Privacy Policy

Last Updated: February 8, 2018

This privacy policy tells you how Symphony Learning LLC (“Symphony”, “we”, “us”, “our”) uses personal information collected at this site and our related services, including our online and software Symphony Math student program, and our online Administration Module (“Services”). Please read this privacy policy before using the site or submitting any personal information. By using our services, you are accepting the practices described in this privacy policy. These practices may be changed, but any changes will be posted and changes will only apply to activities and information on a going forward, not retroactive basis. You are encouraged to review the privacy policy whenever you visit the site to make sure that you understand how any personal information you provide will be used.

NOTE: the privacy practices set forth in this privacy policy are for our Services only. If you link to other web sites, please review the privacy policies posted at those sites. Symphony Learning is not responsible for the privacy practices or content of those sites. This policy may change periodically, but any changes will be posted on this web site. Your continued use of our Services constitutes your agreement to the changes. If you do not agree to future changes to this Privacy Policy, you must stop using the Services after the effective date of such changes.

 

Who We Are

Symphony Learning provides web-enabled software with an intuitive interface to help students understand mathematics at an intuitive level. Students are provided access to our programs through their schools and school districts (“Local Educational Agencies” or “LEAs”), who can track their students’ performance in real-time, and identify areas of need to help improve their students’ math ability.  We serve students of all ages, but our primary audience is students ages 5 to 14.

Inside the United States, Symphony Learning sells its programs through a combination of third party service providers (“Service Providers”) and in-house staff. Where available, Service Providers help our customers use Symphony Math, and guide them through orientation and training in the use of our programs. They also coordinate the purchase of our program. Outside the United States Symphony Learning only uses Service Providers to train and deliver our Services.

The Federal Trade Commission has jurisdiction with enforcement authority over Symphony Learning LLC.

 

How We Collect Information

Our Web Site

On our main site we collect personally identifiable information about you when voluntarily submitted through our web forms. The information may include:

  • School Representative Name
  • School Name
  • School Address
  • School Telephone Number
  • Email Address

This information is used to provide contact information for inquiries regarding our products, product registration, and product feedback.

Our Student Program

LEAs engage Symphony Learning to provide our services to their students. To use the software, we must receive student information from the LEA. Personally identifiable information can only be submitted to Symphony Learning by the LEA, and is necessary for use of our Services. Student  accounts are established by the LEA. The minimum information required to create a student account is:

  • First Name
  • User Name
  • Password
  • Grade Level

In addition, we offer optional data fields. A full list of fields is available here.

As students use the Symphony Math student program, we collect information related to their performance and progress. This data may include assessment scores, individual task scores, dates and times of program use, and curriculum settings.

Our Administration Module

On our secure Administration Module site we maintain data that is needed in order to maintain LEA rosters and also view student and group data, including student performance metrics associated with our program, such as student scores on our assessments and historical tracking of program achievement.

Symphony Learning also collects information relating to the school and staff members. Each staff member must have a Staff Account, which must include the following data:

  • First Name
  • Last Name
  • Email Address
  • Password

During the purchase process, our Service Providers send us a confirmation of the sale which may contain the name and address of the school, and also the name and contact information for the main technical contact at the school.

 

Privacy Details 

What information is collected online from children under 13?

Children under 13 use the Symphony student programs using a student account. These accounts are established by the LEA. The minimum information required to create a student account is:

  • First Name
  • User Name
  • Password
  • Grade Level

In addition, we offer optional data fields. A full list of fields is available here.

Do you obtain parental consent prior to collecting information from the child?

COPPA and other U.S. laws authorize LEAs to act in place of the parent or guardian in deciding whether to give consent to the collection and use of student information for educational purposes.  By creating student accounts, LEAs provide consent and authorization for Symphony Learning to store and process personal data about those children for purpose of providing our Services.  Children under 13 cannot create their own accounts and parents do not have access to the administrative portion of our Sites where student accounts are created. When we receive or access student personal data from LEAs through their use of our Services, we understand that we are acting in the capacity of a “school official” under FERPA, and are committed to complying with the limitations and requirements imposed on us as an educational service provider to our school and district customers under FERPA and other applicable state student records privacy laws.  Student personal data is used only for the purpose of fulfilling our duties and provisioning our products and services under our services agreement with our school and district customer, and is not otherwise used or disclosed except as provided for in the service agreement, as required by law, or as authorized or directed in writing by our LEA customer.

 

Information Security

Whenever you use the Administration Module or Symphony Math student program, all data transactions are made using secure socket layers, the best protection that we have available for protecting your information. For information on SSL and HTTPS transactions, click here.

Symphony Learning partners with an established and reputable host provider for the storage of sensitive customer data. Our data servers are located in one location within the United States, and we use dedicated machines that are accessible only by our staff and the administrators at our host provider. Our content asset servers, which provide customer access to sounds, images, and movies, may be hosted at several locations throughout the world to ensure a consistent and reliable user experience, but do NOT contain any personally identifiable information.

 

Distribution of Information

Symphony Learning does not provide, sell, trade, or rent personally identifiable information to any non-agent third parties or for any use not in line with the purposes for which the data was originally provided. If this practice should change in the future we will update this policy to identify those third-parties and provide individuals with opt-in or opt-out choice, as applicable. We may disclose this information as follows:

LEAs and Associated Staff Members

We may provide student information, records, and performance data as part of our Administration Module and services.

Parents and Legal Guardians

We may provide student information, records, and performance data to the students’ parents and/or legal guardians.

Service Providers

Our Service Providers may have access to personally identifiable information when they perform services on our behalf, such as product training, purchasing, and/or data storage, subject to confidentiality and security obligations.

Legal Compliance

We may share information with governmental agencies or other companies assisting us in fraud prevention or investigation. We may do so when: (1) required by law; or, (2) trying to protect against or prevent actual or potential fraud or unauthorized transactions; or, (3) investigating fraud which has already taken place. The information is not provided to these organizations for marketing purposes. Note that we may be required to release the personal data of EU individuals in response to lawful requests from public authorities including to meet national security and law enforcement requirements.

Pursuant to the EU-US Privacy Shield Framework Symphony Learning may be liable for the appropriate onward transfer of personal data to third parties.

Symphony Learning complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.  Symphony Learning has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.

If there is any conflict between the terms of this privacy policy and the the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification please visit https://www.privacyshield.gov/.

 

Reviewing, Editing, and Deleting Your Information

We acknowledge the right of individuals to access their personal data. Parents and legal guardians can request to see the personally identifiable information that we have collected about their children. Parents and legal guardians may also ask to have that information deleted, and can inform us that they do not consent to any further collection or use of their child’s personally identifiable information. Requests to access data and/or deletion of information can be made at any time via written request by either the LEA or from a confirmed parent or legal guardian.

Upon written request, Symphony Learning will provide a full inventory of personal information held on the student’s behalf. We will respond within 30 days, and take all reasonable steps to allow the review and correction/deletion of this inventory. In the EU, this is subject to the limitations set forth in the US Department of Commerce’s Privacy Shield Principles. Contact information is provided at the end of this policy document.

 

Cookie/Tracking Technology

Our Services may use cookies and tracking technology depending on the features offered. Cookies and tracking technology are useful for gathering information such as browser type and operating system, tracking the number of visitors to the site, and understanding how visitors use the site. Cookies can also help customize the site for visitors. Personal information cannot be collected via cookies and other tracking technology, however, if you previously provided personally identifiable information, cookies may be tied to such information. Aggregate cookie and tracking information may be shared with third parties, but only if such aggregated data is not readily traceable back to the individual to whom it refers.

 

Privacy Contact Information

Privacy Officer
Symphony Learning LLC
PO Box 382
Scituate, MA 02066
E-mail: privacy@symphonylearning.com
Telephone: 1-800-234-3030

In compliance with the Privacy Shield Principles, Symphony Learning commits to resolve complaints about our collection or use of your personal information. European Union individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us by using the information provided above.:

Symphony Learning has further committed to refer unresolved Privacy Shield complaints to BBB EU Privacy Shield, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information or to file a complaint.

Finally as a last resort and in limited circumstances EU individuals with residual complaints may invoke a binding arbitration option before a Privacy Shield Panel.