Each product or resource, together with challenge websites for national and regional events which may use or integrate with some of the aforementioned websites (the Site) is owned and operated by 3P Learning Ltd (and/or our subsidiaries or licensors) (collectively, ‘3P Learning’ or ‘us’ or ‘we’).
This policy addresses the following topics: (click to jump to the relevant content)
Collectively, this legislation includes, without limitation:
The United States Children’s Online Privacy Protection Act (“COPPA”) and Rule as administered by the Federal Trade Commission
The United States Family Educational Rights and Privacy Act (“FERPA”)
The Alberta Freedom of Information and Protection of Privacy Act
The Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”)
The Freedom of Information and Protection of Privacy Act (British Columbia) (“FIPPA”)
The Personal Information International Disclosure Protection Act (Nova Scotia) (“PIIDPA”).
The Municipal Freedom of Information and Protection of Privacy Act, Ontario (“MFIPPA”)
The Student Online Personal Information Protection Act, California (“SOPIPA”)
With effect from 25 May 2018, the EU General Data Protection Regulation (Regulation 2016/679)(“GDPR”).
What personal information we collect
We collect two main types of information – personal information and anonymous information – and we may use personal and anonymous information to create aggregate information (which does not identify and cannot reasonably be used to identify an individual student).
We collect the following categories of personal information:
As a customer, prospective customer, or user of our Site, we may collect information such as your name, contact information including phone number and email address, school name, class year and country or state of residence or school.
We may also collect details of other interactions that you have with us, together with any other information that you choose to provide us with, for example, through your interactions with our customer and technical support teams.
We do not however collect any unnecessary personal information from Registrants (for instance, information about religious beliefs).
It is impractical in most circumstances for you to remain anonymous, and we may not be able to interact with you, provide access to the Site, or answer your enquiry if we are not able to identify you or collect your personal information.
In the case of school/educational institution customers (School Customer), we seek consent from the School Customer to be provided with Registrant information for and on behalf of that student or teacher.
In the case of individual / home subscriptions (Home Customers) we seek consent from the Home Customer at the time of purchasing and registering the product to use the information collected. Where the Home Customer is a student who is a minor, we ask that permission be sought by that student’s parent / legal guardian.
Registrants who do not give this consent (or do not have this consent provided on their behalf) cannot provide us with their personal information and cannot use the Site. You can however withdraw your consent at any time.
What we will do with your information
The information collected from Registrants, customers or prospective customers may be used for the following purposes:
to provide access to our products and services;
to manage prospective purchases, purchased subscriptions and payments including to provide quotes or offers for, and updates about, our products and services;
to send a confirmation notice to the Registrant of the registration;
to administer and manage accounts, including password resetting, responding to questions raised by Registrants, to contact the Registrant about any problems with the Registrant’s account or conduct on the Site;
to send out a 3P Learning newsletter or emails about the Site including information about current events, changes, improvements, upgrades, new product development and rules of the Site;
to publish the names of winners and high performers on the Site or in the 3P Learning newsletter and to provide results data for each Registrant or school class;
to send prizes or certificates for participation and performance on the Site;
for administrative, planning, product or service development, staff training, quality control and research purposes relating to our products and services;
for marketing purposes, but only where we have express or implied consent to contact someone or we are otherwise permitted by law to do so. Registrants may also opt out at any time by following the specific opt out instructions within the communications that we send.
Hall of Fame leaderboards: 3P Learning strives to provide a highly engaging Site for students. Given students have indicated their strong preference for their name to be shown publicly on our Sites in recognition of their achievements, we allow this – but we do not allow full names (i.e. First Name and Surname) to be shown publicly. In addition, all administrative user access to any Site permits the partial (to initials only) or full anonymising (by use of a pseudonym) of names, where preferred by the user. If you have any questions about the Hall of Fame and managing the information that is disclosed, please contact us.
The Site does not provide students with any means to communicate directly with each other. There are no chat rooms connected with the learning resources.
Access to, and use of customer feedback forums, such as 3P Learning Uservoice, is designed for use by parents, teachers and other contributors who are not legally minors.
What we will not do with your personal information
3P Learning will keep your personal information confidential and not sell or disclose your information to advertisers or any external third parties, unless:
we believe, in good faith, that we are required to share your information with a third party such as a regulator or court in order to comply with law, regulation, legal process, court order or subpoena;
to enforce our Terms & Conditions or the terms of the licence granted to access and use the Site;
the disclosure is to a third party that acts on our behalf, powers certain aspects of our Sites or processes data on our behalf, such as a distributor of our products and services, the licensor or owner of a product or resource that we distribute, or to a contracted service provider;
to protect the safety and security of our Registrants and our Site.
Generally we will only use your information within 3P Learning, however, sometimes we provide data on results to government education departments, peak bodies managing or representing schools, or schools themselves, especially in the case of School Customers, who use the features of our products (such as performance reporting tools) for educational / teaching purposes. We will require these third parties to comply strictly with our instructions, use the information only for legitimate educational interests and not for any commercial purposes.
We do not sell data to advertisers (whether personal, anonymous or aggregated). We do not use data to engage in targeted advertising to children and we do not create or build personal profiles of students other than for the purpose of supporting authorized educational/school purposes or as otherwise specifically authorized by a parent/student or school/educational institution customer.
How we collect and process your information
We may collect your personal information in a number of ways, including:
directly from you (unless it is unreasonable or impracticable to do so);
from our school / educational institution customers (e.g. teachers or school administrators that purchase access to our Site for their students and teachers); or
from third parties such as our distributors (resellers and sales agents).
In order to register for 3P Learning resources, students registering individually and not part of a school, must give their consent at the time of registration to provide us with their personal information such as their name, age and email address (or if they are under 13 years of age, or legally a minor in their relevant location, a parent or guardian must consent on their behalf).
Alternatively, parents registering on behalf of their child(ren), must give their consent at the time of registration to provide us with information about them and their child(ren).
Teachers or administrators registering for their class or school must give their consent at the time of registration to provide us with their own name, class name, school name and their email address, as well as the names of their students.
How long we hold your information
We retain the personal information that we collect from and about our Registrants for as long as it is needed to provide access to the Site or to manage that Registrant’s account. We take reasonable steps to delete the personal information we collect if your registration to use our Site lapses and you opt out of receiving further communications from us, or if you ask us to delete your information. We may however retain and use personal information as necessary to comply with our legal and regulatory obligations, to resolve disputes and to enforce our agreements, and we may retain and use anonymous and aggregated information for performance reporting, benchmarking and analytic purposes and for product and service improvement.
Registrants can request that their personal information be deleted by contacting the 3P Learning Data Protection and Privacy Officer (contact details below).
Updating and accessing your personal information
Registrants have a right to request a copy of the personal information we hold about them, and Registrants can also update their personal information at any time, in each case by contacting 3P Learning.
If you wish to receive a copy of this information or to update or correct information held about you, please address your request to the Privacy and Data Protection Officer (contact details below). We will endeavour to deal with your request promptly.
Keeping your personal information secure
3P Learning is committed to information security. We will use all reasonable endeavours to keep the personal information we collect and use in a secure environment, and we have implemented appropriate technical, administrative and physical security measures that are designed to protect personal information from unauthorised access, disclosure, use and modification. As part of our privacy compliance processes we review these security procedures to consider appropriate new technology and methods and engage independent third parties to review and audit aspects of our information security.
As part of a major project to evolve and future-proof our infrastructure, in August 2015 we began a major new partnership with Microsoft. In addition to being able to offer a greater range of support for the latest mobile devices, our two flagship learning platforms – Mathletics and Spellodrome – were transitioned fully to Microsoft’s industry-leading Azure cloud platform. This marked a new era of data capacity, storage and security for our data. The Microsoft Azure platform delivers an enterprise-level cloud. Microsoft’s industry-leading approaches to data security were central to our decision to relocate our key platforms within the environment. All data is stored securely within an isolated network and database infrastructure. It is not accessible to any other person or account within the public cloud. Access is strictly limited to only specific elements of the 3P Learning resources.
Data transfers, storage and processing globally
Registrants’ personal information is uploaded to and stored on servers that are maintained by third parties that comply with strict contractual privacy obligations. These servers are located in the East US 2 region within Microsoft Azure (https://azure.microsoft.com/en-au/regions) and this location was chosen as it is one of the most advanced Azure regions.
As we operate globally, we may on occasion allow your personal information to be accessed in countries other than your own location. We may do this where data is accessed:
by companies within the 3P Group (i.e. 3P Learning Limited and its subsidiaries) for operational, administrative and compliance purposes;
by our sales, operational or global customer support teams (primarily, although not exclusively, located in Australia, the United Kingdom, the USA and Canada); or
by one of our licensors (who owns, develops and hosts a particular product) or distributors (sales agents or resellers) who requires the information to set up, service or manage a customer account;
where a copy is sent to the Registrant itself at their request.
By consenting to the collection and use of their personal information, Registrants’ consent to their personal information being transferred and stored in this manner.
Registrants in Canada, please refer to our additional information about Canadian users. In accordance with various Canadian provinces’ privacy legislations applicable to many of our school customers we do not store Canadian students’ personal identifiable information outside of Canada. All the data pertaining to a student’s activity within the platform (non-identifiable data) is stored in the East US 2 region of Microsoft Azure. Access to the data is restricted only to the users themselves – and then only via our own applications. It is strictly inaccessible outside of the environment of a 3P Learning resource account and each user only has access to their own data (or in the case of a school’s administrator or IT technician, the data within the school’s wider account).
In the APAC region, we may record, with your express consent, customer service calls for quality and staff training purposes. If, with your consent, we record a customer service telephone call, that recording will be stored in data centres located in Australia and deleted when no longer required.
Anonymous or aggregated information
In addition to personal information and results data, 3P Learning also collects anonymous information about Registrants and the activities of Registrants on the Site. Anonymous information is information that is not linked to the name or identity of a user. This information is used for educational performance reporting and analytics and to assist us in enhancing the learning resources. The information remains anonymous at all times.
3P Learning utilises third-party providers to power certain elements of the Company’s online marketing and advertising. These service providers collect data about your activities that does not personally or directly identify you when you visit our website or the websites and online services where we display advertisements (i.e. publishers). This information may include the content you view, the date and time that you view this content, the products you purchase, or your location information associated with your IP address. We use the information we and these third party service providers collect to serve you more relevant advertisements regarding 3P Learning resources (referred to as “retargeting”). We collect information about where you saw the ads and what ads you clicked on. This is data that does not personally or directly identify you.
When agreeing to the Term and Conditions, Registrants grant us the right to use this anonymous information for our own purposes, such as the preparation of statistical reports or to improve and change the content of our products.
Keep track of whether you are signed in or have previously signed in so that we can display all the features that are available to you;
Remember your settings on the pages you visit, so that we can display your preferred content the next time you visit;
Customise the function and appearance of the pages you visit based on information relating to your account; for example, in order to default you to a particular grade level, or to remember customised settings for a report.
If you are not satisfied with the response you receive, you may have the right to contact the regulator responsible for privacy in your home country.
More privacy information
For more information on privacy legislation and guidelines in your local jurisdiction please contact your relevant local authorities.
3P Learning is committed to providing access to our resources through an environment that is compliant with all national and provincial privacy requirements applicable to us, and those requirements that apply to our School Customers across Canada.
We sometimes transfer school information to others, including to affiliated entities or unrelated companies (“service providers”), that carry out certain functions on our behalf such as order fulfillment, accounts receivable and data processing. Student names or other personally identifiable information, however, remains in Canada. In those cases where we do need to use the services of a third party, we require them not to use or disclose the information for any purpose other than as directed by 3P Learning.
We take all reasonable contractual or other measures to protect your personal information while processed or handled by these service providers. If the information is located outside Canada it will be subject to legal requirements in those foreign countries applicable to our service providers, however the information they have will not be personal in nature.
Special Information for users in the European Union
3P Learning welcomes the EU General Data Protection Regulation (GDPR) as an essential set of regulations to affirm our commitment to data protection across the European Union. We are committed to ensuring:
Personal data is processed fairly, lawfully and in a transparent manner
Personal data is collected and processed only for specified and lawful purposes
Processed data is adequate, relevant and not excessive
Processed data is accurate and, where necessary, kept up to date
Personal data is not kept longer than necessary
Personal data is processed in accordance with an individual’s rights
Personal data is kept secure
Personal data is not transferred to countries outside of the EU without adequate protection
Is personal information transferred outside of the European Union? Yes, personal information in relation to Registered Users and customers located in the EU may be transferred outside of the EU in 2 main situations:
User data is uploaded to and stored on our servers located in the USA which are maintained by Microsoft Azure. These servers are located in the East US 2 region within Microsoft Azure (https://azure.microsoft.com/en-au/regions) and this location was chosen as it is one of the most advanced Azure regions. Microsoft has extensive expertise in protecting data, championing privacy, and complying with complex regulations, and currently complies with both the EU-U.S. Privacy Shield and EU Model Clauses, thereby helping to support 3P Learning’s compliance with the requirements of the GDPR. Additional information about Microsoft’s compliance with the EU GDPR is available at https://www.microsoft.com/en-us/TrustCenter/Privacy/gdpr/default.aspx.
In most instances, personal data about our EU based customers is collected, accessed and managed by our sales, operational and customer support teams in the United Kingdom. Very occasionally however, such information may be shared with our employees in one of ours offices outside of the UK e.g. to respond to an urgent customer support query outside of normal hours or for internal reporting processes. Our main offices outside of the EU are located in Calgary, Canada and Sydney, Australia. To ensure appropriate safeguards exist in relation to such transfers, 3P Learning has implemented standard contractual clauses to cover the transfer of data relevant to EU registrants to other companies within the 3P Group that are not located in the EU.
Additionally, please refer to information about our Hall of Fame.
Specific information in relation to Reading Eggs and Mathseeds: Reading Eggs and Mathseeds are distributed in the EU by 3P Learning in partnership with Blake eLearning, the owners and operators of the Reading Eggs and Mathseeds sites (and a company incorporated in Australia). We have arrangements in place to document our respective obligations in relation to personal information collected and used about Registered Users and to ensure appropriate safeguards exist in relation to the transfer of personal information by 3P Learning outside of the EU to Blake eLearning.