Effective Date: May 22th, 2018
DATA YOU PROVIDE TO US. We collect information from you, such as first and last name, gender, e-mail and mailing addresses, phone number, professional title, company name, educational institution or organization name, and password when you provide such information to our Site or to an Instructure employee, or otherwise provide this information to Instructure, such as via email. When you participate in one of our surveys, we may collect additional profile information, such as information indicating your interest in specific Instructure services. We collect information about you when you apply for positions within Instructure. We also collect other types of personal data and demographic information that you provide to us voluntarily. This includes information provided to Instructure employees in the course of routine interactions with them or provided in response to an email from Instructure.
DATA COLLECTED VIA TECHNOLOGY. To make our Site more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including browser type, operating system, Internet Protocol (IP) address, domain name, geographic location, and/or a date/time stamp for your visit. We also use web beacons and cookies and navigational data like Uniform Resource Locators (URL) to gather information regarding the date and time of your visit and the solutions and information for which you searched and which you viewed.
WEB BEACONS are digital images we use to log information on our Site and in our emails. We use web beacons to manage cookies, count visits, and to learn what marketing works and what does not. We also use web beacons to tell if you open or act on our emails.
COOKIES are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site.
Our Site uses the following types of cookies:
STRICTLY NECESSARY COOKIES: These cookies are essential in order to enable you to move around the Site and use its features. Without these cookies, services like enabling appropriate content based on your type of device cannot be provided.
PERFORMANCE COOKIES: These cookies collect information about how visitors use the Site, so that we can analyze traffic and understand how our visitors use the Site. We may use third party service providers for this purpose who may set their own cookies on the Site. These cookies do not collect information that identify an individual visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the Site works.
FUNCTIONALITY COOKIES: These cookies allow our Site to remember choices you make (such as your user name, or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.
SOCIAL MEDIA COOKIES: These cookies are used when you share information using a social media sharing button or “like” button on our Site or you link your account or engage with our content on or through a social media site such as Facebook, Twitter or Google+. The social network will record that you have done this. This information may be linked to targeting/advertising activities conducted by third parties on Instructure’s behalf.
TARGETING AND ADVERTISING COOKIES: These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers.
If you don’t want to receive cookies, you can alter your browser settings. The procedure for doing so varies from one browser application to another. If you wish to reject cookies from our Site, but wish to accept those from other sites, you may be able to choose the option in your browser settings to receive a notice before a cookie is stored on your device. By disabling cookies, you may be prevented from accessing some features of our Site or certain content or functionality may not be available.
We may also work with third parties that collect data about your use of the Site and other sites or apps over time for non-advertising purposes. Instructure uses Google Analytics and other third-party services to improve the performance of the Site and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you use our Site, visit https://www.google.com/policies/privacy/partners/, and to opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.
TESTIMONIALS. We display personal testimonials of satisfied customers on our Site in addition to other endorsements. With your consent we may post your testimonial along with your name.
USE OF YOUR DATA.
In general, personal data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. Instructure uses your personal data for any lawful purpose, including, but not limited to, the following purposes: to create and maintain your account; to identify you as a user in our system; to operate, maintain, and improve our Site and services; to personalize and improve your experience; to send you administrative e-mail; to process applications; to respond to your comments or inquiries; to send you surveys, promotional communications about our products and services or the products and services of third parties (“PARTNERS”); to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity; and to make telephone calls to you, from time to time, as a part of secondary fraud protection or to solicit your feedback with your permission.
We may partner with ad networks and other ad serving providers (“ADVERTISING PROVIDERS”) that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information Advertising Providers collect about your use of the Site and other sites over time, including information about relationships among different browsers and devices. This type of advertising is known as interest-based advertising.
We do not use automatic decision-making or engage in profiling.
Where we intend to use or otherwise process your personal data for a purpose other than the purpose for which it was collected, we will provide you with information regarding the purpose for the processing, as well as other relevant information, prior to processing your personal data for the new purpose.
DISCLOSURE OF YOUR DATA.
THIRD PARTY SERVICE PROVIDERS. We may share your personal data with third party service providers. For example, we may share data with service providers who host our websites or provide email services on our behalf.
PARTNERS. We may also share your personal data with our Partners. Our Partners may use your personal data for their own direct marketing purposes.
We may also share information about you in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving sale, transfer, divestiture or disclosure of all or a portion of our business or assets to another company. In the event that information is shared in this manner, notice will be posted on our Site.
We may also share de-identified and/or aggregated data with others for their own uses.
NOTICE TO EU AND EEA RESIDENTS.
LAWFUL BASIS FOR PROCESSING. We may process your personal data to respond to your inquiries concerning our products and services. Additionally, we process your personal data for direct marketing and communications purposes when these interests are not overridden by your data protection rights. Where we process your personal data for this purpose, our legitimate interest is to carry out our activities in furtherance of the well-being of all our employees and members.
On certain occasions, we process your personal data when it is necessary for the performance of a contract to which you are a party, such as to provide services to you that you have requested.
On other occasions, we process your personal data where required by law. We may also process your personal data if necessary to protect your interests or the interests of a third party.
If the processing of personal data is necessary and there is no statutory basis for such processing, we will ensure that your consent is obtained to process your personal data. You have the right to withdraw your consent to processing of personal data at any time. If you wish to exercise the right to withdraw consent, contact us via the “Contact” section below, or click the unsubscribe link in any email communications you receive from us.
RIGHTS. You have the right to request access to the personal data we hold about you. You have the right to request that we rectify or erase your personal data. You also have the right to request that we restrict or block the processing of your personal data. Under certain circumstances, you have the right to receive personal data about you that we store and transmit to another without hindrance from us, including requesting that we provide your personal data directly to another, i.e., a right to data portability; and where we previously obtained your consent, to withdraw consent to processing your personal data.
See the “Contact Information” section below. Please be aware that Instructure may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so. Additionally, you have the right to lodge a complaint against us. To do so, contact the supervisory authority in your country of residence.
RETENTION. We will process and store your personal data only for the period necessary to achieve the purpose of the storage, or as permitted by law. The criteria used to determine the period of storage of personal data is the respective statutory retention period or for certain marking data for our services or other products. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of a contract or the initiation of a contract.
TRANSFERS OF PERSONAL DATA. Please be aware that the personal data we collect may be transferred to and maintained on servers or databases located outside your state, province, country, or other jurisdiction, where the privacy laws may not be as protective as those in your location. If you are located outside of the United States, please be advised that we process and store personal data in the UE.
Residents of the EU and Switzerland have the right to access the personal data that Instructure maintains, and in some cases, may have the right to correct or amend information that is inaccurate or has been processed in violation of the Privacy Shield Principles, to the extent allowed by law. To exercise this right, contact us at firstname.lastname@example.org.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Instructure is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Instructure may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, you may also contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
NOTICE TO CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS (AS PROVIDED BY CALIFORNIA CIVIL CODE SECTION 1798.83).
SOCIAL NETWORKING PLATFORMS.
We may allow you to connect and share information with certain social networking platforms (“SOCIAL NETWORKING PLATFORMS”) (e.g., a Facebook application). By choosing to use these Social Networking Platforms, you allow Instructure to share information with the Social Networking Platform. For example, you might use an application to publish Instructure related notices on your Facebook wall. If you do not want us to continue to provide your information to the Social Networking Platform, you may change your privacy settings in the Social Networking Platform.
You can also access certain features of our Site using Social Networking Platforms. These services will authenticate your identity and provide you the option to share certain personal data with us such as your name, email address, and other personal data to pre-populate an application.
YOUR CHOICES REGARDING YOUR PERSONAL DATA.
CHOICES. We offer you choices regarding the collection, use, and sharing of your personal data. When you receive newsletters or promotional communications from us, you may “opt-out” by following the unsubscribe instructions provided in e-mails you receive from us or by contacting us directly at the contact information below.
Most web browsers are set to accept cookies by default. If you prefer, you can typically remove and reject cookies from our Site with your browser settings. If you remove or reject our cookies, it will affect how our Site and services work for you.
CHANGES TO YOUR PERSONAL DATA.
You may change some of your personal data in your account by editing your profile within the Service. You may also request changes or deletions by e-mailing us at the e-mail address set forth below. We will respond to your request, when permitted by law, within 30 days. We may be unable to delete information that resides in our archives.
SECURITY OF YOUR PERSONAL DATA.
Instructure takes reasonable steps to help protect your personal data in an effort to prevent unauthorized access, use, or disclosure. Despite these measures, you should know that Instructure cannot fully eliminate security risks associated with personal data. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. Any content you post while using the services is at your own risk. If you have any questions about security on our Site, you can contact us at the contact information set forth below.