Privacy Policy for Education Tools and Services

CDW LLC and its affiliates (collectively referred to as “CDW”, "we," "our," or "us") provide a suite of services and complementary tools that enable educational institutions, teachers and students to get the most out of their Google Apps for Education platform (the "Google Platform"). We understand that security and privacy of personal information is very important to the schools, school districts, and related entities and organizations as well as their administrators (each a "School") that we serve and their students, parents, teachers and staff (collectively, "you"). This Privacy policy ("Privacy Policy") describes how we collect, use, share and retain your information through your use of our tools ("Tools"), or through the support, audit and other services we provide ("Services").

By accessing or using our Tools and Services on any computer, mobile phone, tablet or other device (collectively, "Device") you consent to the terms of this Privacy Policy. We may modify this Privacy Policy at any time as stated below. Your continued use of our Tools and Services constitutes your acceptance of this Privacy Policy and any updates. This Privacy Policy is incorporated into, and is subject to, the Terms of Use for the Tools and Services.

Our services are not supported for customers in Europe.

European users who installed our services prior to May 2018 are advised to cease their use.

We collect information to provide you with our innovative Tools and Services and to operate our business. We collect Personal User Data, Tool or Service Specific Data, and Anonymous User Data in support of these efforts.

1. "Personal User Data" is information that can be used, directly or indirectly, alone or together with other information, to identify you as the user of one of our Tools. This may include your first and last name, email address, telephone number, and location.
   
   
2. "Tool or Service Specific Data" includes any information provided by you as part of the functionality of a Tool or the provision of the Services. This may include personal information about you as the user, account username, password, and student information such as student name, email rosters, and class codes.

"Anonymous User Data" is information that is anonymous, aggregate, de-identified, or otherwise does not reveal your identity.

1. Services. Depending on the nature of the engagement, Schools may provide us with information required to provide the Services. This may include Tool or Service Specific Data, Personal User Data of students or staff as well as access to account credentials, Devices or systems that contain Personal User Data and/or Tool or Service Specific Data. This information is provided and controlled by your School or your child’s School, and is only used in providing our Services in a manner consistent with this Privacy Policy and applicable law, including the Family Educational Rights and Privacy Act (“FERPA”). We do not use student Personal User Data to target ads.
   
   We may also collect Anonymous User Data from our Services. This information may be used to improve our Services or Tools.
   
   
2. Tools. You will be required to provide your email address when you use our Tools. We do not collect any other Personal User Data through your use of our Tools unless you are specifically prompted for participation within a Tool’s dashboard where we may collect Tool and Service Specific Data. You will be provided with an ongoing opt-out option when prompted for any additional information. Our Tools are explicitly designed not to prompt for or collect Personal User Data from student users. The Tool and Service Specific Data collected will be used for the exclusive purpose of providing you with access to paid features of the Tools.
   
   We may collect Anonymous User Data such as the domain (e.g. "myschool.org") portion of your email address or other activity markers that allow us to analyze and report on aggregate user behavior. We use this information to improve our Tools, report usage to existing domain customers, to maintain license subscriptions, and for contacting schools that may be interested in our Services or Tools.
   
   
3. Tools with Access to Google Services. During installation, our Tools may ask either you or the domain administrator for the School to authorize us to take actions on your behalf within the services provided by the Google Platform. This authorization process utilizes OAuth2.0 protocols and provides our Tools with a token that allows us limited access and the ability to take specific actions within the Google Platform ("Google Services").
   
   These Google Services typically involve sending, storing, and sharing information with others, and may include Personal User Data. Your relationship with Google, Inc. with respect to the Google Services is defined under the terms of use and data privacy policies of Google, Inc.
   
   Unless explicitly initiated by you, no information from within the Google Services is ever shared with us, stored by us in your Google account in a manner that is publicly accessible, or held at rest in a data storage location that is not directly under your control via your Google account.

We will only disclose your Personal User Data or Tool and Service Specific Data as stated in this Privacy Policy; with your consent; as needed to complete a transaction or provide the Services or Tools; or as otherwise indicated at the time of collection. We do not disclose your Personal User Data or Tool or Service Specific Data to third parties for advertising purposes.

We may disclose your Personal User Data or Tool and Service Specific Data in the following ways:

1. Student Data. Student Personal User Data is not disclosed to third parties except as authorized and directed by your School. A School may instruct and authorize us to share student Personal User Data with third-party tools or applications it has approved for use by students and/or staff and for which it has obtained your consent (including parental consent, as required). This may include third-party tools or applications that allow schools to (i) monitor the online activities of students and staff, (ii) interact with parents, students and teachers, or (iii) enhance the education of their students. We may resell or support some of these third-party tools or applications subject to the request and authorization of a School. The practices of the third-party tools or applications will be governed by their privacy policy and terms of use. We strongly encourage you to review such policies prior to sharing any Personal User Data and providing consent to the School.
   
   
2. Services and Tools. In order to enable us to provide the Services we may provide Personal User Data or Anonymous User Data to certain third-party business partners whose products are complementary to our Services. This may include information related to the School and its IT liaison.
   
   
3. Service Providers. We may share Personal User Data or Tool and Service Specific Data with service providers who provide us with technology services such as web hosting, payment processing and analytics services.
   
   
4. As Required by Law or to Protect Rights. We may be required, subject to applicable law, to disclose your Personal User Data or Tool and Service Specific Data if: (i) it is reasonably necessary to comply with legal process (such as a court order, subpoena, search warrant, etc.) or other legal requirements of any governmental authority or as otherwise required by law, (ii) such a disclosure would potentially mitigate our liability in an actual or potential lawsuit, (iii) it is necessary to protect our legal rights or property, (iv) it is necessary to protect the legal rights or property or physical security of others, or (v) for the prevention or detection of crime and such disclosure is lawful.
   
   
5. Business Transfers. If we ever merge with another company, or should we decide to sell, divest or transfer some part or all of our business, we expect that the Personal User Data, Tool and Service Specific Data and Anonymous User Data we have collected will be transferred along with our other business assets.

We are committed to protecting the security and privacy of your Personal User Data and Tool and Service Specific Data including the Personal User Data of the students in the schools we serve. We comply with applicable laws and regulations, which govern or apply to our Tools and the provision of our Services.

1. Information Security. We maintain strict administrative, technical, and physical procedures to protect any Personal User Data and Tool and Service Specific Data that is stored on our servers against unauthorized access, theft and loss.
   
   
2. Your Responsibility. Our Tools may contain features that, if used incorrectly, can result in the inappropriate sharing of sensitive information including Personal User Data within the Google Platform. It is solely your responsibility to share sensitive information appropriately when using our Tools.

1. Student Personal User Data Student Personal User Data is provided and controlled by your School or your child’s School (as the case may be).  Upon request, we will grant you reasonable access to such data for the purpose of reviewing and/or requesting changes. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our databases.
   
   Parents have the right to ask that the online records of their children under the age of 13 be removed from the storage of any online service provider. If you wish to request that we remove your child’s records from our database, please contact the appropriate official at your child’s School and ask them to carry out this action in collaboration with our team. If you have any questions about reviewing, modifying, or deleting your child’s records, please contact the appropriate official at your child’s School directly.
   
   
2. Opting-Out. You may opt-out of allowing us to share your Personal User Data and Tool and Service Specific Data with third-party business partners for the purpose of providing products and services that are complementary to our Services. You may also elect to opt-out when prompted by our Tools to provide any additional information or to allow access tokens.
   
   
3. Access Tokens for Google Services. If you have installed our Tools and enabled the access tokens for Google Services, you can revoke the access tokens at any time from your Google Account settings. In the case of domain-installed apps, access tokens can be revoked by the domain administrator for your child’s School.
   
   
4. Deleting or Disabling Cookies. You may be able to disallow cookies to be set on your browser. Please look for instructions on how to delete or disable cookies and other tracking/recording tools on your browser’s technical settings. You may not be able to delete or disable cookies on certain mobile devices and/or certain browsers. For more information about managing your cookie settings, please visit www.allaboutcookies.org. Please note that if you disable and do not accept cookies, some features and services may not be available to you.
   
   
5. Manage Your Geolocation Services. Most mobile Devices provide users with the ability to disable location services. Disabling location services will not allow us to collect your location data (by virtue of the location of your mobile Device) when you use our Tools. Most likely, these controls are located in the Device’s settings menu. If you have questions about how to disable your Device’s location services, we recommend you contact your mobile service carrier or your Device manufacturer.

Except as set forth below, we may retain Personal User Data for the period of time required to provide the Services or the Tools. We may continue to retain Personal User Data for a commercially reasonable time following termination of the Services (i) for backup, archival, or audit purposes, (ii) to enforce our Terms of Use or otherwise defend our legal rights, or (iii) to comply with our legal obligations. Access credentials associated with a School will be promptly deleted upon termination. We may retain and use Anonymous User Data indefinitely.

For Services that involve provisioning of student accounts or other Google resources, student Personal User Data may be retained for the period of time required for the student to have access to our Tools or for us to perform the Services. Student Personal User Data will be deleted in accordance with the retention policy contained in the applicable terms of use unless we are otherwise instructed by your School.

Schools may provide student Personal User Data, which may include personally identifiable information from "educational records" as defined by FERPA, in connection with the provision of Services or use of our Tools. Student Personal User Data is owned and controlled by the Schools at all times. Schools are solely responsible for compliance with the Children’s Online Privacy Protection Act of 1998 ("COPPA") and FERPA, including, but not limited to, obtaining parental consent as required concerning the collection and disclosure of students’ Personal User Data used in connection with the provisioning and use of the Tools or as otherwise contained in this Privacy Policy. Schools are solely responsible for obtaining parental consent before allowing any User under the age of 13 to use any of the Tools.

Our Tools may contain links to or from third-party websites, applications or services. Please note that this Privacy Policy does not apply to the practices of companies we do not own or control or to people we do not employ or manage. As such, we have no control over the privacy practices of third parties and are not responsible for the privacy policies of any third-party websites, applications or services. We recommend that you review the privacy policies and terms of use of any third-party prior to visiting its website, downloading its applications or authorizing the third-party to access Personal User Data through our Services.

Our servers are located and our digital operations are conducted in the United States. Regardless of where you live, you consent to have your Personal User Data and any Tool and Service Specific Data transferred, processed and stored in the United States, and allow CDW to use and collect your Personal User Data, Tool and Service Specific Data and Anonymous User Data in accordance with this Privacy Policy.

If you have any questions or would like to learn more about this Privacy Policy, please contact us at personaldatainquiry@cdw.com.

Alternatively, inquiries may be addressed to:

Global Compliances & Ethics
CDW LLC
200 N. Milwaukee Ave.
Vernon Hills, IL 60061
USA

We may modify this Privacy Policy from time to time so you should review this page periodically.  If we make material changes to this Privacy Policy, we will provide our customers with notice in accordance with law. If a customer does not wish to be bound by the new policy, the primary administrative contact for the customer can request that we delete the School’s data from our systems.