Scholastic Reading Pro & Reading Pro Library Privacy Policy

Welcome to Scholastic Limited’s Privacy Policy for the online reading management programmes Scholastic Reading Pro and Reading Pro Library, through which it provides customers and customer end users (being teachers, administrators and students of schools, colleges, academies and other education institutions) with access to various online services to help monitor and assess independent reading and raise reading standards at student, class and whole school level (collectively the “Services”).

Scholastic Limited (“we”, “us” or “our”) knows that your privacy is important to you, and we want you to know that it is important to us too. This Privacy Policy will (amongst other things):

• describe the types of personal data we collect when you access and/or use the Services via the Scholastic Learning Zone platform (“SLZ”) or otherwise;
• inform you as to how and in what circumstances we use, share and look after your personal data once it is collected; and
• tell you about your privacy rights and how the law protects you and your personal data.

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy aims to give you information on how we collect and process your personal data through your use of the Services.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data (for example the SLZ Privacy Policy available at https://www.scholastic.co.uk/SLZ-UK-Privacy-Policy). This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER

This Privacy Policy is issued on behalf of the Scholastic Limited so when we mention “Scholastic”, “we”, “us” or “our” in this Privacy Policy, this is who we are referring to. Scholastic Limited is the controller and responsible for the Services.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out below.

CONTACT DETAILS

If you have any questions about this Privacy Policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Scholastic Limited

Email address: privacy@scholastic.co.uk

Postal address: Westfield Road, Southam, Leamington Spa, Warwick, CV47 0RA

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our Privacy Policy under regular review. This version was last updated in January 2023.

It is important that the personal data we hold about you is accurate and current. We encourage you to review, update and correct the personal data that we hold about you. Please keep us informed if your personal data changes during your relationship with us.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Students:
  • Identity data, including your full name, student ID, the name of your school, your year group, your class name(s) and your Lexile level/reading ability;
  • Profile data, including the username and password that you use to access the Services, books you have read and had recommended to you and competition or quiz results , as well as interests, likes, dislikes and preference/favourites (e.g. favourite pop star or football team) from a pre-selected list;
  • Technical data, including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Services , operating system, search terms, referring page, device information, pages visited, and user interaction information) (via cookies and related tracking technologies); and
  • Usage data, including information about how you use the Services, such as any schoolwork you may do using the Services and information or education records you choose to include about yourself via a teacher or otherwise via the Services, messages with teachers, book ratings, book reviews, voice recordings of book readings.

• Teachers and School Administrators:
  • Identity data, including your full name, user ID, and the name of your school;
  • Contact data, including your work email address and telephone number;
  • Profile data, including the username and password that you use to access the Services classes created by you (including class codes) on certain of our Services, which students subsequently attend your classes, the activities you assign students in your classes and the scores achieved by students in your classes, messages with students;
  • Technical data, including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Services, operating system, search terms, referring page, device information, pages visited, and user interaction information (via cookies and related tracking technologies);
  • Usage data, including information about how you use the Services; and
  • Marketing data, including your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of the Services. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the Services). In this case, we may have to cancel all or some of the Services you have subscribed to / purchased from us and we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, Profile and Marketing & communications data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our Services;
  • create an account on SLZ in order to access the Services;
  • apply for and/or subscribe to our Services;
  • request marketing to be sent to you;
  • enter a quiz or competition; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with the Services, we will automatically collect Technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

• Third parties or publicly available sources. We will receive Technical data about you from various third parties as set out below:
  • analytics providers; and
  • search information providers.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Performance of a Contract: this means that we process your personal data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

• Legitimate Interests: this means that we process your personal data where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. “Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best Services and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

• Comply with a Legal Obligation: this means that we process your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

Where you are a teacher or an administrator, we will get your express opt-in consent before sending you any marketing communications or sharing your personal data with any third party for marketing purposes.

For the avoidance of doubt, we will not send any marketing communications to students who use the Services.

OPTING OUT

You can ask us acting on our behalf to stop sending you marketing communications at any time by logging into SLZ and/or the Services and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message sent to you or by contacting us at any time.

COOKIES

The Services use cookies to distinguish you from other users. This helps us to provide you with a good experience when you use our Services and also allows us to improve our Services.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Services may become inaccessible or not function properly.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of the Services. They include, for example, cookies that enable you to make use of the Services.
• Analytical or performance cookies. These allow us to see how you are using the Services. This helps us to improve the way our Services work, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to use our Services. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

SLZ is has an idle session timeout of 3600 seconds (i.e. 1 hour). Once timeout happens it invalidates the user’s current session and then there is no further use or deployment of session cookies. The remaining supporting cookies will be there until the restarting of the user’s browser. Once the user’s browser closes, these cookies will be cleared.

We do not share the information collected by the cookies with any third parties.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Site and/or Services.

Please note that we remove all records associated with a user when the user leaves the school and the school notifies us of this. It is the responsibility of the school or its teachers (as applicable) to ensure that user is deleted from a school’s records and no longer able to access the Services.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA We may share your personal data with the parties set out below for the purposes set out in the table above.

• Other companies in the Scholastic Group acting as joint controllers or processors.
• Service providers acting as processors who provide services such as IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide services such as consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Some of our Scholastic Group companies and external third parties are based outside the UK (but within the EEA) so their processing of your personal data will involve a transfer of data outside the UK (but within the EEA).

We do not transfer your personal data outside the European Economic Area (EEA) except in exceptional circumstances, for example to Scholastic Group companies and/or external third parties providing ancillary services in respect of the Site based outside the EEA. Where our in-house support team (based in India), having already attempted to provide you with technical support without processing your personal data, is unable to provide you with such technical support without processing your personal data, in which case we will always seek your prior explicit consent before sharing your personal data with them in order to resolve any issues you are experiencing with the Services.

Whenever we transfer your personal data out of the UK or EEA (as applicable), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data (e.g. the UK or EU/EEA member states).
• Where we use certain service providers or transfer personal data to other Scholastic Group companies, we may use specific contracts approved for use in the UK or EU (as applicable) which give personal data the same protection it has in the UK or EU (as applicable). Please contact us if you want further information on the specific mechanism used by us when transferring your personal data to other countries.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We will retain your personal data for the duration of your school’s subscription to the Services and for a period of up to one (1) year following the closing date of your school’s subscription to the Services (subject to your school renewing its subscription within such one (1) year period). You can request further information about our data retention policy by contacting us at privacy@scholastic.co.uk.

We will contact your school throughout this one (1) year period to advise them of when your rights to access the Services will lapse, when your personal data will be deleted and to encourage them to renew its subscription to the Services.

Your school may instruct us at any time within such one (1) year period to delete any or all of the personal data we hold in relation to its teachers, administrators and/or students, in which case we will comply with such request promptly rather than continue to retain your personal data for the remainder of such one (1) year period.

It is the responsibility of your school to:

• inform us if a teacher, administrator or student with access to the Services has left the school; and
• delete or request that we delete such teacher’s, administrator’s or student’s personal data from the Services. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.