eDynamic Learning Privacy Policy

Date of last modification February 26, 2019

eDynamic Learning is a provider of online educational courses.  Most of our customers are schools who offer our courses to their students, teachers, and administrators as part of an online learning system managed by the school.  We also have corporate customers who offer our courses to their employees for training purposes, and we offer some of our courses for direct purchase online.  We have offices in Canada (Kelowna, British Columbia) and the United States (Southlake, Texas) and offer our courses to customers worldwide.

This Privacy Policy describes the personal data that we collect from and about individuals who interact with us and our course content, how and why we collect that data, the ways we use it, and the circumstances under which we share it with others.

If you have any questions or concerns about our privacy practices, or want to send us a request to access, amend or delete your personal data, please contact us at: privacy@edynamiclearning.com; 101-1865 Dilworth Drive Suite #510 Kelowna, BC V1Y 9T1 Canada.

These words have special meanings in this Privacy Policy:

  • account user” means an individual who interacts with us as a representative of the school or other entity that purchases our services or who purchases a course from us directly on our website;
  • content user” means an individual who views our course content;
  • visitor” means an individual who visits our website, interacts with us at a trade show or other industry event, or communicates with us or our partners in some other way other than as an account user or content user;
  • we,” “our” and “us” refer to eDynamic Learning, Inc.
  • website” refers to www.edynamiclearning.com and any other website where this Privacy Policy is posted;
  • you” and “your” refer to visitors, account users, and content users.

Visitors: personal data that we collect from and about visitors, and how we use that data

When you use our site we will capture and analyze information about your visit using our web server logs and third party analytics services such as Google Analytics and Intercom. For example, we will capture your IP address and internet service provider, the time and duration of your visit, including the time and duration of your visit to each page out our site, your browser type (including plug ins), and information about your device, such as the operating system, time zone setting, and language setting.  We also use clear gifs in our email to discover whether you have opened our email and to help us set cookies to capture and analyze your visits to our site and web served content in the email.  If you arrive at our site by clicking on an advertisement, our advertising service will report to us the fact that you arrived at our site by clicking on this ad and the site where the ad was displayed. Please see the section below captioned Online Technologies for more information on cookies and clear gifs.

If you express an interest in evaluating or purchasing our offerings, whether by chat, email, submission of a web form, telephone, or in person (such as at a  meeting, trade show or other event) we may collect information such as your name, job title, the organization you represent, email address, and phone number.  We may also receive this kind of information from our marketing partners if you provide it to them.  Our marketing partners are identified on our list of Trusted Partners. We also subscribe to information services that help us identify and communicate with prospective customers for our products. You should review the privacy policy of any of our partners with whom you interact.  We use this information to respond to your requests and to provide you with information about our offerings and our Trusted Partners’ offerings.

We do not associate personal data collected via automated means with personal data we collect in other ways.  We use the data described in this section to improve our website, our product offerings, and our technology.

Account Users: personal data that we collect from account users, and how we use that data

Online purchases on our website

For courses that are purchased from us directly on our website, we collect account user’s first and last name and email address, and the name of the course they would like to purchase.

Sales to Organizations

If your organization has purchased our services, and you are listed in our account records as a representative of your organization, such as a purchasing manager, billing contact, administrator, support contact, or other role, then we will require you or your organization to provide personal data about you as necessary to manage your account and provide your organization with customer support, such as your name, business email address, business phone number, and other contact information.  We may also require each account user to have a unique user name and password for your use in managing your account or requesting support online.

If you contact us for support via email or chat, we will collect and store any personal data you may elect to provide as part of your support request.  If you request support from one of our support partners, then this kind of personal data may be transmitted to us from our support partner.  Our support partners are listed on our Trusted Partners list.

We use account user data to manage our relationship with the organization that is our customer.  For example, we use the data to confirm your identity when you log on to manage the account or request support, to send and collect invoices, to communicate with the organization about changes to our offering, and the like.

If we host the learning management system that your organization uses, then we have the technical means to access all the data that your organization may input to the LMS.  See the section below captioned Our Hosted LMS.  Our support personnel may inadvertently view this information as part of providing support, but we do not collect or store this information.

We do not associate the data we have about you as an account user with any data we have about you as a visitor or a content user.

Personal data that we collect about content users and how we use that data

Course purchased on our website

If a course is purchased directly from us on our website, we will pass the information we have about the purchase (account user’s first and last name, email address, and course purchased) to a Trusted Partner who delivers the course via the Trusted Partner’s LMS.  We do not collect data about the content use in this context.  You should review the Trusted Partner’s Privacy Policy for more information on their practices.

Access via an organization’s LMS

We host our courses on servers that we control, and deliver the courses to content users via our customer’s learning management system or “LMS.”  See the section below captioned “Learning Management Systems and Learning Tools Interoperability.”   The interaction between our servers and the customer’s LMS permits us to collect aggregate data about content users such as the number of users accessing a certain course, how often the course is viewed, which organization the content users are coming from, and the LMS that they are using.  Where our customer’s LMS interacts with our servers using the LTI standard we are provided with a unique identifier for each individual content user, and depending on how the organization has configured their LMS, we may also be provided with that content user’s role (student/teacher/admin), the course viewed, the date and time that the course was viewed, the LMS that was used, and the organization’s account identification number.

Some of our customers use an LMS that we provide as a managed service in partnership with our Trusted Partners.  As the universal administrator of that LMS, we have access to all of the data that the organization chooses to manage via the LMS, which may include student names, user names, email address, quiz results and other performance assessments, and integrations with identity and access management systems.  Although we have the technical means to access that data, we do not access that data except to the limited extent necessary to respond to a request for LMS support from our customer.  See the section below captioned Our Hosted LMS.

We may be given access to content user data as part of providing implementation and other support for our services offerings.  We will use this data only to provide the requested support.

We use content user data for analytics purposes, such as counting the users who view a particular course, and understanding how many courses a certain user views on average.

We do not associate (i.e. personally identify) the data we have about content use with other that we may have about that individual user as a visitor or account user.

Third parties who collect data on our site

We may use services such as Youtube to show you videos or other content on our site. These services may capture information about your IP address, internet service provider, and other information of the type collected by web servers generally.  These service providers are responsible for posting and complying with their own privacy policies.

Aggregate and Anonymous Data

This Privacy Policy does not cover our use of anonymous data or aggregate data.  Anonymous data is data about user activity that is not collected in a way that permits us or anyone else to identify that data to a specific individual.  For example, we may ask our service providers who provide site analytics to report the number of site visitors who look at a given page on our site without any information as to IP address or other personal identifier as to any of the visitors.  Aggregate data is data is derived from personal data of many individuals and aggregated in such a way that it cannot be used to identify any individual whose data is included in the aggregate data.

Disclosure of your personal data to others

We have never sold personal data.  If we ever sell our company we may transfer your data to the buyer, but we will not sell your personal data separately from a sale of the related business assets.

We will disclose your data to others only under the following circumstances unless you have given us an advance written consent to disclose it in some other way:

We may disclose your personal data to an acquiror or potential acquiror of our business, but only to the extent customary in these circumstances and subject to the potential acquirer’s agreement to maintain the information in confidence and use it only for the purpose of evaluating the acquisition or managing the business in accordance with this policy.

We may share account user data that we collect with our Trusted Partners.  Our Trusted Partners are permitted to use this data solely for purpose of helping us manage the services relationship with the organization that is our customer as described above.

We use third party services to help us manage our data and our services such as web site hosting companies, content hosting services, email providers, chat service providers, web forms services, customer relationship management services, and email marketing services. These third parties are permitted to use your personal data solely for the purpose of providing their services to us.

If you place an order on our website, our third-party payment processor, currently Stripe, will collect your credit card information for payment purposes.  You should visit the payment processor’s privacy policy for information on their privacy practices.

We may share your account user and content user data with your organization that is our customer as necessary to manage the customer’s account, collect fees, and otherwise enforce our contract with the customer.  If we have to bring a court action to enforce our rights against your organization we may have to disclose your personal data as part of the litigation or other dispute process, but we will use reasonable efforts to minimize the disclosure and protect it from further use or disclosure. Other account users may have access to your account user personal data and your content user personal data depending on the access granted by the organization that is our customer.

We may disclose your personal data to regulatory and law enforcement agencies when we believe release is appropriate to comply with the law or to protect the rights and safety of others, or in response to a subpoena or other compulsory legal process.

Children’s Privacy

While many of our course offerings are designed for children, we do not intentionally collect any personal data from anyone under 13 years of age.  We may collect information about children from their parents or guardians or from our customers.  We rely on our customers to comply with applicable regulations for the protection of children, including parental notice and consent requirements for disclosure of this data to us for the purposes described in this Privacy Policy.  Except for the limited data we collect about our content users as described above, we do not intentionally collect data about children.  If you are a parent or guardian and have a concern about our course content or the data we collect about your child as a content user, we ask that you first contact the organization that is our customer.  If you believe we have data about your child other than the limited data we collect in connection with their use of our content, please contact us at the address appearing above and we will delete that information.

Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost or accessed in an unauthorized manner, including being altered or disclosed.  These measures include requiring our service providers to comply with appropriate security measures as necessary for us to meet our security obligations to you.

We have put in place procedures to handle security incidents, including a process for making notifications to you or a data breach as required by law.

Data Integrity

We process personal information only for the purposes for which it was collected and in accordance with this Privacy Policy. We regularly review our data collection, storage, and processing practices to ensure that we only collect, store, and process the minimum personal information needed for the purpose collected. We take reasonable steps to ensure that the personal information which we process is accurate, complete, and current, but we depend on our users to update or correct their personal data whenever necessary.

International Transfer of Information

Any personal information collected will be processed and stored on servers based in Canada and the United States but may be accessed by our employees, contractors or affiliated organizations anywhere in the world.

Data Retention

We will retain your personal data only for as long as reasonably necessary to fulfil the purpose for which it was collected, and to comply with our legal obligations.  We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Requests to access, amend, delete or restrict the use of your personal data.

Please send us a request at the address shown above if you would like to know what personal data we have about you, or would like us to correct inaccurate data, delete your personal data, or restrict the use of your personal data. We commit to responding to your request promptly and honoring your reasonable requests.  We will comply with all applicable legal requirements related to your requests, but please note that we are not required by law to delete or restrict the use of your data in a way that prevents us from complying with our legal obligations to our customer or that interferes with our reasonable record keeping as necessary to demonstrate compliance with our contracts and applicable law.  If our access to your personal data is based on our cloud hosted LMS service, we may refer your request to our customer – please see the section below captioned Our Hosted LMS.

Communications Policy

If you do not want to receive our email you may unsubscribe by using the unsubscribe link in the email or by writing to us at the address above.  If you are a designated representative of our customer you cannot opt out of receiving our communications related to the customer’s account, but we will otherwise honor your opt out request.

Online Data Collection Technologies

A cookie is a unique alphanumeric identifier that is placed by a web server on each browser used to visit the website.  Cookies are used to analyze visitors’ use of the website.  For example, a website operator can use the cookie to identify the number of unique visitors to the site, whether or not those visitors are repeat visitors, and information about the visitor’s activity on the site, device and device settings.  A tracking pixel, also known as a web beacon, is a small graphic (usually 1 pixel x 1 pixel) invisible to the eye, that is embedded in web content or email.  When content that has an embedded web beacon is viewed, the browser will request content from a web server, which in turn will set a cookie.

You can manage browser cookies through your browser settings. The ‘Help’ feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to disable cookies, and when cookies will expire. If you disable all cookies on your browser, neither we nor third parties will transfer cookies to your browser. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some features and services may not work.

Our web server does not recognize or respond to any “do not track” setting you may have in your browser.

Learning Management Systems (“LMS”) and Learning Tools Interoperability (“LTI”)

Learning Management Systems or “LMS” are software platforms designed for delivering and managing educational programs at schools, businesses and other organizations.  A typical LMS will include access to online courses and other content, and the means to administer the program such as documentation of courses taken, quizzes or other assessments, and record keeping.

Content users access our courses by means of the LMS that has been selected by the organization that is our customer.  Our customers use various LMS platforms, such as Blackboard, Buzz, Canvas, Desire 2 Learn,  Moodle, and Schoology.  Our customers may use the LMS software on systems that the customer controls, or may our managed LMS. We offer a cloud hosted version of the Buzz LMS as our managed LMS.

Depending on the features of the LMS, our courses may be stored on our customers LMS platforms or may be delivered to the content user via the Internet in response to a request originated by the content user.

The Learning Tools Interoperability or “LTI” standard is a learning industry initiative that is designed to standardize the way that content providers interact with the various LMS platforms, and therefore facilitate the distribution of content.   Most LMS platforms support the LTI standard, but some do not.  In particular, older versions of LMS platforms may not support the use of LTI.

Our Hosted LMS

If your personal data is provided to us by the organization that is our customer as part of its use of our hosted LMS, then we do not control the use or disclosure of that data.  We process this hosted data only as permitted by our contract with the organization or as instructed by the organization.  If you would like access to the data that we have about you in this role as a service provider, or would like to amend, delete or restrict the use of this data, we ask that you first contact the organization that is our customer to make this request.

Changes to our Privacy Policy

If we decide to change our Privacy Policy, we will post those changes on this page, and update the Privacy Policy modification date stated at the top of the policy.  We will manage your personal data in accordance with the version of the Privacy Policy that was posted at the time we collected the data.