Last Updated: December 22, 2020
Contact Information and Data Protection Officer
Off2Class is headquartered in Ontario, Canada. Off2Class has appointed an internal data protection officer for you to contact if you have any questions or concerns about Off2Class’ personal data policies or practices. Off2Class’ data protection officer’s name and contact information are as follows:
Kris Jagasia, Off2Class, 374 St. Clements Ave, Toronto, Ontario, Canada (kris [at] off2class [dot] com)
What information do we collect?
- “Personal Information” is information about an identifiable individual. Personal Information includes but is not limited to your name, residential address, residential telephone number and personal e-mail address.
- “Business Contact Information” is your name, position name or title, company, work address, work email address and work telephone number. Business Contact Information generally does not constitute Personal Information.
- “De-identified Information” means information (including Personal Information) that has been aggregated, anonymized and de-identified, so that it cannot (directly or indirectly) be used, alone or in combination with other data within our possession or control, to identify an individual.
We collect information from Customers (i.e., school boards or administrators, teachers or tutors) when you request and activate a Subscription Account or Free Account on the Site (an “Account”). No Personal Information is required for Customers to use the Site (e.g. you can use an anonymous email address and username to use the Site, without any loss in Site functionality). However, we understand that some Customers will use personally identifiable email addresses and usernames to use the Site, which will constitute Personal Information. We take this responsibility seriously and use this Personal Information only to deliver our Services to you.
When registering an Account, the Customer may be asked to enter your Business Contact Information (i.e., your name, work e-mail address or work address).
When the Customer (or a teacher where he/she is the Authorized Person of a school board or school administrator) is using the Student Management System on the Site, the names, email addresses or mailing addresses of your students with whom you intend to use this Site may also be entered. Such information may only be provided as follows:
- You must receive consent directly from all students over the age of 19 in order to enter any of their Personal Information on the Site. Alternatively, non-personally identifiable information (for example, non-identifiable usernames and email addresses that do not divulge the identity of students) may be used.
- For all students ages 19 or younger, we recommend that you enter only non-personally identifiable information (for example, non-identifiable usernames and email addresses that do not divulge the identity of students). Alternatively, you must obtain consent from the parents or guardians of such students or from the school administrator (in the U.S., where applicable) in order to enter any Personal Information on the Site.
Please note that Customers who wish to use the Site without entering student email addresses, for example, because student email addresses may contain personally identifiable information, may be able to use a Single Sign-On (SSO) protocol to access the Site which may forgo the need to enter student email addresses into the Site. Please contact your Off2Class Product Specialist or Customer Success Manager to learn about SSO options at Off2Class.
We do not knowingly collect Personal Information other than as set out above. We do not collect any Personal Information related to:
- Race or ethnic origin
- Political opinions
- Religious or philosophical beliefs
- Trade union memberships
- Genetic or biometric data
- Health or mortality
- Sex life or sexual orientation
We do not use Personal Information to make automated decisions.
Customers (or teachers where they are the Authorized Persons) should instruct students not to inadvertently enter Personal Information on the Site (for example, when answering a free text or essay-type homework question).
What do we use your information for?
Any of the Personal Information we collect from you may be used in one of the following ways:
- to facilitate the creation of and secure your Account;
- identify you as a user in our system;
- to process transactions you have initiated;
- to provide you with the Services you request;
- to administer a contest, promotion, survey or other Site feature that you have chosen to participate in; or
- to send you periodic emails with information directly relevant to your use of the Service.
Your Personal Information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the Service.
How do we protect your information?
We implement security safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. We use physical, organizational and technological measures to protect Personal Information, such as firewalls, encryption, and employee education.
We will keep Personal Information only for as long as it remains necessary for the purposes for which it was collected, or as required by law. We use secure means of disposing of Personal Information.
Processing and Storage of Personal Information
Your Personal Information may be processed or stored outside of Canada and as a result may be accessible without notice to you by the courts, law enforcement and national security authorities of that jurisdiction.
Yes, only to increase the quality of your experience while using the Service. For example, we use a cookie to remember which lesson plan you last opened on our Teacher Page. This way, when you come back to the library on our Teacher Page, the dropdown lists will be pre-loaded to the last lessons you opened.
Cookies provide additional functionality to websites to better match users’ interests and preferences. With most Internet browsers, you can erase cookies from your computer hard drive, block the creation of cookies, or receive a warning before a cookie is stored, although doing so may affect your use of the Site and your ability to access certain features of the Site. Please refer to your browser instructions or the help section of your browser to learn more about these functions.
Our Site may also use web beacons. When you access certain of our web pages, a non-identifiable notice of that visit is generated. These technologies usually work in conjunction with cookies. If you do not want your cookie information to be associated with your visits to these pages, you can set your browser to turn off cookies. If you turn off cookies, web beacons will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable cookie information and are disregarded.
We collect De-identified Information that is recorded by the standard operation of our Internet servers using Google Analytics, such as the operating system you are using, the sections of the Site you visit, and the Site pages read and images viewed. We do not knowingly track anyone under the age of 18.
We also collect De-identified Information when a student completes a “Student Ratings” features associated with our Subscription Accounts or Free Accounts. This consists of gathering of anonymized (‘star scale’) ratings from students about their teachers/lessons and anonymized regression analysis of teacher performance by matching student outcomes (for example, numerical scores on tests versus ratings).
This De-identified Information is used: (i) for Site and system administration purposes; (ii) to improve the Site and the Services’ product offerings; (iii) to conduct internal reviews of the number of visitors to the Site; (iv) to help us better understand visitors’ use of our Site and Services; (v) to respond to specific requests from our visitors; and (vi) to protect the security or integrity of our Site when necessary.
Do we disclose any information to outside parties?
We may transfer your Personal Information as an asset in connection with any contemplated or actual sale, merger or other disposal of all or part of our business or assets, or as part of a corporate reorganization or other change in corporate control, including for the purposes of determining whether to proceed with such transaction or fulfilling any records or other reporting requirements to such parties. In such circumstances, we will ensure that any transfer of Personal Information is subject to applicable law and reasonable data protection security protocols.
We may also release your Personal Information when we believe release is appropriate to comply with the law, enforce our Site policies, or protect ours or others rights, property, or safety.
Other than as required or allowed by law (for example, in response to a court order or subpoena, or to comply with local or federal regulations), your Personal Information will not be used for any other purpose without your consent.
We may use De-identified Information, including but not limited to Student Ratings from Free Accounts (but not Subscription Accounts), to deliver Facebook Ads or Google Ads that are targeted to the interests of our Customers who have registered for our advertiser-supported Free Accounts (or whose Subscription Accounts have expired and reverted to Free Accounts).
OFF2CLASS WILL NEVER SERVE ADVERTISING TO STUDENTS, REGARDLESS OF WHETHER YOU SIGN UP FOR A SUBSCRIPTION ACCOUNT OR FREE ACCOUNT.
If you prefer not to receive targeted advertising, you can opt-out of some network advertising programs that use your information. For example, the Digital Advertising Alliance (DAA) Opt-Out Page at http://www.aboutads.info/choices/ provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies’ pages where you can opt-out of receiving targeted advertisements from those companies. In addition, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. Please note that even if you choose to opt-out of targeted advertising, you will still see advertisements while you are browsing online. However, the advertisements you see may be less relevant to you and your interests.
Third party links
Occasionally, at our discretion, we may include links to third-party products or services on our Site. These third-party websites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our Site and welcome any feedback about these third-party websites. You can contact our Data Protection Officer whose contact information is at the bottom of this policy for any comments about third-party links.
General Data Protection Regulation or “GDPR”
You may be aware that a European Union law, called the General Data Protection Regulation or “GDPR” gives certain rights to individuals in relation to their personal data. We make all reasonable efforts to be in compliance with the requirements of GDPR and most importantly we want to make it easy for you to exercise the rights granted to you under GDPR with respect to your use of the Site. A key aspect of GDPR is that your data belongs to you, and you have a right to be forgotten. You can contact our Data Protection Officer whose contact information is at the bottom of this policy should you have any questions related to exercising the rights granted to you under GDPR with respect to your use of the Site.
Children’s Online Privacy Protection Act Compliance
We make all reasonable efforts to be in compliance with the requirements of the U.S. Children’s Online Privacy Protection Act (COPPA), we do not collect any information from anyone under 13 years of age, without appropriate consent. This Site, our products, and services are all directed to people who are at least 13 years old or older. Third party (such as a student who you intend to use this Site with) information entered into this Site can only be entered by people who have the authority to enter that information. We will not be liable or responsible for any third party Personal Information that is entered on this Site without authorization. If a teacher enters information for a student who is under the age of 13, we recommend not entering any personally identifiable information. As noted above, you may enter a non-identifiable username and an anonymous (non-identifiable) email address and this will be sufficient for your student to use the Service.
Correcting Your Personal Information
We want to make sure that the Personal Information that we have collected about you is accurate, complete, and current. However, we will not routinely update this information, unless it is necessary for us to do so to fulfill the purposes for which we collected the Personal Information.
Since we generally rely on you to inform us if there have been any changes to the Personal Information that we have collected about you, please let us know if any of this information has changed by updating your Account information or by contacting our Data Protection Officer as set out below.
Access to Personal Information including Subject Access Request (SAR)
If you have any questions about the accuracy of the Personal Information that we have collected about you, you can have access to that Personal Information in order to verify and update it, unless we are permitted or required under applicable laws to refuse your access to such Personal Information. You may also request to have your Personal Information removed from the Site.
You may contact our Data Protection Officer at the contact information below to request access to Personal Information that we have about you. We will respond to requests within 30 days and where requested, provide a copy of your Personal Information within 30 days.
Questions and Further Information
© Global Online Language Services Inc.