Scholastic Network Partners, LLC. Privacy Policy

EFFECTIVE DATE: July 28, 2023

Thank you for choosing online products and services owned and operated by Scholastic Network Partners, LLC dba The Scholastic Network and dba TSN (hereafter called "TSN"). This Privacy Policy (this "Policy") outlines how TSN collects, uses, discloses, and safeguards Personal Information (defined below) in connection with TSN’s online and/or mobile services, websites, software, and content assets (collectively, the "Services"), including the Services provided through the following sites (collectively, the "Sites"):

• www.tsnvcs.com
• portal.thescholasticnetwork.com

This Policy is meant to be reviewed in conjunction with the TSN Terms of service available at https://www.tsnvcs.com/school/terms_of_service (the "Terms of Service"). Capitalized terms that are used but not defined in this Policy have the meanings given such terms in the Terms of Service.

1. General

TSN ("we", "us", or "our") respects the privacy of everyone that uses the Services. As a user of the Services, you have a right to know how TSN collects, uses, discloses, and safeguards your Personal Information and the rights you have in relation to your Personal Information. For purposes of this Policy, "Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. However, "Personal Information" does not include anonymous, aggregated, or other non-personally identifiable information (i.e., information that cannot be associated with or traced back to a specific individual or household)

The Sites are hosted in the United States and are subject to U.S. state and federal law. If you are accessing the Services from other jurisdictions, please be advised that you are transferring your Personal Information to us in the United States, and by using the Services, you are agreeing to that transfer and use of your Personal Information in accordance with this Policy. You also agree to abide by the applicable laws of the State of Texas and U.S. federal law concerning your use of the Services and your agreements with us as stipulated in the TSN Terms of Service. If your use of the Services would be unlawful in your jurisdiction, please do not use the Services.

2. How TSN Collects and Uses Information

A. Subscriber Information

When you subscribe to the Services, TSN will ask you to provide certain Personal Information and other information about you and, if applicable, information about your organization ("Subscriber Information"). TSN collects Subscriber Information directly from you. For example, if you purchase a license to use the Services on behalf of a school or other organization, TSN will collect information about you and your organization, including your name, your email address, your role within your organization, your organization’s name, your organization’s physical address, and payment information for your organization.

TSN uses your Subscriber Information to set up and administer your TSN account, provide the Services for you and your Users (as defined below), support and develop the Services, provide you and your Users with information and updates about the Services and your TSN account, communicate with you about billing obligations, and process payments.

B. User Information

If your organization (district, school, college, university, business, etc.) subscribes to the Services, your organization will have at least one, and sometimes many, individuals registered as users of its TSN account (each, a "User"). TSN collects information, including Personal Information, when individuals register as Users of your organization’s TSN account and thereafter when Users access the Services ("User Information"). For example, if you are registering as a User of your organization’s TSN account, we will ask you to provide us your name, email address, your role within your organization (student, teacher, administrator, etc.), and other information we may need in order to activate and maintain your User account. TSN collects User Information directly from individual Users and, from time to time, from the User’s organization and account administrator(s).

TSN uses User Information to contact Users from time to time in connection with the Services (such as to address issues or complaints related to a User’s use of TSN or any of the Services), provide Users with information about TSN or the Services, verify Users’ identities or login credentials, provide legal and other notices to Users, and notify Users regarding potential violations of TSN’s terms and policies.

C. Content Information

As a TSN subscriber, you and your Users may voluntarily upload certain information to the Services ("Content Information"). For example, student Users may upload assignments into the Services as directed by their teachers, and school administrators may upload information into the Services in order to communicate that information with other Users of the school’s TSN account. TSN does not monitor or control Content Information; you and your Users determine what information will be uploaded into the Services through your TSN account, which of your Users will have access to that content, and if and when that content will be removed from the Services. You, as the TSN account owner, are responsible for managing Content Information entered into the Services through your TSN account and for taking all measures, and obtaining all consents, necessary to comply with applicable privacy laws to ensure that TSN may lawfully (i) share Content Information as directed by you and your Users, and (ii) otherwise process, use, and disclose Content Information to provide the Services to you and your Users.

TSN uses Content Information only as required to perform the Services for you and your Users. TSN functionality allows Users to control their Content Information, including which other Users may access or use their Content Information. TSN will only use and share Content Information as you and your Users direct using functionality and controls within the Services. You and your Users are solely responsible for controlling what Content Information is entered into the Services through your TSN account and how and with whom that Content Information is used and shared with other Users.

D. Automatically-Collected Information

Like many websites and online services, TSN automatically collects information when you and your Users access the Services, read our emails, or otherwise engage with TSN and its personnel ("Automatically-Collected Information"). Automatically-Collected Information is typically collected through a variety of tracking technologies, including cookies, log files, and similar technology (collectively "Tracking Technologies"). These Tracking Technologies collect information about how you access and use the Services (e.g., referring/exit pages and URLS, how frequently you access the Services, the pages you view, the links you click, and other actions you take within the Services); information about your browser and information about the device(s) you use to access the Services (e.g., Internet Protocol (IP address), browser type, browser language, Internet service provider, device type, model and manufacturer, a unique ID that allows us to uniquely identify your browser, device or account, operating system brand and model, and whether you access the Services from multiple devices). We may also collect information about your geographical location data at the city level. We may collect analytics data, or use third-party analytics tools, such as Google Analytics, to help us measure traffic and usage trends for the Services and to understand more about the demographics and behaviors of our users. You can learn more about Google's practices at http://www.google.com/policies/privacy/partners. We may also work with third party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.

We use or may use the data collected through tracking technologies to secure the Services, to improve the Services, to save you time, to provide better technical support, for promotional purposes, and to track website usage. For example, tracking technologies help us to:

• 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.
• Customize the function and appearance of the pages you visit based on information relating to your account; for example, to default you to a particular access level.
• Track website usage for various purposes including website optimization, website improvement, sales, marketing, and billing.

Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some features and services (particularly those that require you to sign in) may not function properly if your cookies are disabled. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you access our email and perform certain functions with it. Deleting cookies does not prevent the collection of information through non-cookie technologies and does delete Local Storage Objects (LSOs) such as Flash objects and HTML5. You can learn more about Flash objects — including how to manage privacy and storage settings for Flash cookies — on Adobe's website. If you choose to delete Flash objects from our sites, then you may not be able to access and use all or part of the sites or benefit from the information and services offered.

3. Information TSN Never Collects

The Services do not gather, store, or require information related to any of the following:

• Student data beyond the required information stated in Section 2 above.
• Employee data beyond the required information stated in Section 2 above.
• Any other personally identifiable information (PII) other than that stipulated in Section 2 above.

4. Use of Collected Information

TSN uses the information we collect for the following purposes:

• To provide and maintain the Services. We use the information we collect to deliver the Services to you and your Users. For example, we use your information to give you access to the appropriate licensed account, process payments, or provide you with ongoing support for your use of the Service.
• To improve, personalize, and develop the Services. We use information to tailor the content and information that we may send or display to users, to offer personalized content and instructions, and to otherwise personalize your experience while using the Services, including on various devices you may use to access the Services. We collect statistics to better understand how users access and use our Services, monitor the effectiveness of our Services, detect usage patterns, and to diagnose or fix technology problems. We also use information to demonstrate the effectiveness of the Services, perform research, and to develop, support, and improve theServices.
• To communicate with you. We use your information to provide transactional notifications for certain activities relating to your use of the Services. For example, we may send email notifications to highlight new features, to provide receipt for payment or other subscription notices. From time to time, we may send periodic promotional or informational emails to you and your users. We do not use Student Data to send marketing communications, and we do not send marketing communications to student Users. You may opt-out of certain communications (e.g., marketing or certain notifications about your use of the Services) by following the opt-out instructions contained in the email. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).
• To promote safety and security and respond to legal requests. We use information to promote the safety and security of the Services, our uses and other third parties. For example, we may use the information to authenticate users, facilitate secure payments, detect and prevent fraud and other harmful activities, respond to legal requests or claims, and enforce our terms and policies.

5. Sharing of Collected Information

TSN may share or disclose your personal information as needed to provide the Services or with your consent/permission. We may also share personal information in the circumstances below.

A. Sharing with Third Parties

We may share information when you direct us to share such information with another party. We may also share information with third-party service providers, for example, (i) if you authorize Google login, similar authentication tools for your account; (ii) if you authorize Canva to share your Canva content directly to the Services; or, (iii) you subscribe to TSN Premium Content inside of the Network.

B. Others within your Organization

TSN may share information collected from users associated with an organization with other users or persons designated by that organization, such as teachers and school administrators, business leaders, or HR professionals. Messages and content shared or posted by members of an organizational community, such as messages between a teacher and students in a class or managers and their direct reports will be accessible by account administrators or other designated organizational users.

C. Vendors and Service Providers

TSN may share information with our trusted vendors, third party service providers and individuals to provide services or products for us or on our behalf, which may include analytics, hosting, billing, targeted advertising, and marketing (provided however, that TSN will not knowingly use any Student Data to target advertising or marketing). Vendors and service providers who have access to Student Data, if any, shall be contractually bound to uphold privacy and confidentiality terms no less protective than those provided herein.

D. Aggregate or De-Identified Information

We may share information in aggregated and/or anonymous form that cannot reasonably be used to identify an individual. For example, TSN may disclose aggregated user statistics (e.g., the total number or percentage of Users of the Services from a particular geographic region) in order to describe the Services to current and prospective partners and other third parties, and for other lawful purposes.

E. Merger or Sales

If TSN becomes involved in a merger, acquisition, bankruptcy, change of control, or any form of sale of some or all of its assets, your personal information may be transferred or disclosed in connection with the business transaction. In such an event, we will make efforts to provide notice before personal information is transferred and becomes subject to a different privacy policy. We will not transfer Student Data associated with School accounts in the event of a merger or sale unless the recipient has committed to similarly stringent privacy protections as described herein, or we will provide Schools with notice and an opportunity to opt-out of the transfer of Student Data by terminating their accounts and any associated student users before the transfer occurs.

F. Other

TSN may release personal information if it has a good faith belief that access, use, preservation, or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process, or enforceable governmental request; (b) enforce applicable Terms of Service, including investigation of potential violations thereof; (c) detect, prevent or otherwise address fraud, security or technical issues; (d) protect the rights, property, or personal safety of TSN, its users, or the public; or (e) as required or permitted by law.

6. Third-Party Tracking for Online Advertising

TSN does not display any targeted advertising on the Services.

7. Email Communications

TSN may send you email notifications regarding our products and services, or your use of our products and services. Only TSN (or its vendors or service providers operating on its behalf) will send you these emails. You can choose not to receive these emails by clicking the unsubscribe link in any email or by contacting support@tsnvcs.com. Please note that you are not permitted to unsubscribe or opt-out of non-promotional messages regarding your account, such as account verification, changes or updates to features of the Services, or technical or security notices.

8. Accessing and Updating your Personal Information

You may edit your account information at any time by signing in to your Services account. In the Network, click on the Account Menu in the upper right corner and click on your name. You may change your name, email address, and password. Other information may be changed by an authorized user who has been granted administrative rights over your account.

If you do not provide and maintain accurate information for your account, TSN may not be able to provide you with notices set forth in this Privacy Policy or in our Terms of Service. You are solely responsible for the accuracy of all of your information.

If you are an educational institution using the Services and providing students with their own account access (i.e. as student content creators), please refer all questions and requests regarding access, modification, or deletion of a student user's information to the appropriate Service account administrator for your account/license. Should the educational institution need assistance with such requests, they may contact TSN at support@tsnvcs.com.

9. Protection and Retention of Information

A. Retention of Personal Information

TSN will retain personal information for as long as needed to provide the Services and for our internal business purposes, which may extend beyond the termination or cancellation of your subscription or user account. For example, we may retain certain data as necessary to prevent fraud or future abuse, for recordkeeping or other legitimate business purposes, or if required by law. We may also retain and use information which has been de-identified or aggregated such that it can no longer reasonably identify a particular individual. All retained personal information will remain subject to the terms of this Privacy Policy.

Student Data. We will not knowingly retain Student Data beyond the time period required to support an educational purpose, unless authorized by an educational institution. We do not delete or de-identify any Student Data from an active student user account associated with a School except at the direction of the School. The School is responsible for maintaining current student rosters and identifying Student Data which the School no longer needs for an educational purpose by removing students from your account.

Unless otherwise directed by you, we will delete or de-identify personal information of student and child users after a period of inactivity, after the termination or cancellation of the license subscription, or after termination of our agreement with you. Authorized Service administrators may contact us at support@tsnvcs.com to additional retention questions.

We may not be able to immediately or completely delete all data in all instances, such as information retained in technical support records, customer service records, backups, and other similar business records. We will not be required to delete any information which has been de-identified or disassociated with personal identifiers such that the remaining information cannot reasonably be used to identify a particular individual.

B. Protection of Personal Information

The protection and security of your personal information is very important to TSN. We have implemented a variety of physical, administrative and technological safeguards designed to preserve the integrity and security of the personal information we collect and to protect against unauthorized access to data. These include internal reviews of our data collection, storage, and processing practices and security measures. We restrict access to personal information to TSN employees, contractors, and agents who need to know that information in order to operate, develop, or improve our Services. Our employees may be subject to disciplinary action, including termination, if they fail to meet privacy and confidentiality obligations. However, no security system is impenetrable—for that reason, we cannot guarantee the security of your personal information. If personal information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and take all steps required by applicable laws and regulations.

Maintaining the security of your personal information also requires your cooperation and involvement. For your protection, remember to sign out of all accounts before closing your browser. There is a sign out link available on most TSN Network pages and Service pages that require a username and password prior to access such pages. After signing out, make sure to close all browser windows. In addition, do not use the "Remember" feature if you are signing in to your account from a computer that other persons may have access to. This is to ensure that others cannot access your personal information if you share a computer with someone else or are using a public computer.

If you have any concerns about the security of your account or the security of the Service, we ask that you report your concern to us immediately at support@tsnvcs.com. We appreciate your feedback and take all reported concerns seriously.

Data storage and transfer. TSN is located in the United States. Personal information collected through our Website and Service may be stored and processed in the United States or any other country in which TSN or its affiliates or service providers maintain facilities.

C. European Economic Area ("EEA") Requirements

For personal information subject to the European Union General Data Processing Regulation ("GDPR"), we rely on several legal bases to process the data. These legal bases include where:

• The processing is necessary to perform our contractual obligations in our Terms of Service or other contracts with you (such as to provide you the Service as described in our Terms of Service);
• You have given your prior consent, which you may withdraw at any time (such as for marketing purposes or other purposes we obtain your consent for from time to time);
• The processing is necessary to comply with a legal obligation, a court order or to exercise or defend legal claims;
• The processing is necessary for the purposes of our legitimate interests, such as in improving, personalizing, and developing the Service, marketing the Service, such as new features or products that may be of interest, and promoting safety and security as described above.

If you have any questions about or would like further information concerning the legal basis on which we collect and use your personal information, please contact us at support@tsnvcs.com.

Residents in the EEA are entitled to certain rights with respect to personal information that we hold about them under the GDPR:

• Right of access and portability. The right to obtain access to your personal information, along with certain related information, and to receive that information in a commonly used format and to have it transferred to another data controller;
• Right to rectification. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete;
• Right to erasure. The right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed;
• Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information; and,
• Right to object. The right to object, on grounds relating to your particular situation, to the processing of your personal information, and to object to processing of your personal information for direct marketing purposes, to the extent it is related to such direct marketing.

You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you need further assistance regarding your rights, please contact us via email at legal@tsnvcs.com. In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

D. Additional Information & Jurisdictional Requirements

TSN may choose or be required to provide different or additional disclosures relating to the processing of personal information about you if you reside in a specific county, region, or state. TSN recognizes you have choices regarding your personal information. In some jurisdictions, the controls and choices may be enforceable as rights under applicable law.

• You have the right to know about the personal information TSN collects and how it is used and shared;
• You have the right to delete personal information collected from TSN (with some exceptions as permitted by law);
• You have the right to opt-out of receiving sales/marketing communications or of sharing your personal information;
• You have the right to correct inaccurate personal information that TSN has about you; and,
• You have the right to limit the use and disclosure of sensitive personal information.

To exercise any of your rights, please contact your Service administrator or legal@tsnvcs.com. TSN will need to verify your identity before processing your request and/or require you to log into your account, if you have one. In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.

To discuss your rights under specific laws applicable to your country, region, or state, please contact us at legal@tsnvcs.com. In the subject line of the email, please include "Rights Request for" along with the name of the specific jurisdiction for which you’re inquiring.

E. Protection of Students’ and Children’s Data

TSN does not permit students and children to create their own accounts and does not knowingly collect personal identifying information from children under the age of 13 without the consent and at the direction of educational institutions. If you believe any TSN Service inadvertently holds information from a child under 13 without parental or institutional consent, please contact us at legal@tsnvcs.com as soon as possible.

If you are an educational institution or business, you may authorize TSN to collect information from a child under 13. You are responsible for obtaining and maintaining all necessary consents from the child’s parents or guardians.

When TSN provides the Service to you and you provide children under the age of 13 with a user account to the Service, our collection, use and disclosure of childrens' data is governed by our Terms of Service and/or any other agreement with you, by the provisions of the Family Educational Rights and Privacy Act ("FERPA"), the Children's Online Privacy Protection Act ("COPPA") and other applicable laws that may relate to the collection and use of personal information of children/students. If you have any questions about the use of children’s and/or students' data, contact us at legal@tsnvcs.com. To modify, delete, or review this data, please contact your local Service administrator.

• The Family Educational Rights and Privacy Act ("FERPA"). This Privacy Policy and our Service are designed to meet our responsibilities to protect personal information from the students' educational records under FERPA. We agree to work with you to jointly ensure compliance with the FERPA regulations.
• The Children's Online Privacy Protection Act ("COPPA"). This Privacy Policy and our Service are designed to comply with COPPA. We do not knowingly collect personal information from a child under 13 unless and until you authorize us to collect such information through the provision of the Service on your behalf. When an educational institution uses our Service in the classroom or in an educational context, we rely on that institution to provide appropriate consent and authorization for a student under 13 to use the Service and for TSN to collect personal information from such student, as permitted by COPPA. Upon request, we will provide you with the opportunity to review and delete the personal information collected from your children/students. If you are a parent and you have questions about your child's use of our Service and any information collected, you should discuss your questions with your child's educational institution.
• Students Online Personal Information Protection Act ("SOPIPA"). This Privacy Policy and our Service are designed to comply with SOPIPA. We do not use Student Data for targeted advertising purposes. We do not use collected information to amass a profile of a K-12 student except in furtherance of K-12 purposes. We never sell Student Data unless the sale is part of a corporate transaction, such as a merger, acquisition, bankruptcy, or other sale of assets, in which case we make efforts to ensure the successor entity honors the privacy commitments made in this policy and/or we will notify you of such a sale and provide you an opportunity to opt-out by deleting your account before the data transfer occurs. We will not sell students' personal information to third parties other than in the context of a business transaction.

10. Protection and Retention of Information

TSN's Services may contain links to and from third-party websites of our business partners, advertisers, and social media sites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and their practices are not covered by this Privacy Policy. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third-party sites.

11. Updates to this Privacy Policy

TSN may, in its sole discretion, modify or update this Policy at any time, which will be reflected in the 'Last Updated' date set forth at the beginning of this Policy. If we change this Policy in a material manner, we will do our best to notify you of the changes by posting a notice on our website or through other appropriate communication channels. Your continued use of the Services following the effective date of such update constitutes your acceptance of the revised Policy. If you do not agree to any of the terms in this Policy or to any future terms in a future revision of this Policy, do not use or access (or continue to access) the Service.

We will not make any material changes to our Privacy Policy or Terms of Service that would result in children/student data being used in a materially different manner than was disclosed when the information was collected without first giving notice to applicable institutions and providing a choice before such data is used in a materially different manner than was disclosed when the information was collected.

12. Contact TSN

If you have any questions regarding this Policy, please contact us using the information below. We will do our best to answer your question promptly and accurately.

Scholastic Network Partners, LLC (dba The Scholastic Network, dba TSN)
PO Box 764
Blanco, TX 78606

800-660-5572
legal@tsnvcs.com
support@tsnvcs.com

Last Updated: August 1, 2023