App Vetting Profile for VitalSource Learning Platform

Product: VitalSource Learning Platform

Vetted by Andrew Alfers, Vice President, Product Management at VitalSource on 2021-02-09

Privacy Rubric Results

This product has met the criteria required to achieve the 1EdTech Data Privacy Seal.

N/A
UNMET
PARTIAL
MEETS

Data Collection

Security

3rd Party Data

Advertising

Certified

Rubric Area	Expectations
General	Meets	Partially Meets	Doesn't Meet
User Notes User Notes GEN1 - How are changes to key policies managed? ANSWER: Notification is provided to the user in advance and a history of policy revisions are available User Notes: Changes to this Policy The information practices described in this Policy are current as of the effective date at the end of this document. VitalSource reserves the right to periodically update this Policy at its discretion. Notice of any revisions will be posted to this page and are effective once posted. If you are concerned about how your Information is used, bookmark this page and check back periodically. Changes to this Policy The information practices described in this Policy are current as of the effective date at the end of this document. VitalSource reserves the right to periodically update this Policy at its discretion. Notice of any revisions will be posted to this page and are effective once posted. If you are concerned about how your Information is used, bookmark this page and check back periodically.	Answer Meets Expectations	Unselected Option:	Unselected Option:
Data Collected	Meets	Partially Meets	Doesn't Meet
User Notes User Notes DCQ1 - Do the policies list all data collected? ANSWER: Policies list the data collected OR policies state no data is collected User Notes: Information We Collect The Information that we collect depends on the Products and features within those Products that a user of the Product or Distributor uses. We collect Information from website visitors, potential customers, Product users, Distributors, K-12 School personnel (collectively, “Users”) and from K-12 students (“Students”) VitalSource collects information from Users and Students when they purchase, redeem, download, access or use any content or the Products; register a Product with VitalSource; create an account; take notes or participate in assessments in a Product; use collaboration features; submit requests; and access Products, including when they visit any of our websites; as described further below. Information Provided Directly to Us Users Depending on the Products, the types of Information we collect include name, address, email address, phone number, other contact information, academic institution, payment information collected and used by our third party payment processors such as credit or debit card numbers, information regarding Product use, and user-generated content such as notes, highlights, and responses to assessments; and any other type of Information or Personal Data submitted to us. Users can choose not to provide such Information, but, in general, most of the Information we request is required for us to provide the Products and the lack of such Information will prevent us from doing so. We will collect, use, transfer and disclose this Information as described in this Policy. Students We collect Information from and about Students in order to provide the Products to Students as directed by K-12 Schools. K-12 Schools’ that create Student accounts with VitalSource Products authorize us to collect the following Personal Data from and about Students to enable Students to use our Products: name, email address, login credentials, K-12 School name, Information regarding Students’ use of the Products, and user-generated content such as the Student’s notes, highlights, and responses to assessments; and any other type of Information or Personal Data the Student submits through the Products. VitalSource also offers K-12 Schools the ability utilize certain Products without enabling VitalSource to collect or use Students’ Personal Data, such as name or login credentials. Specifically, VitalSource, through its integration partners, utilizes reference accounts in order to create and manage content through Bookshelf accounts. In such instances, VitalSource only uses and stores the reference account number for the Student account, along with the content made available to the Student and the Student’s notes and highlights, in managing these accounts. Information We Collect The Information that we collect depends on the Products and features within those Products that a user of the Product or Distributor uses. We collect Information from website visitors, potential customers, Product users, Distributors, K-12 School personnel (collectively, “Users”) and from K-12 students (“Students”) VitalSource collects information from Users and Students when they purchase, redeem, download, access or use any content or the Products; register a Product with VitalSource; create an account; take notes or participate in assessments in a Product; use collaboration features; submit requests; and access Products, including when they visit any of our websites; as described further below. Information Provided Directly to Us Users Depending on the Products, the types of Information we collect include name, address, email address, phone number, other contact information, academic institution, payment information collected and used by our third party payment processors such as credit or debit card numbers, information regarding Product use, and user-generated content such as notes, highlights, and responses to assessments; and any other type of Information or Personal Data submitted to us. Users can choose not to provide such Information, but, in general, most of the Information we request is required for us to provide the Products and the lack of such Information will prevent us from doing so. We will collect, use, transfer and disclose this Information as described in this Policy. Students We collect Information from and about Students in order to provide the Products to Students as directed by K-12 Schools. K-12 Schools’ that create Student accounts with VitalSource Products authorize us to collect the following Personal Data from and about Students to enable Students to use our Products: name, email address, login credentials, K-12 School name, Information regarding Students’ use of the Products, and user-generated content such as the Student’s notes, highlights, and responses to assessments; and any other type of Information or Personal Data the Student submits through the Products. VitalSource also offers K-12 Schools the ability utilize certain Products without enabling VitalSource to collect or use Students’ Personal Data, such as name or login credentials. Specifically, VitalSource, through its integration partners, utilizes reference accounts in order to create and manage content through Bookshelf accounts. In such instances, VitalSource only uses and stores the reference account number for the Student account, along with the content made available to the Student and the Student’s notes and highlights, in managing these accounts.	Answer Meets Expectations	Unselected Option:	Unselected Option:
User Notes User Notes DCQ2 - Do the policies indicate how data is collected? ANSWER: Policies state specifically how data is collected OR policies state no data collected User Notes: Information We Collect The Information that we collect depends on the Products and features within those Products that a user of the Product or Distributor uses. We collect Information from website visitors, potential customers, Product users, Distributors, K-12 School personnel (collectively, “Users”) and from K-12 students (“Students”) VitalSource collects information from Users and Students when they purchase, redeem, download, access or use any content or the Products; register a Product with VitalSource; create an account; take notes or participate in assessments in a Product; use collaboration features; submit requests; and access Products, including when they visit any of our websites; as described further below. Information Provided Directly to Us Users Depending on the Products, the types of Information we collect include name, address, email address, phone number, other contact information, academic institution, payment information collected and used by our third party payment processors such as credit or debit card numbers, information regarding Product use, and user-generated content such as notes, highlights, and responses to assessments; and any other type of Information or Personal Data submitted to us. Users can choose not to provide such Information, but, in general, most of the Information we request is required for us to provide the Products and the lack of such Information will prevent us from doing so. We will collect, use, transfer and disclose this Information as described in this Policy. Students We collect Information from and about Students in order to provide the Products to Students as directed by K-12 Schools. K-12 Schools’ that create Student accounts with VitalSource Products authorize us to collect the following Personal Data from and about Students to enable Students to use our Products: name, email address, login credentials, K-12 School name, Information regarding Students’ use of the Products, and user-generated content such as the Student’s notes, highlights, and responses to assessments; and any other type of Information or Personal Data the Student submits through the Products. VitalSource also offers K-12 Schools the ability utilize certain Products without enabling VitalSource to collect or use Students’ Personal Data, such as name or login credentials. Specifically, VitalSource, through its integration partners, utilizes reference accounts in order to create and manage content through Bookshelf accounts. In such instances, VitalSource only uses and stores the reference account number for the Student account, along with the content made available to the Student and the Student’s notes and highlights, in managing these accounts. Information We Collect The Information that we collect depends on the Products and features within those Products that a user of the Product or Distributor uses. We collect Information from website visitors, potential customers, Product users, Distributors, K-12 School personnel (collectively, “Users”) and from K-12 students (“Students”) VitalSource collects information from Users and Students when they purchase, redeem, download, access or use any content or the Products; register a Product with VitalSource; create an account; take notes or participate in assessments in a Product; use collaboration features; submit requests; and access Products, including when they visit any of our websites; as described further below. Information Provided Directly to Us Users Depending on the Products, the types of Information we collect include name, address, email address, phone number, other contact information, academic institution, payment information collected and used by our third party payment processors such as credit or debit card numbers, information regarding Product use, and user-generated content such as notes, highlights, and responses to assessments; and any other type of Information or Personal Data submitted to us. Users can choose not to provide such Information, but, in general, most of the Information we request is required for us to provide the Products and the lack of such Information will prevent us from doing so. We will collect, use, transfer and disclose this Information as described in this Policy. Students We collect Information from and about Students in order to provide the Products to Students as directed by K-12 Schools. K-12 Schools’ that create Student accounts with VitalSource Products authorize us to collect the following Personal Data from and about Students to enable Students to use our Products: name, email address, login credentials, K-12 School name, Information regarding Students’ use of the Products, and user-generated content such as the Student’s notes, highlights, and responses to assessments; and any other type of Information or Personal Data the Student submits through the Products. VitalSource also offers K-12 Schools the ability utilize certain Products without enabling VitalSource to collect or use Students’ Personal Data, such as name or login credentials. Specifically, VitalSource, through its integration partners, utilizes reference accounts in order to create and manage content through Bookshelf accounts. In such instances, VitalSource only uses and stores the reference account number for the Student account, along with the content made available to the Student and the Student’s notes and highlights, in managing these accounts.	Answer Meets Expectations	Unselected Option:	Unselected Option:
User Notes User Notes DCQ3 - Do the policies state who owns the data? ANSWER: Policies state the user owns the data alone OR policies state no data collected User Notes: Stipulated in contract by data controller. Stipulated in contract by data controller.	Answer Meets Expectations	Unselected Option:	Unselected Option:
User Notes User Notes DCQ4 - Do the policies allow users to delete their data entirely? ANSWER: Policies allow users to delete data entirely after a period of time OR policies state no data collected User Notes: K-12 Students K-12 Schools can review and delete Student Personal Data through the Products. K-12 Schools may also request the review or deletion of such information by contacting us. We will also assist the K-12 School in facilitating requests from Students or parents upon K-12 School request. Parents and Students may make a request for access, review, correction or deletion of Personal Data in the Products by contacting the appropriate official at the student’s K-12 School. If the K-12 School determines that the request should be implemented, the School may either make the change themselves or submit the request to us. K-12 Students K-12 Schools can review and delete Student Personal Data through the Products. K-12 Schools may also request the review or deletion of such information by contacting us. We will also assist the K-12 School in facilitating requests from Students or parents upon K-12 School request. Parents and Students may make a request for access, review, correction or deletion of Personal Data in the Products by contacting the appropriate official at the student’s K-12 School. If the K-12 School determines that the request should be implemented, the School may either make the change themselves or submit the request to us.	Answer Meets Expectations	Unselected Option:	Unselected Option:
User Notes User Notes DCQ5 - Do the policies state the retention of data? ANSWER: Policies have a 60-day or less retention policy OR policies state no data collected User Notes: We keep Personal Data for no longer than necessary for the purposes for which it is processed. The length of time for which we retain Personal Data depends on the purposes for which we collected and use it, the instructions of a controller when we act as a processor, the instructions of K-12 Schools for Student Personal Data, and/or our requirements to comply with applicable laws. We keep Personal Data for no longer than necessary for the purposes for which it is processed. The length of time for which we retain Personal Data depends on the purposes for which we collected and use it, the instructions of a controller when we act as a processor, the instructions of K-12 Schools for Student Personal Data, and/or our requirements to comply with applicable laws.	Answer Meets Expectations	Unselected Option:	Unselected Option:
Security	Meets	Partially Meets	Doesn't Meet
User Notes User Notes SECQ1 - Do the policies state how data is protected? ANSWER: Policies list the steps taken to protect data or OR policies state no data collected User Notes: We provide additional details on our security policies upon request. Security VitalSource takes information security seriously and has taken various measures to keep your Information secure from unauthorized access or disclosure, whether that Information is stored physically or electronically. VitalSource has established administrative, technical, physical, electronic and managerial procedures to help prevent unauthorized access, maintain data security and use the Information collected from you in accordance with this Policy. VitalSource has security measures in place to protect against loss, misuse, or alteration of your Information. Despite these efforts, VitalSource cannot guarantee that unauthorized access or disclosure of Information will never happen. If you have concerns, do not use the Products. We provide additional details on our security policies upon request. Security VitalSource takes information security seriously and has taken various measures to keep your Information secure from unauthorized access or disclosure, whether that Information is stored physically or electronically. VitalSource has established administrative, technical, physical, electronic and managerial procedures to help prevent unauthorized access, maintain data security and use the Information collected from you in accordance with this Policy. VitalSource has security measures in place to protect against loss, misuse, or alteration of your Information. Despite these efforts, VitalSource cannot guarantee that unauthorized access or disclosure of Information will never happen. If you have concerns, do not use the Products.	Answer Meets Expectations	Unselected Option:	Unselected Option:
User Notes User Notes SECQ2 - Do the policies state all confidential & sensitive information is encrypted throughout? ANSWER: Data encrypted throughout OR passes an encryption test with no vulnerabilities OR policies state no data collected User Notes: We provide additional details on our security policies upon request. Security VitalSource takes information security seriously and has taken various measures to keep your Information secure from unauthorized access or disclosure, whether that Information is stored physically or electronically. VitalSource has established administrative, technical, physical, electronic and managerial procedures to help prevent unauthorized access, maintain data security and use the Information collected from you in accordance with this Policy. VitalSource has security measures in place to protect against loss, misuse, or alteration of your Information. Despite these efforts, VitalSource cannot guarantee that unauthorized access or disclosure of Information will never happen. If you have concerns, do not use the Products. We provide additional details on our security policies upon request. Security VitalSource takes information security seriously and has taken various measures to keep your Information secure from unauthorized access or disclosure, whether that Information is stored physically or electronically. VitalSource has established administrative, technical, physical, electronic and managerial procedures to help prevent unauthorized access, maintain data security and use the Information collected from you in accordance with this Policy. VitalSource has security measures in place to protect against loss, misuse, or alteration of your Information. Despite these efforts, VitalSource cannot guarantee that unauthorized access or disclosure of Information will never happen. If you have concerns, do not use the Products.	Answer Meets Expectations	Unselected Option:	Unselected Option:
User Notes User Notes SECQ3 - Do the policies state whether or not it enforces strong password creation? ANSWER: Supplier enforces strong password creation OR supplier user base exempt from password requirements or OR no account creation required User Notes: Password Creation Requirements Passwords must be eight or more characters in length; Passwords must have at least one capital and one lowercase letter; Passwords must have at least one special character (i.e. !@#$()%^&). Bookshelf will not accept the following symbols in passwords: & + ; space Password Creation Requirements Passwords must be eight or more characters in length; Passwords must have at least one capital and one lowercase letter; Passwords must have at least one special character (i.e. !@#$()%^&). Bookshelf will not accept the following symbols in passwords: & + ; space	Answer Meets Expectations	Unselected Option:	Unselected Option:
User Notes User Notes SECQ4 - Do the policies indicate whether or not it leverages 2 step (or other forms of multifactor) authentication? ANSWER: Supplier uses SSO or an LTI launch OR no account creation is required OR supplier user base exempt from 2-step authentication requirements User Notes: No account creation required. No account creation required.	Answer Meets Expectations	Unselected Option:	Unselected Option:
User Notes User Notes SECQ5 - Do the policies state the use of cookies? ANSWER: Policies list all cookies used and each cookie's purpose OR policies state that it only uses cookies that are crucial for app functionality User Notes: https://support.vitalsource.com/hc/en-us/articles/360003928273-VitalSource-Technologies-LLC-Cookies-Notice Examples of ways that we use Cookies include: To track usage of the Products; To control the display of ads, including interest-based ads; To determine if you opened our emails; To customize elements of the promotional layout and/or content of the pages of our website; and To personalize information. We (or third-party service providers on our behalf) may also use cookies to collect aggregate information about Products on an anonymous basis. We may share such anonymous information with our business partners, advertisers and other third parties for any business purpose. https://support.vitalsource.com/hc/en-us/articles/360003928273-VitalSource-Technologies-LLC-Cookies-Notice Examples of ways that we use Cookies include: To track usage of the Products; To control the display of ads, including interest-based ads; To determine if you opened our emails; To customize elements of the promotional layout and/or content of the pages of our website; and To personalize information. We (or third-party service providers on our behalf) may also use cookies to collect aggregate information about Products on an anonymous basis. We may share such anonymous information with our business partners, advertisers and other third parties for any business purpose.	Answer Meets Expectations	Unselected Option:	Unselected Option:
Third Party Data	Meets	Partially Meets	Doesn't Meet
User Notes User Notes SHRQ1 - Do the policies state the use of third parties? ANSWER: Policies list each third party separately OR policies state third party use strictly for app functionality OR policies state that they do not use third parties User Notes: We will not use Student Personal Data for any purposes other than K-12 Schools’ educational purposes unless we the Data is De-identified Data. We will not use Student Personal Data for behaviorally-targeted advertising purposes, and we do not sell or rent such Student Personal Data to any third party for any purpose. We will not use Student Personal Data for any purposes other than K-12 Schools’ educational purposes unless we the Data is De-identified Data. We will not use Student Personal Data for behaviorally-targeted advertising purposes, and we do not sell or rent such Student Personal Data to any third party for any purpose.	Answer Meets Expectations	Unselected Option:	Unselected Option:
User Notes User Notes SHRQ2 - Do the policies state what information is shared with each 3rd party? ANSWER: Policies list the data it shares with each third party separately OR policies state that it does not share any data with any third party User Notes: We will not use Student Personal Data for any purposes other than K-12 Schools’ educational purposes unless we the Data is De-identified Data. We will not use Student Personal Data for behaviorally-targeted advertising purposes, and we do not sell or rent such Student Personal Data to any third party for any purpose. If we share Information, including Personal Data, with third parties, we require the recipient to maintain appropriate levels of confidentiality, integrity, availability and data protection for such Personal Data, and we will never sell Information to any third party. We share information as follows: With the Distributor, VitalSource shares User information related to use results from Users’ interaction with, results from assessments taken, user-generated content, and overall engagement with relevant Products, including interactive elements. Examples include: An academic institution, or their affiliated store, licensing our e-commerce platform to provide you access to Products An academic institution, or their affiliated store, licensing our Products to provide you access to content in your Learning Management System A company licensing our Product(s) to provide you access to a course or training materials on our Product(s), either through a code you are given, or a direct integration with our Product(s) VitalSource does not share Students Personal Data with publishers or Distributors, other than the Student’s own K-12 School. With Content Owners in certain cases: For instructors that get desk copies, samples, or free access to Content Owner’s Products we share your name, activity, and institution, in addition to the contact information that you specifically provide for purposes of sharing with Content Owners. When we report sales to Content Owners, we include data identifying the institution or school associated with such sales. When Users ask us to convey to Content Owners course and enrollment metrics so that they can provide you with pricing or other special terms. For content identified as courseware, Content Owners, and not VitalSource, host the content that you are trying to access, we provide Content Owners the information required to provide you access to the Product(s) you have licensed, such as your name, email, and course id. We share De-Identified Data of usage and user-generated data associated with Content Owner’s content. With trusted third parties performing certain tasks on our behalf. For example, this may include but is not limited to service providers providing customer support, operation and administration of the Products, processing information that you provide to us, and other tasks related to the Products. We allow these third parties to access only the information needed to perform those services. With other visitors to the Product or users of the Product, to the extent that Users submit content to publicly accessible portions of the Product, visitors and users may be able to view your content and Personal Data that identifies you as the author. Legal Process and Protection of VitalSource and Others. We may share information if required to do so by law or in a good faith belief that such disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order) or other lawful requests by public authorities, including to meet national security or law enforcement requirements; (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of VitalSource, its agents and affiliates, its users and/or the public. With affiliates of VitalSource, or with successors in the event of or in contemplation of a merger, acquisition, divestiture or reorganization, in whole or part, for use consistent with this Privacy Policy. As otherwise described to Users at the point of collection, pursuant to User consent, or as otherwise permitted by law. We will not use Student Personal Data for any purposes other than K-12 Schools’ educational purposes unless we the Data is De-identified Data. We will not use Student Personal Data for behaviorally-targeted advertising purposes, and we do not sell or rent such Student Personal Data to any third party for any purpose. If we share Information, including Personal Data, with third parties, we require the recipient to maintain appropriate levels of confidentiality, integrity, availability and data protection for such Personal Data, and we will never sell Information to any third party. We share information as follows: With the Distributor, VitalSource shares User information related to use results from Users’ interaction with, results from assessments taken, user-generated content, and overall engagement with relevant Products, including interactive elements. Examples include: An academic institution, or their affiliated store, licensing our e-commerce platform to provide you access to Products An academic institution, or their affiliated store, licensing our Products to provide you access to content in your Learning Management System A company licensing our Product(s) to provide you access to a course or training materials on our Product(s), either through a code you are given, or a direct integration with our Product(s) VitalSource does not share Students Personal Data with publishers or Distributors, other than the Student’s own K-12 School. With Content Owners in certain cases: For instructors that get desk copies, samples, or free access to Content Owner’s Products we share your name, activity, and institution, in addition to the contact information that you specifically provide for purposes of sharing with Content Owners. When we report sales to Content Owners, we include data identifying the institution or school associated with such sales. When Users ask us to convey to Content Owners course and enrollment metrics so that they can provide you with pricing or other special terms. For content identified as courseware, Content Owners, and not VitalSource, host the content that you are trying to access, we provide Content Owners the information required to provide you access to the Product(s) you have licensed, such as your name, email, and course id. We share De-Identified Data of usage and user-generated data associated with Content Owner’s content. With trusted third parties performing certain tasks on our behalf. For example, this may include but is not limited to service providers providing customer support, operation and administration of the Products, processing information that you provide to us, and other tasks related to the Products. We allow these third parties to access only the information needed to perform those services. With other visitors to the Product or users of the Product, to the extent that Users submit content to publicly accessible portions of the Product, visitors and users may be able to view your content and Personal Data that identifies you as the author. Legal Process and Protection of VitalSource and Others. We may share information if required to do so by law or in a good faith belief that such disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order) or other lawful requests by public authorities, including to meet national security or law enforcement requirements; (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of VitalSource, its agents and affiliates, its users and/or the public. With affiliates of VitalSource, or with successors in the event of or in contemplation of a merger, acquisition, divestiture or reorganization, in whole or part, for use consistent with this Privacy Policy. As otherwise described to Users at the point of collection, pursuant to User consent, or as otherwise permitted by law.	Answer Meets Expectations	Unselected Option:	Unselected Option:
User Notes User Notes SHRQ3 - Do the policies state whether or not users can opt out of 3rd party data sharing? ANSWER: Policies include an easy opt out process for users OR policies state that it does not share any data with any third party User Notes: We will not use Student Personal Data for any purposes other than K-12 Schools’ educational purposes unless we the Data is De-identified Data. We will not use Student Personal Data for behaviorally-targeted advertising purposes, and we do not sell or rent such Student Personal Data to any third party for any purpose. If we share Information, including Personal Data, with third parties, we require the recipient to maintain appropriate levels of confidentiality, integrity, availability and data protection for such Personal Data, and we will never sell Information to any third party. We share information as follows: With the Distributor, VitalSource shares User information related to use results from Users’ interaction with, results from assessments taken, user-generated content, and overall engagement with relevant Products, including interactive elements. Examples include: An academic institution, or their affiliated store, licensing our e-commerce platform to provide you access to Products An academic institution, or their affiliated store, licensing our Products to provide you access to content in your Learning Management System A company licensing our Product(s) to provide you access to a course or training materials on our Product(s), either through a code you are given, or a direct integration with our Product(s) VitalSource does not share Students Personal Data with publishers or Distributors, other than the Student’s own K-12 School. With Content Owners in certain cases: For instructors that get desk copies, samples, or free access to Content Owner’s Products we share your name, activity, and institution, in addition to the contact information that you specifically provide for purposes of sharing with Content Owners. When we report sales to Content Owners, we include data identifying the institution or school associated with such sales. When Users ask us to convey to Content Owners course and enrollment metrics so that they can provide you with pricing or other special terms. For content identified as courseware, Content Owners, and not VitalSource, host the content that you are trying to access, we provide Content Owners the information required to provide you access to the Product(s) you have licensed, such as your name, email, and course id. We share De-Identified Data of usage and user-generated data associated with Content Owner’s content. With trusted third parties performing certain tasks on our behalf. For example, this may include but is not limited to service providers providing customer support, operation and administration of the Products, processing information that you provide to us, and other tasks related to the Products. We allow these third parties to access only the information needed to perform those services. With other visitors to the Product or users of the Product, to the extent that Users submit content to publicly accessible portions of the Product, visitors and users may be able to view your content and Personal Data that identifies you as the author. Legal Process and Protection of VitalSource and Others. We may share information if required to do so by law or in a good faith belief that such disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order) or other lawful requests by public authorities, including to meet national security or law enforcement requirements; (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of VitalSource, its agents and affiliates, its users and/or the public. With affiliates of VitalSource, or with successors in the event of or in contemplation of a merger, acquisition, divestiture or reorganization, in whole or part, for use consistent with this Privacy Policy. As otherwise described to Users at the point of collection, pursuant to User consent, or as otherwise permitted by law. We will not use Student Personal Data for any purposes other than K-12 Schools’ educational purposes unless we the Data is De-identified Data. We will not use Student Personal Data for behaviorally-targeted advertising purposes, and we do not sell or rent such Student Personal Data to any third party for any purpose. If we share Information, including Personal Data, with third parties, we require the recipient to maintain appropriate levels of confidentiality, integrity, availability and data protection for such Personal Data, and we will never sell Information to any third party. We share information as follows: With the Distributor, VitalSource shares User information related to use results from Users’ interaction with, results from assessments taken, user-generated content, and overall engagement with relevant Products, including interactive elements. Examples include: An academic institution, or their affiliated store, licensing our e-commerce platform to provide you access to Products An academic institution, or their affiliated store, licensing our Products to provide you access to content in your Learning Management System A company licensing our Product(s) to provide you access to a course or training materials on our Product(s), either through a code you are given, or a direct integration with our Product(s) VitalSource does not share Students Personal Data with publishers or Distributors, other than the Student’s own K-12 School. With Content Owners in certain cases: For instructors that get desk copies, samples, or free access to Content Owner’s Products we share your name, activity, and institution, in addition to the contact information that you specifically provide for purposes of sharing with Content Owners. When we report sales to Content Owners, we include data identifying the institution or school associated with such sales. When Users ask us to convey to Content Owners course and enrollment metrics so that they can provide you with pricing or other special terms. For content identified as courseware, Content Owners, and not VitalSource, host the content that you are trying to access, we provide Content Owners the information required to provide you access to the Product(s) you have licensed, such as your name, email, and course id. We share De-Identified Data of usage and user-generated data associated with Content Owner’s content. With trusted third parties performing certain tasks on our behalf. For example, this may include but is not limited to service providers providing customer support, operation and administration of the Products, processing information that you provide to us, and other tasks related to the Products. We allow these third parties to access only the information needed to perform those services. With other visitors to the Product or users of the Product, to the extent that Users submit content to publicly accessible portions of the Product, visitors and users may be able to view your content and Personal Data that identifies you as the author. Legal Process and Protection of VitalSource and Others. We may share information if required to do so by law or in a good faith belief that such disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order) or other lawful requests by public authorities, including to meet national security or law enforcement requirements; (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of VitalSource, its agents and affiliates, its users and/or the public. With affiliates of VitalSource, or with successors in the event of or in contemplation of a merger, acquisition, divestiture or reorganization, in whole or part, for use consistent with this Privacy Policy. As otherwise described to Users at the point of collection, pursuant to User consent, or as otherwise permitted by law.	Answer Meets Expectations	Unselected Option:	Unselected Option:
User Notes User Notes SHRQ4 - Do the policies state if the supplier requires 3rd parties to adhere to the terms of the vendor/customer agreement? ANSWER: Supplier claims responsibility for third party privacy practices OR policies state that it does not share any data with any third party User Notes: We will not use Student Personal Data for any purposes other than K-12 Schools’ educational purposes unless we the Data is De-identified Data. We will not use Student Personal Data for behaviorally-targeted advertising purposes, and we do not sell or rent such Student Personal Data to any third party for any purpose. If we share Information, including Personal Data, with third parties, we require the recipient to maintain appropriate levels of confidentiality, integrity, availability and data protection for such Personal Data, and we will never sell Information to any third party. We share information as follows: With the Distributor, VitalSource shares User information related to use results from Users’ interaction with, results from assessments taken, user-generated content, and overall engagement with relevant Products, including interactive elements. Examples include: An academic institution, or their affiliated store, licensing our e-commerce platform to provide you access to Products An academic institution, or their affiliated store, licensing our Products to provide you access to content in your Learning Management System A company licensing our Product(s) to provide you access to a course or training materials on our Product(s), either through a code you are given, or a direct integration with our Product(s) VitalSource does not share Students Personal Data with publishers or Distributors, other than the Student’s own K-12 School. With Content Owners in certain cases: For instructors that get desk copies, samples, or free access to Content Owner’s Products we share your name, activity, and institution, in addition to the contact information that you specifically provide for purposes of sharing with Content Owners. When we report sales to Content Owners, we include data identifying the institution or school associated with such sales. When Users ask us to convey to Content Owners course and enrollment metrics so that they can provide you with pricing or other special terms. For content identified as courseware, Content Owners, and not VitalSource, host the content that you are trying to access, we provide Content Owners the information required to provide you access to the Product(s) you have licensed, such as your name, email, and course id. We share De-Identified Data of usage and user-generated data associated with Content Owner’s content. With trusted third parties performing certain tasks on our behalf. For example, this may include but is not limited to service providers providing customer support, operation and administration of the Products, processing information that you provide to us, and other tasks related to the Products. We allow these third parties to access only the information needed to perform those services. With other visitors to the Product or users of the Product, to the extent that Users submit content to publicly accessible portions of the Product, visitors and users may be able to view your content and Personal Data that identifies you as the author. Legal Process and Protection of VitalSource and Others. We may share information if required to do so by law or in a good faith belief that such disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order) or other lawful requests by public authorities, including to meet national security or law enforcement requirements; (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of VitalSource, its agents and affiliates, its users and/or the public. With affiliates of VitalSource, or with successors in the event of or in contemplation of a merger, acquisition, divestiture or reorganization, in whole or part, for use consistent with this Privacy Policy. As otherwise described to Users at the point of collection, pursuant to User consent, or as otherwise permitted by law. We will not use Student Personal Data for any purposes other than K-12 Schools’ educational purposes unless we the Data is De-identified Data. We will not use Student Personal Data for behaviorally-targeted advertising purposes, and we do not sell or rent such Student Personal Data to any third party for any purpose. If we share Information, including Personal Data, with third parties, we require the recipient to maintain appropriate levels of confidentiality, integrity, availability and data protection for such Personal Data, and we will never sell Information to any third party. We share information as follows: With the Distributor, VitalSource shares User information related to use results from Users’ interaction with, results from assessments taken, user-generated content, and overall engagement with relevant Products, including interactive elements. Examples include: An academic institution, or their affiliated store, licensing our e-commerce platform to provide you access to Products An academic institution, or their affiliated store, licensing our Products to provide you access to content in your Learning Management System A company licensing our Product(s) to provide you access to a course or training materials on our Product(s), either through a code you are given, or a direct integration with our Product(s) VitalSource does not share Students Personal Data with publishers or Distributors, other than the Student’s own K-12 School. With Content Owners in certain cases: For instructors that get desk copies, samples, or free access to Content Owner’s Products we share your name, activity, and institution, in addition to the contact information that you specifically provide for purposes of sharing with Content Owners. When we report sales to Content Owners, we include data identifying the institution or school associated with such sales. When Users ask us to convey to Content Owners course and enrollment metrics so that they can provide you with pricing or other special terms. For content identified as courseware, Content Owners, and not VitalSource, host the content that you are trying to access, we provide Content Owners the information required to provide you access to the Product(s) you have licensed, such as your name, email, and course id. We share De-Identified Data of usage and user-generated data associated with Content Owner’s content. With trusted third parties performing certain tasks on our behalf. For example, this may include but is not limited to service providers providing customer support, operation and administration of the Products, processing information that you provide to us, and other tasks related to the Products. We allow these third parties to access only the information needed to perform those services. With other visitors to the Product or users of the Product, to the extent that Users submit content to publicly accessible portions of the Product, visitors and users may be able to view your content and Personal Data that identifies you as the author. Legal Process and Protection of VitalSource and Others. We may share information if required to do so by law or in a good faith belief that such disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order) or other lawful requests by public authorities, including to meet national security or law enforcement requirements; (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of VitalSource, its agents and affiliates, its users and/or the public. With affiliates of VitalSource, or with successors in the event of or in contemplation of a merger, acquisition, divestiture or reorganization, in whole or part, for use consistent with this Privacy Policy. As otherwise described to Users at the point of collection, pursuant to User consent, or as otherwise permitted by law.	Answer Meets Expectations	Unselected Option:	Unselected Option:
User Notes User Notes SHRQ5 - Do the policies state whether or not user is notified of a change in third parties? ANSWER: Supplier changes third party and keeps the same data sharing terms OR supplier does not use any third parties User Notes: We will not use Student Personal Data for any purposes other than K-12 Schools’ educational purposes unless we the Data is De-identified Data. We will not use Student Personal Data for behaviorally-targeted advertising purposes, and we do not sell or rent such Student Personal Data to any third party for any purpose. If we share Information, including Personal Data, with third parties, we require the recipient to maintain appropriate levels of confidentiality, integrity, availability and data protection for such Personal Data, and we will never sell Information to any third party. We share information as follows: With the Distributor, VitalSource shares User information related to use results from Users’ interaction with, results from assessments taken, user-generated content, and overall engagement with relevant Products, including interactive elements. Examples include: An academic institution, or their affiliated store, licensing our e-commerce platform to provide you access to Products An academic institution, or their affiliated store, licensing our Products to provide you access to content in your Learning Management System A company licensing our Product(s) to provide you access to a course or training materials on our Product(s), either through a code you are given, or a direct integration with our Product(s) VitalSource does not share Students Personal Data with publishers or Distributors, other than the Student’s own K-12 School. With Content Owners in certain cases: For instructors that get desk copies, samples, or free access to Content Owner’s Products we share your name, activity, and institution, in addition to the contact information that you specifically provide for purposes of sharing with Content Owners. When we report sales to Content Owners, we include data identifying the institution or school associated with such sales. When Users ask us to convey to Content Owners course and enrollment metrics so that they can provide you with pricing or other special terms. For content identified as courseware, Content Owners, and not VitalSource, host the content that you are trying to access, we provide Content Owners the information required to provide you access to the Product(s) you have licensed, such as your name, email, and course id. We share De-Identified Data of usage and user-generated data associated with Content Owner’s content. With trusted third parties performing certain tasks on our behalf. For example, this may include but is not limited to service providers providing customer support, operation and administration of the Products, processing information that you provide to us, and other tasks related to the Products. We allow these third parties to access only the information needed to perform those services. With other visitors to the Product or users of the Product, to the extent that Users submit content to publicly accessible portions of the Product, visitors and users may be able to view your content and Personal Data that identifies you as the author. Legal Process and Protection of VitalSource and Others. We may share information if required to do so by law or in a good faith belief that such disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order) or other lawful requests by public authorities, including to meet national security or law enforcement requirements; (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of VitalSource, its agents and affiliates, its users and/or the public. With affiliates of VitalSource, or with successors in the event of or in contemplation of a merger, acquisition, divestiture or reorganization, in whole or part, for use consistent with this Privacy Policy. As otherwise described to Users at the point of collection, pursuant to User consent, or as otherwise permitted by law. We will not use Student Personal Data for any purposes other than K-12 Schools’ educational purposes unless we the Data is De-identified Data. We will not use Student Personal Data for behaviorally-targeted advertising purposes, and we do not sell or rent such Student Personal Data to any third party for any purpose. If we share Information, including Personal Data, with third parties, we require the recipient to maintain appropriate levels of confidentiality, integrity, availability and data protection for such Personal Data, and we will never sell Information to any third party. We share information as follows: With the Distributor, VitalSource shares User information related to use results from Users’ interaction with, results from assessments taken, user-generated content, and overall engagement with relevant Products, including interactive elements. Examples include: An academic institution, or their affiliated store, licensing our e-commerce platform to provide you access to Products An academic institution, or their affiliated store, licensing our Products to provide you access to content in your Learning Management System A company licensing our Product(s) to provide you access to a course or training materials on our Product(s), either through a code you are given, or a direct integration with our Product(s) VitalSource does not share Students Personal Data with publishers or Distributors, other than the Student’s own K-12 School. With Content Owners in certain cases: For instructors that get desk copies, samples, or free access to Content Owner’s Products we share your name, activity, and institution, in addition to the contact information that you specifically provide for purposes of sharing with Content Owners. When we report sales to Content Owners, we include data identifying the institution or school associated with such sales. When Users ask us to convey to Content Owners course and enrollment metrics so that they can provide you with pricing or other special terms. For content identified as courseware, Content Owners, and not VitalSource, host the content that you are trying to access, we provide Content Owners the information required to provide you access to the Product(s) you have licensed, such as your name, email, and course id. We share De-Identified Data of usage and user-generated data associated with Content Owner’s content. With trusted third parties performing certain tasks on our behalf. For example, this may include but is not limited to service providers providing customer support, operation and administration of the Products, processing information that you provide to us, and other tasks related to the Products. We allow these third parties to access only the information needed to perform those services. With other visitors to the Product or users of the Product, to the extent that Users submit content to publicly accessible portions of the Product, visitors and users may be able to view your content and Personal Data that identifies you as the author. Legal Process and Protection of VitalSource and Others. We may share information if required to do so by law or in a good faith belief that such disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order) or other lawful requests by public authorities, including to meet national security or law enforcement requirements; (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of VitalSource, its agents and affiliates, its users and/or the public. With affiliates of VitalSource, or with successors in the event of or in contemplation of a merger, acquisition, divestiture or reorganization, in whole or part, for use consistent with this Privacy Policy. As otherwise described to Users at the point of collection, pursuant to User consent, or as otherwise permitted by law.	Answer Meets Expectations	Unselected Option:	Unselected Option:
Advertising	Meets	Partially Meets	Doesn't Meet
User Notes User Notes ADVQ1 - Do the policies indicate if advertisements are displayed? ANSWER: No ads are displayed User Notes: We will not use Student Personal Data for any purposes other than K-12 Schools’ educational purposes unless we the Data is De-identified Data. We will not use Student Personal Data for behaviorally-targeted advertising purposes, and we do not sell or rent such Student Personal Data to any third party for any purpose. We will not use Student Personal Data for any purposes other than K-12 Schools’ educational purposes unless we the Data is De-identified Data. We will not use Student Personal Data for behaviorally-targeted advertising purposes, and we do not sell or rent such Student Personal Data to any third party for any purpose.	Answer Meets Expectations	Unselected Option:	Unselected Option:
User Notes User Notes ADVQ2 - Do the policies indicate whether or not users are targeted for advertisement? ANSWER: Policies guarantee no ad targeting OR Policies state no ads are used on its platform User Notes: We will not use Student Personal Data for any purposes other than K-12 Schools’ educational purposes unless we the Data is De-identified Data. We will not use Student Personal Data for behaviorally-targeted advertising purposes, and we do not sell or rent such Student Personal Data to any third party for any purpose. We will not use Student Personal Data for any purposes other than K-12 Schools’ educational purposes unless we the Data is De-identified Data. We will not use Student Personal Data for behaviorally-targeted advertising purposes, and we do not sell or rent such Student Personal Data to any third party for any purpose.	Answer Meets Expectations	Unselected Option:	Unselected Option:
User Notes User Notes ADVQ3 - Do the policies indicate whether or not any 3rd parties track or collect information for advertisement? ANSWER: Policies state third parties are not used for ads or tracking User Notes: We will not use Student Personal Data for any purposes other than K-12 Schools’ educational purposes unless we the Data is De-identified Data. We will not use Student Personal Data for behaviorally-targeted advertising purposes, and we do not sell or rent such Student Personal Data to any third party for any purpose. We will not use Student Personal Data for any purposes other than K-12 Schools’ educational purposes unless we the Data is De-identified Data. We will not use Student Personal Data for behaviorally-targeted advertising purposes, and we do not sell or rent such Student Personal Data to any third party for any purpose.	Answer Meets Expectations	Unselected Option:	Unselected Option:
User Notes User Notes ADVQ4 - Do the policies indicate whether or not web beacons or other tracking methods are used for ad purposes? ANSWER: Policies state that it only tracks interactions within its application OR policies state that it does not use any tracking technologies for ads User Notes: We will not use Student Personal Data for any purposes other than K-12 Schools’ educational purposes unless we the Data is De-identified Data. We will not use Student Personal Data for behaviorally-targeted advertising purposes, and we do not sell or rent such Student Personal Data to any third party for any purpose. We will not use Student Personal Data for any purposes other than K-12 Schools’ educational purposes unless we the Data is De-identified Data. We will not use Student Personal Data for behaviorally-targeted advertising purposes, and we do not sell or rent such Student Personal Data to any third party for any purpose.	Answer Meets Expectations	Unselected Option:	Unselected Option:
User Notes User Notes ADVQ5 - Do the policies state whether or not users can opt out of sharing data with advertisers? ANSWER: Policies state in detail how users can opt out of sharing data with advertisers OR policies state no ads are used on its platform User Notes: We will not use Student Personal Data for any purposes other than K-12 Schools’ educational purposes unless we the Data is De-identified Data. We will not use Student Personal Data for behaviorally-targeted advertising purposes, and we do not sell or rent such Student Personal Data to any third party for any purpose. We will not use Student Personal Data for any purposes other than K-12 Schools’ educational purposes unless we the Data is De-identified Data. We will not use Student Personal Data for behaviorally-targeted advertising purposes, and we do not sell or rent such Student Personal Data to any third party for any purpose.	Answer Meets Expectations	Unselected Option:	Unselected Option:

Vetting Context

Policies Cited

The following urls were cited as a basis for this information.

Terms of Service/Terms of Use https://support.vitalsource.com/hc/en-us/articles/204612518-VitalSource-Technologies-LLC-Terms-and-Conditions-of-Use
Privacy Policy https://support.vitalsource.com/hc/en-us/articles/201646123-VitalSource-Technologies-LLC-Privacy-Policy
Cookie Policy https://support.vitalsource.com/hc/en-us/articles/360003928273-VitalSource-Technologies-LLC-Cookies-Notice

Geographical Context

(Laws and regulations can vary across regions)

Tennessee

United States

Regulatory Compliance

The information below provides insight into compliance with various regulatory policies.

GDPR Compliant: Yes
FERPA Compliant: Yes
COPPA Compliant: Yes

This application can be used by children under the age of 13.

Email Andrew about this record

The views and opinions expressed in this information are those of the authors and do not necessarily reflect the official policy or position of 1EdTech. The information provided is intended to surface trends about the policies and procedures of systems leveraged by the educational community. It should not be considered legal advice.

Disclaimer: 1EdTech Trusted Apps provides a vetting of a product's data policy according to the 1EdTech Trusted Apps Rubric. Achieving the TrustEd Apps Certified Seal indicates adherence to a baseline level of privacy. Institutions should review an application's detailed vetting results before approving it for use.

App Vetting Rubric Version: 2

ABOUT US

TrustEd Apps Profile for VitalSource Learning Platform