide safeguards to your privacy. We encourage you to read the privacy statements of the third-party products and services you use.

What else should I know?

Your choices about how we use or collect your information. You can always choose not to provide us with certain information, but not providing that information may result in you being unable to use or purchase our services. If you have provided certain Personal Information to us, such as addresses, credit card numbers, or phone numbers, you may review and update this information at any time by going to your account settings page.

You may control information collected by cookies by updating your browser settings. If you do so, some of our services may not function properly. We may choose not to recognize or respond to any Do Not Track signals.

You may opt out from receiving commercial or promotional emails from us either by visiting your account settings page or by clicking the opt-out link in the emails we send you.

You can choose to opt out of certain data collections and usage:

  • To opt out of cookies that may be set by third-party data or advertising partners, please visit http://www.aboutads.info/choices/
  • To opt out of our data collection for targeted advertising, click here. You must opt out separately on all devices you use. Later deleting your cookies may require you to go through the opt-out process again.
  • To opt out of third-party mobile application ad tracking and analytics, click here.

Retention: After we deem your information no longer relevant to our purposes, we will take steps to have it deleted, aggregated, or made anonymous.

Contact Us

If you have any questions, comments, or concerns about this privacy policy, please email us at email us at support@skillstruck.com

COPPA Policy

Skill Struck, LLC (“Skill Struck”) values the privacy of children and of all of its users. This COPPA Privacy Policy (“COPPA Policy”) is designed to comply with the Children’s Online Privacy Protection Act (“COPPA”) and contains important information about how we collect, use, and disclose the personal information we collect from children under thirteen years old who take courses provided through our website, https://www.skillstruck.com/, (the “Site”) and the services, such as courses, provided on our Site (the “Services”). Skill Struck provides online courses in software coding and web development. Skill Struck may partner with foundations, non-profits, or for-profit entities to make these courses available to schools and other educational organizations. In the course of providing these Services, Skill Struck may come into contact with information, including personal information, from the course taker. Some, but not all, courses are directed towards children under 13. This COPPA Privacy Policy applies to the information we collect from children under 13 through Skill Struck courses directed towards children. Skill Struck will handle children’s personal information as described in this COPPA Policy. Any personal information we collect about other users (e.g., teens and adults) will be treated in accordance with the Skill Struck Privacy Policy (“Privacy Policy”). The use of our Site and any dispute over privacy, is subject to this COPPA Policy, the Privacy Policy, and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. Our Terms of Service and Privacy Policy are incorporated by reference into this COPPA Policy.

Who Will Collect Information About Children?

Skill Struck operates the Site and Services and will collect children’s personal information as described in this COPPA Policy and our Privacy Policy. We can be contacted at:

1555 N. Freedom Blvd.
Provo, Utah 84604
(949) 491-2793
support@skillstruck.com

Even if Skill Struck courses are offered in conjunction with an outside partner, the partner will not receive any individual personal information from users of the Site, including children. Skill Struck may provide partners with aggregate or de-identified information about users.

What Information Do We Collect About Children and Why?

As described in further detail below, we collect some personal information from children so that we can track their progress through our courses. Data is retained for education purposes only.

How Is Information Collected?

We may collect information about children directly from children, as well as automatically through a child’s use of our Site and Services. We will not require a child to disclose more information than is reasonably necessary to use our Services. A copy of a notice of our privacy practices as posted on the learning platform.

What Information Do We Collect Directly?

From children under 13, we utilize the date of birth to verify the child’s age but do not store the age. We only store whether or not the child is under 13. If a child is under 13, we collect the child’s first name, and last initial. We do not ask children for their full last name. Children must create their own usernames, but are not required to provide an email. We only use user name and email address (if provided) to track a child’s progress in our courses or to reset passwords; we will not contact a child using his or her email address or username. We may also collect additional demographic information (such as race and gender) from children; however, we do not associate this with the child’s name or other personal information and we use it only to compile aggregate and de-identified information about participants in our courses. Parents may ask us to stop collecting personal information from their child by emailing us at support@skillstruck.com. However, in such cases the child will not be able to take or complete our courses. If a parent directs us to stop collecting and using a child’s personal information, we must disable his or her use of our courses to ensure that no information is collected.

What Information Do We Collect Automatically?

We may automatically collect the following information about a child’s use of our Site through cookies and other technologies: domain name; browser type and operating system; web pages viewed; links clicked; the length of time spent on our Site; the length of time our courses were taken; Google Analytics statistics; the referring URL, or the webpage that led the child to our Site; language information; device name and model; operating system type, name, and version; and activities within our Site. We may also collect IP address, device identifier or a similar unique identifier from users of our Site, including children; we only use such identifiers to support the internal operations of our Site and we do not use such identifiers to collect information about the child outside of our Site.

What Other Information Do We Collect About Children?

We collect information about children’s performance and activities on our Site, including completion of courses. This information is for internal use only and will not be disclosed to other entities; however, we do not use this information in personally identifiable form for our own commercial purposes. Before we analyze or use any activity data for our own commercial purposes, we de-identify and/or aggregate such information.

How Do We Use Children’s Information?

We use personal information collected from children for the following purposes:

  1. To provide our Services; and
  2. To respond to customer service and technical support issues and requests.

We de-identify and/or aggregate the information we collect from children under 13 before we use it for any other purposes, as noted below.

Unique Identifiers. We only collect and use unique identifiers, such as IP addresses, as necessary to operate our Site or Services, including to maintain or analyze their functioning; perform network communications; authenticate users or personalize content; and protect the security or integrity of users and our Site and Services. We never use unique identifiers to track users across third-party apps or websites.

Aggregate or De-identified Information. We may use aggregate or de-identified information about children for research, analysis, and similar purposes. When we do so, we strip out names, e-mail, contact information, and other personal identifiers. We may use aggregate or de-identified information for the following purposes:

  1. To better understand how users access and use our Site and Services;
  2. To improve our Site and Services and respond to user desires and preferences; and
  3. To conduct research or analysis, including research and analysis by third parties.
How Do We Share Children’s Information?

We do not sell children’s personal information, and a child may not make his or her personal information public through our services without their parents approval. In general, we may disclose the personal information that we collect about children to provide our Services, to comply with the law, and to protect Skill Struck and other users of our Services. For example, we may share children’s personal information as follows:

  1. Service Providers. We may disclose the information we collect from children to third-party vendors, service providers, contractors, or agents who perform functions on our behalf.
  2. Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the personal information we have collected from our users to the other company.
  3. In Response to Legal Process. We also may disclose the personal information we collect in order to comply with the law, a judicial proceeding, court order, subpoena, or other legal process.
  4. To Protect Us and Others. We also may disclose the personal information we collect where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service, Privacy Policy, or this COPPA Policy, or as evidence in litigation in which Skill Struck is involved.
  5. With Parents. Parents may request information about the information we have collected from their child by contacting us at support@skillstruck.com.
  6. Aggregate adn De-Identified Information. We may also use and share aggregate or de-identified information about users with third parties for marketing, research, or similar purposes.
What Are Your Rights to Review, Delete, and Control Our Use of Children’s Personal Information?

Parents have a right to review the information we have collected about their children and students, respectively, and to delete it, and to tell us to stop using it. To exercise these rights, you may contact us at support@skillstruck.com. You will be required to authenticate yourself as the child’s parent to receive information about that child. Please note that copies of information may remain in cached or archived form on our systems after you request us to delete it.

How Will We Make Changes to This COPPA Policy

This COPPA Policy is current as of the Effective Date set forth above. We may change this COPPA Policy from time to time, so please be sure to check back periodically. We will post any changes to this COPPA Policy on our Site, at skillstruck.com. If we make any changes to this COPPA Policy that materially affect our practices with regard to the personal information we have previously collected from a child, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.