At Centricity, we take privacy seriously and are committed to complying with, and maintaining the standards for the collection, and processing of personal data, that is “personal data shall be processed fairly and lawfully”, and in accordance with the provisions of Jamaican Data Protection Act of 2020, as well as the UK Data Protection Act, EU General Data Protection Regulation, and the US Children’s Online Privacy Protection Act.
This policy explains when and why we collect personal information about children, Teachers / Homeschool facilitators and other users (“you”), how this information is used, the conditions under which it may be disclosed to others and how it is kept secure.
This policy may change from time to time so please check this page occasionally to ensure that you’re happy with any changes.
1. How we collect your personal information
We may collect and process the following information about you
Personal information you give to us – this is information about you that you give to us by entering information via our website or mobile application (where applicable) or by corresponding with us by phone, email or otherwise and is provided entirely voluntarily.
The information you give to us includes your name, school name, child’s name your username and password, email address, phone number and credit card information.
Personal information we collect about you – we may automatically collect the following information: with regard to each of your visits to our website we may automatically collect technical information, including anonymous data collected by the hosting server for statistical purposes, the Internet protocol (IP) address used to connect your computer or device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
From time to time, we may receive your personal information from other sources or third parties and we will use this information in accordance with this Privacy Policy.
2. What type of personal information do we process about you
We may process a range of personal information about you including the following types of information: contact (such as your name, email address), monitoring (information relating to the surveillance or monitoring of your activities whilst using our services), cardholder (your payment card details) and correspondence (information contained in our correspondence or other communications with you about our products, services or business).
Any personal information you provide to us is on a voluntary basis. However we will not be able to provide you with our services/products as we require this information to enter into a contract with you.
3. How we use your personal information
We and our third-party service providers may use the information collected from Students as follows:
Adult Student Information – Information collected from Adult Students may be used:
To permit you to register and use the Services, including, for example, to send you communications.
To respond to your inquiries and fulfill your requests, retrieve your password, or provide technical support. For Consumer and Other Accounts to provide marketing communications that we believe may be of interest to you. While it is never our intention to send any marketing messages to children, if you believe a Child Student has received such a marketing communication, please contact us as described below.
Both Adult and Child Student Information – Information collected from both Adult and Child Students may be used:
To allow us to assess and improve the Services, its educational content, and other services we provide, for example, to improve our content and user experience; to research, evaluate, and improve the Services’ educational efficacy; and to inform our understanding of the Services’ user base.
To customize, adapt, and personalize Students’ viewing and content-consumption experience, for example, by measuring a Child Student’s performance.
To maintain and analyze the functioning of the Services.
As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to detect violations of and enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates, including the security of the Services; (f) to protect our rights, privacy, safety, or property, or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain (collectively, (a)-(g) are Other Uses and Disclosures).
In connection with a CONTRACT with you
We may use and process your personal information where we have supplied you (or continue to supply you) with any products or services, where we have arranged for the supply of another company’s products or services to you, or where you are in discussions with us about any new product or service. We will use this information in connection with the contract for the supply of products or services when it is needed to carry out that contract or for you to enter into it.
Please see What type of personal information do we process about you above for details of the types of personal information we process for these purposes.
Where you have provided CONSENT
We may use and process your personal information where you have consented for us to do so for the following purposes:
contact you with marketing information about our products, services and offers if you register an account with us online or when you refresh your marketing preferences when responding to a request from us to do so;
In order to comply with any LAW or regulation
Where we reasonably believe that you are or may be in breach of any applicable laws, we may disclose your personal information to relevant third parties, including to law enforcement agencies or your internet service provider.
Where there is a LEGITIMATE INTEREST
We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business for the following purposes.
- analysis to inform our marketing strategy, and to enhance and personalize your customer experience;
- analysis to help us understand and improve how our products and services are used;
- network and information security in order for us to take steps to protect you and/or your information against loss or damage, theft or unauthorized access;
- comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
- preparation of statistical information regarding performance and usage in different age groups (for which we will ask you to provide your child’s age);
- management of queries, complaints, or claims;
- notify and contact competition entrants;
- develop and offer new services, products or features and to inform you of such information;
- contact you for administrative purposes, for example to confirm that your account has become dormant and regarding subscription renewal; and
- marketing (please see section 6 for further information).
Others who may receive or have access to your personal information
Our service providers – We may disclose your information to our providers of analytical services, to help us understand and improve how our products and services are used, to identify how often you use our services and to provide us with performance data and download information.
Credit/debit card payment processors
When you purchase any products or services, please be aware that your credit/debit card payment is not processed by Centricity, but by a third party payment processor, who specializes in the secure online capture and processing of credit/debit card transactions. If you have any questions regarding secure transactions, please contact us using the details at the end of this policy.
Other ways we may share your personal information
We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganization. We may also transfer your personal information if we’re under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our customers.
However, we will always take steps with the aim of ensuring that your privacy rights continue to be protected.
We may share aggregated non-personally identifiable information publicly, including with press and educational administrators in order to demonstrate how our products and services are used, or with users and potential users.
We will never monetize the Personal Information of any Student of the Services by providing it to a third party in exchange for money, except in the context of a sale of the Company.
4. Where we store your personal information
All data managed by Centricity is hosted on a third party platform based in the United States or their affiliated sites. All information you provide to us may be transferred to countries outside the US. By way of example, this may happen where any of our third party service providers are from time to time located in a country outside of the US. These countries may not have similar data protection laws to the US.
- If we transfer your information outside of the US in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy.
This steps include imposing contractual obligations on the recipient of your personal information or ensuring that the recipients are subscribed to ‘international frameworks’ that aim to ensure adequate protection. Please contact us using the details at the end of this policy for more information about the protections that we put in place and to obtain a copy of the relevant documents.
- If you use our services whilst you are outside the US, your information may be transferred outside the US in order to provide you with those services.
- If you register for and use our services from outside the US, your information will be transferred into the US in order to provide you with those services. If you are based in the US, we will store your information in accordance with the regulations stated in COPPA.
5. How long we keep your personal information for:
If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws.
We do not retain personal information in an identifiable format for longer than is necessary.
We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any other purposes listed under How we use your personal information.
The only exceptions to this are where:
- the law requires us to hold your personal information for a longer period, or delete it sooner
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further Erasing your personal information or restricting its processing)
- in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.
If you notify us that you wish to close your account, we will include anonymised information in our statistics, and we will then delete your personal information.
Security
The security of your Personal Information is important to us, and we employ physical, technical, and administrative security measures designed to safeguard the information collected by the Services. We use industry standard SSL (secure socket layer technology) encryption to transfer PI. Other security safeguards include, but are not limited to, data encryption, firewalls, and physical access controls to buildings and files. We also conduct periodic audits of our security (no less than annually) to apply best practices and reasonable industry standards. However, no data transmission over the Internet can be guaranteed to be completely secure. If there is a breach of our security, we will notify you where required by law or deemed necessary and appropriate under the circumstances.
You can help protect against unauthorized access to your Account and PI by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your Account.
We are committed to maintaining the security and confidentiality of your and your children’s information, including, but not limited to, any Student Data, which we receive through School Accounts. Some of the precautions we take include (a) limiting employee access to your and your children’s PI to only those employees with a need to such access to fulfill their job responsibilities; (b) conducting background checks on our employees and, specifically, upon all employees that may have access to Student Data; (c) requiring employees to sign confidentiality agreements upon hiring; (d) conducting regular employee privacy and data security training and education; and (e) protecting PI with commercially reasonable technical, contractual, administrative, and physical security safeguards.
Please be aware, however, that no information system can be guaranteed to be 100 percent secure, so we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to the Services over networks that we do not control, including the internet and wireless networks. If you have reason to believe that your interaction with us is not secure, please contact us as described below.
Children’s privacy
- Protecting the privacy of children is especially important to us and we recognise the need to take further measures with respect to personal data about children.
- This section of the policy is aimed at teachers, homeschool facilitators and other adults holding parental responsibility over the child/children they permit to use the services (“you“, “Responsible Adult”). We do not offer services direct to children, other than tools for which no registration is required, and our Terms do not allow children to register for the website.
- You have complete control over the information we collect from your child/children and you are required to monitor any content produced by your child/children to ensure that it does not contain any personal information.
- All work is private by default. We do not make public the child/children’s work without consent of the child/children’s Responsible Adult. However, you may choose to post the content on parts of our website that are public.
- Before you make any content public, please note that our Terms of Use require you to monitor the content and ensure that there is nothing that would allow a child to be identified and that there is no inappropriate material.
- Please keep in mind that anything, once shared online, can be ‘screen grabbed’ by others.
Please note that Centricity shall not be responsible for any content the Responsible Adult chooses to make public.
We actively encourage children using our website not to:
share any personal identifiable information on our website;
identify themselves other than by using their username.
Your rights
Your (data subject) rights:
You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information.
Accessing your personal information
You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address shown below. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
Correcting and updating your personal information
The accuracy of the information you provide, is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you.
In the meantime, if your personal details change i.e. email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us in any of the details described below.
Withdrawing your consent
Where we rely on your consent as the legal basis for processing your personal information, as set out under the section “ How we use your personal information”, you may withdraw your consent at any time by writing to us at the address shown below. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can do so using our Unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.
Erasing your personal information or restricting its processing
In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Provided we do not have any continuing lawful reason to continue processing or holding your personal information, we will make reasonable efforts to comply with your request.
Transferring your personal information in a structured data file
Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under the section “ How we use your personal information”, you may ask us to provide you with a copy of that information in a structured data file. This information can be provide to you electronically on request.
Links to other websites
Our website may contain links to other websites run by other organisations. This policy does not apply to those other websites and Apps‚ so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites and Apps even if you access them using links that we provide.
In addition, if you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.
6. Marketing
We may collect your preferences to receive marketing information directly from us in the following ways:
- If you register an account with us
- If you make a sales enquiry or place an order we may contact you with marketing information in the ways mentioned in the notices presented to you, except where you indicate you would prefer otherwise.
- We may contact you with marketing information by post or by telephone or with targeted advertising delivered online through social media and platforms operated by other companies, unless you object.
- We will only share your data with our recommended third party partners for them to contact you with marketing information about their products and services where you have indicated that you would like us to do so.
- If you do not complete a purchase and have not indicated that you would prefer otherwise, we may send a reminder to you about your incomplete purchase.
- You have the right to opt-out of our use of your personal information to provide marketing to you in any of the ways mentioned above.
Contact us
Please direct any queries about the way we process your personal information, using our contact details below.
Our email address is admin@cbslearningservics.com