Skill Struck Data Privacy Policy

Updated May 2020

Skill Struck LLC. (“Skill Struck”, “We”, “Us”, or “Our”) respects your privacy, and we strive constantly to earn and keep your trust. All personal information you share with us is treated with the utmost care. We have created this privacy policy to establish our commitment to the privacy of your data and the data of your students and children. It describes how Skill Struck collects, uses, shares and secures the personal information you provide. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. The use of information collected through our service shall be limited to the purpose of providing the service for which you (your school or school district), has engaged Skill Struck.

This privacy policy applies exclusively to the Skill Struck SaaS-based educational products and associated services, including the website skillstruck.com (the “Site”).

  1. Information We Collect and How We Use It
  2. Children’s Privacy
  3. Sharing Information with Third Parties
  4. Information Security
  5. Changes to This Privacy Policy
  6. Contact Us

If you have questions or complaints regarding our privacy policy or practices, please contact us at support@skillstruck.com.

Skill Struck receives and processes the personal data of the students, staff and other users of Skill Struck products and services through service agreements with school and district customers that purchase our products and services on behalf of those users. An individual (user or the user’s parent or legal guardian) who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct the query to the school or district or other Skill Struck customer through which the user receives access to the Skill Struck product (the data controller). If requested to remove data, we will respond within a reasonable timeframe.

We will retain personal data we process on behalf of our clients for as long as needed to provide services to our clients, to comply with our legal obligations, resolve disputes, and enforce our agreements.

Software, services, and programs delivered and accessed through the Internet necessarily involve the transmission and processing of personal data, sometimes on an international basis, depending, for example, on where the user is located. When personal information is provided to Skill Struck through the Site, the information will be processed and stored on servers located in the United States, and by using the Site, you acknowledge and give Skill Struck authorization to such transfer, processing and storage on behalf of yourself, your organization, and your students or other users as applicable.

Information We Collect and How We Use It

Skill Struck collects information, including personal information that you provide to us. We also collect personal information when your school, district, or organization creates accounts for administrators, teachers, and students. Skill Struck only collects information that is relevant and not excessive for the purposes for which it is to be processed. Personal information includes information that can identify you. For teachers or administrators, this includes full name, e-mail address, and school. For students, this includes full name, student ID, school, teacher name, and potentially parent email. If the school or district elects to do so, additional optional data may be entered for students that may include demographic data such as gender, birth date, ethnicity, special education, instructional language, participation in free lunch programs, and Title 1 status. This information is only used by Skill Struck for the purpose of completing the purpose for which provided. Data generated through the use of the Site from which personal information and attributes about any user has been removed (“de-identified data”), may be used by Skill Struck for lawful purposes, including, without limitation, product and service improvement or development, general product and service analysis, benchmarking, development of best practices, and/or educational research or statistical assessment.

Links to 3rd Party Sites

Our Site also includes links to other websites whose privacy practices may differ from those of Skill Struck. If you submit personal information to any of those websites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

Children's Privacy

What information is collected online from children under 13?

Children under 13 access Skill Struck using a student account. Typically these accounts are established by the student’s school or by Skill Struck using information provided by the school. The minimum information required to create a student account is:

  • First Name
  • Last Name
  • Student ID Number
  • Student Email

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

No. Student accounts are created by teachers or school administrators, or by Skill Struck using information provided by the school. COPPA and other laws authorize schools 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 the student account on the Site, teachers provide consent and authorization for Skill Struck to store and process personal data about those children for the purpose of providing the Skill Struck program. Children under 13 cannot create their own accounts and parents do not have access to the administrative portion of our Site where student accounts are created.

When we receive or access student personal data and education records from our school and district customers through their use of our products and 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 school or district customer.

Can a child enter personal information into your Site?

No. Personal information about children can only be entered by school personnel or by Skill Struck personnel acting on their behalf. There is no way for a student using the Skill Struck program to enter or store additional personal information on our Site. The Skill Struck program collects and stores data created by student use of the program (namely, coding level and progress data), which is linked to each student’s respective personal information.

Is a child’s personal information required for participation in the Skill Struck program?

Yes. Students need individual accounts to access the Skill Struck program and so that their progress in the software program can be monitored by the school or organization and its teachers.

Is children’s information shared with unrelated third parties?

No. Personal information obtained online from students is not released to any unrelated third party except as permitted by law or as expressly set forth in this policy (such as to certain Affiliated Businesses, as provided below), or at the direction of the school.

What are the choices of a parent or guardian?

Skill Struck collects information under the direction of its Clients (school or organization personnel or administrators of the Skill Struck product), and has no direct relationship with the students and children whose personal data it processes in working with schools or school districts. If you are a parent or guardian or otherwise a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. Service providers that we utilize to provision our products and services, and who may access or receive personal information to provide those services or functionality, are under contractual obligations with respect to the personal information and are covered by the service agreements with our Clients.

Parents and legal guardians can make choices regarding the personal information we store online for their children by contacting their child’s school or organization to review what personal information is being collected. Parents who experience difficulty or require additional information may contact Skill Struck directly, however, parents should start by contacting the school or organization first since the school/organization is the entity that contracted with Skill Struck for the services and authorized the information to be collected and stored. In addition, the child’s school or organization is best positioned to verify the parent’s identity and connection to the student, which would be necessary before Skill Struck could respond to this type of request.

Upon written request from the school or organization, or from a confirmed parent or legal guardian (as noted above), Skill Struck will provide an inventory of the personal information it holds on their behalf and take reasonable steps to allow such persons to review their information for the purposes of correction or removal, subject to the limitations (including disproportionate burdens) set forth in the US Department of Commerce's Privacy Shield Principles. We will respond to all inquiries within 30 days of receipt. Please see the contact information provided at the end of this privacy policy to contact us.

Sharing Information with Third Parties

Skill Struck does not release personal information collected or received in the Site to any unrelated third parties for promotional purposes. We may, however, share aggregated product usage data with unrelated third parties, and share personal information only as described below:

Affiliated Businesses

We may disclose information (including personal information) collected from our Site with our local authorized Skill Struck representatives for sales and support purposes. We require these representatives to comply with this policy. Skill Struck will not share your contact information with other businesses except service providers and successors, as described below.

Service Providers

We may share your information with our service providers—that is, organizations providing services to support Skill Struck functions, such as our hosting services provider, mail and email processing providers, payment processing providers, and research and support providers. All such service providers are bound by contract to refrain from using the personal information we collect from you for any purpose other than providing the specified service to Skill Struck.

Successors

In the event Skill Struck is sold to a new owner, whether by merger, stock sale, asset sale or other means, we retain the right to transfer personal information to the new owner, provided we notify you this is occurring (which may be by posting on our websites) and the new owner agrees to respect the privacy policy in effect with respect to this personal data.

Laws and Legal Rights

We also may release personal information at the request of law enforcement authorities, when ordered to do so where a formal request has been made such as in a court order, subpoena or judicial proceeding by a court or similar legal process, or when we have the right to do so and believe it is necessary to assert or protect our legal or intellectual property rights, or in protecting the physical safety of our employees, users and the general public.

Fraud Prevention

In order to protect our customers, users and ourselves from fraud or theft, we may provide personal information to law enforcement agencies or to other organizations that agree to respect the privacy policy in effect with respect to this personal data.

Information Security

Skill Struck utilizes standard security measures, such as firewall, limited access, and SSL encryption technology, designed to help protect against loss, misuse, and alteration of user information collected by Skill Struck during its transmission. Access to your data is controlled by both physical and logical controls. Only selected members of the Skill Struck staff can access the raw data or backups. All backups stored offsite are encrypted and deleted when they become obsolete. Our production systems are housed in a tier-1 hosting facility that is monitored 24 hours a day, 7 days a week. Access to these systems requires prior written approval from Skill Struck management and all access is logged and monitored. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Site, you can contact us at support@skillstruck.com.

Cookies and other Tracking Technologies

Skill Struck and our service providers use cookies or similar technologies. These technologies are used in administering the Site and maintaining user progress within the program, analyzing trends and user movements within the Site, and to gather general usage and demographic information about our user base as a whole. We may receive reports associated with these technologies by these providers on an individual as well as aggregated basis.

As is true of most websites, we gather certain information automatically and store it in log files. This information may include IP addresses, browser types, referring/exit pages, operating systems, date and time stamps, and “clickstream” data. We do not link this automatically collected data to other information we collect about you.

Teacher and student activity is stored in a relational database and used for reporting and analysis, including student user progress monitoring for teachers and administrators, and aiding Skill Struck in trend analysis and providing customer support.

We do not give log file information or student usage information to third parties, except (i) those service providers engaged to support and assist in administering our Site, or (ii) in a sanitized form disassociated from your IP address or other personal data, or (iii) as authorized or directed by the school.

Enforcement

Skill Struck periodically verifies that this privacy policy properly describes the information we collect and how we use it, and that we act in compliance with this policy. Please contact us if you have questions or concerns using the contact information below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this policy.

With respect to any complaints relating to this policy that cannot be resolved through our internal procedures, we will cooperate with appropriate regulatory authorities to resolve such complaints.

Testimonials

From time to time we may display personal testimonials of satisfied customers on our Site in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update your testimonial of request that it be removed, you can contact us at support@skillstruck.com.

Social Media Widgets

Our Site includes Social Media Features and Widgets, such as the Facebook button and Twitter button. These features may collect certain information, such as your IP address or which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with any of these features is governed by the privacy policy of the company providing it.

Changes to This Privacy Policy

Last updated: May 2020

We may amend this privacy policy at any time. If we make material changes in the way we collect, use, and/or share your personal information, we will notify you by prominently posting notice of the changes on the Site covered by this privacy policy for thirty (30) calendar days prior to the implementation of the material change and provide instructions on how to remove your information prior to the changes taking effect.

Your Choices and Access to Your Information

Skill Struck offers those who provide personal information the opportunity to withdraw consent with respect to the information they submitted at any time ("opt-out"), in which case such personal information will not be further processed. Our email programs allow you to choose to receive or stop receiving communications from us. We honor a “once out – always out” policy. Each secondary email we send to our recipients contains ‘Unsubscribe’ instructions. Once you opt out, you are opted out of that type of communication until we are explicitly told in writing that you want to opt back in. You may opt out of email programs at any time by following the Unsubscribe instructions provided in the email you receive from us. Upon request Skill Struck will provide you with information about whether we hold any of your personal information. For the Site and mobile application, you may access your personal information for the purposes of correcting, amending, or deleting it by logging into your account and reviewing and selecting your profile preferences. You may also contact us to request assistance for which we will respond to within a reasonable timeframe and as may be required by law.

Skill Struck acknowledges that you have the right to access your personal information. If you are a student or other end user receiving access to Skill Struck through a school or organization, you will need to contact the administrator that submitted your personal information to us, and we will support them as needed in responding to your request to access, change or delete the personal information submitted and associated with your account. Requests will be addressed within a reasonable timeframe and as may be required by law.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Contact Us

If you have questions or concerns regarding your privacy, please contact us as follows:

Privacy Officer
Skill Struck LLC
1555 N. Freedom Blvd. 200 W
Provo, UT 84604
E-mail: support@skillstruck.com