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We reserve the right to change the policy at any time, so please check back regularly to keep informed of updates to this policy.

Last updated: 23 February 2022


Discovery Education Europe Limited privacy policy

This Privacy Policy (“Policy”) describes how Discovery Education Europe Limited, a company registered in England and Wales (registration number 03261277), whose registered office is located at One Lyric Square, Hammersmith London W6 0NB United Kingdom, (“Discovery Education,” “we,” “us,” or “our”) collects and processes personal data about our customers and users of our website.

1. Who we are

Discovery Education is an online education service provider that produces and delivers high-quality digital content for primary and secondary education and beyond, including textbooks, streaming media and other rich content. The services we offer enable teachers and pupils to participate in enhanced learning experiences. Depending on the context of the personal data you or your school provides, Discovery Education may be the data “controller” or “business”, or “processor” or “service provider” of your personal data under applicable data protection laws. Discovery Education is a “processor” or “service provider” of its customer data, personal data submitted to the Services or collected through the Services on behalf of or at the direction of the subscriber (the schools or school districts who are the “controllers” of the personal data), and personal data it receives or collects from the subscriber. When Discovery Education is acting as a “processor” or “service provider”, Discovery Education will only process the personal data on behalf of and subject to the terms of its contract with the subscriber, to the extent such contract exists, unless otherwise required by law. If you have questions about our processing of your personal data on behalf of a subscriber, please refer to the subscriber’s privacy policy.

We respect the privacy of pupils, teachers, our customers, and users of our websites and services, and have developed this Policy to demonstrate our commitment to protecting your privacy. In order to deliver our services to you, from time to time we collect personal data. The information we collect from you, along with the content that you use on our services and the data on how you use our websites and services help us to provide a range of services that meet your needs.

Please read this Policy carefully. It is your choice whether or not to provide personal data to us. If you choose not to provide your personal data to us, you may not be able to use our Services and we may not be able to communicate with you.

2. Scope

This Policy applies to personal data that Discovery Education collects and processes about our customers, users of the password-protected online subscription services, and users of our websites (identified below) and through our provision of subscription services, digital content, virtual and in-person events, classroom contests and challenges, professional development services to teachers, surveys, and feedback forms (“Services”). This Policy does not apply to Discovery Education, Inc., the related websites, and services. For information about Discovery Education, Inc.’s data privacy practices, please review the Privacy Policy available at: www.discoveryeducation.com/privacy-policy.

For the purposes of this Policy, the term “Websites” shall refer collectively to www.discoveryeducation.co.uk and www.discoveryeducationglobal.com as well as the other websites that we operate and that link to this Policy.

In this Policy, “personal data” means information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, and an online identifier or to one or more factors specific to a person’s physical, physiological, genetic, mental, economic, cultural, or social identity. Personal data does not include aggregate information or de-identified information, meaning that the information can no longer be attributed to an identifiable natural person without the use of additional information.

Personal data is required for us to be able to provide the majority of our Services to you. In addition, some of the Services we provide require that we disclose your personal data to third parties, such as to companies that help us to provide our Services. If you are not willing to provide your personal data and have it disclosed to third parties in accordance with this Policy, you may not be able to use our Services.

Our Websites and Services may contain links to other websites that do not operate under this Policy. These third-party websites may independently solicit and collect personal data from you. We encourage you to review the privacy statements of all third-party websites you visit to understand their information practices.

While we strongly support the protection of privacy on the Internet, we do not have control over, and cannot be responsible for, the actions of other third parties. We encourage you to review each such third party’s privacy statement and other otherwise understand its privacy practices, before providing personal data directly to it.

This Policy does not apply to information that is collected from Discovery Education’s employees, job applicants, or independent contractors.

3. Overview of Categories of Personal Data We Collect

We collect personal data to operate effectively and provide you with the best experiences with our Services. You provide some of this information directly, such as when you create an account, complete a survey, or contact us for support. We may get some of your information, such as your IP address, by recording how you interact with our Services. We may also get information about you from your school to register you for the Services. We may also get information about teachers, educators, and school administrators from other third parties, such as entities that serve as resellers of the Services and entities that license datasets of teachers, educators, and school administrators.

We may receive and collect certain personal data automatically, as outlined elsewhere in this Policy, including information collected by Google Analytics regarding our Websites and Services, information your Internet browser automatically sends when you visit our Websites and Services, and information collected by cookies. We may collect personal data that can identify you such as your name and email address, and other information that does not directly identify you.

Information Provided by You

We collect the following types of personal data from you when you access and browse our Websites (including when you submit personal data to us through data entry fields on the website), access the Services, enter a competition or contest, participate in a survey, and where we provide other services to you.

The most common of these circumstances where you would provide personal data and the categories of personal data we collect in those circumstances include the following:

  1. Purchasing, Registering or Using Our Services. In order to purchase, register, or use certain features of our Websites and certain Services, you (or your school) may be required to create a password-protected user account and provide us with personal data, including first name, middle initial, last name, username (Logon ID), password, teacher ID, teacher email, NAHT membership, pupil ID, pupil key stage, school, school postcode, local authority, and parent/guardian email. We will store and use this information to administer the Websites and Services in which you choose to participate, and as permitted by this Policy.
  2. Contacting Customer Service. When you contact our customer service, we may ask you to provide, or confirm, personal data, including your first and last name, job title, email address, phone number, city, school name, city, school postcode, and country, so that we can better serve you.
  3. Entering a promotion, contest or sweepstakes. If you enter a promotion, contest or sweepstakes we offer, we may ask you to provide personal data, including first name, last name, birth date and/or age, school address, email address, key stage, telephone number, and/or a video, so that we can consider your entry and, if you win, so that you may redeem your prize.
  4. Emails. For non-pupil users of the Services, we may collect your email address, first and last name, and school information if you sign up to receive online emails.
  5. Participating in a survey. If you participate in a survey, we may collect your session ID and ask you to provide your first name, last name, job title, email address, phone number, key stage you teach, your school name, and your school address details for internal analysis, research studies, and to support product and services development.
  6. Promotional or Marketing Communications. If you sign up to receive promotional communications or notifications from us, we may ask you to provide personal data, including first name, last name, and email address, so that we can provide these to you.

The above list provides examples of the personal data that may be collected when using the Websites and Services. If you do not want Discovery Education to collect your personal data, please do not provide it to us.

Information that We Collect Automatically From You On Our Websites and Services

We also may use various technologies to collect information from your computer or device and about your activities on our Websites and Services.

  1. Information collected automatically. We may automatically collect information from you when you visit our Websites and Services. We use this information to deliver our webpages to you upon request, to tailor our Services to the interests of our users and to measure traffic within our Services. This information may also include your IP address, your browser type and language, access times, the content of any undeleted cookies that your browser previously accepted from us, referring or exit website address, internet service provider, date/time stamp, operating system, locale and language preferences, and system configuration information.
  2. Interacting with Social Networking Sites. If you choose to join (or “like”) a Discovery Education page on a social media site, the social media site may provide us with certain information about you, including but not limited to your other “likes,” your email address, place of residence and other information from your public profile if you interact with our social media pages, DE Facebook, Twitter, LinkedIn, etc., so we can tailor our interactions to you. Please see the privacy policy for the applicable social media site to learn more about how these sites share your personal data.
  3. Cookies. When you visit our Websites and/or Services, we may assign your computer one or more cookies to help you navigate our website efficiently, to personalise your online experience, and to perform certain functions, including website traffic analysis. Through the use of a cookie, we also may automatically collect information about your online activity on our site, such as the web pages you visit, the links you click, and the searches you conduct on our site. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies please note that you may not be able to sign in or use some of the interactive features offered on our Websites and Services. A cookie is a small text file that is stored on a user’s computer for record keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our website. A persistent cookie remains on your hard drive for an extended period of time. For example, when you sign in to our Websites and Services, we will record your GUID (Globally Unique Identifier) in the cookie file on your computer. This cookie is removed when you sign-out. In the case of sites and services that do not use a user ID, the cookie will contain a unique identifier. We may allow our authorised service providers to serve cookies from our website to allow them to assist us in various activities, such as doing analysis and research on the effectiveness of our site, content and advertising. You may delete or decline cookies by changing your browser settings (click “Help” in the toolbar of most browsers for instructions). If you do so, some of the features and services of our Websites and/or Services may not function properly. To read more about how we use cookies, please review our Cookie Policy, www.discoveryeducation.co.uk/cookie-policy.
  4. Other technologies. We may use standard Internet technology, such as web beacons and other similar technologies, to track your use of our Websites and Services. We also may include web beacons in promotional e-mail messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customise the services we offer our Websites and Services visitors, to deliver targeted advertisements, and to measure the overall effectiveness of our online advertising, content, programming or other activities. Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies. Unlike cookies, which are stored on the user’s computer hard drive, web beacons are embedded invisibly on the web pages (or in email) and are about the size of the period at the end of this sentence. Web beacons may be used to deliver or communicate with cookies, to count users who have visited certain pages and to understand usage patterns. We also may receive an anonymous identification number if you come to our site from an online advertisement displayed on a third-party website.

Information Collected From Other Sources

We may also get information about teachers, educators, and school administrators from other third parties, such as entities that serve as resellers of the Services and entities that license datasets of teachers, educators, and school administrators. We may also obtain both personal and non-personal data about you from advertising companies, and ad networks business partners, contractors and other third parties and add it to our account information or other information we have collected. We may combine this information with information we collect through our Websites or from other sources to carry out the purposes as described herein.

4. Purposes and Our Legal Bases for Processing Personal Data

Purposes for using personal data

While the purposes for which we may process personal data will vary depending upon the circumstances, in general we use personal information for the purposes set forth below.

Our purpose when collecting, storing, and using information is to provide you the most engaging and rewarding experience with our Websites and Services and to ensure you have full access to our sites pursuant to our Terms of Use. We may use information that we collect about you to:

  • Deliver the Services you request, license or purchase, such as educational programmes, information, or newsletters;
  • For pupil users, we use the information to present personalised pages;
  • For non-pupil users of the Services who have opted-in to receiving Discovery Education information, and for other users of our Services who have provided contact information through the Websites or otherwise, to alert you to Service enhancements, new content, professional development opportunities, special events, educational programmes and news from Discovery Education;
  • For teacher or instructor users, with your explicit consent, we may collect your National Association of Head Teachers membership number during the order process, to validate and provide product discounts. You are not required to provide your NAHT membership number in order to purchase the product, but if you elect not to do so, you will not benefit from the discount.
  • Manage the Services and provide you with customer support;
  • Complete a transaction or service requested by you;
  • Ensure the Services are relevant to your needs;
  • Make improvements to Websites and Services;
  • Advertising and marketing purposes, including helping us create and publish content most relevant and impactful to you; developing and displaying content and advertising tailored to your interests on our site and other sites; measuring and improving the effectiveness of our advertising campaigns; developing sales leads; and serving ads to sales leads;
  • Notify you about a change to this Privacy Policy or our Terms of Use, if necessary;
  • Allow you access to limited-entry areas of the Services;
  • Contact you in response to sign up forms such as Contact Us or Order Inquiry;
  • Perform research and analysis about your use of, or interest in, our Services, digital content, and our Websites;
  • Communicate with you by e-mail, postal mail, telephone and/or mobile devices about our products or services that may be of interest to you;
  • Verify your eligibility and deliver prizes in connection with promotions, contests and sweepstakes;
  • Enforce our Terms of Use;
  • Manage our business and perform functions as otherwise described to you at the time of collection;
  • To aggregate and/or de-identify information about users or to use suggestions, comments, and ideas that are not personally identifiable. We are free to use and disclose through any means and use for any purpose information that is not personally identifiable in our sole discretion;
  • Track and analyse non-identifying and aggregate usage and volume statistical information from our visitors and customers and provide such information to third parties;
  • For legal compliance purposes;
  • Protect against or identify possible fraudulent transactions, and otherwise as needed to manage our business;
  • Keeping our websites, apps, products and IT systems secure;
  • Ensuring that our own processes, procedures and systems are as efficient as possible;
  • Analysing and enhancing the information that we collect, with the goal of reducing what information we collect;
  • For service administration requirements where we need to contact you for reasons related to our services (for example, where we need to send you a password reminder, to notify you about services updates or amendments to our Terms of Use, Cookies Policy or Privacy Policy); and/or
  • Notify you about products and services that we think may interest you (if you prefer that we not contact you in this manner, please follow the Opt-Out instructions in this Policy). Discovery Education never contacts pupils for this purpose.

Legal Basis for Processing

The General Data Protection Regulation (GDPR) and other relevant laws require that we inform you of the legal bases for our processing of your personal data. Where the GDPR is applicable, our legal basis for processing your personal data will depend on the personal data concerned and the specific context in which we collect it. Discovery Education relies on the following lawful basis for processing personal data: your explicit consent, processing is necessary for the performance of a contract to which you are a party, legitimate interest, and compliance with legal obligations.

When we have collected your personal data to provide you with Services that you have requested, our legal basis for the processing of that personal data is that it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract. If you refuse to provide us with your personal data, you may be unable to obtain the products and services from us that you requested.

We also collect and process personal data about you as necessary to operate our business, sales, account management, provide direct marketing, product development and improvement, product usage analytics, meet our contractual and legal obligations, and/or fulfill our other legitimate interests (when not overridden by your data protection interests or fundamental rights and freedoms).

When you participate in a survey, competition, sweepstake, promotion, and/or contest, our legal basis for the processing of your personal data is your explicit consent.

From time to time, you may provide us with your personal information in order to receive a discount on a product. In this instance, our legal basis for the processing of that personal data is your explicit consent. Where our processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. This does not affect the lawfulness of the processing based on consent before its withdrawal.

If you have any questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided below.

5. How Long We Retain Your Personal Data

We will retain your personal data for as long as is needed to fulfill the purposes set forth in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

Upon expiration or termination of any subscriber agreement, we destroy personal data previously received from the subscriber/customer when the subscriber signed up for the Services along with information relating to the subscriber/customer’s use of the Services no later than sixty (60) days following such termination, unless a reasonable written request is submitted by subscriber/customer/distributor to Discovery Education to retain such personal data.

For teacher or instructor users who provided their NAHT trade union membership number, Discovery Education purges the NAHT trade union membership number after it validates the membership with NAHT.

6. Sharing of Personal Data

We share your personal data as necessary to provide the Services you request, including sharing information with third party service providers, when required by law, to protect rights and safety, and with your consent.

We may share personal data with:

  • Authorised service providers: We may share your personal data with our authorised service providers that perform certain services on our behalf. These services may include delivering our Website or Services to you or providing customer service and support to the Services you have licensed, providing marketing to you, performing business and sales analysis, supporting our Website and Service functionality, conducting surveys and research for product development and improvement, and supporting contests, promotions, sweepstakes, surveys and other features offered through our Websites and Services. Any research reports and white papers that we create do not contain personal data.
  • Corporate Education Partners: When you engage in promotions, contests and/or sweepstakes offered through our Websites, we may share personal data with third party service providers that administer the promotion, contest and/or sweepstake, and we may share personal data of the winner of the promotion, contest and/or sweepstake with the partner who sponsored or funded the promotion, contest and/or sweepstake. When you elect to engage in a particular promotion, contest and/or sweepstake program, you authorise us to provide your name, email address and other information to that third party service provider and corporate education partner. We may also share aggregate usage and statistical reports relating to usage of the Websites, Services, and digital content with our partners. These reports do not contain personal data.
  • National Association of Head Teachers: Discovery Education offers a discount to NAHT members for the Pathway product. With your explicit consent, we may disclose your name and trade union membership number for NAHT that you provide during the order process with NAHT to validate your membership in order to provide the product discount.
  • Other situations: We also may disclose your information:
    1. In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
    2. When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our website terms and conditions or other agreements or policies, related to this Privacy Policy, to our Websites or to our Services.
    3. In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
    4. When you provide us with your consent to share your information with third parties.

Third-Party Privacy Policies: Any third parties to whom we may disclose personal data may have their own privacy policies which describe how they use and disclose personal data. Those policies will govern use, handling and disclosure of your personal data once we have shared it with those third parties as described in this Policy. If you want to learn more about their privacy practices, we encourage you to visit the websites of those third parties. These entities or their servers may be located either inside or outside your jurisdiction of residence.

Aggregated and Non-personal data: We may share aggregated and non-personal data we collect under any of the circumstances set forth in this Policy. We may share aggregated information with third parties, including advisors, partners, and potential customers, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to our Websites and Services and the most popular features or services accessed. This information does not contain any personal data and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.

7. Cross-border Transfer

Maintaining the security of your personal data is important to us. On occasion, we may engage service providers to perform certain services in respect of the products and services we offer, for example in relation to the provision of invoicing or helpdesk services, or in order to carry out internal reporting or product surveys. This engagement may necessitate the transfer of, storage or processing of data to or by those service providers, who may be located outside the UK or European Union. Some of those countries, including the United States, may not provide equivalent levels of data protection as those in your own country of residence. In such circumstances, we have put in place appropriate safeguards (through the use of Standard Contractual Clauses) to protect the personal data that is transferred to, stored and/or processed in other countries.

8. Your Privacy Rights

You may have certain rights in relation to your personal data. If you would like to exercise any of them, please contact us (contact details below).

We will consider all such requests and provide our response within a reasonable period (and in any event within any time period required by applicable law). Please note, however, that certain personal data may be exempt from such requests in certain circumstances.

If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.

How You Can Access or Request to Delete Your Information

If you have an online account with us, you have the ability to access, review, edit, correct, and update your personal data online by logging into your account, to the extent that information is held within our subscription services. You can also review and update your personal data by contacting your school.

If you are a user of the Services, you may request to have your personal data that you provided when you subscribed along with the information relating to your use of the Services removed from our databases, as well as request for the deletion/deregistration of any online accounts you have created (where applicable) by submitting a request to our contact information set forth at the end of this Policy, and insert “Privacy Rights Request” in the subject line. We will remove such information as soon as practicable for us, however, we may still retain certain information associated with your account for analytical purposes and record keeping integrity, as well as to prevent fraud, collect any fees owed, enforce our terms and conditions, take actions we deem necessary to protect the integrity of our web site or our users, or take other actions otherwise permitted by applicable law. In addition, if certain information has already been provided to third parties as described in this Policy, retention of that information may be subject to those third parties’ policies.

Your Choices About Collection and Use of Your Information

You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our website because such information may be required in order for you to participate in a contest, survey, or sweepstakes; ask a question; or initiate other transactions on our website.

Opt-Out

At any time you can choose to no longer receive commercial or promotional emails or newsletters from us by modifying your email preferences by selecting the “Opt-Out” link found in the footer of the communication or on our Websites and following the instructions or contacting us. Non-pupil users of the Services may be given a choice as to whether you want to receive e-mail messages about products and services related to your interest. You may modify your choice at any time by using the “Opt-Out” link as described above.

You also will be given the opportunity, in any commercial e-mail that we send to you, to opt out of receiving such messages in the future. It may take up to thirty (30) days for us to process an opt-out request or such shorter period as may be prescribed by applicable law. We may send you other types of transactional and relationship e-mail communications, such as service announcements, administrative notices, and surveys, without offering you the opportunity to opt out of receiving them. Please note that changing information in your account, or otherwise opting out of receipt of promotional email communications will only affect future activities or communications from us.

Even if you opt-out of receiving promotional or marketing communications, you may continue to receive emails and notifications relating to your subscription, service announcements, administrative notices, surveys, and/or other business-related communications.

9. Children’s Personal Data

In most instances, Discovery Education will only request the name and email address of a child in order to complete an immediate request from the child. The information that is collected will only be used for the requested purpose and will be deleted after such use.

For pupils using the Services, any personal data that may be provided, which may include, but is not limited to, first and last name, key stage and school, will be provided by the academy trust, individual school, or individual using the Service.

Use of Personal data Collected from Children

When we collect personal data from children, we will only use that information for the express purpose for which it was collected. The personal data will not be used for any other purpose.

Sharing of Personal data Collected from Children

Except as provided in this Section, we do not share personal data collected from children with any third parties. We may, however, share a child’s personal data that we have collected from the child’s school or from the child through the provision of Services in the following limited instances:

  • We may share such information with service providers who help Discovery Education maintain the Services and provide other administrative services to us. We seek to ensure that these service providers may not use the personal data for any other purpose. These service providers have agreed to maintain the confidentiality, security and integrity of the personal data.
  • We may disclose a child’s personal data to third parties in order to comply with law (including court orders and subpoenas); to comply with requests from law enforcement agencies or the government; to enforce our Terms of Use; to protect our rights, privacy, safety or property and the rights, privacy, safety or property of our employees or other users of our Services; to protect our operations; and to permit us to pursue available remedies or limit the damages that we may sustain.

Note to Parents and Legal Guardians

Please contact Discovery Education at any time regarding privacy questions or concerns, or to request to review what personal data we have collected from a child (contact information below). Parents may also contact their child’s school at any time to request that we delete the personal data of a child or a parent and/or refuse to permit further collection or use of a child’s information. Steps will be taken verify that any person requesting a child’s information is that child’s parent or guardian.

10. Other Important Information

Below, you will find additional privacy information you may find important.

Security

The security and confidentiality of your personal data is important to us. We follow generally accepted standards (including by taking physical, electronic and procedural measures) to protect the personal data provided to us.

While we are focused on the security of your personal data and follow strict standards, processes and procedures that are designed to protect your personal data, you must remember that the Internet is a global communications vehicle open to threats, viruses and intrusions from others and so we cannot promise, and you should not expect, that we will be able to protect your personal data at all times and in all circumstances.

Users should also take care with how they handle and disclose their personal data and should avoid sending personal data through insecure email.

No Rights of Third Parties

This Policy does not create rights enforceable by third parties.

Changes to this Policy

We will occasionally update this Policy to reflect material changes in our privacy practices. If we make any material changes in the way we collect, use, and/or share your personal data, we will notify you by email and posting the modified Policy on our Websites and Services and indicating at the top of the Policy the date it was last updated, and, where required by applicable law, obtain your consent. We may also notify you by sending you an e-mail. We encourage you to review the Policy each time you visit one of our Websites and Services to see if this Policy has been updated since your last visit to make sure you understand how your personal data will be processed.

11. Age Screening

If we become aware that we have inadvertently received personal data from a user under the age of thirteen other than in a legally permissible situation, we will delete the information from our records as soon as we discover it.

12. Additional Information for Residents in Certain Jurisdictions

In this section, we set forth additional information as required under applicable privacy laws in certain jurisdictions.

  1. Chile

    In this section, we provide information for residents of Chile, as required under Chilean privacy laws, in particular Law 19,628 on the protection of privacy.

    Your Privacy Rights

    You may have certain rights in relation to your personal data. If you would like to exercise any of them, please contact us (contact details below). We will consider all such requests and provide our response or acknowledge our receipt of your request within two business days.

    Your Right to Opt-Out

    If you elect to opt-out from marketing and/or promotional communications, we will no longer send you these types of communications from the time we receive your request.

    Sharing of Personal Data

    How Long We Retain Your Personal Data

    We will retain your personal data for as long as is needed to fulfill the purposes set forth in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

    Upon expiration or termination of any subscriber agreement, we destroy personal data previously received from the subscriber/customer when the subscriber signed up for the Services along with information relating to the subscriber/customer’s use of the Services no later than thirty (30) days following such termination, unless a reasonable written request is submitted by subscriber/customer/distributor to Discovery Education to retain such personal data.

    Changes to this Policy

    We will notify you about changes to this Privacy Policy and, if necessary, and obtain your consent to the updated versions.

  2. United Kingdom/European Union/European Economic Area

    If you are an individual located in the United Kingdom, European Union, or European Economic Area, you have the following rights, under the GDPR, regarding your personal information:

    You have the right to request access to your personal data, and the rectification of inaccurate personal data concerning you and obtain a copy of the personal data held by us. You have the right to obtain the deletion or the restriction of processing of your personal data in certain circumstances, including when the data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, except when we are required by law to maintain or otherwise process your personal data, for the establishment, exercise, or defense of legal claims, or for the protection of the rights or another person. You may have the right to request that we stop processing your personal data and/or to stop sending you marketing communications. In certain circumstances, you may have the right to be provided with your personal data in a structured, machine readable and commonly used format and to request that we transfer the personal data to another data controller without hindrance. You also have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work, or place of an alleged infringement of the applicable data protection law.

    If you would like to make such a request, please email: ukprivacy@discoveryed.com and insert “GDPR Privacy Rights Request” in the subject line or call this toll free number: 1-800-323-9084. To protect your privacy and security, we may take steps to verify your identity before taking action on your request.

  3. India

    In this section, we provide information for residents of India, as required under applicable privacy laws.

    In this Policy as it relates to individuals located in India, “personal data” means information which can directly or indirectly (or in combination with other information) is capable of identifying a person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, and an online identifier or to one or more factors specific to a person’s physical, physiological, genetic, mental, economic, cultural, or social identity.

    Disclosure of Personal Data We do not Collect

    If you are a resident of India, we do not ask for or collect sensitive personal data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, sexual orientation, criminal background or membership in past organizations, including trade union memberships).

    Children’s Personal Data

    If you are below the age of eighteen, we would request that you obtain the permission from your parent, or guardian to register and use our Services. We collect extremely limited data of users below the age of thirteen and recommend their use of our services only with parental, guardian or teacher supervision. Accordingly, we request parents and guardians to oversee and approve any usage of our Services by children.

    Please contact Discovery Education at any time regarding privacy questions or concerns, or to request to review what personal data we have collected from a child (contact information below). Parents may also contact their child’s school at any time to request that we delete the personal data of a child or a parent and/or refuse to permit further collection or use of a child’s information. Steps will be taken verify that any person requesting a child’s information is that child’s parent or guardian.

    Security

    In addition to the section on Security above, we have implemented a comprehensive documented information security program and information security policy that contains managerial, technical, operational and physical security control measures to secure the Sensitive Personal Information and Personal Data collected by us. Where we have given you (or where you have chosen) a username and password which enables you to access the Services, you are responsible for keeping these details confidential. We ask you not to share your password with anyone.

    We also carry out periodic checks and review of our security practices and upgrade these from time to time.

  4. Lebanon

    In this section, we provide information for residents of Lebanon, as required under Lebanese privacy laws, including the E-Transactions and Personal Data Protection Law.

    Personal data is required for us to be able to provide the majority of our Services to you. In addition, some of the Services we provide require that we disclose your personal data to third parties, such as to companies that help us to provide our Services and whose identity we will disclose prior to collecting/processing your personal data. If you are not willing to provide your personal data and have it disclosed to third parties in accordance with this Policy, you may not be able to use our Services and we may not be able to communicate with you.

    Overview of Categories of Personal Data We Collect

    We collect personal data to operate effectively and provide you with the best experiences with our Services. You provide some of this information directly, such as when you create an account or contact us for support. We may get some of your information, such as your IP address, by recording how you interact with our Services. We may also get information about you from your school to register you for the Services. We may also get information about teachers, educators, and school administrators from other third parties, such as entities that serve as resellers of the Services and entities that license datasets of teachers, educators, and school administrators. When we get such data from other third parties, you will be informed of the nature of the data collected, of the purpose of the processing as well as of your right to object to the collection/processing of your personal data.

    When we receive your personal data from a third party, you will be informed of the nature of the data collected, of the purpose of the processing as well as of their right to object to the collection and processing of the data. Personal data relating to minors shall not be collected and processed without their parents or guardians’ prior consent.

    Cookies

    We may allow our authorised service providers to serve cookies from our website to allow them to assist us in various activities, such as doing analysis and research on the effectiveness of our site, content and advertising. These service providers will be identified at the time you are asked to accept or decline cookies.

    Sharing of Personal data

    We share your personal data as necessary to provide the Services you request, including sharing information with third party service providers; when required by law; to protect rights and safety; and with your consent.

    We may share personal data with:

    • Authorised service providers: We may share your personal data with our authorised service providers that perform certain services on our behalf and that we will identify prior to communicating your personal data to them. These services may include delivering our Website or Services to you or providing customer service and support to the Services you have licensed, providing marketing to you, performing business and sales analysis, supporting our Website and Service functionality, conducting surveys and research for product development and improvement, and supporting contests, promotions, sweepstakes, surveys and other features offered through our Websites and Services. Any research reports and white papers that we create do not contain personal data.
    • Partners: When you engage in promotions, contests and/or sweepstakes offered through our Websites, we may share personal data with third party service providers that administer the promotion, contest and/or sweepstake; we will identify these service providers at the time that we offer these promotions, contests and/or sweepstakes. We may share personal data of the winner of the promotion, contest and/or sweepstake with the partner who sponsored or funded the promotion, contest and/or sweepstake. You will be informed of the identity of the sponsor prior to our communicating your personal data to it. When you elect to engage in a particular promotion, contest and/or sweepstake program, you authorise us to provide your name, email address and other information to that third party service provider and corporate education partner that we will identify at the time we offer the promotion, contest and/or sweepstake program. We may also share aggregate usage and statistical reports relating to usage of the Websites, Services, and digital content with our partners. These reports do not contain personal data.
    • Other situations: We also may disclose your information:
      1. In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
      2. When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our website terms and conditions or other agreements or policies.
      3. In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
      4. When you provide us with your consent to share your information with third parties.

    When sharing any personal data we ensure that the third party receiving such data has same or similar protections as those employed by us.

    Third-Party Privacy Policies: Any third parties to whom we may disclose personal data may have their own privacy policies which describe how they use and disclose personal data. Those policies will govern use, handling and disclosure of your personal data once we have shared it with those third parties as described in this Policy. If you want to learn more about their privacy practices, we encourage you to visit the websites of those third parties. These entities or their servers may be located either inside or outside the United States. We shall however inform third parties to which your personal data was transferred of any amendment made to such data pursuant to your request.

    Cross-border Transfer

    In addition to Section 6 above, when we transfer your personal data to other countries, we will notify you of the identity of these service providers and entities operating the server prior to such transfer.

    Your Privacy Rights

    If you are an individual located in Lebanon, you may have additional rights available to you under applicable laws, including:

    You have the right to obtain a copy of your personal data, and to amend, update or delete any personal data concerning you that is ambiguous, inaccurate, expired, or false. However, there may be circumstances where we may not honor your deletion request, including when we are required by law to maintain or otherwise process your personal data, for the establishment, exercise, or defense of legal claims, or for the protection of the rights or another person. You may have the right to request that we stop processing your personal data and/or to stop sending you marketing communications.

    We will process your request to erase, complete, correct, or update your personal data that is ambiguous, inaccurate, incomplete, or expired within 10 days. Please note, however, that certain personal data may be exempt from such requests in certain circumstances. If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.

    If you would like to make such a request, please email: ukprivacy@discoveryed.com and insert “Privacy Rights Request” in the subject line or call this toll free number: 1-800-323-9084. To protect your privacy and security, we may take steps to verify your identity before taking action on your request.

    Children’s Personal Data

    In addition to Section 9 above, we will obtain either, directly or indirectly through your school, the consent of parents or guardians prior to collecting the personal data of children under the age of 18.

    Changes to this Policy

    We will notify you about changes to this Privacy Policy. You will be required to acknowledge such amendments in order for us to continue processing your personal data and provide the related Services.

  5. Kingdom of Saudi Arabia

    In this section, we provide information for residents of the Kingdom of Saudi Arabia, as required under applicable laws.

    Your Right to Opt-Out

    We will not send commercial or promotional emails or newsletters between 10:00 p.m. and 8:00 a.m. local time. At any time you can choose to no longer receive commercial or promotional emails or newsletters from us by modifying your email preferences by selecting the “Opt-Out” link found in the footer of the communication or on our Websites and following the instructions or contacting us. If you elect to opt-out of receiving future commercial e-mail, we will process your request within 24 hours of receipt of the request.

    Even if you opt-out of receiving promotional or marketing communications, you may continue to receive emails and notifications relating to your subscription, service announcements, administrative notices, and/or other service-related communications.

    Changes to this Policy

    We will notify you about changes to this Privacy Policy. You will be required to acknowledge such amendments in order for us to continue processing your personal data and provide the related Services.

  6. People’s Republic of China

    In this section, we provide information for residents of the People’s Republic of China, as required under Chinese privacy laws, including without limitation theCybersecurity Law, the Civil Code, Personal Information Security Specification.

    In this Policy as it relates to residents of the People’s Republic of China, “personal data” means information (including sensitive personal information) relating to an identified or identifiable natural person or otherwise information that can be used to independently identify or be combined with other information to identify a natural person’s information. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, and an online identifier or to one or more factors specific to a person’s physical, physiological, genetic, mental, economic, cultural, or social identity. Personal data does not include aggregate information or anonymised information, meaning that the information can no longer be attributed or connected to an identifiable natural person and information is irretrievably anonymised.

    Information Provided by You

    With your consent (where required by applicable law), we collect the following types of personal data from you when you access and browse our Websites (including when you submit personal data to us through data entry fields on the website), access the Services, enter a competition or contest, participate in a survey and where we provide other services to you.

    How We Use Personal Data

    With your consent (where required by applicable law), we use the personal data we collect for a variety of purposes. (Refer to Section 4 above for a list of the purposes for which personal data will be processed).

    Sharing of Personal data

    We share your personal data as necessary to provide the Services you request, including sharing information with third party service providers; when required by law; to protect rights and safety; and with your consent.

    With your consent (where required by applicable law), we may share personal data with:

    • Authorised service providers: We may share your personal data with our authorised service providers that perform certain services on our behalf. These services may include delivering our Website or Services to you or providing customer service and support to the Services you have licensed, providing marketing to you, performing business and sales analysis, supporting our Website and Service functionality, conducting surveys and research for product development and improvement, and supporting contests, promotions, sweepstakes, surveys and other features offered through our Websites and Services. Any research reports and white papers that we create do not contain personal data.
    • Corporate Education Partners: When you engage in promotions, contests and/or sweepstakes offered through our Websites, we may share personal data with third party service providers that administer the promotion, contest and/or sweepstake, and we may share personal data of the winner of the promotion, contest and/or sweepstake with the partner who sponsored or funded the promotion, contest and/or sweepstake. When you elect to engage in a particular promotion, contest and/or sweepstake program, you authorise us to provide your name, email address and other information to that third party service provider and corporate education partner. We may also share aggregate usage and statistical reports relating to usage of the Websites, Services, and digital content with our partners. These reports do not contain personal data.
    • National Association of Head Teachers: Discovery Education offers a discount to NAHT members for the Pathway product. With your explicit consent, we may disclose your name and trade union membership number for NAHT that you provide during the order process with NAHT to validate your membership in order to provide the product discount.
    • Other situations: We also may disclose your information:
      1. In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
      2. When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our website terms and conditions or other agreements or policies, related to this Privacy Policy, to our Websites or to our Services.
      3. In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

    Cross Border Transfer

    If your data is subject to any offshore/cross-border transfer as set out in the main body of this Privacy Policy, we will obtain explicit consent from you with respect to such offshore transfer of personal data and undertake certain security assessments mandated by local laws and regulations.

    Additional Privacy Rights

    In addition to the privacy rights described in Section 7, you have the right to request access to your personal data, and the rectification of inaccurate personal data concerning you and obtain a copy of the personal data held by us. You have the right to obtain the deletion or the restriction of processing of your personal data in certain circumstances, including when the data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, except when we are required by law to maintain or otherwise process your personal data, for the establishment, exercise, or defense of legal claims, or for the protection of the rights or another person. You may have the right to request that we stop processing your personal data and/or to stop sending you marketing communications. In certain circumstances, you may have the right to be provided with your personal data in a structured, machine readable and commonly used format and to request that we transfer the personal data to another data controller without hindrance.

    If you are an individual located in the People’s Republic of China, you may also have additional rights available to you under applicable laws as set out above. You may submit your request by using these contact details: please email: ukprivacy@discoveryed.com and insert “Privacy Rights Request” in the subject line or call this toll free number: 1-800-323-9084. To protect your privacy and security, we may take steps to verify your identity before taking action on your request.

    Use of Personal data Collected from Children
    Where required by applicable law, we will obtain express consent from the child’s parent or legal guardian before any collection, use, transfer and processing of the child’s personal data. When we collect personal data from children, we will only use that information for the express purpose for which it was collected. The personal data will not be used for any other purpose.

    Age Screening

    If we become aware that we have inadvertently received personal data from a user under the age of fourteen other than in a legally permissible situation, we will delete the information from our records as soon as we discover it.

13. Contact Us

If you have any questions about this Policy or our privacy practices, please contact us by e-mail or postal mail as follows:

  • ukprivacy@discoveryed.com
  • Discovery Education Europe Limited (Attn: Marissa Jones), One Lyric Square, Hammersmith London W6 0NB, United Kingdom
  • Tel: 0800 6 527 527

If you’re based in the EU/EEA and wish to contact us via our GDPR Representative, DataRep, you may do so at: