Privacy Policy

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1. Introduction

This Privacy Statement provides information on how Steptech Innovation LLC collects, uses, and protects personal information. Steptech Innovation supports the most critical processes of managing student, class, and school data, and we are committed to the highest standards of protection for personal data at all times. When we refer to “us,” “we,” “our,” or “Steptech Innovation” in this Privacy Statement, we are referring to Steptech Innovation and its affiliates. Privacy is a fundamental right for all individuals. Our clients entrust us with the personal information of both employees and parents, and students. On this basis, we take the responsibility attached to this information very seriously.

This Privacy Statement governs all the manners in which Steptech Innovation collects personal information directly from you as an individual. Whether you are a visitor to our websites, request a trial of our products or any other communication with us (such as attendance at a conference or trade show), this Privacy Statement governs our use of personal information for products and services that we provide directly to you as what is known as a “data controller.” How we collect information and how we use information may differ based on our relationship with you as an individual. We have identified below the different relationships we may have with you, and our respective use of information we collect.

When a customer’s privacy statement/policy governs. If you are an end-user (parent or student, applicant or employee) of our customer (a school or school district) and you are using Steptech Innovation products and services through our customer (your school or school district), we are considered a “data processor.” In these cases, your school or school district’s privacy statement or privacy notice governs the use of any personal information. Our Privacy Statement does not supersede the terms of any agreements between us and your school or school district (our customer), nor does it affect the terms of any agreement between the student and the student’s school or school district.

The nature of the personal information we collect and how we use it depends on the context in which we collect that personal information. Please see the section below that applies to you.

You may visit any Steptech Innovation website without having to log in or provide any personal information. If you are on a Steptech Innovation website to access a service or product, you may need to log in to make use of the functionality of the particular product

1. Information We Collect
   1. Directly from you. You may voluntarily provide us information when you complete a form or survey on our website or subscribe to our blog or newsletters. This may include some or all of the following categories of information: Name and Role; Job title; Signature; Profession; Social media account name; User name; Telephone Number; Street Address; and Email address.
      • You may also provide information when you register for an account through a Steptech Innovation website to log in to use a product or service.
   2. Indirectly from you. We collect information about the pages you visit and how you access and use the Steptech Innovation websites using cookies, tracking technologies and other third party analytics tools. Specifically, We and our service providers use cookies and similar technologies such as local storage (HTML5), web beacons, Javascript, and eTags on our websites. This information includes information about the devices you use to access the Steptech Innovation website including unique device identifiers, IP address, operating system, browser, and cookies. Depending on your device settings, we may also collect information about your geographical location and what websites you may travel from to our website. We use this information to better understand our customers and users, so that we may provide more effective advertising and products. You can learn about our use of cookies, and set your preferences, in our Cookie Statement.
   3. Information from third parties. We may supplement the information we collect with information from the Steptech Innovation affiliates and other third parties that we use to promote our products and services. For example, we may receive information from a third party about how well an online marketing or email campaign performed, or from conference and trade show organizers.
2. How We Use This Information
   We use the information collected to provide and improve our website services and our products and to analyze usage information for sales and marketing purposes. We also use the information collected to communicate with you in any manner that you have requested. This analysis is necessary to further our legitimate interest in understanding our users and their interactions with us and our websites to best iterate and improve on our websites and communications, including marketing purposes, and to provide you with content that you have requested.Third party information that we collect from social media may be used to provide you with requested information or our newsletter or contact you regarding our services, opportunities, products, and/or events.
3. How We Share This Information
   Where we use third-party analytics tools to help us understand how the Steptech Innovation websites are used, these parties will have access to some of your personal information. This includes analytics tools such as Google Analytics and LinkedIn Lead Gen. Learn more about our use of cookies in our Cookie Statement.We also share information with our vendors and service providers and other third parties for legal or business purposes, but only as permitted and subject to required limitations. See Vendors, Partners, & Other Disclosures.

If you are a customer of Steptech Innovation, we are providing our products and services directly to your school or school district and we are a “data controller” for purposes of the personal information collected in connection with the customer accounts.

1. Information We Collect
   1. Directly from you. We collect information necessary to provide the educational technology services as directed by you. The information collected from you depends on the specific product and what is needed to integrate with your systems and to set up and maintain accounts. This includes information in the following data categories:
      • Account information: The exact elements will depend on the product and what specific information you as a customer provide us, but often we receive from you include pupil records of students and parents of students enrolled in your school or district, such as directory information, email addresses, student IDs, account credentials, courses students are enrolled in, health information kept in student records.
      • We also collect employee account information including user names, email addresses and titles to initially set up products and services for you.
      • Depending on your needs as a customer, we may also collect financial information of students and parents of students as you make available to us in order to provide services.
   2. Indirectly from you. We collect device and usage information when you access and use our products and services, including information that your browser or the mobile app sends when you are using it. This data may include your unique device identifier, IP address, your browser type and configuration, the date and time of your use of the product or service and cookie data. Specifically, we and our service providers use cookies and similar technologies such as local storage (HTML5), web beacons, Javascript, and eTags. The purpose of collecting such information is for improvement of our products and services to better meet the needs of our customers and their users. Learn more about our use of cookies in our Cookie Statement.
   3. From third parties. We may receive information from affiliates in our Steptech Innovation Group of companies and other third parties. For example, we may receive limited personal information from third-party services that integrate with or complement Steptech Innovation products or services in order to provide you with the best possible user experience.
2. How We Use This Information
   We use your information to provide you the features and functionality of the Steptech products and services, as well as to communicate directly with you and allow you to communicate with other Steptech users. It is necessary for us to use your information in this manner in order to provide you with the services your school district has requested pursuant to its agreement with Steptech Innovation.We will use your information to provide you with news and information about new products and services. Any such marketing communications from us may be discontinued at any time. See Marketing. We may also use de-identified and aggregated information to understand and improve our products and services. We may share general customer contact information with certain Partners as is necessary to offer and provide our products and services to our current and prospective clients. No customer data other than general institution contact information is provided for these purposes. For absolute clarity, we do not provide any student data or personally identifiable information to any Partners for marketing purposes.
3. How We Share This Information
   We share information to provide the Steptech products and services to you and further improve them. Within Steptech, your information will be accessed only by those who have a need to provide the Steptech Innovation products and services. We use vendors to help us provide the Steptech Innovation products and services to your school or school district. For example, if your school or school district has a hosted Steptech product or service, Amazon Web Services and Azure provide our cloud hosting facilities. Third-party analytics tools may also have access to your personal information to help us understand how the Steptech products and services are being used. Learn more about our use of cookies and analytic tools in our Cookie Statement.
4. Student Personal Information
   Steptech is a data processor with respect to student personal information and the Steptech customer (school or school district) is the data controller. Where a Steptech customer enters into an agreement with Steptech to provide products and services, that Steptech customer acknowledges that Steptech is a data processor with respect to personal information received from that Steptech customer or from a student/parent in connection with the Steptech products and services.
   1. Student Personal Data Ownership All student personal data remains the property of and is solely owned, and thereby controlled, by our Steptech customers. You grant Steptech a non-exclusive, royalty free license, to use equipment, software, your data or other material of yours solely for the purpose of providing, maintaining, and supporting you and other licensees with Steptech products and services.Steptech will only use student personal data for the purposes of providing the products and services that our customers (school or school districts) have contracted with us to provide and we will process student personal data according to instructions and the terms of our contract with our customers. Student personal data will not be used for targeted Advertising by Steptech or any of its affiliates.

The school or school district decides how your personal information is used.

Steptech provides learning and registration products and services to end-users of a school or school district (our customers) as a “data processor.” The main responsibility of what is known as a “data controller” lies with the school or school district. This also means that the school or school district’s own privacy statement governs the use of student personal information. Steptech’s customers determine what information we collect through the Steptech products and services and how it is used, and we process that information according to our customer’s instructions and the terms of our contract with our customer.

This section of our Privacy Statement is provided for informational purposes and describes how parent and student personal information is used when Steptech products and services are provided through a school or school district. How that information is used depends on the school or school district, so please consult your institution’s privacy statement.

1. Information We Collect
   1. Information provided to us by a school or school district. The Steptech products and services integrate with our customer’s systems. The specific information that is collected from the school or school district depends upon the Steptech product or service, but in general, this information includes but is not limited to:name, age, email address, student ID, account credentials, academic and student records, certain health information kept in student records, courses a student is enrolled in when we initially set up the products, and additional records as requested by the school or school district. Depending on the school or school district’s request, we may also collect financial information of students and parents of students as is made available to us in order to provide services. Steptech will receive regular updated information to keep account information accurate and up to date.
   2. Directly from a parent or student: Depending on the Steptech products and services your school (or your child’s school) uses, we will collect the following data categories directly:name, age, email address, student ID, account credentials, academic and student records, certain health records, courses a student is enrolled in when we initially set up the products and services for your institution, and additional records as requested by the school or school district. Depending on the school or school district’s request, we may also collect financial information of students and parents of students in order to provide services. Steptech will receive regular updated information to keep account information accurate and up to date.
   3. Indirectly from a parent or student: We collect device and usage information when you access and use Steptech products and services, including information that your browser or the mobile app sends when you are using it. This data may include your unique device identifier, IP address, your browser type and configuration, the date and time of your use of the product or service, and cookie data. Specifically, We and our service providers use cookies and similar technologies such as local storage (HTML5), web beacons, Javascript, and eTags. The purpose of collecting such information is for improvement of our products and services to better meet the needs of our customers and their users. Learn more about our use of cookies in our Cookie Statement.
2. How We Use This Information
   1. On behalf of your school or school district. We use your information on behalf of and under the instruction of your child’s school or school district, which is the data controller. We use the information in accordance with our agreement with your child’s school or school district to operate, maintain, and provide the features and functionality of the Steptech products and services. Your child’s school or school district determines how the personal information is used.
3. How We Share This Information
   We share student information in accordance with our agreement with your (or your child’s) school or school district. Generally, this includes the sharing of such information inside and outside Steptech under certain terms. Student information will be accessed inside Steptech only by those who have a need to know to provide the Steptech products and services and improve them. For example, our technical and client support teams may have access to personal information when the Steptech products and services are implemented for your school or school district or when software or other changes are required for support and maintenance purposes. We use vendors to help us provide the Steptech products and services to you (or to your child) on behalf of our school or school district customer.
4. Information We Collect
   1. Information provided to us by a school, district, or education agency. The Steptech applicant tracking products and services integrate with our customer’s systems. The specific information that is collected from our customer depends upon the Steptech product or service, but in general, this information includes but is not limited to: name, age, email address, social security number, account credentials, academic and student records, background check information, and additional records as requested by the customer. Steptech will receive regular updated information to keep account information accurate and up to date.
   2. Directly from a customer’s applicant: Steptech will collect the following data categories directly from a customer’s applicant-user: name, age, email address, social security number, account credentials, academic and student records, background check information, and additional records as requested by the customer. Steptech will receive regular updated information to keep account information accurate and up to date.
   3. Indirectly from the customer's applicant: We collect device and usage information when you access and use Steptech products and services, including information that your browser or the mobile app sends when you are using it. This data may include your unique device identifier, IP address, your browser type and configuration, the date and time of your use of the product or service, and cookie data. Specifically, We and our service providers use cookies and similar technologies such as local storage (HTML5), web beacons, Javascript, and eTags. The purpose of collecting such information is for improvement of our products and services to better meet the needs of our customers and their users. Learn more about our use of cookies in our Cookie Statement
5. How We Use This Information
   1. On behalf of the customer. We use your information on behalf of and under the instruction of the customer education agency, which is the data controller. We use the information in accordance with our agreement with our customer to operate, maintain, and provide the features and functionality of the Steptech products and services. The school, district, or education agency determines how the personal information is used.
6. How We Share This Information
   We share student information in accordance with our agreement with a customer. Generally, this includes the sharing of such information inside and outside Steptech under certain terms. Applicant information will be accessed inside Steptech only by those who have a need to know to provide the Steptech products and services and improve them. For example, our technical and client support teams may have access to personal information when the Steptech products and services are implemented for a customer or when software or other changes are required for support and maintenance purposes. We use vendors to help us provide the Steptech products and services to you on behalf of our customers.

1. Vendors. We engage directly with certain third-party companies to help us provide the Steptech products and services to our customers or to you or to perform work on our behalf (“Vendors”). Our vendors are required to abide by our privacy and security instructions and are contractually restricted from using any personal information they access or receive from us for any purposes other than as needed to perform such services. We may use vendors to help us conduct marketing campaigns or events and disclose customer contact information necessary for those activities.
2. Partners. Your institution may work with third-party companies to provide additional content and functionality which requires access to Steptech products and services (“Partners”) Only with your institution’s permission, will we share information about you, such as your name, email, or student ID, that is required to provide you with access to the products and services that have been requested by your institution. In these cases, these Partners will enter into an agreement directly with your institution regarding the processing of any data at the direction of your institution.
3. Other Types of Disclosures. We may also share your information where required under the following circumstances:
   • Where permitted by applicable law and by contracts with our customers, we may disclose your information in the course of a corporate transaction such as a merger, acquisition, sale of assets, or a financing, or pursuant to a bankruptcy, dissolution proceeding or reorganization.
   • We may need to disclose your information to comply with legal or regulatory requirements and to respond to lawful requests, court orders, and legal processes. Where such disclosures relate to personal data we hold as a data processor on behalf of our customers, we will refer such requests to our customers where permissible.
   • We may need to disclose your information to protect and defend the rights, property, or safety of Steptech, our customers, or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or other misuse of our systems.
   • We may utilize aggregated or de-identified (anonymized) information that is no longer associated with a person to enhance and promote the Steptech products and services. Steptech does not rent, sell, or otherwise provide access to student personal data to third parties for marketing or advertising purposes.

1. Marketing. We conduct marketing to promote the Steptech products and services, but do not use or disclose information (whether personal information or otherwise) about students that we collect through the provision of Steptech products and services for targeting of advertisements to students.When we conduct (or sponsor) events, conferences, and webinars, we will collect information about attendees, such as the session they attend and their contact information to provide them information about Steptech products and services and other Steptech information.
   • Marketing Preferences and Opt-Out. Our marketing emails will always include an “unsubscribe” link so that you can change your preferences and opt-out of receiving marketing emails or communications from Steptech. You can also send us email at support@steptechno.com to unsubscribe. Please note that even if you opt-out of marketing emails, we may still need to contact you with important information about your Steptech account.

1. Interest-based Advertising. We use third party advertising tools to collect information about your visits to the Steptech websites to provide targeted advertisements to you based on your browsing history on other websites or on other devices you may use. If you would prefer to not receive personalized ads based on your browser or device usage, you may generally express your opt-out preference to no longer receive tailored advertisements. Please note that you will continue to see advertisements, but they will no longer be tailored to your interests.To learn more or opt-out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit:
   • Digital Advertising Alliance (DAA)’s self-regulatory opt-out page (http://optout.aboutads.info/) and mobile application-based “AppChoices” download page (https://youradchoices.com/appchoices)
   • European Interactive Digital Advertising Alliiance (EDAA)’s consumer opt-out page (http://youronlinechoices.eu)
   • Network Advertising Initiative (NAI)’s self-regulatory opt-out page (http://optout.networkadvertising.org/).

1. Google Analytics and Advertising. We also use Google Analytics and other third-party cookies to collect certain information about your visits to our Steptech websites.  You can opt-out of third-party cookies from Google Analytics using the Google Analytics opt-out browser setting add-on or other ad management tools.You can learn more about our use of cookies in our Cookie Statement and you can learn about managing your preferences.
2. “Do Not Track” Signals. Without a common industry or legal standard for interpreting so-called “Do Not Track” (DNT) signals, Steptech does not respond to browser DNT signals.  We will continue to monitor further development of a DNT standard by the privacy community and industry.

We keep website usage information for as long as necessary for the purposes described above. Account information is retained until you delete the account and for a limited period thereafter. Where you have provided information in forms, we retain the information as long as it is required, depending on the nature of the request. If you unsubscribe from receiving marketing communications from us, we will keep a record of this to ensure that you do not receive such communications in the future.

We keep information collected on behalf of our customers for as long as necessary and pursuant to contractual terms. We dispose of information that is not held pursuant to contractual terms in a commercially reasonable time period or at the request of a customer.

We do not knowingly collect any information from children under the age of 16 unless and until the Steptech customer (school or school district) has provided authorization for a student under 16 to use the Steptech products and services and for us to collect personal information from such student.

Please contact us at privacy@steptechno.com if you believe that we have inadvertently collected personal information from a child under 16 without proper consent.  This will allow us to delete such information as soon as possible.

Steptech employs a variety of physical, administrative, and technological safeguards that are designed to protect personal information against loss, misuse, and unauthorized access or disclosure. We strive to continuously enhance our technical and operational security measures. Our measures consider the type and sensitivity of the data being collected, used, and stored, and the current state of technology and threats to information. Steptech’s security measures include data encryption, firewalls, data use and access limitations for personnel and vendors, and physical access controls to our facilities. Steptech also aligns its privacy and security operations to best practices and relevant international regulations.

Steptech, in its role as a vendor to educational agencies and institutions, both public and private entities (“Educational Agencies”), receives disclosures from the Educational Agencies, which include the personal information and other data (“Student Data”) contained in student records as well as directly from students and parents of students. Only information that is needed for Steptech to perform services, which are outsourced to Steptech by the Educational Agencies, is disclosed to Steptech. These disclosures are authorized by the federal Family Educational Rights and Privacy Act (FERPA). Steptech considers Student Data to be strictly confidential and does not use Student Data for any purpose other than improving and providing our products and services to the Educational Agencies or on the Educational Agencies’ behalf. Our collection, use, and sharing of Student Data is governed by our contracts with the Educational Agencies, the provisions of FERPA, the Children’s Online Privacy Protection Act (COPPA), and other applicable state and federal laws and regulations that relate to the collection and use of personal information of students. If you have questions about reviewing, modifying, or deleting personal information of a student, please contact the relevant Educational Agency(ies) directly.

If you are a California resident, California Civil Code Section 1798.83 allows you to request information on how we disclose personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. You may make one request each year by emailing us at privacy@steptechno.com or writing to us (see address below in “CONTACT US”).

Please see HERE for our privacy notice regarding the California Consumer Protection Act (CCPA).

Our Steptech websites may provide links to third party websites or resources. The information practices of those websites are not covered by this Privacy Statement or any other policies or terms applicable to the Steptech websites or the Steptech products or services. We recommend that you review any terms of use and privacy policy of any linked third party website before providing any information.

We may update this Privacy Statement and its last updated date to reflect changes to our data governance practices. If we propose to make any material changes, we will notify you by means of a notice on this page prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Pursuant to state law, the following state specific language is hereby incorporated into this Privacy Statement, provided that Steptech is providing and/or offering you Steptech products or services in one of the following states (capitalized terms below which are not otherwise defined in this Privacy Statement are as defined either in the applicable state law or in your Steptech agreement):

California – Steptech will not use your data for any purpose beyond the indicated purposes in the Terms of Use, which includes this Privacy Statement. This includes, but is not limited to, Steptech’s policy to never use PII from a Pupil’s Records to engage in targeted advertising.

Please see HERE for our privacy notice regarding the California Consumer Protection Act (CCPA).

Colorado – Steptech will not use your data for any purpose beyond the indicated purposes in the Terms of Use, which includes this Privacy Statement. Only the Steptech employees that have a legitimate interest in accessing your data, will be granted authorization by Steptech.

Connecticut – Steptech will not use your data for any purpose beyond the indicated purposes in the Terms of Use, which includes this Privacy Statement. This includes, but is not limited to, Steptech’s policy to never use any student’s PII to engage in targeted advertising. Steptech also avers to utilize industry standard security, or better, to ensure the protection of said student PII. Connecticut law shall govern this agreement between you and Steptech. All terms herein are defined in accordance with Public Act No. 16-189, and in case of any ambiguity or conflict between the terms herein and Public Act No. 16-189, then Public Act No. 16-189 will govern.

Florida – Steptech will provide notification of a security breach pursuant to requirements as mandated in the Florida Information Protection Act of 2014.

Maryland – Steptech will not use Covered Information to engage in targeted advertising.

New York – In accordance with New York Education Law § 2-d, Steptech will comply with and attach to your contract the Parents’ Bill of Rights for Data Privacy and Security, as applicable.

Pennsylvania – Steptech will provide notification of a security breach pursuant to the requirements of Pennsylvania’s Breach of Personal Information Notification Act.

Washington – Steptech will provide notice before making material changes to this Privacy Statement.

The Personal Information Protection and Electronic Documents Act (PIPEDA) is a Canadian federal law that applies to the collection, use, and disclosure of personal information in the course of commercial activities in all Canadian provinces as supplemented by substantially similar provincial privacy laws in Alberta, British Columbia and Québec. PIPEDA also applies to international and interprovincial transfers of personal information. This policy is designed to comply with PIPEDA.

If you have any questions or concerns about your privacy or this Privacy Statement, please Contact Us at privacy@steptechno.com.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.