- Test Scores: Academic and cognitive test scores prior to and during the program are collected, tracked and analyzed.
- Recordings: All group, 1:1 and online meeting sessions may be recorded with audio and/or video, including interactions on Zoom or any similar system.
- Activity Tracking: Screenshots, including browser, screen or computer activity, will be taken while a student is working. Keyboard and mouse activity will also be tracked. Webcams, computer microphones and online meeting tools may be used to record the student as part of the Alpha Technology. In the pro sports analogy, this is game film which allows analysis, instruction and improvement of both learning and instruction.
- Productivity Gamification: Productivity may be tracked in order to display a leaderboard to users, or provide rewards, and the purchase or other history related to the redemption of those rewards may be tracked and analyzed.
- Biometrics: Biometric data, information and identifiers may be collected to analyze and improve learning, or as part of assessments, evaluation and testing.
- Marketing: You may choose to take part in marketing videos or photos for the Alpha website, social media and other online and offline properties or media describing their interactions with Alpha. You may also appear in videos or photos if you are participating in on campus or group activities. You expressly give permission for Alpha and any such media to use your image or likeness in any digital media format (e.g., photo, video, website, email and web-related publications) or associated format (photo or screenshot for a physical newsletter referencing the online media) in connection with the purposes described above, without payment, including the right to digitally alter the image, and release any and all copyright ownership or claims. For clarity, this release and permission also extends to your child.
We intend to proceed with additional data collection in the future, or in specific student cases, which may involve the use of additional software, hardware, or mobile phone applications/usage. For example, if a student has poor sleep habits impacting learning, sleep tracking using an iPhone or activity tracker may be implemented in order to analyze and suggest improvements. Or if students are taught meditation in order to encourage a focused state of mind, a headband monitor and app may be used to collect data for analysis.
Our intent is to utilize the Alpha Technology now and in future iterations to leverage data and technology to its fullest in order to put your student in the position to learn, which may include automated analysis and actions as a result of the processing of this data. If you do not wish to put data and technology to work in this manner, please explore alternative options for your education.
- Our Collection of Parent, Student and Your Information
Personal Data. The information we collect may include your personal data, such as your name, contact information, IP addresses, information concerning your education and usage of the Alpha Technology, and other data that may identify you.
We collect personal data about you at several different points, including but not limited to the following:
- as described above in the examples of the importance of the Alpha Technology;
- when we engage in educational instruction or correspond with you;
- when you use the Alpha Technology, including but not limited to when you register as an user of Alpha Technology and an account is created for you;
- when you schedule a tour with us, you may need to provide your name and your child’s name, and your email address and phone number;
- when you enroll in any newsletter or other periodic communication;
- when you contact us for help;
- when the Alpha Technology captures analytics data or sends error reports;
- when you choose to provide materials or information as part of the Alpha Technology; and
- as described in Section 13 (Children’s Privacy) and Section 14 (Parental Rights).
- Information Collected Automatically or From Others
Automatic Data Collection. We may collect certain information automatically when you use the Alpha Technology. This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Alpha Technology, information about the links you click, and other information about how you use the Alpha Technology. Information we collect may be associated with accounts and other devices. Alpha Technology may collect precise geolocation information in accordance with applicable law.
In addition, we may automatically collect data regarding your use of Alpha Technology, such as the types of content you interact with and the frequency and duration of your activities. Unless contrary to applicable law or contractual agreement, we may combine your information with information that other people provide when they use Alpha Technology.
- Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Alpha Technology may not work properly.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Alpha Technology that collects information about users’ engagement on the Alpha Technology. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular item.
Information from Other Sources. We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you. For example, the Alpha Technology may collect information about you from third-party learning applications and compile that information as part of the Alpha Technology. Additionally, if you access Alpha Technology through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through Alpha Technology may include your name, your user identification number, your user name, location, gender, birth date, email, profile picture, and your contacts stored in that service. This supplemental information allows us to, among other things, verify information that you have provided to us and to enhance our ability to provide you with appropriate information as part of the school and Alpha Technology.
Children’s Privacy and Parental Rights. As further described in Section 13 (Children’s Privacy) and Section 14 (Parental Rights) and above in the description of the importance of the Alpha Technology.
- Our Use of your Personal Data
Alpha may use information that we collect about you to:
- Fulfill educational objectives, such as:
- delivering the educational services by way of the Alpha Technology;
- managing our relationship with you and provide you with support and other assistance;
- communicating with you by email, postal mail, telephone or mobile devices about your education, Alpha and the Alpha Technology;
- undertaking activities to verify or maintain the quality or safety of Alpha and the Alpha Technology;
- managing Alpha and the Alpha Technology, and
- allowing you to register for events or other opportunities.
- Analyze and improve the school and Alpha Technology pursuant to our legitimate interest, such as:
- utilizing the information to improve your education;
- detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
- performing research and analysis about your use of, or interest in, Alpha Technology or content offered by others, and short-term, transient use, such as contextual customization;
- undertaking research for educational and technological development and demonstration;
- improving, upgrading or enhancing Alpha Technology or the applications, offerings and services of our service providers;
- verifying your identity and preventing fraud;
- debugging of the Alpha Technology to identify and repair errors that impair existing intended functionality; and
- enforcing our terms and legitimate interests.
- Provide you with additional content and educational opportunities, such as:
- developing and displaying content and educational materials tailored to you as part of the Alpha Technology;
- auditing of Alpha and the Alpha Technology relating to interactions, transactions and other compliance activities; and
- performing functions you consent to or that are otherwise described to you at the time of collection.
- As further described in Section 13 (Children’s Privacy), Section 14 (Parental Rights) and above in the description of the importance of the Alpha Technology.
Use De-identified and Aggregated Information. We may use personal data and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Alpha Technology, or other analyses we create.
Share Content with Others. Alpha Technology may offer various tools and functionalities to share with other users.
- Our Disclosure of Parent, Student and your Personal Data to Third Parties
- Affiliates and Service Providers. We may provide your information to affiliated entities within our corporate group, as well as with vendors who perform functions on our behalf; such parties provide hosting and maintenance services, virtual infrastructure, payment processing, analysis and other services for us.
- Independent Contractors. We may utilize independent contractors subject to confidentiality obligations as an alternative to employees.
- Business Partners. We may share your data with any parent company, subsidiaries, joint ventures, and other entities under a common control or third-party acquirers;
- Disclosure for Merger, Sale or Other Asset Transfer. We may allow a potential acquirer or merger partner to review our information, although we would restrict their use and disclosure of this data during the diligence phase;
- Disclosure to Protect Us or Others. As required by law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to Alpha; or when we believe, in our sole discretion, that the disclosure of personal data is necessary to prevent physical harm or financial loss; to report suspected illegal activity or to investigate violations of our agreements or Alpha policies; to enforce our terms and conditions, to protect the security or integrity of our products and services.
- Based on Consent. When you give us permission to do so.
- Children’s Privacy and Parental Rights. As further described in Section 13 (Children’s Privacy) and Section 14 (Parental Rights) and above in the description of the importance of the Alpha Technology.
Please note that these third parties may be in other countries from you.
Potential for Other Users to Contact You. To the extent that a given application supports personal messaging functionality or email between and among users of the Alpha Technology, you may receive personal messages from other users. You may be able to disable this functionality by using the unsubscribe and other disabling instructions in the given application.
Prohibited Disclosures. We will not sell personally identifiable information of children or parents to third parties. Furthermore, we will not disclose any information for behavioral targeting of our students.
- Our Security Measures to Protect your Personal Data
Alpha uses industry-standard technologies when transferring and receiving data exchanged between Alpha and other companies to help ensure its security. The Alpha Technology has security measures in place to help protect information under our control from the risk of accidental or unlawful destruction or accidental loss, alteration or unauthorized disclosure or access. However, “perfect security” does not exist on the Internet. Also, if the Alpha Technology contains links to other sites, Alpha is not responsible for the security practices or the content of such sites.
- Our Use of Automatic Collection, Links and Other Technologies
- Automatic Collection Technologies. We, as well as third parties on the Alpha Technology, may use Analytics Systems to automatically collect information through the Alpha Technology. Our uses of these Analytics Systems fall into the following general categories:
- Operationally Necessary. This includes Analytics Systems that may allow for the identification of irregular site behavior, prevent fraudulent activity and improve security or that are essential to allow you to make use of our functionality;
- Performance Related. We may use Analytics Systems to assess the performance of Alpha Technology, including as part of our analytic practices to help us understand how students use the Alpha Technology;
- Functionality Related. We may use options or other systems that allow us to offer you enhanced functionality when accessing or using Alpha Technology. This may include identifying you when you sign into Alpha Technology or keeping track of your specified preferences, interests, or past items viewed;
- Targeting Related. We may use first party or third-party Analytics Systems to deliver content, including content determined relevant to you, on Alpha Technology.
- Website Links. We may create links to other websites. Additionally, many other sites that are not associated with or authorized by Alpha may have links leading to our site. Alpha cannot control the material in connection with these links and we are not responsible for any content appearing on these sites. You are subject to the privacy practices of that third party. We encourage you to ask questions before you disclose any personal data to others.
- Cross-Device Tracking. Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.
- Notice Regarding Third Party Websites, Social Media Platforms and Software Development Kits. Alpha Technology may use third parties to present or serve content and technology, software or services. These third parties may gather information concerning the content delivered, your use of the Alpha Technology, and other information in connection with their services and your usage.
We may use third party software, APIs and software development kits (“SDKs”) as part of the functionality of Alpha Technology. The software, APIs and SDKs may allow third parties including analytics and advertising partners (to the extent disclosed) to collect your personal data for various purposes including to provide analytics services and content that is more relevant to you. For more information about our use of third-party software, APIs and SDKs, please contact us as set forth below.
- Data Retention
Information will be maintained for the period required to achieve the purpose for which the information was collected. We will follow a data retention schedule which may retain some permanent academic school records indefinitely and deidentify or destroy other records according to a retention schedule that ranges from graduation / disenrollment to 4-5 years later. Information that is transitory and not needed to fulfill a long term purpose will be deidentified or destroyed sooner.
- International Transfers of your Personal Data
Information about you may be stored and processed in the United States, European Economic Area, or any other country in which our agents, contractors or service providers maintain facilities, and by accessing our websites and using our mobile apps, software and Alpha Technology, you consent to the transfer and/or or access of your information outside of your country.
- Accuracy of Personal Data
We do our best to ensure that the personal data we hold, and use is accurate. We rely on you to disclose to us all relevant information and to inform us of any changes.
- Your Access to your Personal Data and Deletion Upon Request at Departure
Reasonable access to your personal data may be provided upon request made to Alpha at the contact information provided below. If access cannot be provided within a reasonable time frame, Alpha will provide the requesting party a date when the information will be provided. If for some reason access is denied, we will provide an explanation as to why access has been denied. We may charge a reasonable fee in advance for copying and sending the information requested.
- Your Choices
In certain circumstances we offer those who provide personal data a means to choose how we use the information provided. Where you have consented to the processing of your personal data, you may withdraw that consent at any time and prevent further processing by contacting us as described below. Even if you opt out, we may still collect and use non-personal data regarding your activities on Alpha Technology and for other legal purposes as described above.
We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law.
Mobile Devices. We may send you push notifications through our mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers, except to the extent required by applicable law.
Cookies and Interest-Based Advertising. You may stop or restrict the placement of Analytics Systems on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download Digital Advertising Alliance’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice.
Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.
- Your Privacy Rights
If you live outside Texas, depending on where you reside, or in the future as privacy laws change, or based upon the Children’s Online Privacy Protection Act (“COPPA”) for children under 13 years of age, you may have the right to exercise additional rights available to you under applicable laws, including as applicable:
- Right of erasure. You may have a broader right to erasure of personal data that we hold about you. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations, among other things.
- Right to object to processing. You may have the right to request that we stop processing your personal data, including the right to opt in or opt out of the sale of your Personal Data to third parties, or to stop sending you marketing communications.
- Right to restrict processing. You may have the right to request that we restrict processing of your personal data in certain circumstances. For example, where you believe that the personal data we hold about you is inaccurate or unlawfully held.
- Right to data portability. 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 would like to exercise any of the above rights, or others that apply to you, or you believe that we should honor such right in your case, please contact us utilizing the contact details in the “Contacting Us” Section below. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.
In some cases, our ability to uphold these rights for you may depend upon our obligations to process personal data for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the Alpha Technology. Where this is the case, we will inform you of specific details in response to your request.
- Children’s Privacy
The Alpha Technology and other activities involve the collection and maintenance of personal data about children under 13, as well as other personal data of students, through use of the Alpha Technology. It is operated by: Alpha, 1201 Spyglass Dr., Austin, TX 78746. Please contact us at email@example.com with any questions about the collection, use and sharing of children’s personal data, and specifically the personal data of children under 13 years old, including requesting a list of our service providers acting as sub-processors.
The information collected about children under 13, as well as other personal data of applicants and students, includes: name; email; password; phone number; IP address; cookie identifiers; geolocation; standard browser data such as pages visited, duration on each page, and productivity/idleness; analytics data; any personal data or information provided in response to assessments or tests; any personal data or information captured by browser or screen tracking in connection with the student’s use of their browser or operating system; any personal data contained in messages, posts or videos; any information required in student profiles; any information collected by third-party learning applications; any purchase history in connection with the debit cards used for financial rewards; phone usage (in connection with data tracked by the mobile app); any information provided in student emails or support requests; and other personal data as described in Section 1 (Our Collection of Your Information) and Section 2 (Information Collected Automatically or From Others).
The information about children under 13, as well as other personal data of applicants and students, is or may be used for: student assessment and testing, account creation, user verification, deliver and improve the Alpha Technology, display of student profiles to other users, provide financial rewards, productivity monitoring and gamification, transactional emails, share content between users, user interaction, customer support, user communication, prevent fraud; community discussions and networking; display of a leaderboard for students in connection with learning app usage and other activity; detect security incidents; analytics; respond to legal inquiries; terminate accounts; or other usage disclosed in Section 3 (Our Use of your Personal Data).
The information about children under 13, as well as other personal data of applicants and students, is disclosed to: Alpha affiliates, service providers and vendors (including for the purposes of coaching, user engagement, communication, financial rewards, hosting, support, analytics and other internal purposes), other authorized users with whom the child or student shares and/or communicates, recipients of child or student emails; government and/ or legal requestors as required by law or in connection with child usage, others as necessary (based on the appropriate consent of the parent/ legal guardian), and other cases as described in Section 4 (Our Disclosure of your Personal Data to Third Parties).
Information may also be disclosed in connection with efforts by Alpha, service providers/vendors, or others, to improve education and learning, provided that appropriate privacy protections for the information are in place. For example, a vendor may aggregate information provided or made available by Alpha for use, research, or study by Alpha and third-parties.
The parent of a child under 13 or a student (for certain student information, subject to an applicable data protection law) can review or have deleted the personal data held by the Alpha Technology and refuse to permit its further collection or use. A parent may do so by notifying Alpha through any designated contact mechanism (i.e., an administrator) and/or notifying us through the contact information below.
- COPPA, Parental Rights and Data Collection about Parents
In addition to the information in Section 13, in connection with children under the age of 13, parents (including legal guardians) have specific rights under the Children Online Privacy Protection Act (COPPA). These rights with respect to children under the age of 13 include:
- Direct notice to parents and obtain verifiable parental consent, with limited exceptions, before collecting personal data online from children;
- Give parents the choice of consenting to the collection and internal use and sharing of a child’s information as required by COPPA;
- Provide parents access to their child’s personal information to review and/or have the information deleted;
- Give parents the opportunity to prevent further use or online collection of a child’s personal information as required by COPPA;
- Not condition a child’s participation in an online activity on the child providing more information than is reasonably necessary to participate in that activity.
Parents may have additional rights under federal, state and local laws concerning this data. Please contact us using the contact information below to exercise any such rights that apply to you.
To the extent not covered elsewhere, Alpha also collects personal data or other information about parents, including without limitation, name, contact information, account verification details, financial payment details, consent requirements, and other information reasonably necessary in connection with the Alpha Technology.
- Contacting Us
To contact us for questions or concerns about our privacy policies or practices please reach out to us at firstname.lastname@example.org.
Last Updated: January 23, 2023