It is Promethean’s privilege to provide Product solutions around the world that transform learning and business spaces into engaging and collaborative environments and immerse customers in the latest interactive technology. The trust you have in Promethean’s Product solutions is the foundation of who we are as a company. That trust is why protecting the privacy and security of your Personal Information is paramount to Promethean. We want you to know that:
- Promethean is committed to protecting your Personal Information;
- Promethean will not sell any of your Personal Information to third parties for their marketing purposes;
- Promethean will use your Personal Information to provide you with superior products and services;
- Promethean will abide by privacy laws and regulations as applicable around the world; and
- Promethean will use reasonable security measures to protect your Personal Information.
We promise to Process your Personal Information in a manner that is always lawful, fair and transparent. We also promise to provide you with choice and control over the use of your Personal Information in accordance with prevailing laws and obligations.
A. How Do We Collect Your Information and What Do We Use It For?
1. Information You Provide to Us.
a. Explain Everything Product
i. Account Information for Adults. We intentionally minimize the Personal Information required to use Promethean Products. A username and password are required to create and access your account. In addition, we may also collect contact information such as first name, last name, User type (e.g., teacher, administrator, etc.) and e-mail address. We process this information to provide the Products to include but not be limited to the EE Service or access to the EE App. The legal basis for this Processing activity is the performance of a contract and Promethean’s legitimate interest in providing quality, engaging and useful products and services.
ii. User Submission. We receive and store any information you knowingly enter on the into Promethean Products (including through User Submissions (as defined in the Agreement), whether via computer, mobile phone, tablet, or other wireless device that you provide to us in any other way. This information may include Personal Information such as your name and email address and Student’s Personal Information.
iii. Student Information. Promethean collects limited Personal Information from students (“Student Personal Information“) only when that student’s school, district, and/or teacher has contracted with Promethean for the use of Promethean Products and such use leads to Promethean’s collection of Student Personal Information for an educational purpose and the use and benefit of the learning environment.
Students under 18 years of age (“Underage Student”) are not allowed to create an account within a Promethean Product or Online Service unless the Student’s parent or guardian has provided verifiable parental consent or, alternatively, a teacher, school or school district has consented to the processing of the Student Personal Information for an educational purpose. Underage users may only utilize a Product under a student account established by a school customer as part of a group account or an account of a customer over 18 years of age. In all such cases, a student is only permitted to use the Product in an educational context. Promethean does not offer, and Underage users are not permitted, to use any Promethean Product for any purpose, including any commercial purpose, other than an educational purpose. If Promethean becomes aware that an Underage user is using a Product for any purpose other than an educational purpose, or where the adult or School customer does not have the right, authority or legal basis to authorize the Underage user to use the Promethean Product, Promethean may, in its sole discretion, immediately terminate the Underage user’s account and delete all data associated with the account.
SCHOOLS ARE REQUIRED TO COMPLY WITH APPLICABLE LAW AND ARE ONLY PERMITTED TO UPLOAD CONTENT TO THE PRODUCTS THAT CONTAIN THE PERSONAL INFORMATION OF ANY STUDENTS IN COMPLIANCE WITH APPLICABLE LAW. FOR SCHOOLS LOCATED IN THE UNITED STATES, IN THE EVENT PRODUCT LICENSES ARE ASSIGNED TO STUDENTS, YOU ACKNOWLEDGE AND AGREE THAT UNDER THE FAMILY EDUCATIONAL RIGHTS AND PRIVACY ACT (FERPA) PROMETHEAN IS ACTING IN THE CAPACITY OF A SCHOOL OFFICIAL AND ALL STUDENT PERSONAL INFORMATION WILL REMAIN UNDER THE SCHOOL’S DIRECTION AND CONTROL. FOR SCHOOLS LOCATED IN THE UK AND EU, THE SCHOOL WILL BE THE CONTROLLER WITH REGARDS TO ANY STUDENT PERSONAL INFORMATION UPLOADED INTO THE PROMETHEAN PRODUCT AND PROMETHEAN WILL BE THE PROCESSOR WITH REGARDS TO ANY SUCH STUDENT DATA.
b. One.Promethean.Com Product
i. Account Information. We intentionally minimize the Personal Information required to create a One.Promethean.com account. Specifically, limited information such as an e-mail address and password are required to create and access your account. We process this information to provide the One.Promethean Service to you. The legal basis for this Processing activity is the performance of a contract and Promethean’s legitimate interest in providing quality, engaging and useful products and services.
ii. Contact Information. In addition, we may collect contact information such as first name, last name, and e-mail address. We process this information to provide the Service, Mobile Application or the System to you. The legal basis for this Processing activity is the performance of a contract and Promethean’s legitimate interest in providing quality, engaging and useful products and services.
iii. Your organization name (e.g., school name, district name, etc.). We may collect this information to associate your account with other accounts within your organization and to ensure that the administrator of your organization’s use of the Product or Online Service can perform administrative functions relative to your account (and all other accounts associated with your organization).
iv. Each time you login and access the Product or Online Service, we will collect certain login information which may include your IP address, device type, name, date and time of your visit, information on your browser version, information on your operating system, including language settings, MAC addresses, and User ID. We will Process this information to provide you with access to One.Promethean Service. The legal basis for this processing activity is the performance of a contract and Promethean’s legitimate interest in providing quality, engaging and useful products and services and to guarantee the stability and security of the One.Promethean Service.
You are under no obligation to provide Personal Information to a Product when such information is requested. However, if you choose to withhold any requested information, we may not be able to provide you with the Product or certain other services or features within the Product.
You may access, correct, update, or delete your Personal Information in your profile by making the change on your account profile page. If you encounter any problems correcting, updating or deleting any Personal Information in your profile, please contact us at email@example.com.
Please be advised that requesting removal of, or not providing, certain information may result in your not receiving notification of updates to the Product or Online Service or other valuable information regarding your use of the Product or Online Service. Failure to provide information requested by Promethean or removing certain information may mean that you are not able to access relevant features of the Product or Online Service and may even result in your not being able to use the Product or Online Service at all.
If you are using the Product or Online Service as part of an organization such as a school or school district, you may need to direct any request to access, make changes to or delete Personal Information including Student Personal Information to your School’s designated Administrator. Your school’s Administrator may have access to the School’s Authorized Users’ information and the ability to update, correct, or delete the information contained therein.
Please also be advised that we have entered in agreements with certain Schools that require us to direct any requests for any change, update or deletion of Personal Information contained within an account affiliated with the School to the School for action. Accordingly, in some instances, we may be required to direct you to contact your School to ask your school to instruct us to change, update or delete the Personal Information within your account.
2. Your use of the System. During your use of a Product, we may collect and process Personal Information that is sent to us automatically by your Web browser or mobile device in connection with your use of the Product (as applicable):
a. The Product may make use of your device attributes (e.g., IP address, the name and version of your operating system, the name and version of your browser, the date and time of your use of the Product, etc.) and settings that will allow us to generally determine your geographic location. Such technologies may include IP address mapping, or other suitable technologies. We use this information to enhance and personalize your experience and to provide the Product and we will not use such information for any other purpose. The legal basis for this processing activity is the performance of a contract and Promethean’s legitimate interest in providing quality, engaging and useful products and services.
b. When you contact or send communications to Promethean, for example when you contact customer support, report a problem, or submit questions, concerns, or comments regarding the Product, we may collect Personal Information such as your first name, last name, email address, telephone number and other important information about your inquiry or concern. This information is used to respond to your communications, fulfill your requests, or provide other customer support. This processing activity is based on your consent, in the performance of a contract, depending on the initial purpose for contacting our customer support, and Promethean’s legitimate interest in providing quality, engaging and useful products and services.
c. When you subscribe to other Promethean Products, features, or activities that we may offer from time to time as a new Product or through the Product, and you submit or upload Personal Information in connection with such features or activities, Promethean will Process such Personal Information for the purposes of providing and delivering such features or activities. The legal basis for this processing activity is based on the performance of a contract, and Promethean’s legitimate interest in providing quality, engaging and useful products and services.
3. Cookies and Similar Technologies
a. Cookies. A cookie is a small text file that is placed on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, for example so you don’t have to re-enter such information whenever you come back to the website or browse from one page to another. A cookie can be classified by its lifespan and the domain to which it belongs. By lifespan, a cookie is either a:
i. Session cookie which is erased when the user closes the browser; or
ii. Persistent cookie which remains on the user’s computer/device for a pre-defined period.
As for the domain to which it belongs, there are either:
i. First-party cookies which are set by the web server of the visited page and share the same domain; or
i. Capture and store Users’ preferences, account settings, and certain login information (mainly for convenience, user verification, and account security);
ii. Compile statistics and analytics about your use of and interaction with a Product, including details about how and where our Products are downloaded from or accessed, how often a User visits or uses the Product, the date and time of User visits to, and actions on the Product, which areas of the Product are visited and for how long, and other similar traffic, usage, and trend data;
iii. Mobile analytic tools to allow us to better understand the functionality of our mobile application on your device and gain insights about how mobile application is used;
iv. Gather important functionality, testing, and performance data about our Products, including performance data related to our mobile application, such as networking activity, CPU load, and resource usage, among other relevant data;
v. Gather demographic information about our User base; and
vi. Perform other similar lawful functions.
c. Cookies used by our Products. The following lists enable you to recognize the cookies placed on your browser when you use a Product. Although we strive to list all cookies used by us or our technology partners, if you find a discrepancy or think that a cookie has been omitted, please contact us at firstname.lastname@example.org.
i. One.Promethean Cookies used on the website or web portal can be found at portal.mypromethean.com/opensourcesoftwareandcookies.
ii. Explain Everything Cookies used on the EE Site and EE Mobile App can be found at https://explaineverything.com/privacy-policy/cookie-preferences/.
1. Google Chrome: https://support.google.com/chrome/answer/95647,
2. Internet Explorer: https://support.microsoft.com/help/260971/description-of-cookies,
3. Mozilla Firefox: https://support.mozilla.org/kb/cookies-information-websites-store-on-your-computer,
4. Safari (Desktop): https://support.apple.com/kb/PH5042,
5. Safari (Mobile): https://support.apple.com/HT201265,
6. Android Browser: https://support.google.com/nexus/answer/54068?visit_id=0-636612941590933601-131731679, and
7. Opera: https://www.opera.com/help.
You can also learn more about cookies by visiting www.aboutcookies.org, which includes additional useful information on cookies and how to block or delete cookies that are already on your computer.
Please note that by blocking or deleting cookies used in a Product or Online Service or Mobile Application, you may not be able to take full advantage of the Product or Online Service and the Product or OnlineService may not function correctly or at all.
C. How Do We Use Your Information? In addition to the specific uses above, any Personal Information that you provide or that we collect by or through a Product may be generally used for the following purposes:
1. To operate, maintain, and improve a Product or Online Service.
2. To give you access to the Product or Online Service and related features, or to restrict your access.
3. To personalize the Product, or Online Service, or content made available to you, or stored by you, within the Product, as well as make the Product more user-friendly.
4. To allow you to manage your account or account information, update your account settings, and (where applicable) organize your content within the Product or Online Service, make purchases or subscribe to Products and services made available to you by Promethean.
6. To provide technical support or customer service.
D. Information Sharing
Promethean may share your Personal Information as set forth below. Please note that Promethean does not sell or rent your Personal Information to third-party companies for their marketing purposes.
2. API Integration. Promethean Products and Online Services use API integration for several third-party services including, but not limited to, Dropbox, Box, Microsoft, Google Drive, and others. All user login information is collected and stored only by these third-party cloud services. The Products and Online Services do not store or access any login credentials for any third-party services. Please refer to those companies’ privacy policies and terms of service if you have concerns or questions.
3. Legal disclosures. We may disclose Personal Information about you as required or permitted by law and/or to comply with a judicial proceeding, court order, or legal process served on Promethean. To the extent permitted by applicable law, we may also disclose Personal Information about you in response to a request from law enforcement agencies, regulators, or other public agencies (including schools or children services) or if such disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using any Promethean Product or Online Service, protect the security or integrity of our Products and Online Services, or enable us to take precautions against liability or to protect our rights.
4. Business transfers. Information about our Users, including Personal Information, may be disclosed, and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets. When required by applicable law, we will inform you of such disclosure prior to any such disclosure.
5. Anonymized information. We share aggregated, automatically collected, or otherwise non-Personal Information with third parties for various purposes, including (i) compliance with reporting obligations; (ii) for business or marketing purposes; (iii) to assist us and other parties in understanding our Users’ interests, habits and usage patterns for certain programs, content, services, promotions and/or functionality available through the Product. We do not share Personal Information about you in this case.
6. Product Specific Information Sharing.
a. Explain Everything Information Sharing with other Users of the Product
You may choose to populate your user profile on the EE Service with Personal Information, including, without limitation, your name, photograph, and school affiliation. If you are a student, your user profile may only include your username which may be system generated and may have no correlation to your real name). This user profile information will be displayed to other users to facilitate user interaction within the EE Service or facilitate interaction with Promethean. However, please keep in mind that information (whether Personal Information or Student Personal Information or not) or content that you voluntarily disclose or otherwise publish (including User Submissions) through the EE Service becomes publicly available and can be collected and used by others, in accordance with the privacy settings you select in your account preferences. Your display name may be displayed to other users when you upload content, presentations, images, or videos or send messages through the EE Service and other users can contact you through messages and comments. Please note that certain images, presentations, captions or other content (for example, videos) that you submit to, or create on the EE Service (including User Submissions) may be redistributed through the Internet and other media channels (for example, YouTube) and, consequently, may be viewed on these other media channels by the general public.
Explain Everything web app’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
E. Security and Data Retention
1. Security. The security of your Personal Information is important to us. When you enter information in a Product or Online Service, Promethean will encrypt that information using secure socket layer technology (SSL) or similar technologies. We have security measures in place to attempt to protect the Personal Information and other information submitted to us and under our control against loss, misuse, and alteration. While we cannot ensure or guarantee that loss, misuse, or alteration of information will never occur, we use reasonable efforts to prevent it. Please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure.
2. Retention. Promethean may retain Users’ account data internally for the following purposes:
a. Billing information, excluding payments made via a third-party payment processor, and transaction histories are retained to resolve subsequent billing disputes and inquiries.
b. User account history is retained to support subsequent customer service inquiries and to provide, improve and develop Products, and other Promethean products and services.
c. To promote safety and security on and for the Products or Online Service.
d. To comply with legal obligations.
e. For other lawful purposes.
We may retain your information for as long as is necessary and relevant to your use of a Product or Online Service and our operations, which may include retaining your information beyond the end of your use of the Product or Online Service. We will comply with any lawful request you submit to Promethean regarding the processing of your Personal Information in accordance with applicable law.
4. Accessing and Updating Your Personal Information
If Personal Information about you changes, or if you no longer desire to use our Product or Online Service, you may correct, update, amend or delete your account under your account settings at any time.
F. Retention and Deletion of Personal Information:
1. We will retain your information for as long as your account is active or as needed to provide you the EE Service, or as described herein. We only want to retain and process your personal information for as long as needed for the purposes that we have collected your personal information. Accordingly, to protect against retaining or processing your personal information for longer than is needed for the purposes of providing you with the EE Service, we may delete your personal information due to inactivity if you fail to log in or access your account for a period of time. You may, of course, cancel your account at any time. If you wish to cancel your account, please contact us at email@example.com.
2. . Promethean will promptly delete or de-identify Student Data upon request or instruction by the school or teacher within thirty (30) days of such request or instruction. Please contact us at privacy@ to request account deletion. We will retain, delete, or de-identify Student Data according to our policies below:
a. Explain Everything. Upon expiration or termination of an Explain Everything subscription, all accounts under the subscription will be converted to a free account and data associated with the accounts will remain in the free account, except for student accounts, which are discussed below in more detail.
b. . With regards to free accounts, where the EE Service does not detect customer activity for a specified period of time, the EE Service may disable the account and all data associated with the account will be deleted.
c. Explain Everything Student Accounts. Student accounts will be disabled in one or more of the following situations:
i. When a teacher or school’s subscription terminates; or
ii. When a teacher disables a code that was shared with one or more students that allowed the one or more students to create an account.
In all cases, all Student Data in each disabled account will either be de-identified so that the Student Data in each such disabled account is permanently irretrievable or deleted. Information associated with a student’s former account that has been de-identified cannot be retrieved or made available to the student via any new student account. We may maintain anonymized or aggregate Student Data, including usage data, in a form that does not identify a particular individual, for analytics purposes. Promethean in its sole discretion may delete anonymized or aggregate Student Data at any time.
G. Children’s Privacy
Promethean does not knowingly collect any information from children under the age of eighteen (18) unless and until a school or teacher has provided appropriate consent and authorization for a student under eighteen (18) to use the EE Service and for Promethean to collect information from such student. Please contact us at firstname.lastname@example.org if you believe we have inadvertently collected personal information from a child under eighteen (18) without proper consents so that we may delete such information as soon as possible.
H. Storage and International Transfer of Your Personal Information
All Personal Information (i.e., profile data and general End-User content), which we collect, is sent to and stored on secure servers in the United States or as otherwise indicated at the following link: portal.mypromethean.com/opensourcesoftwareandcookies.
Such storage is necessary to Process the information. Promethean operates globally and we may transfer the Personal Information that we collect from you to our other offices and/or to the third-parties as described herein. Accordingly, Personal Information may be Processed outside of your country or regional area. Wherever we transfer your Personal Information, we will take reasonable steps to comply with applicable law, protect your Personal Information, ensure an adequate level of protection, and have appropriate safeguards for our Users’ rights and legal remedies.
I. Questions and Complaints
Lower Philips Rd
Blackburn, UK, BB1 5TH
Please note that our European Union Representative for personal data processing and other privacy related inquiries is:
PROMETHEAN POLAND SPÓŁKA Z OGRANICZONĄ
ODPOWIEDZIALNOŚCIĄ (“Promethean Poland sp. z o.o.”)
ul. Grabarska 1
J. EU Users.
Accessing, Correcting, and Deleting your Personal Information: If you are an EU resident, you have certain rights in relation to your Personal Information: (i) the right to be informed about how your Personal Information is being used; (ii) the right to access the Personal Information we hold about you; and (iii) the right to request the correction of inaccurate Personal Information we hold about you and to request the blocking or deletion of your Personal Information where the processing does not comply with local data protection laws. To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out above. Please provide as much information as you can about the Personal Information you are enquiring about. We will respond to your request within thirty (30) days (or less, if required by law). If you ask us to correct, update, delete, or change the Personal Information we hold about you, we will do so if we are satisfied that this is required. If we decide not to change your Personal Information in the manner you have requested, we will advise you of this in writing and how you can complain if you are not satisfied with our decision. If you request a change to your Personal Information and we do not make that change, you may request that we note on our records that you requested a change to your Personal Information that was not made and the reasons that change was not made.
Please contact us at email@example.com if you have questions about accessing, correcting or deleting your Personal Information.
You acknowledge, agree and consent to the following: Promethean will store and process Personal Information in various data centers around the world, including the United States, and that your Personal Information may not be stored or processed only within the country in which it was collected unless and except to the extent required by law. If you are located in the European Union (the “EU”) or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. As such, Promethean has entered into standard EU model contract clauses with its intragroup companies with which it shares Personal Information to ensure that the transfer of personal data of EU citizens outside the European Economic Area is safeguarded in the same way the data is required to be safeguarded in the EU. You warrant and agree that Promethean may transfer and process your Personal Information in the United States or any other country in which Promethean or its parent, subsidiaries, affiliates, or service providers maintain facilities. If applicable, you further warrant and agree that you have obtained all necessary consents from your students or Authorized Users for Promethean to process such Personal Information in the United States and elsewhere in the world.
You are responsible for understanding and complying with the local data protection and data privacy laws where you reside. By using the Product or Online Service, you consent to your Personal Information being sent to and stored at the locations, and countries, as outlined herein.
K. Security incidents
Promethean will notify you at the email address you provided to us in the event of a data breach or exposure of your personal data to unauthorized individuals.
L. For California Users.
1. Student records obtained by Promethean from a Local Educational Agency (an “LEA”) continue to be the property of and under the control of the LEA. The LEA retains full ownership rights to the information in the Personal Information and education records it provides to a Product or Online Service.
2. Promethean Product or Online Services users may retain possession and control of their own generated content by signing into and accessing their Product or Online Service account and downloading (or updating) their information within the Product or Online Service. Students have access to and control of their own information and student-generated content subject to the limitations imposed by the student’s teacher. For example, if a student completes an assessment using Promethean’s Product or Online Service and submits the assessment to the teacher within the Product or Online Service, the student may only retain possession and control of (or change answers to) the assessment if permitted by the teacher.
3. Parents, legal guardians, or eligible students may review Personally Identifiable information in the student’s records and correct erroneous information by contacting their educational institution. Additionally, Product and Online Services users may access, correct, update, or delete personal information in their profile by signing into the Product or Online Service, accessing their account, and making the appropriate changes, or by contacting us directly from within the Product and Online Service, or submitting your request to us at firstname.lastname@example.org.
4. We are committed to maintaining the security and confidentiality of student records. Towards this end, we take the following actions: (i) we limit employee access to student data to only those employees with a need to such access to fulfill their job responsibilities; (ii) we conduct background checks on our employees and, specifically, upon all employees that may have access to student data; (iii) we require employees to sign confidentiality agreements prior to being granted access to any sensitive data; (iv) we conduct regular employee privacy and data security training and education; and (v) we protect personal information with technical, contractual, administrative, and physical security safeguards in order to protect against unauthorized access, release or use.
5. In the event of an unauthorized disclosure of a student’s records, we will (1) promptly notify the LEA unless specifically directed not to provide such notification by law enforcement officials; and (2) enact the response plan and procedures described in the Promethean Data Breach Incident Response Plan that is available to the LEA upon request.
7. We will not use any Personal Information within a student’s records in Products or Online Services to engage in targeted advertising.
8. We will delete or de-identify student personal information when it is no longer needed, upon expiration or termination of our agreement with an LEA with any deletion or de-identification to be completed according to the terms of our agreement with the LEA, or at the direction or request of an LEA (school).
9. We will work with the educational institution to ensure compliance with FERPA by providing parents, legal guardians and students with the ability to inspect and review their student records within the Product or Online Service and the means to correct any inaccuracies therein.
M. Privacy Statement Changes and Updates
Last Updated: 1 November 2023