Last updated: December 15th, 2023
This Privacy Policy describes how FIRSTDRAFT LLC (the “Site”, “we”, “us”, or “our”) collects, uses, and discloses your personal information when you visit, use our services, or otherwise communicate with us (collectively, the “Services”). For purposes of this Privacy Policy, “you” and “your” means you as the user of the Services, whether you are a registered user, website visitor, or another individual whose information we have collected pursuant to this Privacy Policy. For purposes of this Privacy Policy, “personal information” and “personally identifiable information (PII)” have the same meaning.
Please read this Privacy Policy carefully. By using and accessing any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use or access any of the Services.
We may update this Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy on the Site, update the “Last updated” date and take any other steps required by applicable law.
We will not violate the privacy rights of students as established by the federal Family Educational Rights and Privacy Act (FERPA) at 20 U.S.C. 1232g and 34 C.F.R. part 99, which is a federal law that protects the privacy of student education records, primarily by limiting the use and disclosure of personal information, also known as personally identifiable information (PII). To view our FERPA Statement, please visit: https://learn.firstdraft.com/ferpa_statement.
To provide the Services, we collect and have collected over the past 12 months personal information about you from a variety of sources, as set out below. The information that we collect and use varies depending on how you interact with us.
In addition to the specific uses set out below, we may use information we collect about you to communicate with you, provide the Services, comply with any applicable legal obligations, enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.
The types of personal information we obtain about you depends on how you interact with our Site and use our Services. When we use the term “personal information”, we are referring to information that identifies, relates to, describes or can be associated with you. The following sections describe the categories and specific types of personal information we collect.
Any personally identifiable information collected directly from you or through cookies, and our subsequent usage of that information, is pursuant to our FERPA compliance: https://learn.firstdraft.com/ferpa_statement.
Information that you directly submit to us through our Services may include:
Basic contact details including your name and email address.
Account information including your username, password, security questions.
User-generated content including information you provide in the form of creating Lessons or in response to answering Quiz Questions and other gradable exercises.
Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features.
We also automatically collect certain information about your interaction with the Services (“Usage Data”). To do this, we may use cookies and similar technologies (“Cookies”). Usage Data may include information about how you access and use our Site and your account, including device information, browser information, information about your network connection, your IP address and other information regarding your interaction with the Services.
We use the information that we collect for a variety of purposes, including the following:
We use Cookies to power and improve our Site and our Services (including to remember your actions and preferences), to run analytics and better understand user interaction with the Services (in our legitimate interests to administer, improve and optimize the Services).
Most browsers automatically accept Cookies by default, but you can choose to set your browser to remove or reject Cookies through your browser controls. Please keep in mind that removing or blocking Cookies can negatively impact your user experience and may cause some of the Services, including certain features and general functionality, to work incorrectly or no longer be available.
In certain circumstances, we may disclose your personal information to third parties for legitimate purposes subject to this Privacy Policy and within the scope of authorized disclosures under FERPA. Such circumstances may include:
With third party vendors who perform services on our behalf (e.g., Updating lesson grades in a Learning Management System, executing code blocks, data analytics, and cloud storage).
Within our corporate group in our legitimate interest to run a successful business.
When personally identifiable information is required by the third party vendor for e.g. updating grades and providing transcripts of grades and progress reports, we provide the information as is to third parties, pursuant to our FERPA compliance: https://learn.firstdraft.com/ferpa_statement. When this information is not required by the third party vendor, e.g. when collecting business analytics through third party vendors, we anonymize personally identifiable information.
We have, in the past 4 months disclosed the following categories of personal information and sensitive personal information (denoted by *) about users for the purposes set out above in “How we Collect and Use your Personal Information” and “How we Disclose Personal Information”:
We do not use or disclose sensitive personal information for the purposes of inferring characteristics about you. When personally identifiable information, such as names and email addresses, are not required by the third party vendor, we anonymize this data.
The Services may enable you to create lessons and other user-generated content. If you choose to submit user-generated content to any public area of the Services, this content will be public and accessible by other users.
We do not control who will have access to the information that you choose to make available to others, and cannot ensure that parties who have access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available, or for the accuracy, use or misuse of any information that you disclose or receive from third parties.
Our Site may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services.
The Services are not intended to be used by children, and we do not knowingly collect any personal information about children. If you are the parent or guardian of a child who has provided us with their personal information, you may contact us using the contact details set out below to request that it be deleted.
As of the Effective Date of this Privacy Policy, we do not have actual knowledge that we “share” or “sell” (as those terms are defined in applicable law) personal information of individuals under 16 years of age.
Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” In addition, any information you send to us may not be secure while in transit. We recommend that you do not use insecure channels to communicate sensitive or confidential information to us.
How long we retain your personal information depends on different factors, such as whether we need the information to maintain your account, to provide the Services, comply with legal obligations, resolve disputes or enforce other applicable contracts and policies.
You have certain rights and choices with respect to your personal data such as:
Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request in a timely manner as required under applicable law.
If you have complaints about how we process your personal information, please contact us using the contact details provided below. If you are not satisfied with our response to your complaint, depending on where you live you may have the right to appeal our decision by contacting us using the contact details set out below, or lodge your complaint with your local data protection authority.
Please note that we may transfer, store and process your personal information outside the country you live in, including the United States. Your personal information is also processed by staff and third party service providers and partners in these countries.
If we transfer your personal information out of Europe, we will rely on recognized transfer mechanisms like the European Commission’s Standard Contractual Clauses, or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined to provide an adequate level of protection.
Personally identifiable information like names and email addresses are encrypted throughout the transfer, storage, and processing in all cases.
Should you have any questions about our privacy practices or this Privacy Policy, or if you would like to exercise any of the rights available to you, please email us at support@firstdraft.com.