Blackboard Web Community Manager Privacy Statement

Blackboard has been retained by the School to provide and host the Solution on the School’s behalf and under the School’s control. The School customizes the content, controls who can register for and use the various features of the Solution and who can access the Personal Information posted or maintained on the Solution. Subject to the particular policies and functionality selected by the School, Blackboard may collect Personal Information from the users of the School’s Solution, which could include School administrators, teachers, and other individuals associated with the educational institution providing the Solution, students, parents and guardians who use the Solution provided by the School, and visitors to the School’s websites and online services offered through the Solution (collectively referred to as “users” or “you”). We do not collect, maintain, use or share Personal Information collected through the Solution for any purpose beyond what is needed to provide the functionality of the Solution and as otherwise described herein or as authorized by our agreement with the School.

The type of information Blackboard may collect when we host the School’s Solution could include:

• Information you provide. You may visit portions of the Solution as a guest without registering. Registration, however, will give you access to certain features as well as the ability to personalize content. When you register, we will collect certain Personal Information on behalf of the School, which could include your name, contact information, and e-mail address, and could include demographic information such as your education level, gender and interests. Depending on the portions of the Solution your School has purchased, and the settings and functionality established by the School, we may collect additional information such as your mobile phone number, and any other information the School has configured the Solution to request. 
  Your School may elect to provide Personal Information to us on your behalf in order to use certain features and functions of the Solution. By way of example, a School-designated official may input registration information for you, either manually or through a system feed. After registration, the site administrator for the school may decide to assign to you a role(s) or group(s). Based upon your designated role(s) or group(s), you may have access to additional information or services. If you have questions concerning your role(s) or group(s), please contact the School. 
  Your School may provide additional information to us in other situations, for example, in connection with a customer support request or a content submission request. 
  We use this information to operate, maintain, and provide to you and other users the features of the Solution, including to provide you with the features of the Solution selected and controlled by the School. We may use this information to communicate with you, such as to send you email messages, push notifications, text messages, and to permit other Users of the Solution to contact you, to improve and develop our product and services, to improve customer service, and for other systems maintenance purposes. 
  Please see Section 4 for information on how we collect and process Student Data through the Solution.
• Information we collect from third party services and social media sites. We may collect information about you from third party services that you connect to the Solution or interact with through the Solution, such as liking or sharing content on Facebook, Twitter or other third party social networks. We may collect information that a third party service provides to us when you access your account through the third party service, for example if you use a single-sign on like G Suite Google Apps for Education or PassKey Manager™ or similar solution to access your account. These services will authenticate your identity and provide you the option to share certain Personal Information with us, which could include your name, email address, address book and contacts, or other information. The data we receive is dependent on that third party’s policies and your privacy settings on that third party site, as well as the features, functionality and third party integrations offered by your School through the Solution.
• Information collected through your use of the Solution. In addition to the information you actively provide, we also collect information about how you use the Solution, your actions taken through the Solution, your communications with others through the Solution, and any additional data or information that is generated by your use of the Solution. 
  Depending on the features and functionality utilized by a School, users may be able to post, download or upload various pieces of content and/or information on or through the use of the Solution, and/or interact with third party social media services or other collaboration or communication tools, or communicate with one another. For example, teachers or administrators may post blogs, announcements and other information and content directly onto the Solution, and/or users may chat with each other, or send instant messages, text messages or e-mail, via technology which may now or in the future be made available over the Solution, and may share information, photographs, images or recordings with each other or with others in the community. The use of these features is controlled by the School and not by Blackboard. Blackboard has no practical ability to restrict the information, conduct, communications, or content which might be posted on or exchanged through the use of its technology Solution, nor can Blackboard ensure prompt removal of any such communications, information or content after transmission or posting. If you are concerned about any information or content that may be posted, transmitted or accessed on the Solution, please contact the School.

Information sharing directed by School. Blackboard processes and shares Personal Information under the direction and control of your School. Depending on the features and functionality selected by your School, the Solution may facilitate the exchange of information between and among users and third parties, and your School may adjust features, settings and permissions which govern how Personal Information is accessed and shared among users and third parties. For example, your School may maintain social commenting features to enable users to communicate with teachers, parents, or community members. Similarly, your School can control which individuals can be registered to use certain Solution features and which individuals or groups are granted privileges to access, view or use Personal Information collected, exchanged or maintained on the Solution. Users who have been assigned administrative privileges by your School have access to all registered user information on their Solution, and may be able to grant access rights to other users. Your School may integrate third party features or permit third party partners to collect Personal Information on the Solution in order to provide a service, such as social networks, content providers, or educational partners. Additionally, your School or its authorized users may provide consent or authorization for us to share Personal Information with a specific individual or third party upon request.

Accordingly, we share Personal Information as needed to provide these features and functionality of the Solution and as directed by the School and its authorized users. Contact your School for more information regarding information access and sharing controlled by your School.

Other instances in which information may be shared. In addition to the information sharing practices discussed above, Blackboard may share or disclose Personal Information collected through the Solution in the following ways:

• With service providers and advisors. Blackboard utilizes other companies to provide services on its behalf, including but not limited to customer support, web analytics, hosting, coordination of mailings and event management. These companies are permitted to access information only as needed to perform those services. Blackboard requires these companies to maintain the confidentiality of Personal Information and prohibits them from using the information for any other purpose than helping us provide the Solution to you and your School, or performing business services on our behalf.
• With law enforcement, regulators and other parties for legal reasons. Personal Information may be disclosed to such third parties as required by law or subpoena or if we believe in good faith that disclosure is reasonably necessary to (i) comply with legal process, (ii) enforce the Terms of Use or our agreements, (iii) respond to claims that any content provided by using the Solution violates the rights of third parties, or (iv) protect the rights, property, or personal safety of Blackboard, its users, or the public.
• With third parties in connection with a business transaction. Blackboard may share Personal Information other than Student Data, as defined below, with other parties in connection with any company transaction, such as a merger, sale of all or a portion of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of bankruptcy or related or similar proceedings. We will not share Student Data with a third party pursuant to such a transaction unless the party agrees to honor the privacy commitments made in this Privacy Policy or we will use our best efforts to provide your School with notice and an opportunity to opt-out of the transfer of Student Data by terminating your School’s Solution accounts before the transfer occurs.

Additionally, Blackboard may share Personal Information that has been de-identified or aggregated to determine the demographic composition of our user base, to distribute statistics and general marketplace information about Blackboard’s products and services, and to perform research and improve the Solution and our other services. This de-identified or aggregate information does not reasonably identify specific users.

Blackboard does not knowingly collect any information from children under the age of 13 unless and until your School has provided appropriate consent and authorization for a student under 13 to use the Solution and for Blackboard to collect this information. Your School controls the use of such information. We rely on your School to obtain any necessary parental consent before permitting a child under 13 to access or provide information through the Solution, and to otherwise comply with the privacy obligations under COPPA and other applicable (state) laws, including to provide notice and a means for a parent to access information collected from a child and to request such information be modified or deleted. If you have any questions regarding the collection and use of Personal Information from a child under 13 through the Solution, please contact your School.

Please contact us at [email protected] if you believe we have inadvertently collected Personal Information from a child under 13 without proper consents so that we may delete such information as soon as possible. Certain deletion requests may require your School’s authorization.

• Interactive Communications. Depending on the features and functionality selected by your School to offer through the Solution, you and other registered users may be able to collaborate and communicate through email, phone, chat, or other communication method. These communications are directed and controlled by the School and by users. You should contact your School with questions regarding communications you receive through the Solution.
• E-Alerts. The E-Alert feature is a Solution feature available on certain platforms. There are two types of E-Alerts: (1) Broadcast E-Alerts are used by School administrators to send messages to a specific group or multiple groups of users; and (2) Content E-Alerts are messages to users when certain changes are made to one or more homepages or sections to which they subscribe. These E-Alert communications are directed and controlled by the Schools and by authorized School users, who control whether to send an E-Alert and the contents within the message. You may be able to opt-out of E-Alerts through options in your account settings. Otherwise, you should contact your School with questions regarding E-Alert communications you receive through the Solution.
• Blackboard Communications. From time to time, Blackboard may send communications to you and other users. It may be necessary for Blackboard to send out a service-related announcement. For instance, if our service is temporarily suspended for maintenance, we might send administrators and other designated School users a notification email. For example, Blackboard may send promotional emails to School administrators or other decision-makers. You may opt-out of receiving future promotional emails by clicking on the unsubscribe link in the email.

Data Retention. We retain Personal Information on behalf the School only as necessary to provide the service requested, comply with our legal obligations, resolve disputes and enforce our agreements, all in compliance with applicable laws. When a School administrative user deletes your account, the information contained in your user account is no longer available except to the extent it is stored in backed-up data repositories, which are destroyed pursuant to our standard data retention schedule. Please contact your School if you have questions about data retention and deletion. Any request we receive to delete Personal Information may require authorization from the School providing the Solution.

Data Security. The School will remain responsible for the privacy and security of your Personal Information, including Student Data, that it collects and processes through the Solution, and for compliance with applicable data privacy laws that may apply to the collection, processing and disclosure of information through the Solution.

Blackboard maintains administrative, technical and physical procedures to protect Personal Information. Security safeguards may include but are not limited to data encryption, firewalls, data use and access limitation, and physical access controls to buildings.

Data Storage and Transfer. Unless and except to the extent limited in our agreement with your School, your information may be stored and processed in the United States or any other country in which Blackboard or its subsidiaries, affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including your Personal Information, to a country and jurisdiction that are not considered to have equivalent data protection laws as your jurisdiction. Blackboard complies with applicable data transfer requirements. Blackboard is Privacy Shield certified and additionally uses EU-approved standard contractual clauses to legitimately transfer EU Personal Information to jurisdiction that are not considered equivalent. Please refer questions to your School to determine how your School protects EU Personal Information, if any, which may be stored or maintained by Blackboard or its other service providers in the United States or elsewhere outside of your jurisdiction.

We reserve the right to change this Privacy Policy from time to time in our sole discretion. We will post changes on this page and indicate the “last modified” date at the top of this page. Please check back often for any updates. Your continued use of the Solution after any change in this Privacy Policy will constitute your acceptance of such change.

We will not make any material changes to this Privacy Policy that relate to the collection or use of Student Data without first giving notice to the School and providing a choice before Student Data is used in a materially different manner than was disclosed when the information was collected.