Digital Products Privacy Statement

Purpose.

Wilson Language Training Corporation (“WLT,” “we,” “us,” or “our”) understands that privacy is incredibly important. The purpose of this Digital Products Privacy Statement (the “Statement”) is to inform our customers, users, and parents of users of our Digital Products regarding our current practices for protecting the privacy of student data and educator data.

Scope.

This Statement applies to our provision of Digital Products to educators and administrators (“Educators”), to schools or school districts who purchase our Digital Products on behalf of their Educators (“Schools”), and to the students whose information we may receive from Educators, who are typically students in K-12 or beyond (“Students”).

This Statement does not apply to our corporate website www.wilsonlanguage.com, which is subject to the Wilson Website Privacy Policy .

As used in this Statement:

“Customer” refers to either: (i) Schools, or; (ii) an individual Educator when they purchase Digital Products licenses directly from us for their own use (e.g., when an educator provides freelance tutoring).

“Digital Products” refers, collectively and individually, to FUN HUB®, Virtual Implementation Support (VIS), and/or those portions of Wilson Academy that are exclusively available to our paid Customers.

“Educator Data” refers to information about an Educator that, either alone or in combination with other reasonably available information, can be used to identify the Educator.

“Student Data” refers to any personally identifiable information of a Student, as that term is defined under the Family Educational Rights and Privacy Act (FERPA).

“User” refers to users of our Digital Products.

Use of our Digital Products by Students.

As required under our Digital Products Terms of Service, a Student may only use our Digital Products with the prior consent of a parent, guardian, or eligible student, or by the School acting on behalf of the Student.  When our Customer is a School, we receive Student Data pursuant to the “school official” exception under FERPA. Our Digital Products are only used in the context of School-directed learning; accordingly, Schools are not required to obtain parental consent under COPPA to provide us with Student Data described in this Statement, although many Schools choose to do so to comply with state or local requirements. When our Customer is an individual Educator, we require the Educator to obtain express parental consent prior to providing us with any Student Data. We rely on each of our Customers to provide appropriate notice to parents of their use of services like Digital Products, and for such Customers to provide consent, if necessary, and authorization for us to collect Student Data.

Information We Collect.

In connection with providing our Digital Products, we receive or collect certain Student Data and Educator Data as described below:

Student Data

We receive the following Student Data from our Customers in connection with our provision of Digital Products:

• Name
• School, grade, and Fundations® level
• Fundations assessment scores

Student Data is collected only as reasonably necessary to provide the services to our Customer.

We never collect the following information from or about Students:

• Precise geolocation data
• Biometric or health data
• Information about a person’s ethnic, racial, or national origin
• Information about a person’s religious or political beliefs

Additional Student Data for the WRS Services. As part of Wilson Academy, and only as part of the WRS Level I or WRS Level II certification process, we work with Educators to support Students who require intervention or who are otherwise having trouble learning to read. Accordingly, as part of that certification process, we additionally collect the following Student Data:

• Native language
• Handedness
• Learning disability status
• Educational history (e.g., type of reading instruction, grades retained (if applicable))
• Normative assessment scores

Student Data collected as part of WRS certification is only collected after the Educator or School has obtained express written consent from the parent or guardian of the Student.

Educator Data

We receive the following Educator Data in connection with an Educator’s use and access to the Digital Products: first and last name, school name, school district, school email address, as well as other information about the Educator’s School to provide the Educator with the services and interact with Educators regarding our products and services. Additionally, for Wilson Academy, we collect information about an Educator’s professional and educational background directly from the Educator. When an Educator participates in a Wilson Academy or VIS event, we may record those interactions.  We will provide the Educator with notice at the time that the recording will start, at which point the Educator will have the opportunity to opt out of the recording process. Please be aware that opting out may prevent the Educator from participating in the session.

Usage Data:

In connection with a User’s interactions with our Digital Products, WLT or our third-party service providers automatically collect certain data (“Usage Data”). This Usage Data includes, but is not limited to, the content that a user chooses to interact with, their responses to questions within our Digital Products, and other information about their use of and interaction with our Digital Products. As part of Usage Data, we collect a User’s IP address or other identifiers for the device. We use Usage Data to enhance and improve our product and service offerings and to provide our products and services to the User.

Cookies.

We may use and collect cookies or other technologies (“Cookies”) to collect data in order to support Users’ use and access to the Digital Products, to enhance and personalize their experience with the Digital Products, and for analytics purposes. These Cookies are not used for marketing to Students.

De-Identified Data

We may also create de-identified or aggregate data sets from the data we receive or collect (“De-identified Data”), to improve our product and service offerings, to understand how our products are being used, and for other lawful business purposes, as described in the “How We Use De-Identified Data” section below.

Inquiries

If a person reaches out to us regarding our Digital Products, we will collect and use only that additional personally identifiable information which is required to respond to the request.

How We Use Information

How we use Student Data

Our use of Student Data is consistent with applicable laws and regulations, including, without limitation, the Federal Family Educational Rights and Privacy Act (FERPA), the California Student Online Personal Information Protection Act (SOPIPA), the Children’s Online Privacy Protection Act (COPPA), and other state laws. All Student Data is handled securely, as described in the “How We Secure Your Information” section below. We do not obtain any ownership interest in Student Data.

We use Student Data for the following purposes:

• to provide our Digital Products,
• to provide related reports and services to the Customer
• for customer support
• to improve our products and services, and;
• To comply with applicable laws.

How we use Educator Data

We use Educator Data to register and maintain Educator’s account, to offer Educators the services, and to support our interactions with Educators and Schools, and to provide Educators with information concerning our programs and services, newsletters, updates, and related materials.

How We Use De-Identified Data:

We may use and share De-identified Data in a manner that complies with applicable laws, for our permitted business purposes, including for improving our product and service offerings, for customer service purposes, for research and development, and to understand how our products are being used.

Sharing of Your Information

We may share Student Data and/or Educator Data (collectively, “Customer Data”) for the following purposes:

Services. We will share Customer Data with the Customer in connection with providing the Digital Products. We do not control Educators’ use or handling of Customer Data.

Service Providers. We may share Customer Data with service providers who support our provision of the Digital Products by offering us hosting services, information technology and support (e.g., video hosting), IT security, analytics, and technologies that enhance and personalize a User’s experience with the Digital Products. These vendors do not use or collect Student Data. We evaluate the privacy and security controls of those service providers before we agree to use their services. These service providers are bound by applicable laws and contractual obligations of confidentiality and privacy to maintain Customer Data in a secure and confidential manner.

Google Analytics. As part of collecting Usage Data, we use Google Analytics to collect information about Educators’ use of our Digital Products. We do not use Google Analytics on Student-facing portions of our Digital Products, and we do not use the information we receive from Google Analytics to market to Students. Google Analytics collects information such as how often an Educator uses the Digital Products and what content they visit when they do so. Google Analytics collects only the IP address assigned to an Educator on the date the Educator uses the Digital Platform, rather than Educator name or other identifying information. We use information generated in connection with Google Analytics for IT support, to understand how our websites are used, and for marketing purposes (Unless otherwise agreed to with a Customer). Google’s ability to use and share information collected by Google Analytics about an Educator’s use of Digital Products is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Google is bound by applicable laws and contractual obligations of confidentiality and privacy to maintain Customer Data in a secure and confidential manner.

Merger or Transfer. If we sell or otherwise transfer our business, we will not transfer Customer Data unless the purchaser agrees to adhere to data-security and privacy standards no less stringent than the terms of this Statement.

Legal Compliance. We may disclose Customer Data to the extent required by law.

Additional Sharing of Educator Data:

Affiliated College or University. Some universities that offer courses in teaching or education will partner with Wilson to offer course credits to Educators in connection with completion of Wilson Academy trainings. In connection with those programs, we may share relevant Educator Data (and not Student Data) with the affiliated college or university for the purpose of confirming a particular Educator is entitled to course credits.

Wilson Certification Status. Please note that on occasion, we receive inquiries as to whether an individual Educator is Wilson® certified or has otherwise participated in our programs. Our policy is to not disclose personal information about participants in our programs. However, unless an Educator has specifically requested otherwise in writing, we will share information regarding the Wilson® credentials and the level of participation in our professional learning programs of a given Educator, if requested.

Additional Notes on Information Sharing:

• Other than the disclosures described above, we do not disclose Student Data other than as authorized and permitted by the School. 
• We do not sell Student Data, and advertisements are not placed within the Digital Products. Without limiting the foregoing, we do not transfer Student Data for any third-party marketing or targeted advertising or for any other type of behavioral advertising.
• Our Digital Products do not have any features or functionality that would permit or support the visibility of Student’s information and their interactions with other students, so there is no opportunity for cyber-bullying. Use of our Digital Products does not involve creating a profile, and there is no social component to our Digital Products.

How We Secure Your Information

In connection with providing the Digital Products, we will implement and maintain reasonable technical, administrative, and physical safeguards. For more details on our safeguards and our IT security program, please review our Information Technology Security Standards .

Your Data Rights

Choices About Your Information:

Student Data:

Parents of students, guardians, or eligible students who use our Digital Products may request to review, access, correct, delete, or remove their Student Data by contacting their School administrator. The School administrator can then verify the identity of the requesting party and notify us of the request. We will promptly comply with valid requests for correction or removal of Student Data. We cannot delete, change, or divulge any Student Data unless authorized by the Student’s School.

Educator Data:

For Educators who are provided access to the Digital Products by their Schools, the Educator may request to review, access, correct, delete, or remove their Educator Data by contacting their School administrator. We will promptly comply with valid requests for correction or removal of Educator Data. We cannot delete, change, or divulge any Educator Data unless authorized by the School. For Educators who purchase a license to Digital Products directly from us, those Customers may contact us directly to delete, correct, or remove their data, although such requests may hinder or prevent beneficial use of our Digital Products.

Links to Other Websites and Services

To give Users access to other helpful information, we may provide links to other sites. We provide these links as a convenience, and we do not endorse the content or services offered by, or the privacy policies in place on, these other sites.

Other sites to which we link may have privacy policies that differ from this Statement. We encourage Users to review the privacy policies of each site they may visit through any links. We are not responsible for the conduct or policies of these third parties.

Jurisdiction-Specific Disclosures

California. Educators who are residents of California may be entitled to certain rights with respect to personal information that we collect about them under the CCPA and CPRA, including the Right to Know, the Right to Request Deletion, the Right to Opt-Out of Personal Information Sales, the right to non-discriminatory treatment for exercising any rights, the right to initiate a private cause of action for data breaches, the right to correct inaccurate personal information, and the right to limit use and disclosure of sensitive personal information. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide our services to the Educator in question. To exercise these rights, California Educators may contact us at Legal@wilsonlanguage.com, via phone at 508.368.6678, or by U.S. mail at:

Wilson Language Training Corporation
47 Old Webster Road
Oxford, MA 01540

Canada. In connection with the Digital Products, a Customer with personal information about Canadians must provide any such data to us, or cause data to be provided to us, in strict compliance with applicable laws, which may include, but are not limited to, the Personal Information Protection and Electronic Documents Act (“PIPEDA”), Consumer Privacy Protection Act (“CPPA”), and any other federal or provincial privacy statutes. Provider is a “service provider” for purposes of the CPPA. Without limiting the foregoing, Customer must, to the extent required by applicable laws, provide appropriate notice, and obtain clear consent from, parents, guardians, and eligible students, as applicable. Such disclosure must provide appropriate transparency related to our use of and access to Customer Data from the United States, to the extent required by applicable laws. Customer will obtain consent from parents, guardians, and eligible students, as applicable, in full compliance with Section 15(1)-(5) of the CPPA. In the event that consent to use or sharing of any Customer Data is lawfully withdrawn by a person and that Customer Data has been disclosed to or shared with us in connection with the Digital Products, then Customer must promptly reach out to us to request deletion or return of such person’s personally identifiable information. Upon request, we will provide confirmation of the disposition of such Customer Data.

Updates to Our Privacy Statement

We review this Privacy Statement on an annual basis and make updates from time to time, for example, to reflect changes in the law and to provide more clarity on our practices. When we make any changes, we will provide notice by updating the “last updated” date at the top of this Privacy Statement indicating when it was last revised. For material changes to this Privacy Statement, we will seek to provide notice of such material changes in advance of the change coming into effect, by emailing the Customer point of contact we have in our records.

Please reach out to Legal@wilsonlanguage.com with any questions on this Privacy Statement.