IntraData Privacy Policy with regard to ReadnQuiz

IntraData is committed to the highest standards of protection for student data and personally identifiable information (“PII”) at all times. In addition to handling personal data as outlined in this Privacy Policy, we also comply with the Family Educational Rights and Privacy Act (“FERPA”), a federal statute that regulates the privacy of student records by Educational Agencies that receive financial assistance from the U.S. Department of Education, along with the Children’s Online Privacy Protection Act and applicable state laws. The Privacy Policy pertains to ReadnQuiz, an educational product by IntraData, Inc. (“IntraData”.)

Personally Identifiable, De-Identified & Aggregate Information

PII is information that can be directly utilized to identify a specific individual, or linked data elements that when combined may be used to indirectly identify a specific individual. We consider the following to be examples of PII available in ReadnQuiz: a student’s first and last name, email address (which is not required by ReadnQuiz), student identification number (which is not required by ReadnQuiz) and certain other information to the extent they are linked and/or coupled with PII. De-identified information is information that does not identify a specific individual and cannot reasonably be used to identify a specific individual either alone or in combination with other de-identified data. Aggregate information is data combined into de-identified groups. While we utilize these definitions for your convenience, we comply with the standardized definitions as provided in FERPA.

Data Ownership

Henceforth, “data” is defined as all PII, student quiz results and student feedback on questions. It excludes quiz questions submitted to ReadnQuiz, which, as per the Terms of Service, are owned by IntraData.

All data remains the property of and is solely owned, and thereby controlled, by you. You grant IntraData a non-exclusive, royalty free license, to use equipment, software, your data or other material of yours solely for the purpose of providing, maintaining, and supporting you. However, IntraData may use and distribute the data for any lawful purpose outside the scope of the Agreement, provided always that such data must be de-identified. Upon termination of your contract with IntraData, all of your data is either returned to you or destroyed.

What Information Is Collected

IntraData, in its role as a vendor to educational agencies and institutions, both public and private entities (“Educational Agencies”), receives disclosures from the Educational Agencies, which include the PII contained in student records. Only information that is needed for IntraData to perform services, which are outsourced to IntraData by the Educational Agencies, is disclosed to IntraData. These disclosures are authorized by FERPA.

Information Sharing, Disclosure & Retention

Information collected through ReadnQuiz may be supplied to affiliates of IntraData, and other companies and organizations who perform work for us under contract or sell products or services that complement our products and services. Information is only supplied to other companies and organizations at your request (i.e., you purchase a third-party supplemental product to augment ReadnQuiz). Upon completion of the terms of the contract (i.e., termination by you or IntraData), IntraData destroys any copy of your data that IntraData had in its possession at the time of termination. This will also terminate access through ReadnQuiz for all authorized companies and organizations as well.

We also may disclose PII in the following situations: (a) in response to a subpoena, court order or legal process, to the extent permitted and required by law; (b) to protect user security or the security of other persons, consistent with applicable laws; (c) in connection with a sale, joint venture or other transfer to some or all of the assets of IntraData; or (d) in order to enforce the ReadnQuiz Terms of Service. We otherwise exercise commercially reasonable care to not otherwise share or disclose the names of users or any PII with third parties, except with the prior approval of the user. This includes, but is not limited to, IntraData never selling your data to third-party marketing companies.

In the highly unlikely event that there is an unauthorized disclosure of PII data relating to a student, notwithstanding the above exceptions, IntraData will promptly inform you of the following information, if reasonably available to IntraData: (1) what information was disclosed; (2) the student(s) affected by the disclosure; and (3) IntraData’s course of action to mitigate any further disclosure.

Access & Correcting Erroneous Data

Under FERPA, a school must provide a parent with an opportunity to inspect and review his or her child’s education records within 45 days following its receipt of a request. A school is required to provide a parent with copies of education records, or make other arrangements, if a failure to do so would effectively prevent the parent from obtaining access to the records.

Within your sole discretion, you can allow parents, legal guardians, and eligible students, who are over eighteen years of age, to view and/or download student’s data through ReadnQuiz. In the event there is any erroneous data contained in the student record, IntraData advises parents, legal guardians, and eligible students to contact you to update the erroneous data.

Data Privacy Enforcement

When you purchase ReadnQuiz, IntraData provides you with IntraData’s suggested best practice guidelines. For example, ReadnQuiz makes recommendations pertaining to creating unique and/or complex passwords that enhance the security of your accounts. These guidelines are formulated in an attempt to ensure ReadnQuiz is utilized in a manner consistent with FERPA and other potentially applicable state and federal laws. In the event that you determine IntraData’s best practice guidelines are not suitable for your customized use of ReadnQuiz, you shall ensure that the alternative practices utilized are of equal or better standards in order to protect your data, as required by law.

IntraData trains its employees that access to and/or customer support for your data will adhere to strict data access and destruction policies. Moreover, even when providing support for ReadnQuiz, you have the exclusive control in granting IntraData employees access. IntraData will never attempt to circumvent your control in this regard.

Additional Information

This Privacy Policy or any part thereof may be revised from time to time to remain in compliance with evolving state and federal laws and regulations, and therefore you should check the Terms of Service (including this Privacy Policy) periodically. Revisions are effective upon posting and your continued use of ReadnQuiz following the posting of revisions to the Terms of Service (including this Privacy Policy) will indicate your acceptance of such revisions. If you have any questions concerning the Terms of Service (including this Privacy Policy), please Contact Us.

Contact Us

If you have any questions or concerns about your privacy or this Privacy Policy, please contact IntraData at 877.256.8917 or info@intradata.com.

Incorporations by State

Pursuant to state law, the following state specific language is hereby incorporated into this Privacy Policy; provided that IntraData is providing and/or offering you ReadnQuiz in one of the following states:

California – IntraData will not use your data for any purpose beyond the indicated purposes in the Terms of Service, which includes this Privacy Policy. This includes, but is not limited to, IntraData’s policy to never use PII from a Pupil’s Records to engage in targeted advertising.

Colorado – IntraData will not use your data for any purpose beyond the indicated purposes in the Terms of Service, which includes this Privacy Policy. Only the IntraData employees that have a legitimate interest in accessing your data will be granted authorization by IntraData.

Connecticut – IntraData will not use your data for any purpose beyond the indicated purposes in the Terms of Service, which includes this Privacy Policy. This includes, but is not limited to, IntraData’s policy to never use any student’s PII to engage in targeted advertising. IntraData also avers to utilize industry standard security, or better, to ensure the protection of said student PII. Connecticut law shall govern this agreement between you and IntraData. All terms herein are defined in accordance with Public Act No. 16-189, and in case of any ambiguity or conflict between the terms herein and Public Act No. 16-189, then Public Act No. 16-189 will govern.

Florida – IntraData will provide notification of a security breach pursuant to requirements as mandated in the Florida Information Protection Act of 2014.

Maryland – IntraData will not use Covered Information to engage in targeted advertising.

New York – In accordance with New York Education Law § 2-d, IntraData will comply with and attach to your contract the Parents’ Bill of Rights for Data Privacy and Security, as applicable.

Pennsylvania – IntraData will provide notification of a security breach pursuant to the requirements of Pennsylvania’s Breach of Personal Information Notification Act.

Washington – IntraData will provide notice before making material changes to this Privacy Policy.