Platform Privacy Policy

What does this Privacy Policy Cover?

Echo360 respects your privacy and is committed to protecting your Personal Data. We want to be transparent with you about how we collect and use your Personal Data in making available our Echo360 platform (the “Site”) and tell you about your privacy rights and how the law protects you.

With that in mind, this Privacy Policy is designed to describe:

This Privacy Policy aims to give you information on how Echo360 collects and processes your Personal Data through your use of this Site, including any data you may provide through this Site.

The Privacy Policy is intended to meet our duties of Transparency under the “General Data Protection Regulation” or “GDPR”.

We will post any modifications or changes to this Privacy Policy on this page.

Who we are and how to contact us.

Who we are.

Echo360, Inc. is the Data Controller (for the purposes of the GDPR) of your Personal Data (referred to as either “Echo360”, “we”, “us” or “our”in this Privacy Policy).

Our address is: 11955 Freedom Drive, 7th Floor Reston, VA, USA 20190‏.

How to contact us.

You can contact us by emailing: privacy@echo360.com.

Our Data Protection Officer

The GDPR requires us to appoint a “Data Protection Officer”, this is a person who is responsible for overseeing and advising us in relation to our compliance with the GDPR (including compliance with the practices described in this Privacy Policy). If you want to contact our Data Protection Officer directly, you can email: dpo@echo360.com.

Our EU Representative

As Echo360 does not have an establishment in the European Union, we have appointed a representative based in the United Kingdom, who you may address to raise any issues or queries you may have relating to our processing of your Personal Data and/or this Privacy Policy more generally.

Our EU representative is: Blended Learning Consultancy Ltd. Our EU representative can be contacted directly by emailing them at the following address: EURep@Echo360.com.

Your rights relating to your Personal Data.

By law you have the right to:

  • Request access to your Personal Data.This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
  • Request correction of the Personal Data that we hold about you.This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your Personal Data.This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
  • Object to processing of your Personal Data.This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground.
  • Request the restriction of processing of your Personal Data.This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.

How to exercise your rights

If you want to exercise any of the rights described above, please contact us using the contact details shown here.

Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints

If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at: privacy@echo360.com

We will reply to your complaint as soon as we can.

If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.

What Personal Data we collect.

All the Personal Data we collect about you in our capacity as a Data Controller is outlined in the table below.

Please note that in addition to the Personal Data described in the table below, we also collect certain other Personal Data about you in our capacity as a Data Processor on behalf of your school, college, university or other educational institution (“Education Provider”), in order provide the services they have contracted us to perform. Your Education Provider is the Data Controller in respect of this other Personal Data. We process this other Personal Data solely on the instructions of your Education Provider. If you contact us with regards to the processing activities we carry out on behalf of your Education Provider, we will acknowledge receipt of your query, but we will direct your query to your Education Provider.

Before you read that table, it might be useful to explain what “Personal Data” is. The GDPR definition of Personal Data can be found here. Essentially, it boils down to: information about an individual, from which that individual is either directly identified or can be identified.

It does not include ‘anonymous data’ (i.e., information where the identity of individual has been permanently removed).

However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person).

Category of Personal Data collected What this means
Statistical Viewer Usage Data This includes:

·       Technical Data: you internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Site.

·       Behavioural Data: Inferred or assumed information relating to your behaviour and interests, based on your activity on our Site.

·       Interaction Data: Information regarding your interaction with content on our Site, including, by way of example, counts of views of segments of a presentation or video, frequency of views, participation in discussion, indications of confusion, bookmarks into content, and statistical analysis of notes and discussion.

·       Identity Data: To the extent that you include other Personal Data in notes you make on the Site (e.g. your first name, surname, and any other Personal Data ) we will also process this Personal Data.

Aggregated Data

We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute considered Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. For example, we may aggregate elements of your Statistical Viewer Usage Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

No Special Categories of Personal Data

We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How we use your Personal Data and why.

We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your Personal Data for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so.

What is our “legal basis” for processing your Personal Data?

In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. The legal basis we rely on is known as “legitimate interests”. This means it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.

Category(ies) of Personal Data involved Purposes for which we process this Personal Data Our legal basis for this use of data
Statistical Viewer Usage Data ·       To provide pedagogical insights (including, for example, identify content best suited for key learning objectives, analyse student progress in class or throughout a course of study, correlate user behavior with better learning outcomes, develop predictive analytics related to learning performance, and determine key learning trends).

·       to facilitate the improvement of our current service offerings.

·       to develop new service features and reports.

·       to carry out research and to publish whitepapers (provided that no such whitepapers or publications would include your Personal Data).

Legitimate Interests. We have a legitimate interest in:

·       improving our Site and Service (e.g., improve existing service functionality, add new functionality)

·       carrying out research

·       providing services to our customers, including your Education Provider. Your Education Provider will also be a Data Controller in respect of their processing of Statistical Viewer Usage Data. Your Education Provider will have its own legal basis for such processing. This may include, for example, its legitimate interest in using Statistical Viewer Usage Data to understand student and professor performance and trends.

Personal Data from Third Party Sources

In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we may also collect certain of your Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.

Third party data source Publicly available? Category(ies) or other types of personal data received.
LMS Systems No First name, Last name, Nickname, Email address, Grade Data, country of access
Payment Processors No First name, Last name, Nickname, Email address, Grade Data, country of access
Authentication Providers No First name, Last name, Nickname, Email address, Grade Data, country of access

How we use cookies & other tracking or profiling technologies.

Cookies.

What are cookies?

We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.

We use two broad categories of cookies:

  • first party cookies, served directly by us to your computer or mobile device; and
  • third party cookies, which are served by our partners or service providers on our Site.

Cookies we use

Our Site uses the following types of cookies for the purposes set out below:

Type of cookie Purpose
Essential Cookies These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site and help the content of the pages you request to load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
Functionality Cookies These cookies allow our Site to remember choices you make when you use our Site, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Site which you can customise. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.
Analytics and Performance Cookies These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site. The information collected is aggregated and anonymous. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site.

We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies

You can find out more about how Google protects your data here: https://www.google.com/analytics/learn/privacy.html.

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.

If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Site.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com/uk

You can also prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB

Who we share your Personal Data with.

The table below describes who we share your Personal Data with, what we share and why we share it.

Recipients Category(ies) of Personal Data we share. Why we share it Location(s)
Our Affiliates Statistical Viewer Usage Data Our affiliates help us provide our service and help manage our customer relationships (including providing customer support, customer liaison etc). ·       The United States

·       Australia

Service Providers Statistical Viewer Usage Data Our service providers provide us with IT and system administration services and customer relationship management services. ·       The United States

·       Australia

Your Education Provider Statistical Viewer Usage Data For the purpose of providing our services to your Education Provider for their own internal business purposes. In using this Personal Data, your Education Provider will also be acting as a Data Controller The location in which your Education Provider is based, which may include the United States, Canada, Australia or the EU

 

Data transfers

As you can see from the above, we share your Personal Data both with our affiliated companies within the Echo360 Group and certain external third parties who are based outside the European Economic Area (“Europe”). Any processing of your Personal Data by these parties will involve the processing of your Personal Data outside of Europe.

Echo360 complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the EU to the United States. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall take precedence. To learn more about the Privacy Shield program, the Privacy Shield Principles and to view our certification, please visit www.privacyshield.gov.

As described in the Privacy Shield Principles, Echo360 is accountable for Personal Data that it receives and subsequently transfers to third parties. If third parties that process Personal Data on our behalf do so in a manner that does not comply with the Privacy Shield Principles, we are accountable, unless we prove that we are not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, Echo360 commits to resolve complaints about our collection or use of your Personal Data. EU individuals with inquiries or complaints regarding this Privacy Policy should first contact us at:

Echo360, Incorporated
Privacy Officer/Customer Information
11955 Freedom Drive, Suite 700
Reston, VA 20190
USA
privacy@echo360.com

Echo360 has further committed to refer unresolved Privacy Shield complaints to AAA an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit at http://go.adr.org/privacyshield.html for more information or to file a complaint. The services of AAA are provided at no cost to you.

As further explained in the Privacy Shield Principles, binding arbitration before a Privacy Shield Panel will also be made available to you in order to address residual complaints not resolved by any other means. Echo360 is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

How we keep your Personal Data secure.

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.

We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.

How long we store your Personal Data.

We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above, unless a longer retention period is required by law (for example for regulatory purposes). The table below shows our standard retention practices:

Category of Personal Data Retention period
Statistical Viewer Usage Data For six (6) months after Echo’s agreement with your Education Provider expires.

Our policy on children.

This Site is not intended for children under the age of 16 and we do not knowingly collect data relating to such children.

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your Personal Data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every site you visit.