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TrustEd Apps Profile for Cengage LMS Integration Gateway

Vetted by Eric Galis, CISO at Cengage on 2024-09-11

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 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:
From time to time, we may update this Privacy Notice. When we update this Privacy Notice, we will revise
the “Last Updated” date located at the top of this Privacy Notice and will post the updated Privacy Notice
on our websites and apps. Additionally, if the changes will materially affect the way we use or disclose
previously collected personal information, we will notify you about the change by sending a notice to the
primary email address associated with your account.
From time to time, we may update this Privacy Notice. When we update this Privacy Notice, we will revise the “Last Updated” date located at the top of this Privacy Notice and will post the updated Privacy Notice on our websites and apps. Additionally, if the changes will materially affect the way we use or disclose previously collected personal information, we will notify you about the change by sending a notice to the primary email address associated with your account.
Answer Meets Expectations Unselected Option: Unselected Option:
Data Collected Meets Partially Meets Doesn't Meet
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:
We collect the categories and types of personal information described below. The categories and types of
personal information collected vary depending on your relationship with us.
❖ If you interact with our websites or apps or contact us, we collect the following categories of
personal information:
• Identifiers that allow us to identify you and communicate with you, such as contact information
that you provide us, including your name, mailing address, telephone numbers, email address or
other addresses.
• Internet Network and Device Information that we collect about your session and your activity
and actions when you use our websites and apps or open emails that we have sent you. In
addition to any information that you submit during these sessions, we use cookies and other data
collection tools to automatically collect information about your device and your use of our
websites and apps, including information about whether and for how long you view videos on our
websites and apps. The information we collect includes IP address; internet provider, operating
system and browser used; domain names of the computers you use to visit our websites; viewed
webpages; links that are clicked; the keystrokes typed; movement of the mouse or pointer; type of
device (such as laptop or smart phone); device and advertising identifiers; log files; URIs (Uniform
Resource Identifiers) of the resources requested; the time of the request; the method used to
submit the request to the server; the size of the file obtained in reply; the numerical status code of
the server reply (successful, error, etc.); emails we send that you open, forward or click through to
3
our websites; and other parameters concerning your operating system and computer
environment and/or device cookie settings and other device details, such as MAC address. Please
see “Cookies and Other Data Collection Technologies” below for additional information.
• Communication Information such as the content of emails, text messages, chats or other
communications, call logs and chat logs. Additionally, if you participate in a community or forum
on our websites or apps, information you share within that community or forum may include
personal information.
• Audio Visual Information that we collect when you contact us for support. When you contact us,
your phone conversation with our support team may be monitored and recorded for training and
quality assurance.
❖ If you register for an account with us or purchase or use our products and services, we collect the
categories and types of personal information described below, in addition to those categories of
personal information described directly above. Note that in some cases we provide our products and
services as a “processor” or “service provider” to your educational institution or employer, in which
case we process personal information according to instructions from your educational institution or
employer and our contract with them. In those instances, the information in this Privacy Notice is
intended to provide transparency in relation to our privacy practices and you should refer to the
privacy practices at your educational institution or employer.
• Identifiers that allow us to identify you, such as the account number or id that we assign you,
username and password.
• Internet Network and Device Information about how you interact with Cengage, including your
download history, activity and actions within our products and information about your use of our
content (including time spent on material and results of in-product assessments).
• Customer Records, which include personal information we collect to helps us do business and
interact with you, such as customer account information. It also includes personal information we
require to fill your accessibility requests, such as personal information about your accessibility
needs and materials and products that you use for accessibility. We may also collect the following
personal information, which may vary by product:
o If you are a student: This may include information about your school affiliation, expected
degree and graduation date, your courses of study, grades, learning style, languages
spoken, age range, responses to quizzes and course work, badges earned, files or content
you upload and in some products, messages you send to instructors or the comments
you post in a discussion forum.
o If you are an instructor: This may include information about your school affiliation,
professional credentials, courses you teach, teaching style, grading and assessments, files
or content you upload and in some products, messages you send to students or the
comments you post in a discussion forum.
o If you are an adult learner: This may include your employer, job title, professional
credentials and affiliations, language spoken, age range, courses of study, time spent in
4
the course (including time and day of course access), overall score in course, completion
date and in some products, messages you send to your instructors or the comments you
post in a discussion forum.
• Commercial Information about your purchase and transaction history with us. We also collect
payment card information as needed to process your payment when you purchase products.
• Geolocation Data, which includes information about your location if the product you are using
uses an identity management service.
• Audio Visual Information, such as photographs and video and audio recordings that are
captured when you participate in a course
We collect the categories and types of personal information described below. The categories and types of personal information collected vary depending on your relationship with us. ❖ If you interact with our websites or apps or contact us, we collect the following categories of personal information: • Identifiers that allow us to identify you and communicate with you, such as contact information that you provide us, including your name, mailing address, telephone numbers, email address or other addresses. • Internet Network and Device Information that we collect about your session and your activity and actions when you use our websites and apps or open emails that we have sent you. In addition to any information that you submit during these sessions, we use cookies and other data collection tools to automatically collect information about your device and your use of our websites and apps, including information about whether and for how long you view videos on our websites and apps. The information we collect includes IP address; internet provider, operating system and browser used; domain names of the computers you use to visit our websites; viewed webpages; links that are clicked; the keystrokes typed; movement of the mouse or pointer; type of device (such as laptop or smart phone); device and advertising identifiers; log files; URIs (Uniform Resource Identifiers) of the resources requested; the time of the request; the method used to submit the request to the server; the size of the file obtained in reply; the numerical status code of the server reply (successful, error, etc.); emails we send that you open, forward or click through to 3 our websites; and other parameters concerning your operating system and computer environment and/or device cookie settings and other device details, such as MAC address. Please see “Cookies and Other Data Collection Technologies” below for additional information. • Communication Information such as the content of emails, text messages, chats or other communications, call logs and chat logs. Additionally, if you participate in a community or forum on our websites or apps, information you share within that community or forum may include personal information. • Audio Visual Information that we collect when you contact us for support. When you contact us, your phone conversation with our support team may be monitored and recorded for training and quality assurance. ❖ If you register for an account with us or purchase or use our products and services, we collect the categories and types of personal information described below, in addition to those categories of personal information described directly above. Note that in some cases we provide our products and services as a “processor” or “service provider” to your educational institution or employer, in which case we process personal information according to instructions from your educational institution or employer and our contract with them. In those instances, the information in this Privacy Notice is intended to provide transparency in relation to our privacy practices and you should refer to the privacy practices at your educational institution or employer. • Identifiers that allow us to identify you, such as the account number or id that we assign you, username and password. • Internet Network and Device Information about how you interact with Cengage, including your download history, activity and actions within our products and information about your use of our content (including time spent on material and results of in-product assessments). • Customer Records, which include personal information we collect to helps us do business and interact with you, such as customer account information. It also includes personal information we require to fill your accessibility requests, such as personal information about your accessibility needs and materials and products that you use for accessibility. We may also collect the following personal information, which may vary by product: o If you are a student: This may include information about your school affiliation, expected degree and graduation date, your courses of study, grades, learning style, languages spoken, age range, responses to quizzes and course work, badges earned, files or content you upload and in some products, messages you send to instructors or the comments you post in a discussion forum. o If you are an instructor: This may include information about your school affiliation, professional credentials, courses you teach, teaching style, grading and assessments, files or content you upload and in some products, messages you send to students or the comments you post in a discussion forum. o If you are an adult learner: This may include your employer, job title, professional credentials and affiliations, language spoken, age range, courses of study, time spent in 4 the course (including time and day of course access), overall score in course, completion date and in some products, messages you send to your instructors or the comments you post in a discussion forum. • Commercial Information about your purchase and transaction history with us. We also collect payment card information as needed to process your payment when you purchase products. • Geolocation Data, which includes information about your location if the product you are using uses an identity management service. • Audio Visual Information, such as photographs and video and audio recordings that are captured when you participate in a course
Answer Meets Expectations Unselected Option: Unselected Option:
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:
We collect the categories and types of personal information described below. The categories and types of
personal information collected vary depending on your relationship with us.
❖ If you interact with our websites or apps or contact us, we collect the following categories of
personal information:
• Identifiers that allow us to identify you and communicate with you, such as contact information
that you provide us, including your name, mailing address, telephone numbers, email address or
other addresses.
• Internet Network and Device Information that we collect about your session and your activity
and actions when you use our websites and apps or open emails that we have sent you. In
addition to any information that you submit during these sessions, we use cookies and other data
collection tools to automatically collect information about your device and your use of our
websites and apps, including information about whether and for how long you view videos on our
websites and apps. The information we collect includes IP address; internet provider, operating
system and browser used; domain names of the computers you use to visit our websites; viewed
webpages; links that are clicked; the keystrokes typed; movement of the mouse or pointer; type of
device (such as laptop or smart phone); device and advertising identifiers; log files; URIs (Uniform
Resource Identifiers) of the resources requested; the time of the request; the method used to
submit the request to the server; the size of the file obtained in reply; the numerical status code of
the server reply (successful, error, etc.); emails we send that you open, forward or click through to
3
our websites; and other parameters concerning your operating system and computer
environment and/or device cookie settings and other device details, such as MAC address. Please
see “Cookies and Other Data Collection Technologies” below for additional information.
• Communication Information such as the content of emails, text messages, chats or other
communications, call logs and chat logs. Additionally, if you participate in a community or forum
on our websites or apps, information you share within that community or forum may include
personal information.
• Audio Visual Information that we collect when you contact us for support. When you contact us,
your phone conversation with our support team may be monitored and recorded for training and
quality assurance.
❖ If you register for an account with us or purchase or use our products and services, we collect the
categories and types of personal information described below, in addition to those categories of
personal information described directly above. Note that in some cases we provide our products and
services as a “processor” or “service provider” to your educational institution or employer, in which
case we process personal information according to instructions from your educational institution or
employer and our contract with them. In those instances, the information in this Privacy Notice is
intended to provide transparency in relation to our privacy practices and you should refer to the
privacy practices at your educational institution or employer.
• Identifiers that allow us to identify you, such as the account number or id that we assign you,
username and password.
• Internet Network and Device Information about how you interact with Cengage, including your
download history, activity and actions within our products and information about your use of our
content (including time spent on material and results of in-product assessments).
• Customer Records, which include personal information we collect to helps us do business and
interact with you, such as customer account information. It also includes personal information we
require to fill your accessibility requests, such as personal information about your accessibility
needs and materials and products that you use for accessibility. We may also collect the following
personal information, which may vary by product:
o If you are a student: This may include information about your school affiliation, expected
degree and graduation date, your courses of study, grades, learning style, languages
spoken, age range, responses to quizzes and course work, badges earned, files or content
you upload and in some products, messages you send to instructors or the comments
you post in a discussion forum.
o If you are an instructor: This may include information about your school affiliation,
professional credentials, courses you teach, teaching style, grading and assessments, files
or content you upload and in some products, messages you send to students or the
comments you post in a discussion forum.
o If you are an adult learner: This may include your employer, job title, professional
credentials and affiliations, language spoken, age range, courses of study, time spent in
4
the course (including time and day of course access), overall score in course, completion
date and in some products, messages you send to your instructors or the comments you
post in a discussion forum.
• Commercial Information about your purchase and transaction history with us. We also collect
payment card information as needed to process your payment when you purchase products.
• Geolocation Data, which includes information about your location if the product you are using
uses an identity management service.
• Audio Visual Information, such as photographs and video and audio recordings that are
captured when you participate in a course
We collect the categories and types of personal information described below. The categories and types of personal information collected vary depending on your relationship with us. ❖ If you interact with our websites or apps or contact us, we collect the following categories of personal information: • Identifiers that allow us to identify you and communicate with you, such as contact information that you provide us, including your name, mailing address, telephone numbers, email address or other addresses. • Internet Network and Device Information that we collect about your session and your activity and actions when you use our websites and apps or open emails that we have sent you. In addition to any information that you submit during these sessions, we use cookies and other data collection tools to automatically collect information about your device and your use of our websites and apps, including information about whether and for how long you view videos on our websites and apps. The information we collect includes IP address; internet provider, operating system and browser used; domain names of the computers you use to visit our websites; viewed webpages; links that are clicked; the keystrokes typed; movement of the mouse or pointer; type of device (such as laptop or smart phone); device and advertising identifiers; log files; URIs (Uniform Resource Identifiers) of the resources requested; the time of the request; the method used to submit the request to the server; the size of the file obtained in reply; the numerical status code of the server reply (successful, error, etc.); emails we send that you open, forward or click through to 3 our websites; and other parameters concerning your operating system and computer environment and/or device cookie settings and other device details, such as MAC address. Please see “Cookies and Other Data Collection Technologies” below for additional information. • Communication Information such as the content of emails, text messages, chats or other communications, call logs and chat logs. Additionally, if you participate in a community or forum on our websites or apps, information you share within that community or forum may include personal information. • Audio Visual Information that we collect when you contact us for support. When you contact us, your phone conversation with our support team may be monitored and recorded for training and quality assurance. ❖ If you register for an account with us or purchase or use our products and services, we collect the categories and types of personal information described below, in addition to those categories of personal information described directly above. Note that in some cases we provide our products and services as a “processor” or “service provider” to your educational institution or employer, in which case we process personal information according to instructions from your educational institution or employer and our contract with them. In those instances, the information in this Privacy Notice is intended to provide transparency in relation to our privacy practices and you should refer to the privacy practices at your educational institution or employer. • Identifiers that allow us to identify you, such as the account number or id that we assign you, username and password. • Internet Network and Device Information about how you interact with Cengage, including your download history, activity and actions within our products and information about your use of our content (including time spent on material and results of in-product assessments). • Customer Records, which include personal information we collect to helps us do business and interact with you, such as customer account information. It also includes personal information we require to fill your accessibility requests, such as personal information about your accessibility needs and materials and products that you use for accessibility. We may also collect the following personal information, which may vary by product: o If you are a student: This may include information about your school affiliation, expected degree and graduation date, your courses of study, grades, learning style, languages spoken, age range, responses to quizzes and course work, badges earned, files or content you upload and in some products, messages you send to instructors or the comments you post in a discussion forum. o If you are an instructor: This may include information about your school affiliation, professional credentials, courses you teach, teaching style, grading and assessments, files or content you upload and in some products, messages you send to students or the comments you post in a discussion forum. o If you are an adult learner: This may include your employer, job title, professional credentials and affiliations, language spoken, age range, courses of study, time spent in 4 the course (including time and day of course access), overall score in course, completion date and in some products, messages you send to your instructors or the comments you post in a discussion forum. • Commercial Information about your purchase and transaction history with us. We also collect payment card information as needed to process your payment when you purchase products. • Geolocation Data, which includes information about your location if the product you are using uses an identity management service. • Audio Visual Information, such as photographs and video and audio recordings that are captured when you participate in a course
Answer Meets Expectations Unselected Option: Unselected Option:
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:
From institutional agreement template:
"Customer shall be a Controller and Cengage shall be a Processor with respect to Personal Data Processed hereunder. Where a Data Subject opts into receiving marketing communications from Cengage, or otherwise interacts with Cengage outside of the context of the Agreement, Cengage will Process certain Personal Data about the Data Subject as a Controller and such Processing is not subject to this DPA or the Agreement."
From institutional agreement template: "Customer shall be a Controller and Cengage shall be a Processor with respect to Personal Data Processed hereunder. Where a Data Subject opts into receiving marketing communications from Cengage, or otherwise interacts with Cengage outside of the context of the Agreement, Cengage will Process certain Personal Data about the Data Subject as a Controller and such Processing is not subject to this DPA or the Agreement."
Answer Meets Expectations Unselected Option: Unselected Option:
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:
There are several ways for you to exercise your privacy rights:
• You can exercise your privacy rights by emailing privacy@cengage.com.
• You can request deletion of your personal information by submitting this form: https://cengage.force.com/s/rtbf
There are several ways for you to exercise your privacy rights: • You can exercise your privacy rights by emailing privacy@cengage.com. • You can request deletion of your personal information by submitting this form: https://cengage.force.com/s/rtbf
Answer Meets Expectations Unselected Option: Unselected Option:
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 will retain your personal information in accordance with our retention policies for as long as is
reasonably necessary to accomplish the purpose for which the information was collected or for the period
that may be required or permitted by law, such as for business, legal, accounting or reporting
requirements. In determining the length of the retention period, we will consider the amount, nature
and sensitivity of personal information; the potential risk of harm from unauthorized use or disclosure of
personal information; the purposes for which we process personal information and whether we can
achieve those purposes through other means; and applicable legal requirements.
We will retain your personal information in accordance with our retention policies for as long as is reasonably necessary to accomplish the purpose for which the information was collected or for the period that may be required or permitted by law, such as for business, legal, accounting or reporting requirements. In determining the length of the retention period, we will consider the amount, nature and sensitivity of personal information; the potential risk of harm from unauthorized use or disclosure of personal information; the purposes for which we process personal information and whether we can achieve those purposes through other means; and applicable legal requirements.
Answer Meets Expectations Unselected Option: Unselected Option:
Security Meets Partially Meets Doesn't Meet
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:
9. Information Security
We use physical, technical, organizational and administrative safeguards to help protect your personal
information against unauthorized or unlawful processing and against damage, accidental loss or
destruction.

Security practices can be made available upon request.
9. Information Security We use physical, technical, organizational and administrative safeguards to help protect your personal information against unauthorized or unlawful processing and against damage, accidental loss or destruction. Security practices can be made available upon request.
Answer Meets Expectations Unselected Option: Unselected Option:
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:
9. Information Security
We use physical, technical, organizational and administrative safeguards to help protect your personal
information against unauthorized or unlawful processing and against damage, accidental loss or
destruction.

Security practices can be made available upon request.
9. Information Security We use physical, technical, organizational and administrative safeguards to help protect your personal information against unauthorized or unlawful processing and against damage, accidental loss or destruction. Security practices can be made available upon request.
Answer Meets Expectations Unselected Option: Unselected Option:
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:
Cengage employs a single sign on solution to enable logon security.

Further details about password parameters can be provided upon request.
Cengage employs a single sign on solution to enable logon security. Further details about password parameters can be provided upon request.
Answer Meets Expectations Unselected Option: Unselected Option:
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:
Cengage employs a single sign on solution to enable logon security. We also allow LTI integrations.

Further details about password parameters can be provided upon request.
Cengage employs a single sign on solution to enable logon security. We also allow LTI integrations. Further details about password parameters can be provided upon request.
Answer Meets Expectations Unselected Option: Unselected Option:
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:
Targeted Advertising and Selling

Cengage shall not:

(a) Use any K-12 Student Data for Targeted Advertising.
(b) Create K-12 Student profiles for advertising or for any other purpose that is not required by the Client for educational purposes
(c) Sell K-12 Student Data or otherwise disclose the K-12 Student Data to any third party unless (i) such third parties are data processors acting on our behalf, (ii) the disclosure is required by law or otherwise legally permitted, or (iii) the disclosure is made at the request of the Client for educational purposes.

Cookies and Other Data Collection Technologies
When you visit our websites, use our apps or interact with emails we have sent you, we collect information
by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs
and web beacons. In some cases, we may associate the information collected using cookies and other
data
10
collection technologies with other personal information we have collected about you. Please refer to our
Cookies Notice for more information on our use of cookies and other data collection technologies and how
you can manage such technologies.
Digital Analytics
We may work with third parties that collect data about your use of our websites and services over time for
non-advertising purposes. For example, we use Google Analytics to improve the performance of our
websites and for other analytics purposes. For more information about how Google Analytics collects and
uses data when you use our websites, visit www.google.com/policies/privacy/partners, and to opt out of
Google Analytics, visit tools.google.com/dlpage/gaoptout.
Additionally, many web browsers have settings allowing users to limit the use of cookies or delete cookies.
Please be aware that limiting or deleting cookies may make certain functions of our websites unavailable.
Third-Party Advertising Companies
We have relationships with third-party advertising companies to place advertisements on our websites
and other companies’ websites, except for our websites that process K-12 Student Data, and to perform
tracking and reporting functions for Cengage websites and other websites. These third-party advertising
companies may place cookies and other data collection technologies on your computer when you visit
our websites or other websites so that they can display targeted advertisements to you.
For more information about third-party advertising, please visit the Network Advertising Initiative (NAI) at
www.networkadvertising.org. You can opt-out of targeted advertising by certain third-party advertising
companies by visiting www.networkadvertising.org/consumer/opt_out.asp or
https://optout.networkadvertising.org/?c=1.
If you are a resident of a state with an applicable state privacy law, please also see “Additional U.S. State
Privacy Rights” below for more information related to third-party advertising and opt-out rights.
Third-Party Websites
This Privacy Notice only addresses the use and sharing of personal information by Cengage and does not
apply to your use of a third-party site. Other websites that may be accessible through our websites and
apps have their own privacy policies and data collection, use and disclosure practices. . For example, our
MindTap product uses the YouTube API Services. MindTap uses these services to allow instructors to add
videos and the information collected and shared includes meta data that is used to describe the content of
the videos delivered in the search results.
Our websites and apps may also enable you to interact with us and others via integrated social media tools
or “plug-ins.” . Your interactions with third-party companies and your use of their features are governed by
the privacy policies of the companies that provide those features. We encourage you to read the privacy
notices of these companies.
In addition, if you use these platforms, we may collect personal information about you, as permitted by
the platform’s privacy policies. For example, we may allow you to sign into Cengage websites and apps
using social media, such as Facebook Connect. If you choose to do this, we may collect personal information about you and your connections to facilitate an interactive social experience
Targeted Advertising and Selling Cengage shall not: (a) Use any K-12 Student Data for Targeted Advertising. (b) Create K-12 Student profiles for advertising or for any other purpose that is not required by the Client for educational purposes (c) Sell K-12 Student Data or otherwise disclose the K-12 Student Data to any third party unless (i) such third parties are data processors acting on our behalf, (ii) the disclosure is required by law or otherwise legally permitted, or (iii) the disclosure is made at the request of the Client for educational purposes. Cookies and Other Data Collection Technologies When you visit our websites, use our apps or interact with emails we have sent you, we collect information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons. In some cases, we may associate the information collected using cookies and other data 10 collection technologies with other personal information we have collected about you. Please refer to our Cookies Notice for more information on our use of cookies and other data collection technologies and how you can manage such technologies. Digital Analytics We may work with third parties that collect data about your use of our websites and services over time for non-advertising purposes. For example, we use Google Analytics to improve the performance of our websites and for other analytics purposes. For more information about how Google Analytics collects and uses data when you use our websites, visit www.google.com/policies/privacy/partners, and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout. Additionally, many web browsers have settings allowing users to limit the use of cookies or delete cookies. Please be aware that limiting or deleting cookies may make certain functions of our websites unavailable. Third-Party Advertising Companies We have relationships with third-party advertising companies to place advertisements on our websites and other companies’ websites, except for our websites that process K-12 Student Data, and to perform tracking and reporting functions for Cengage websites and other websites. These third-party advertising companies may place cookies and other data collection technologies on your computer when you visit our websites or other websites so that they can display targeted advertisements to you. For more information about third-party advertising, please visit the Network Advertising Initiative (NAI) at www.networkadvertising.org. You can opt-out of targeted advertising by certain third-party advertising companies by visiting www.networkadvertising.org/consumer/opt_out.asp or https://optout.networkadvertising.org/?c=1. If you are a resident of a state with an applicable state privacy law, please also see “Additional U.S. State Privacy Rights” below for more information related to third-party advertising and opt-out rights. Third-Party Websites This Privacy Notice only addresses the use and sharing of personal information by Cengage and does not apply to your use of a third-party site. Other websites that may be accessible through our websites and apps have their own privacy policies and data collection, use and disclosure practices. . For example, our MindTap product uses the YouTube API Services. MindTap uses these services to allow instructors to add videos and the information collected and shared includes meta data that is used to describe the content of the videos delivered in the search results. Our websites and apps may also enable you to interact with us and others via integrated social media tools or “plug-ins.” . Your interactions with third-party companies and your use of their features are governed by the privacy policies of the companies that provide those features. We encourage you to read the privacy notices of these companies. In addition, if you use these platforms, we may collect personal information about you, as permitted by the platform’s privacy policies. For example, we may allow you to sign into Cengage websites and apps using social media, such as Facebook Connect. If you choose to do this, we may collect personal information about you and your connections to facilitate an interactive social experience
Answer Meets Expectations Unselected Option: Unselected Option:
Third Party Data Meets Partially Meets Doesn't Meet
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:
Sharing Your Personal Information
We share your personal information, to the extent permitted by applicable law, as follows:
• Within the Cengage group of companies.
• If you are affiliated with an educational institution, with your school and if you are a
student, with your instructors. For example, we provide our institutional clients with reports
about how their instructors and students use our products, including information that compares
instructors and students within a school. If you are a student, your instructors will have access to
the information generated by your use of a product for a class and certain information that you
enter into the product. We may also provide personal information to your school, as needed, to
investigate possible academic fraud or cheating. Your school uses your personal information in
accordance with its own privacy policies.
• If you are affiliated with a corporation who has obtained our products, with your employer.
If your employer has obtained our products for its employees’ use and we are processing
9
personal information as a “processor” or “service provider,” we may provide your employer with
reports about how its employees use the product. Your employer may also have access to the
information generated by its employees’ use of the product and information that its employees
have entered into the product. Your employer uses your personal information in accordance with
its own privacy policies.
• With our service providers and advisors to the extent necessary to perform services for us or
on our behalf.
• With learning management systems (LMS) and other education software providers that may
integrate with or complement our products. These providers are given limited access to personal
information in order to deliver the service.
• Advertisers who perform advertising and marketing services on our behalf. We may also permit
these third parties to collect information directly from you on our websites and apps.
• With authorized partners that provide services to you through My Cengage, MindTap and
similar platforms but only to the extent that you have authorized the sharing. For example, you
may request that Cengage share information about the courses you’ve taken with partners to
enable the partner to provide you with resume creation, skills assessments or other services.
Additionally, we may share certain transactional information with our partners as needed to
validate referrals and operate the platforms.
• With companies where you are participating in, or seeking to participate in, a program in
connection with Clinical Experience (Externship) through Ed2go or Ready2Hire.
• With your consent or at your direction.
• With other third parties, as permitted by law, to enforce our rights, including our Terms of Use
or Terms of Service; to protect our property or to protect the rights, property or safety of others;
and to detect, prevent and respond to fraud, illegal activity and intellectual property infringement.
• With law enforcement agencies, government agencies, regulators and courts in the United
States and other countries where we operate, such as in response to a subpoena or court order or
to fulfill a legal obligation.
• With third parties in connection with, or as part of the due diligence for, any proposed or
actual merger, acquisition, sale or transfer of some or all our assets (including in the event of a
reorganization, dissolution or liquidation).
For individuals who contact Ed2Go for more information: If you provide your consent to receive text
messages from Ed2Go, we do not share your consent with third parties.
Sharing Your Personal Information We share your personal information, to the extent permitted by applicable law, as follows: • Within the Cengage group of companies. • If you are affiliated with an educational institution, with your school and if you are a student, with your instructors. For example, we provide our institutional clients with reports about how their instructors and students use our products, including information that compares instructors and students within a school. If you are a student, your instructors will have access to the information generated by your use of a product for a class and certain information that you enter into the product. We may also provide personal information to your school, as needed, to investigate possible academic fraud or cheating. Your school uses your personal information in accordance with its own privacy policies. • If you are affiliated with a corporation who has obtained our products, with your employer. If your employer has obtained our products for its employees’ use and we are processing 9 personal information as a “processor” or “service provider,” we may provide your employer with reports about how its employees use the product. Your employer may also have access to the information generated by its employees’ use of the product and information that its employees have entered into the product. Your employer uses your personal information in accordance with its own privacy policies. • With our service providers and advisors to the extent necessary to perform services for us or on our behalf. • With learning management systems (LMS) and other education software providers that may integrate with or complement our products. These providers are given limited access to personal information in order to deliver the service. • Advertisers who perform advertising and marketing services on our behalf. We may also permit these third parties to collect information directly from you on our websites and apps. • With authorized partners that provide services to you through My Cengage, MindTap and similar platforms but only to the extent that you have authorized the sharing. For example, you may request that Cengage share information about the courses you’ve taken with partners to enable the partner to provide you with resume creation, skills assessments or other services. Additionally, we may share certain transactional information with our partners as needed to validate referrals and operate the platforms. • With companies where you are participating in, or seeking to participate in, a program in connection with Clinical Experience (Externship) through Ed2go or Ready2Hire. • With your consent or at your direction. • With other third parties, as permitted by law, to enforce our rights, including our Terms of Use or Terms of Service; to protect our property or to protect the rights, property or safety of others; and to detect, prevent and respond to fraud, illegal activity and intellectual property infringement. • With law enforcement agencies, government agencies, regulators and courts in the United States and other countries where we operate, such as in response to a subpoena or court order or to fulfill a legal obligation. • With third parties in connection with, or as part of the due diligence for, any proposed or actual merger, acquisition, sale or transfer of some or all our assets (including in the event of a reorganization, dissolution or liquidation). For individuals who contact Ed2Go for more information: If you provide your consent to receive text messages from Ed2Go, we do not share your consent with third parties.
Answer Meets Expectations Unselected Option: Unselected Option:
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:
Sharing Your Personal Information
We share your personal information, to the extent permitted by applicable law, as follows:
• Within the Cengage group of companies.
• If you are affiliated with an educational institution, with your school and if you are a
student, with your instructors. For example, we provide our institutional clients with reports
about how their instructors and students use our products, including information that compares
instructors and students within a school. If you are a student, your instructors will have access to
the information generated by your use of a product for a class and certain information that you
enter into the product. We may also provide personal information to your school, as needed, to
investigate possible academic fraud or cheating. Your school uses your personal information in
accordance with its own privacy policies.
• If you are affiliated with a corporation who has obtained our products, with your employer.
If your employer has obtained our products for its employees’ use and we are processing
9
personal information as a “processor” or “service provider,” we may provide your employer with
reports about how its employees use the product. Your employer may also have access to the
information generated by its employees’ use of the product and information that its employees
have entered into the product. Your employer uses your personal information in accordance with
its own privacy policies.
• With our service providers and advisors to the extent necessary to perform services for us or
on our behalf.
• With learning management systems (LMS) and other education software providers that may
integrate with or complement our products. These providers are given limited access to personal
information in order to deliver the service.
• Advertisers who perform advertising and marketing services on our behalf. We may also permit
these third parties to collect information directly from you on our websites and apps.
• With authorized partners that provide services to you through My Cengage, MindTap and
similar platforms but only to the extent that you have authorized the sharing. For example, you
may request that Cengage share information about the courses you’ve taken with partners to
enable the partner to provide you with resume creation, skills assessments or other services.
Additionally, we may share certain transactional information with our partners as needed to
validate referrals and operate the platforms.
• With companies where you are participating in, or seeking to participate in, a program in
connection with Clinical Experience (Externship) through Ed2go or Ready2Hire.
• With your consent or at your direction.
• With other third parties, as permitted by law, to enforce our rights, including our Terms of Use
or Terms of Service; to protect our property or to protect the rights, property or safety of others;
and to detect, prevent and respond to fraud, illegal activity and intellectual property infringement.
• With law enforcement agencies, government agencies, regulators and courts in the United
States and other countries where we operate, such as in response to a subpoena or court order or
to fulfill a legal obligation.
• With third parties in connection with, or as part of the due diligence for, any proposed or
actual merger, acquisition, sale or transfer of some or all our assets (including in the event of a
reorganization, dissolution or liquidation).
For individuals who contact Ed2Go for more information: If you provide your consent to receive text
messages from Ed2Go, we do not share your consent with third parties.
Sharing Your Personal Information We share your personal information, to the extent permitted by applicable law, as follows: • Within the Cengage group of companies. • If you are affiliated with an educational institution, with your school and if you are a student, with your instructors. For example, we provide our institutional clients with reports about how their instructors and students use our products, including information that compares instructors and students within a school. If you are a student, your instructors will have access to the information generated by your use of a product for a class and certain information that you enter into the product. We may also provide personal information to your school, as needed, to investigate possible academic fraud or cheating. Your school uses your personal information in accordance with its own privacy policies. • If you are affiliated with a corporation who has obtained our products, with your employer. If your employer has obtained our products for its employees’ use and we are processing 9 personal information as a “processor” or “service provider,” we may provide your employer with reports about how its employees use the product. Your employer may also have access to the information generated by its employees’ use of the product and information that its employees have entered into the product. Your employer uses your personal information in accordance with its own privacy policies. • With our service providers and advisors to the extent necessary to perform services for us or on our behalf. • With learning management systems (LMS) and other education software providers that may integrate with or complement our products. These providers are given limited access to personal information in order to deliver the service. • Advertisers who perform advertising and marketing services on our behalf. We may also permit these third parties to collect information directly from you on our websites and apps. • With authorized partners that provide services to you through My Cengage, MindTap and similar platforms but only to the extent that you have authorized the sharing. For example, you may request that Cengage share information about the courses you’ve taken with partners to enable the partner to provide you with resume creation, skills assessments or other services. Additionally, we may share certain transactional information with our partners as needed to validate referrals and operate the platforms. • With companies where you are participating in, or seeking to participate in, a program in connection with Clinical Experience (Externship) through Ed2go or Ready2Hire. • With your consent or at your direction. • With other third parties, as permitted by law, to enforce our rights, including our Terms of Use or Terms of Service; to protect our property or to protect the rights, property or safety of others; and to detect, prevent and respond to fraud, illegal activity and intellectual property infringement. • With law enforcement agencies, government agencies, regulators and courts in the United States and other countries where we operate, such as in response to a subpoena or court order or to fulfill a legal obligation. • With third parties in connection with, or as part of the due diligence for, any proposed or actual merger, acquisition, sale or transfer of some or all our assets (including in the event of a reorganization, dissolution or liquidation). For individuals who contact Ed2Go for more information: If you provide your consent to receive text messages from Ed2Go, we do not share your consent with third parties.
Answer Meets Expectations Unselected Option: Unselected Option:
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 respect the rights of individuals to opt-out of having their business contact information
included in Gale Directory products. If you would like to remove your information from Gale
Directory products, please complete this form.
• You can always opt-out of receiving marketing communications from us by clicking on the opt-
out link in the emails we send. You can also have your name removed from our email marketing
lists by contacting our Customer Service department by email at:
cengagebrain.support@cengage.com or by phone at +1 800.354.9706 (M -F, 8:00 am -6:00 pm
ET).
Please note that even if you opt-out of marketing emails, we may still need to contact you with
important information about your account, about the products or services you purchased and for
other transactional and informational purposes. For example, even if you opt-out of marketing
emails, we will still send you activity or billing confirmations.
We respect the rights of individuals to opt-out of having their business contact information included in Gale Directory products. If you would like to remove your information from Gale Directory products, please complete this form. • You can always opt-out of receiving marketing communications from us by clicking on the opt- out link in the emails we send. You can also have your name removed from our email marketing lists by contacting our Customer Service department by email at: cengagebrain.support@cengage.com or by phone at +1 800.354.9706 (M -F, 8:00 am -6:00 pm ET). Please note that even if you opt-out of marketing emails, we may still need to contact you with important information about your account, about the products or services you purchased and for other transactional and informational purposes. For example, even if you opt-out of marketing emails, we will still send you activity or billing confirmations.
Answer Meets Expectations Unselected Option: Unselected Option:
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:
From DPA template:
Cengage will engage Subprocessors pursuant to written contracts that are consistent with the requirements of this DPA and Data Protection Laws. 
From DPA template: Cengage will engage Subprocessors pursuant to written contracts that are consistent with the requirements of this DPA and Data Protection Laws. 
Answer Meets Expectations Unselected Option: Unselected Option:
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:
From DPA template:
Where required by Data Protection Laws, Cengage will notify Customer of any addition or replacement of any Subprocessors and provide Customer with a reasonable opportunity to object thereto, and such notice may be provided by updating a Subprocessor list, through email to Customer, or through other means determined by Cengage.
From DPA template: Where required by Data Protection Laws, Cengage will notify Customer of any addition or replacement of any Subprocessors and provide Customer with a reasonable opportunity to object thereto, and such notice may be provided by updating a Subprocessor list, through email to Customer, or through other means determined by Cengage.
Answer Meets Expectations Unselected Option: Unselected Option:
Advertising Meets Partially Meets Doesn't Meet
User Notes ADVQ1 - Do the policies indicate if advertisements are displayed?
ANSWER: No ads are displayed
User Notes:
No ads displayed.
No ads displayed.
Answer Meets Expectations Unselected Option: Unselected Option:
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:
No ads displayed.
No ads displayed.
Answer Meets Expectations Unselected Option: Unselected Option:
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:
No ads displayed.
No ads displayed.
Answer Meets Expectations Unselected Option: Unselected Option:
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:
No ads displayed.
No ads displayed.
Answer Meets Expectations Unselected Option: Unselected Option:
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:
No ads displayed.
No ads displayed.
Answer Meets Expectations Unselected Option: Unselected Option:

Vetting Context

Policies Cited

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

Geographical Context

(Laws and regulations can vary across regions)
Massachusetts
United States United States flag

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.


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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.

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App Vetting Rubric Version: 2