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 * Pearson Clinical Privacy Policy





CLINICAL PRIVACY STATEMENT

INTRODUCTION

PLEASE READ THE FOLLOWING CAREFULLY

THIS STATEMENT PROVIDES GENERAL INFORMATION ABOUT THE PRIVACY STATEMENT OF THIS
WEBSITE AND ITS RELATED PLATFORMS (MOBILE OR OTHERWISE). IF YOU ARE UNDER 18
YEARS OF AGE, PLEASE BE SURE TO READ THIS PRIVACY STATEMENT WITH YOUR PARENTS OR
GUARDIAN AND ASK THEM QUESTIONS ABOUT WHAT YOU DO NOT UNDERSTAND.

YOUR USE OF THIS SERVICE CONSTITUTES ACCEPTANCE BY YOU OF THIS PRIVACY
STATEMENT.

THIS PRIVACY POLICY IS SUBJECT TO CHANGE FROM TIME TO TIME BY UPDATED POSTINGS.
THE PRIVACY POLICY IN EFFECT AT THE TIME OF USE OR SUBMISSION OF PERSONALLY
IDENTIFIABLE INFORMATION WILL BE APPLICABLE.

Pearson Clinical Assessments, a business of NCS Pearson, Inc. (“Pearson”)
recognizes the importance of protecting the privacy of our visitors to this Site
while permitting us to conduct legitimate business by providing goods, services
and information of interest.

The rights and responsibilities described in our Privacy Policy do not cover
third party websites that may be linked to our Site(s) or referred to on this
Site(s). These third party websites have their own privacy policies and we
encourage you to read and review them.

For purposes of this Privacy Policy “Personal Data” is any information that can
be used to identify you or that when added with other Personal Data can be
linked to you.

If you have any questions or concerns about the Privacy Statement, please
Contact Us.

YOUR RIGHTS AND RESPONSIBILITIES

You agree that by visiting and/or providing, transmitting, or having another
party you have authorized provide or transmit your Personal Data to us on any of
our Sites, you are accepting the practices described in this Privacy Policy and
any updates made to this Privacy Policy. It is your responsibility to read this
Privacy Policy and check for updates on a regular basis. By continuing to use
our Site, products or services after such updates have been made you are
agreeing to be bound by any changes to this Privacy Policy.

You are never required to provide us with your Personal Data. If you do not
agree to this Privacy Policy, please do not provide, transmit or allow anyone
else to provide or transmit your Personal Data to us; however, if you decide to
not provide to us your Personal Data it may affect our ability to provide to you
any products or services offered.

You agree that we may collect or receive, use, process, disclose, transfer and
retain your Personal Data as described herein. This Privacy Policy governs your
use of any and all of our Sites, platforms, and in purchasing our products and
services in general. We will use your Personal Data only for the purposes set
forth herein.

For California Residents: As described below for particular users, California
residents may submit a Right to Know and Right to Deletion request to Pearson by
using the online form or calling the toll-free phone number on our Rights
Request page.

Under California law, Pearson will only respond to verifiable requests that are
made either: (a) by a California resident; (b) by a person registered with the
California Secretary of State who a California resident has authorized to act on
their behalf; or (c) by a parent or legal guardian, if the California resident
is a minor.

We will not require a California resident to set up an account in order to make
a request or receive the requested information.  In order to respond to a
request, however, we must be able to reasonably verify, understand and fulfill
the request.  We will not be able to respond to the request if we are unable to
verify identity or the authority to make the request.   In conducting
verification, we generally will use personal information previously collected by
us. If the request is made on behalf of another individual, we may require
additional verification and documentation of the individual’s authority to make
the request.  In responding to requests, we may limit the information provided
for privacy and security reasons, as permitted by law.

We will not charge a fee to respond to a request, unless it is excessive,
repetitive or unfounded.  If a fee will apply, we will advise the requester
before completing the request, explain why a fee applies and provide an estimate
of the fee.

For Educators, Administrators, Qualified Customers, and Test Administrators: As
the subject of the Personal Data collected, you have rights related to the
Personal Data that we hold about you.

At any time you have the right to:

 * Request access to the information we hold, use, or disclose about you.
 * Ask us to correct or how to correct any inaccurate or incomplete information
   we have about you.
 * Request us to delete your information from our records.

For Students and Examinees: Students and Examinees should direct any access,
deletion or correction requests related to educational or clinical records and
data directly to their educational institutions or clinicians.  As a service
provider, Pearson cannot delete or modify education records or other records
collected or processed for, or on behalf of, an educational institution, unless
it is directed to do so by the educational institution or clinician and
therefore for any requests submitted to Pearson, we will redirect you to your
educational institution or clinician.

OUR RIGHTS AND RESPONSIBILITIES

We will provide you access to these Rights and Responsibilities and any
subsequent updates.

We encourage you to periodically review this Privacy Policy to learn more about
our information practices as they change over time. We reserve the right to
update this Privacy Policy periodically, without notice. A change in the
effective date will indicate that the Privacy Policy has been updated. Any
changes to our Privacy Policy will become effective upon posting of the revised
Privacy Policy on our Site(s). Your use of our Site(s), and any of our products
and services following such changes constitutes your acceptance of the revised
Privacy Policy then in effect.

Depending on the Services, we may collect and process your personal data in
order to manage day to day business needs including, but not limited to,
performing services on behalf of a business, payment processing and financial
account management, business planning and forecasting, system improvements,
security and fraud prevention, and compliance with legal and regulatory
obligations.

Pearson and its subcontractors will at all times protect your Personal Data with
appropriate operational, administrative, technical, and physical security
safeguards.

We do not disclose your Personal Data to third parties unless otherwise stated
below. We do not monetize Personal Data. We have not sold, within the last
twelve (12) months, any Personal Data collected through this site, except to the
extent that third party targeted advertising cookies are ultimately determined
to involve a sale of personal information under California law. We currently do
not enable third party targeted advertising cookies on this site. The following
categories of personal information may have been collected and shared through
such cookies and related technologies during the past 12 months within the
digital advertising ecosystem:   Identifiers (limited to a numeric identifier,
such as an IP address) Commercial Information, Internet or Similar Network
Activity, Geolocation Data and Inferences draw from other Personal Information.

DATA CATEGORIES

Depending on the Services, we may collect and process the following categories
of data in order to manage day to day business needs including, but not limited
to, performing services on behalf of a business, payment processing and
financial account management, business planning and forecasting, system
improvements, security and fraud prevention, and compliance with legal and
regulatory obligations:

(A) Identifiers such as a real name, address, unique personal identifiers, or
email address

(B) Customer records such as signature

(C) Characteristics of protected classifications under California or federal law

(D) Commercial information, such as products or services purchased, obtained, or
considered

(E) Internet or other electronic network activity information such as
information regarding a consumer’s interaction with an Internet Web site,
application, or advertisement

(F) Geolocation data

(G) Sensory data, such as audio, electronic, visual, or similar information

(H) Professional or employment-related information

(I) Education information

(J) Inferences about preferences, characteristics, psychological trends,
preferences, predispositions, behavior, attitudes, intelligence, abilities, and
aptitudes

COLLECTION AND STORAGE OF INFORMATION

We will collect certain personal information during different activities on this
Site or otherwise, such as user registration, when you purchase materials,
participate in a survey, contact us with questions or offer feedback on the
Site. In connection with such activities, you may be asked to provide certain
information such as your name, mailing address, telephone number, fax number,
credit card number and email address. In order to qualify for the purchase of
materials we may also request professional qualifications, affiliations or
employment information. We may maintain this information in our computer and
ordering system.

PLATFORM AND SYSTEMS INFORMATION

CLASSROOM ASSESSMENTS

aimsweb®Plus


aimswebPlus is an efficient and effective assessment, data management, and
reporting system for grades K-8 that supports multi-tiered instructional models.
aimswebPlus is designed to universally screen and progress monitor. aimswebPlus
allows educators and administrators to capture, manage, and report assessment
data in one web-based system. It includes assessment programming; extensive
reporting and monitoring tools designed for use by education agencies and school
district and school authorized staff.


Access and Information Correction
Access to the aimswebPlus Site is restricted by password to educators only
authorized by the school, district, or State Department of Education
(“Educational Institution”) sponsoring the product. Educational Institutions are
responsible for authorizing educator access to this Site and maintaining all
access information. No parent or student access is authorized through this Site.

Only an authorized educator may enter data on a student’s record through this
Site. An authorized educator may review the student record on this Site, make
student record changes, review available assessment reports and otherwise review
data for that student. An educator may contact Pearson at info@aimsweb.com if
the educator believes there may be an issue with a student record, a report or
encounters any issues in accessing or correcting information through this Site.

Data Collection and Use 
Educator: To create a record for a student the following information must be
collected from educators through this Site: student’s name, grade, birth date,
gender, student identification number, district, school, service code, ethnicity
and free and reduced lunch status. The following additional information may be
collected: Entry Grade, IEP, ESL, Section 504, After School, Correctional,
Summer School, IDEA, Gifted/Talented, Intervention Level, Mobility, Behavior
Disorder, Federal Disability Categories. Upon initial login by an educator the
following personal information may be collected: name, school district, address,
phone number, and email. If Pearson receives inquiries or emails about or
through this Site from educators, Pearson may keep a record of the email,
correspondence and comments, including the individual’s name, school district or
organization name and email address in order to reply to the communication,
perform Site support and issue resolution and maintain business records
concerning this Site. THE ENTRY OF ALL STUDENT PERSONAL DATA IS THE SCHOOL'S
RESPONSIBILITY AND PEARSON ASSUMES NO RESPONSIBILITY TO ENTER, COLLECT, OR
REVIEW ANY SUCH DATA.

 * Student Data: Students cannot access aimswebPlus. Any required student
   testing is conducted in a separate test platform, TestNav. Once a student
   completes testing in TestNav the student testing data is transferred to
   aimswebPlus. The student data collected in AimswebPlus will be used by
   educators to assess student progress and provide necessary intervention and
   remediation appropriate for the specific student. Student testing data can be
   reported to Parents as a pdf file extract from aimswebPlus. 
   
   
 * Parents and Students: Pearson cannot collect personal information directly
   from parents or students through this website. Parents and students will not
   have login or access to AimswebPlus. Parents and students may receive PDF
   report extracts from an educator. Parents and students should direct all
   inquiries related to this Site to their School or School District.

Transmission and Retention of Information
Customers have the ability to export their data at anytime.  However, Pearson
will produce regular backups of any student data of customer and will escrow
these backups. Assuming all fees owed by customer are current and have been
paid, customer may request that any of the student data of customer be copied to
physical data storage media and provided to customer. Charges will apply for
this service. This service (receiving data) will be available to customer only
during the term of this Agreement and for a maximum period of three (3) months
following the termination or expiration of this Agreement. After the three (3)
month period expires, all such data may be destroyed and not available to
customer.

Development Reading Assessment®

Developmental Reading Assessment® (DRA™) is a formative reading assessment
system that allows educators to assess student reading level and observe,
record, and evaluate changes in performance.

Access and Information Correction
Access to DRA is restricted to the administrator designated by each school as
well as educators and view-only access users designated by the administrator.

Users cannot change their unique user identification but they may change their
password at any time.  The educator for a student or school administrator may
add or modify a child's assessment data from the Site at any time.

Data Collection and Use

 * Administrators:  Each school using the Site must designate an administrator,
   whose name is provided to the Site.  The administrator also provides us with
   the following data for the administrator: office phone, birthdate and email
   address.  We are also provided with the name of the school district, the name
   of the school, and the city, county, and zip code of that school.  We collect
   from the administrator the full names of educators that the administrator has
   decided should be eligible to use the Site.  Once entered, each such educator
   is assigned a user identification and password, enabling them to log onto the
   Site and to enter or modify student DRA assessment data for students in their
   class.  An administrator may automatically import student data into the Site
   if the school or district has such files stored or otherwise available
   electronically.  THE ENTRY OF ALL STUDENT PERSONAL DATA OR DRA ASSESSMENT
   DATA IS THE SCHOOL’S RESPONSIBILITY AND PEARSON ASSUMES NO RESPONSIBILITY TO
   ENTER, COLLECT, OR REVIEW ANY SUCH DATA.
   
   
 * Educators: Educators with User IDs and passwords may log onto the Site.  If
   the administrator has not imported or otherwise entered the following
   information regarding the educator's classes and students, educators are
   asked to manually enter their students’ full names, birthdates, grade,
   gender, student ID, and any special education and bilingual classifications. 
   Users should not disclose passwords, except to the school or Pearson and the
   Site.
   
   
 * View-Only Access Users: Other school or district officials that require
   view-only access shall be given access to DRA assessment data upon
   registration.  View-only access users may only view DRA assessment data and
   may not modify or otherwise change any data on the Site.  We will collect the
   name, email address, birthdate and work phone number when registering any
   view-only access user. When registering for view-only access, a view-only
   access user shall require the approval of an administrator for the applicable
   school or district.
   
   
 * Students: Except for collecting the student information from a school
   official or educator for purposes of correlating DRA assessment data to such
   student, the Site does not request or collect any other personal information
   regarding students from the schools, administrators, educators, students or
   parents. In no event do we ask children or students for any personal
   information directly either online or offline.
   
   
 * Testing Information: DRA tests are given by educators and the test results or
   assessments of students’ results are inputted (or otherwise imported) by the
   educator into the Site and are accessible only to educators, the
   administrator or other authorized school official.  Personally identifiable
   assessment results or conclusions are not disclosed to any third party
   although we may share non-personally identifiable aggregate data.

Review360®

Review360 is a web-based behavior improvement system. It gives general and
special educators the training, recommendations, and decision-driving data they
need to manage classroom behavior and help their students succeed academically.

Access and Information Correction
Once a School has entered their students' name and information into the Site,
Users may use the Site to gather and analyze such data, and otherwise track
behavioral data. This Site uses the information collected to create and provide
customized services for you, including customized content and reports. Users
cannot change their unique user identification but they may change their
password at any time. The administrator may add or modify a student’s assessment
data from the Site at any time.

Data Collection and Use
We collect a limited amount of personal information from educators,
administrators, parents and non-registered users ("Users") about themselves and
their students in order to be able to provide the services through the Site in
connection with Review 360. This Site is only intended for use by educators in
schools and/or school districts or related entities (collectively, "Schools"),
and is not intended for use by the student. We limit the collection, use and
disclosure of personal information in accordance with this Privacy Policy. In no
event do we ask students for any personal information directly either online or
offline.

 * Administrators: Each Review 360 licensee using the Site must designate at
   least one License Manager, whose name is provided to the Site. The License
   Manager also provides us with the necessary contact information for the
   administrator. The License Manager will be responsible for setting up all
   applicable professionals utilizing this License. License Managers are also
   responsible for creating additional administrator and professional-level
   accounts. Once entered, each such User is assigned a user identification and
   password, enabling them to log onto the Site and to enter or modify student
   Review 360 data for students. THE ENTRY OF ALL STUDENT PERSONAL DATA IS THE
   SCHOOL'S RESPONSIBILITY AND PEARSON ASSUMES NO RESPONSIBILITY TO ENTER,
   COLLECT, OR REVIEW ANY SUCH DATA.
   
   
 * Educators: Educators with User IDs and passwords may log onto the Site. If a
   license/program/site administrator has not imported or otherwise entered the
   following information regarding the educator's classes and students,
   educators are asked to manually enter their students' information. To create
   a record for a student, you need to supply us with the student's grade,
   unique student number, and campus of registration (this information is used
   to personalize the content of the Site). In addition, if you are registering
   as an educator or a school, you also have the option of supplying us with the
   following information: the student's first language, ethnicity and class
   level, as well as telling us whether the student participates in an
   Individualized Education Program (IEP), or any other customized demographics
   that your school or district asks to collect. Such optional information would
   be used solely to provide the services to the Licensee or User. Users are
   responsible to maintain the confidentiality of their password and user
   identification and therefore this information should not be disclosed to any
   third party.
   
   
 * Students: Except for collecting the student information from a school
   official or educator as required for recording information, the Site does not
   request or collect any other personal information regarding students from the
   schools, administrators, educators, students or parents. In no event do we
   ask students for any personal information directly either online or offline.

WriteToLearn™

WriteToLearn is a tool for building writing skills and reading comprehension in
grades 4-12. This web-based program evaluates students’ understanding of text,
not just grammar and spelling. It also gives educators the ability to deliver
on-demand, personalized feedback.

Access and Information Correction
WriteToLearn is a web-based product of Pearson. Access to WriteToLearn and
reports are password protected. Before the School can use WriteToLearn, the
school's administrator establishes logins and passwords for each participating
educator who in turn provides logins and passwords for students enrolled in
participating classes. A school may also import into WriteToLearn a file
containing student names and assigned passwords. Pearson will use this
information to set up and provide user access, supply the WriteToLearn product
to the School and for statistical research and analysis.

Data Collection and Use
Student responses from WriteToLearn activities are collected and scored
automatically. Through this Site, the School, through the student's educator (as
designated on the Student Enrollment file), may obtain and print reports about
the results for that student and track such student's learning progress.

Data derived from student responses may be analyzed and aggregated by Pearson
for research and statistical analysis purposes to assess the validity, usability
and quality of the WriteToLearn product. Research and statistical analysis data
will exclude the student's name and the educator's name and email address, but
may include responses and results, as well as demographic data supplied
including (a) school and school district name and geographic location; (b) class
name (as specified by the School); (c) grade; and (d) gender. Summary results of
the research and statistical analysis may be shared by Pearson with third
parties.

Pearson will take appropriate, commercially standard steps to keep all
personally identifiable information about students and educators confidential.
Pearson will not share any such personal information with any third party (other
than the School) except in the following circumstances: (a) in response to
subpoenas, court orders, or legal process, to the extent permitted and as
restricted by law; (b) when disclosure is required to maintain security and
integrity of the Site, or to protect any Site user's security or the security of
other persons, consistent with applicable laws.

Ounce and Work Sampling

The Ounce Scale is an observational assessment for evaluating infants’ and
toddlers’ development from birth to 3½ years. The Work Sampling System® is an
early childhood assessment tool that allows educators to evaluate the skills of
children age 3 through third grade. Students demonstrate what they know through
a series of evaluations, which allows their educators to make informed decisions
about how to guide instruction.

Access and Information Correction
Users cannot change their unique user identification but they may change their
password at any time. The educator for a student or administrator may add or
modify a child's assessment data from the Site at any time.

Data Collection and Use
We collect a limited amount of personal information from educators,
administrators, parents and non-registered users about themselves and their
students in order to be able to provide the services through the Site in
connection with Work Sampling Online and Ounce Online. This Site is only
intended for use by parents or guardians and educators, schools and/or school
districts (collectively, "Schools"), and is not intended for use by the student.
We limit the collection, use and disclosure of personal information in
accordance with this Privacy Policy. In no event do we ask children or students
for any personal information directly either online or offline. 

 * Administrators: Each Work Sampling Online and Ounce Online licensee using the
   Site must designate at least one License Manager, whose name is provided to
   the Site. The License Manager also provides us with the necessary contact
   information for the administrator. The License Manager will be responsible
   for setting up all applicable districts and schools utilizing this License.
   License Managers are also responsible for creating additional administrator
   and educator accounts. Once entered, each such User is assigned a user
   identification and password, enabling them to log onto the Site and to enter
   or modify student Work Sampling Online and Ounce Online assessment data for
   students in their class(es). THE ENTRY OF ALL STUDENT PERSONAL DATA OR WORK
   SAMPLING ONLINE OR OUNCE ONLINE ASSESSMENT DATA IS THE SCHOOL'S
   RESPONSIBILITY AND PEARSON ASSUMES NO RESPONSIBILITY TO ENTER, COLLECT, OR
   REVIEW ANY SUCH DATA.
    
 * Educators: Educators with Users IDs and passwords may log onto the Site. If
   an administrator has not imported or otherwise entered the following
   information regarding the educator's classes and students, educators are
   asked to manually enter their students' information. To create a record for a
   student, you need to supply us with the student's name, birth date, and
   gender (this information is used to personalize the content of the Site). In
   addition, if you are registering as an educator or a school, you also have
   the option of supplying us with the following information: the student's
   first language, ethnicity and class level, as well as telling us whether the
   student participates in an Individualized Education Program (IEP), or any
   other customized demographics that your school or district asks to collect.
   Such optional information would be used solely to create aggregated
   non-personalized outcome group progress reports that may be desired by an
   administrator or a school district. You may at any time remove from the Site
   any child record that you create. If you do so, all assessments,
   recommendations, portfolio entries, and other personal information associated
   with such records will simultaneously be removed. Users are responsible to
   maintain the confidentiality of their password and user identification and
   therefore this information should not be disclosed to any third party. 
   
   
 * Guest: As a guest, you may take a tour of the Site, as well as read
   information on the different applications available on the Site. This
   requires neither registration nor log in, and we do not ask for any personal
   information from guests. 
   
   
 * Students: Except for collecting the student information from a school
   official or educator for purposes of correlating Work Sampling Online and
   Ounce Online assessment data to such student, the Site does not request or
   collect any other personal information regarding students from the schools,
   administrators, educators, students or parents. In no event do we ask
   children or students for any personal information directly either online or
   offline. 
   
   
 * Testing Information: Developmental Checklists and other individual reports
   are inputted (or otherwise imported) by the educator into the Site and are
   accessible only to educators, administrators or other authorized school
   official. Personally identifiable assessment results or conclusions are not
   disclosed to any third party although we may share non-personally
   identifiable aggregate data.

ASSESSMENT TECHNOLOGY PLATFORM (ATP): TELL™, NNAT, GMADE™/GRADE™

ATP is an education data portal with various features designed for use by a
variety of education stakeholders, including educators, parents, and students.
Some features of ATP are designed for and available only to administrators and
educators.

The purpose of the ATP features for educators is to facilitate: (a) enrollment
of students for assessments; (b) ordering of assessment-related materials; and
(c) assessment record keeping and reporting.

Access and Information Correction
Access to the ATP Site related to each Assessment Program is restricted by
password to users authorized by the educational institutions or organizations
(“Education Agency”) sponsoring such Assessment Program. State Education
Agencies are responsible for authorizing educator access to this Site, or
providing Pearson with such authorized user information. Only an authorized
educator may enter data on a student's record through this Site. An authorized
educator may review the student record on this Site, make student record
changes, review available assessment reports and otherwise track data for that
student. An educator may contact Pearson at PearsonAccessPrivacy@pearson.com if
the educator believes there may be an issue with a student record, an assessment
report or encounters any issues in accessing or correcting information through
this Site.

Data Collection and Use

 * Administrators: To create an Assessment Program record for a student and
   register students for an assessment in that Assessment Program, the following
   information may be collected from educators through this Site, as specified
   by the Education Agency sponsoring the Assessment Program: student's name,
   birth date, gender, statewide identifier, student's first language,
   ethnicity, grade level, participation in an Individualized Education Program
   (IEP). Other demographic information may also be collected if so specified by
   the Education Agency for the Assessment Program. To order materials related
   to an Assessment Program, the following personal information may be
   collected: name, school district, address, phone number, and quantity. If
   Pearson receives inquiries or emails about or through this Site from
   educators, Pearson may keep a record of the email, correspondence and
   comments, including the individual's name, school district or organization
   name and email address in order to reply to the communication, perform Site
   support and issue resolution and maintain business records concerning this
   Site.
   
   
 * Parents and Students: At this time, Pearson does not seek to collect personal
   information from parents or students through this website.

Pearson will use the data provided by educators through this Site to fulfill
orders for assessments, create reports and records concerning students, and
perform other contractual obligations for the Education Agency sponsoring the
Assessment Program.


CLINICAL ASSESSMENTS

Q-global® and Q-interactive®

Q-Global is a testing system that quickly and efficiently administer
assessments, generate scores, and produce reports. Q-Global is a web-based
system and is accessible from any computer. Q-interactive is a comprehensive
digital system that can be used to administer and score tests traditionally
given by an examiner in one-on-one settings.

Definitions

 * “Qualified Customer” means a qualified clinician, professional, clinic or
   institution, which has an agreement with Pearson to use this system for
   administration, scoring or reporting of certain assessments and complies with
   Pearson’s Terms and Conditions of Sale and Use, Software License, and meets
   Pearson’s Qualifications to Purchase.
 * “Test Administrator” means a Qualified Customer or an individual designated
   and authorized by the Qualified Customer to coordinate and manage the
   assessment and scoring process and/or receive assessment test results and
   reports.
 * “Examinee” means an individual who is assigned or administered a clinical
   assessment by a Test Administrator.

Access and Information Correction
Qualified Customer access to this system is restricted by password to Test
Administrators designated and authorized by the Qualified Customer. The
Qualified Customer authorizes the level and extent of access provided to each
Test Administrator. Examinees assigned to take a clinical assessment through
this system may be provided with access to the assigned assessment
administration window only by, and under the supervision of, an authorized Test
Administrator.

Test answers are not subject to change by anyone after the test report has been
generated. Through this system, an authorized Test Administrator has the
capability to access and correct Personal Information otherwise collected
through this system.

Data Collection and Use
In providing tests and testing services through this system, We collect or
receive Personal Information from Examinees, as well as Test Administrators.
Certain Examinee Personal Information is provided to us by the Test
Administrator; and other information is provided to us by the Examinee. Test
Administrator Personal Information is provided to us by the Qualified Customer
and the Test Administrator. We use Personal Information in order to administer
and score the tests, provide test results to the Qualified Customer and
authorized Test Administrators and provide reports and invoices to the Qualified
Customer and authorized Test Administrators. We will handle and treat all
Personal Information collected and received by us through this system in the
manner outlined in this Privacy Policy. 

 * Test Administrator Personal Information Collected. The Personal Information
   that We collect, receive or process with respect to a Test Administrator
   through this system may include: name, phone number, mobile phone number,
   email address, Pearson qualification level, log-in ID and password.
    
 * Examinee Personal Information Collected. The Personal Information that We
   collect, receive or process with respect to Examinees may include: first
   name, last name, Examinee ID (as assigned by a Test Administrator), date of
   birth, gender, race/ethnicity, handedness and home language. In addition,
   depending upon the particular clinical assessment, a wide range of additional
   demographic information may be collected, including, but not limited to:
   clinical history; education history and issues; work and employment status,
   history and issues; health conditions; medications; employment status;
   marital status; family information and history; and living arrangements.
   Through this system, We collect and score the responses to the clinical
   assessment questions and derive raw scores and test scaled or percentile
   scores. 
   
   The Qualified Customer and the Test Administrator assigning and administering
   tests are responsible to obtain all legally required consents from Examinees
   and, if applicable, their parents or guardians, for the collection and
   processing of data through this system.
   
   
 * Aggregation of Non-Personally Identifiable Data. We will never use any
   personally identifiable information in any manner without Your prior
   permission. However, We may, request to use non-personally identifiable
   statistically aggregated data raw test data and other information collected
   in the testing process for our research, quality control, operations
   management, security and internal marketing purposes and to enhance, develop
   or improve tests and testing processes. 

Retention of Information
Through this system, the Qualified Customer can establish the time period
parameters for retaining Examinee test data and Examinee Personal Information on
this system. The Qualified Customer has the flexibility to archive or export
Examinee test data and Examinee Personal Information at any time.

Transmission of Information
Data collected and received by us in connection with the delivery of assessments
may be transmitted to the United States, Canada and other countries. The
computer servers for this system are currently based in Canada. The Internet is
a global environment. By using this system and sending information to us
electronically, You consent to transborder and international transmission of any
Personal Information collected or processed through this system.

INFORMATION DISCLOSURE AND TRANSMISSION OF DATA

Except for the limited exceptions set forth below, Pearson will not share with,
or disclose to, third parties the names of users, students or other personally
identifiable information collected through or in connection with this Site.
Pearson may, however, use or disclose personally identifiable information: 

 * As requested or required by the school or clinician in support of the
   platform’s purpose. 
 * In response to subpoenas, court orders or legal process, and as otherwise
   required by law;
 * To protect student or user security, or the security of other persons,
   consistent with applicable laws; 
 * In connection with the sale, joint venture or transfer of some or all of the
   assets of NCS Pearson, Inc., subject to written approval from the Educational
   Institution; and/or 
 * To affiliated companies and contractors providing services for the Assessment
   Program who are obligated to take appropriate commercially reasonable steps
   to maintain the confidentiality of such information and use it solely for the
   purposes specified in this Privacy Policy. 

Non-personally identifiable aggregated information collected through this
website may be disclosed to third parties, unless otherwise specified for a
particular product above. 

DATA RETENTION

Unless otherwise specified for a particular product above, we will retain data
as long as our customers require us to retain this data.

COOKIES AND OTHER ONLINE DATA

The Internet is a global environment. By using this site and sending information
to us electronically, you consent to transborder and international transmission
of any data that you choose to submit, including transmission within and to the
United States, where our computer operations are currently based.

With the use of cookies and other technologies, Pearson may receive and store
certain types of information about you whenever you interact with this Service.

Cookies are small text files that we transfer to your hardware, through your web
browser or app, to (a) speed your navigation on the Service, (b) recognize you
and your access privileges, (c) track your usage and preferences of the Service,
(d) detect the existence of any cookies previously set by our server, and (e)
identify certain information on how and when you accessed the Service such as
type of browser, operating system, domain names, IP addresses and the like. The
Help portion of the toolbar 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, or how to disable cookies altogether. Additionally, you
can disable or delete similar data used by browser add-ons, such as Flash
cookies, by changing the add-on’s settings or visiting the website of its
manufacturer. However, cookies allow you to take full advantage of this Service
(disabling cookies may prevent proper functioning of certain parts of the
Service), and we recommend that you leave them turned on. We currently do not
enable third party targeted advertising cookies on this site, except to the
extent that the third party uses the information solely as a service provider to
Pearson.    

Pearson may also use single pixels images, web beacons and other similar
technology (collectively “Beacons”) to (a) track your usage of the Service, (b)
track response rates to certain activities and promotions within the Service and
in marketing campaigns, and (c) identify certain information on how and when you
accessed the Service such as type of browser, operating system, domain names, IP
addresses and the like.

Sharing of Non-Personally Identifying Information with Third Parties

Pearson may share with third parties (including advertising companies and
networks) any anonymized information collected through the Service, including
those collected through the use of cookies and Beacons technology. In such
instance, we do NOT provide such third parties with any personally identifiable
information about you or any other users of the Service.

BY USING THE SERVICE, YOU AGREE THAT PEARSON MAY USE, LICENSE AND OTHERWISE
DISTRIBUTE ANY SUCH NON-PERSONALLY IDENTIFIABLE INFORMATION (ANONYMIZED DATA)
AVAILABLE ON THIS SERVICE, WHETHER COLLECTED BY PEARSON OR A THIRD PARTY, TO
ASSIST IN MARKET EVALUATION, PRODUCT ASSESSMENT AND IMPROVEMENT, EDUCATIONAL
RESEARCH, AND FOR OTHER MARKETING AND COMMERCIAL PURPOSES AS REASONABLY
DETERMINED BY PEARSON.

IP Addresses

An IP address is a number that is assigned automatically to your computer
whenever you use the World Wide Web. Web servers – the big computers that “serve
up” Web pages – automatically identify your computer by its IP address. Pearson
collects IP addresses for system administration; to report aggregate information
to our advertisers, sponsors, and partners; and to audit the use of our Service.
When visitors request pages from Pearson sites, our servers log the guests’ IP
addresses. We typically do not link IP addresses to anything personally
identifiable. This means that a visitor’s session will be logged, but the
visitor remains anonymous to us. We can and will use IP addresses to identify a
visitor if any of the circumstances mentioned in the above section titled
“Sharing Of Personally Identifying Information With Third Parties” occurs.

Do Not Track

This Service does not respond to your browser’s (or app’s) “do-not-track”
signals or comparable signals or mechanisms. Please check our Privacy Statement
frequently as this may change in the future.

Third-Party Promotional Activities

Within the Service, Pearson may offer contests, sweepstakes or promotions that
are sponsored by third-party advertisers or sponsors. These third parties may
obtain personally identifiable information that users voluntarily submit while
participating in the activity. Pearson does not control the third parties’ use
of such information so you should read their privacy policy before participating
in such activities.

Links to Third-Party Sites

Links from the Service can take you to other Pearson sites – School, Higher
Education, Professional, Global, among others – as well as to third-party sites
and resources (collectively, “Other Sites”). The information practices of such
Other Sites are not covered by this Privacy Statement or any other policies or
terms of this Service. Please make sure to review such Other Site’s terms of use
and privacy policies prior to interacting with such sites.

Public Forums

Pearson may make chat rooms, forums, message boards, web pages, and/or public
spaces available to its users. Please remember that any information that is
disclosed in these areas may become public information but, regardless, may be
available to other users of the Service and may be used by Pearson.
Consequently, you should carefully consider whether to disclose your personal
information in such public areas.

Security, Purchases and Credit Card Use

Pearson and its subcontractors will at all times protect your Personal Data with
appropriate operational, administrative, technical, and physical security to
protect the loss, misuse, and alteration of the information under our control.
Essentially, we encrypt all transmission of sensitive data and secure all of our
repositories of data. When you use your credit card to shop at Pearson, your
transaction is secure. For the purposes of handling credit card transactions, we
have contracted with a PCI DSS compliant ecommerce partner. Our servers use
Secure Sockets Layer (SSL), an advanced encryption technology that works with
most major browsers. This technology safeguards your personal information and
privacy. However, you should understand that “perfect security” is never
guaranteed.

Nature of Data on the Internet

Due to the complexity and open nature of the Internet, there is always a risk
that information collected by and/or displayed on the Service may be compromised
or accessed notwithstanding the implementation of reasonable data security
measures by Pearson. To mitigate such risks, you should (a) use secure usernames
and passwords and carefully protect them from disclosure; and (b) implement
updated internet security and virus protection software on your computer system.
Should you suspect that your computer’s security has been compromised or that
your username or password may have been have been accessed by a third party,
please contact us immediately and request to have your password changed.

Cross-Border Transfer of Data

Any personally identifiable information you provide to Pearson in connection
with this Service will be stored on Pearson’s servers or those of its affiliates
and/or authorized vendors and will be accessible by authorized employees, agents
and contractors of Pearson and its affiliates and authorized vendors. Due to the
global nature of the Service, personally identifiable information may be
transmitted, stored or processed in a country other than the one in which you
reside (“Resident Jurisdiction”), including primarily in the United States, the
European Union and India. Reasonable contractual or other measures Pearson may
take to protect your personally identifiable information while outside the
Resident Jurisdiction are subject to applicable foreign legal requirements, for
example, lawful requirements by governmental authorities or court order to
disclose personally identifiable information to government authorities in the
countries in which such data may be stored or processed. SUBJECT TO APPLICABLE
LAW, IF YOU RESIDE IN THE EUROPEAN UNION, CANADA OR OTHER JURISDICTION WITH
SIMILAR DATA TRANSFER REGULATIONS, BY ACCEPTING THE TERMS OF THIS AGREEMENT, YOU
EXPLICITLY CONSENT THAT THE PERSONALLY IDENTIFIABLE INFORMATION YOU PROVIDE MAY
BE TRANSFERRED AND STORED IN COUNTRIES OUTSIDE THE EU, CANADA OR YOUR RESIDENT
JURISDICTION, INCLUDING THE UNITED STATES, IN CONNECTION WITH THE TERMS OF USE,
THIS PRIVACY STATEMENT, AND IN ORDER TO PROVIDE SERVICES TO YOU. IF YOU DO NOT
CONSENT, PLEASE DO NOT PROVIDE US WITH ANY PERSONAL INFORMATION. YOUR PERSONAL
INFORMATION SHALL ONLY BE USED IN ACCORDANCE WITH THE TERMS OF THIS PRIVACY
STATEMENT.

SITE AND CONTENT OWNERSHIP

This Site is owned and operated by NCS Pearson, Inc. The content thereof is
protected by copyright of Pearson and/or its licensors.

CHANGES TO THE PRIVACY POLICY

We reserve the right to change the terms of this Privacy Policy from time to
time by posting an updated Privacy Policy. We encourage You to review this
Privacy Policy from time to time for any changes or updates.

CONTACT INFORMATION

If you have any questions or comments about this Privacy Statement or your
rights, please contact us at dataprivacyUS@pearson.com.

This Privacy Policy is effective as of December 20, 2019.



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