Last Updated: December 30, 2019

Summary

Our Commitment to Privacy

We care about privacy. We believe that privacy is a fundamental right for all individuals. Our clients entrust us with the personal information of their employees and their users, who are often students. We take the obligations that are attached to this information very seriously. We therefore have a dedicated data privacy program with privacy by design at heart. You can learn more about our data privacy program by visiting our Privacy Center.

Scope of Notice

This California Privacy Notice (the “Notice”) supplements the information in our Privacy Statement and applies only to individual residents of the State of California (“consumers” or “you”).

This CA Notice describes how we (as a ‘business’) collect, use, disclose, and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (CCPA).

Where we provide our products and services to consumers on behalf of our clients, we are considered a ‘service provider’ under CCPA. In this case, the client’s privacy notice governs the use of personal information. For example, when we process Student Data on behalf of our client institution, we are acting as a service provider and we retain, use and disclose the Student Data in accordance with our written agreement with the client. Accordingly, this Notice only reflects how we collect, use, disclose, and otherwise process personal information for our own purposes (e.g., for our websites and marketing).

For the purposes of this Notice, personal information does not include:

  • Publicly available information from government records.

  • Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.

  • Information relating to our employees, contractors and other personnel (which is governed by a separate privacy notice)

When we use terms that are defined in the CCPA, they have the same meaning as in the CCPA.

Collection, Use and Disclosure of Personal Information

We collect personal information from and about you for a variety of purposes. For example, we use personal information:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry.

  • To communicate with you, including via email, text message, push notification and/or telephone calls.

  • To operate, maintain, and provide to you the features and functionality of our websites (e.g. blackboard.com, Blackboard Community).

  • To market to you, including through email, direct mail, phone or text message.

  • To organize and conduct webinars, online meetings and in-person events

  • To personalize your experience on our websites.

  • To recognize you and remember your information when you return to our websites.

  • To help maintain the safety, security, and integrity of our websites.

  • For testing, research, analysis, and product development, including to develop and improve our services.

  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

  • For any other business and operational purpose described in our Privacy Statement, and

  • as otherwise permitted or required by law.

In the last 12 months, we have collected and disclosed for a business purpose the following categories of personal information:

Category of Personal Information Collected Sources of Information Disclosed for Business Purpose
Identifiers, such as your name, customer number, address, phone number, email address, date of birth or other similar identifiers.
  • Directly from you
  • From your institution
  • Our business partners
Yes
California Customer Records (Cal. Civ. Code § 1798.80(e)) such as name, contact information, payment information
  • Directly from you
  • From your institution
  • Our business partners
Yes
Protected Classification Characteristics, such as age or disability (if provided for accommodation purposes)
  • Directly from you
Yes
Commercial Information related to the products that you or your institution have purchased or intend to purchase
  • Directly from you
  • From your institution
  • Your browser or device
Yes
Internet/Network Information, such as device information, IP address, logs and analytics data
  • Your browser or device
Yes
Geolocation Data, such as precise location information from your device or rough location generated based on IP address
  • Your browser or device
Yes
Sensory Information, such as recordings of phone calls with us, where permitted by law
  • Directly from you
Yes
Profession/Employment Information, such as the institution you are affiliated with and your role in the organization
  • Directly from you

  • From your institution

  • Our business partners and affiliates

Yes
Other Personal Information that may be contained in online chat, document uploads, and user-generated content
  • Directly from you

  • Your browser or device

Yes
Inferences about your interests and preferences generated or derived from your usage of our services
  • Directly from you

  • Your browser or device

Yes

The categories of third parties to whom we have disclosed personal information for a business purpose include:

  • Our service providers. We engage a number of third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, email delivery services, marketing and advertising services, and other similar services. Our contracts with such third parties restrict the collection, use and disclosure of your personal information for any other commercial purpose;

  • Third parties at your request. We share your personal information with third parties with your consent or at your direction, or with third parties with whom you chose to engage or interact through our services;

  • Businesses as needed to provide services. We may share personal information with third parties you engage with through our services, or as needed to fulfil your request or transaction, including, for example, payment processing;

  • Security providers. We may share your personal information with third-party security providers, for example, to detect, prevent, or otherwise address actual or suspected fraud, harassment, security or technical issues, violations of any law, rule, regulation or of our policies;

  • Business partners. We may disclose personal information to third parties such as our resellers, technology partners, content partners or event sponsors, with whom we partner to provide events, webinars, joint promotional activities or similar marketing-related activities, and such disclosure is necessary to organize and manage these activities;

  • Analytics providers. We work with third party analytics providers to better understand the demographics of our users and visitors, and to personalize, enhance and improve our services;

From time to time, we may also disclose personal information to third parties for other purposes, such as if reasonably necessary to comply with law or a legal or contractual obligation, or in the context of a corporate transaction. Please see our Privacy Statement to learn more.

We do not sell your personal information for profit. However, we do engage in certain data disclosure activities that may be considered ‘sales’ under the broad definitions of the CCPA.

In the previous 12 months, we have ‘sold’ personal information in the following ways:

  • Disclosed identifiers (such as name, email address) and Professional/Employment Information (such as the name of the institution you are affiliated with) to our Business Partners and sponsors of events and webinars for B2B marketing and client engagement purposes.

  • Disclosed identifiers (such as a hashed email address) to social media companies for the purpose of displaying personalized advertising and content to you on those social networks.

As is common practice among companies that operate online, we have permitted third party advertising networks, social media companies and other third party businesses to collect information directly from your browser or device through cookies or similar tracking technology when you visit or interact with our website, use our apps or otherwise engage with us online. For example, they may collect Internet/Network information, such as a cookie or device ID, browsing history and website usage, Geolocation Data, and Inferences generated from your browsing history and interactions with our services as well as other sites and services. These third parties use this personal information to serve targeted advertising or to personalize content and perform other advertising-related services such as reporting, attribution, analytics and market research. These third-party businesses may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties, including other advertising networks. To learn more, please see our Cookie Statement.

Your California Consumer Privacy Rights

As a California resident, you can exercise the following rights in relation to your personal information (subject to certain limitations in the CCPA).

Please remember: If you are a user of our products and services that we provide on behalf of your institution, contact your institution to exercise your rights. They need to manage your request even if it relates to information that we store on behalf of your institution. We will support your institution as needed with your request.

The Right to Know

You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months:

  • The specific pieces of personal information we have collected about you;

  • The categories of personal information we have collected about you;

  • The categories of sources of the personal information;

  • The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;

  • The categories of personal information we have sold and the categories of third parties to whom the information was sold; and

  • The business or commercial purposes for collecting or selling the personal information;

The Right to Request Deletion You have the right to request the deletion or erasure of personal information we have collected from you, subject to certain exceptions.
The Right to Opt Out of Data Sales You have the right to direct us not to sell personal information we have collected about you to third parties.
The Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising these rights.

However, please note that if exercising these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our services or engage with you in the same manner.

To Exercise Your Right to Know or Right to Deletion

To exercise your Right to Know and/or your Right to Deletion, please submit a request by:

  • Emailing [email protected] with the subject line “California Rights Request,”

  • Filling out our California Resident Rights Request Form, or

  • Calling 877-918-2620 (Please note, response times may be faster if you submit your request through our California Resident Rights Request Form above or via email)

We will need to verify your identity before processing most requests, which may require us to obtain additional personal information from you or require you to log into your account, if you have one. We will only use such personal information to review and comply with your request.

In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate information in our systems, or as permitted by law.

To Exercise Your Right to Opt Out of Personal Information Sales

To exercise the Right to Opt Out of personal information Sales, you may submit a request by clicking the button below:

You do not need to create an account with us to exercise your Right to Opt Out of Personal Information Sales. However, we may ask you to provide additional personal information so that we can identify you in our data systems and to track compliance with your opt-out request. We will only use such personal information to review and comply with the request. If you chose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.

Please also refer to our Cookie Statement to learn more about how third party ad networks, social media companies and other third party businesses collect information from you when you visit our online Services and the opt-out choices you may have in relation to those activities.

The Right to Opt In for Minors Under Age 16. We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the "Right to Opt In") from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.

Other Information

Shine the Light Law. California's "Shine the Light" law (Civil Code Section §1798.83) permits California residents that have an established business relationship with us to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes, please click Do Not Sell My Personal Information to be added to our suppression list.

Updates to this Notice. We will update this Notice from time to time. When we make changes to this Notice, we will change the "Last Updated" date at the beginning of this Notice. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us

You can contact us at [email protected]kboard.com and can find our additional contact details in our Privacy Statement.