Last Revision Date – November 11, 2020
Overview and Scope
The Information We Collect
User-Provided Information – Wherever prior and separate registration is needed to use the CAI Application, we will collect and store the information you enter into our systems when you create an account on an applicable CAI Application hosting site (“Sites”), which will generally be accessed via links provided through an organization’s Learning Management System (LMS). We will also collect and store information you provide when engaging with the CAI Application or when contacting us for other purposes or through other methods, such as over email. Information you provide generally will include:
- your name, email address, user name, password and other registration information;
- information you provide us when you contact us for help;
- depending on the CAI Application, transaction-related information, such as when you create or submit an assignment, make a grade prediction, submit or receive feedback on an assignment, create an announcement, or otherwise use features in CAI Applications that rely on user input; and
- information you enter into our system when using the CAI Application, such as contact information and project management information.
Information Provided by Others – We may receive information collected by other organizations that are using an CAI Application. Additionally, certain CAI Applications (specifically: Gallery, Write and Revise, Write and Annotate, and Recommender) can be easily integrated with third-party learning management systems and platforms using the Learning Tools Interoperability® (LTI) standard (collectively, “LTI Applications”). For LTI Applications, we may receive information collected by LMS providers through LTI-enabled transfers or from the organizations and LMS providers directly. For all CAI Applications, including LTI Applications, information provided by others may include all of the same categories listed in the “User-Provided Information” and “Automatically Collected Information” sections above. LTI-enabled transfers occur automatically when using the LTI Application though your LMS and include account information (username and/or email address connected to the account) linked to the LMS you are using to access the LTI Application. The automatic transfer of account information is necessary to provide a fully integrated and seamless user experience between the LMS and LTI Application.
The User-Provided Information, Automatically Collected Information, and Information Provided by Others described above shall be collectively referred to as “CAI Application Data.”
How Your Information Is Used
U-M uses CAI Application Data collected through the CAI Application to enhance the CAI Application’s performance and user experience and for other legitimate educational interests or as required by law. U-M does not sell or rent your personal data.
U-M may use CAI Application Data to:
- provide and administer the course or program in which you are participating, including evaluating your success in and engagement with the education offering;
- improve student interventions and outcomes;
- respond to your requests and communicate with you regarding current or future courses or programs;
- troubleshoot to support a user’s experience;
- conduct research (for example, in the areas of education and cognitive science) and analytics related to our education offerings;
- satisfy legal, regulatory and contractual obligations;
- use as source information to building learning analytics models to enhance teaching and learning at scale; or
- make improvements to the CAI Application.
Additionally, U-M may use CAI Application Data collected about learners enrolled in U-M learning experiences to send advertisements or other marketing materials via email about other programs, promotions or services to students enrolled in U-M courses and programs if they have requested or agreed to receive such information, or where we are otherwise permitted by local law to contact these students for these purposes.
How Your Information Is Shared
U-M will only disclose your personal data to:
- school officials (instructors and administrators) for them to conduct their educational responsibilities, including individuals who work for the LMS provider and, where applicable, at the organization offering the LMS experience;
- government officials, as required by law, such as to comply with a subpoena, or similar legal process or when we believe in good faith that disclosure is necessary to protect our rights (including in legal proceedings), protect your safety or the safety of others, investigate fraud, or respond to a government request; and
- trusted service providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement.
How Your Information is Secured
We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our CAI Application. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches. We maintain the CAI Application and its associated data in ways that comply with the Family Education Rights and Privacy Act (FERPA) and U-M FERPA policies.
Data Retention Policy, Managing Your Information
The Center for Academic Innovation administers cookies to identify a user across page loads during a session and provide an integrated user experience. These cookies may be blocked through settings in your browser, but doing so would affect the functioning of the CAI Application.
We will retain User-Provided Information for as long as you use the CAI Application and for a reasonable time thereafter.
If you’d like us to access, update, correct, or delete User-Provided Information that you have provided via the CAI Application, please contact us at firstname.lastname@example.org and reference the Center for Academic Innovation and the name of the CAI Application in your email. We will respond in a reasonable time. Please note that some or all of the information we collect may be required in order for the CAI Application to function properly, and we may be required to retain certain information by law.
If you do not want us to contact you with marketing communications or other information regarding our products and services (or if you agreed to be contacted for such purposes at the time the CAI Application Data was collected by us but you no longer wish to be contacted or have your information used in such a way), you can let us know by following the unsubscribe instructions on any communications sent to you. You can also unsubscribe at any time by contacting us at email@example.com. Please note that if you have registered an account on the Sites or are registered for an CAI Application, opting out of receiving marketing messages will not apply to CAI Application Data provided to us as a result of signing up to use the CAI Applications, and we reserve the right to send you certain communications relating to your account, your registration, and your use of the Sites and CAI Applications, such as messages relating to account management, customer service and system maintenance. These transactional account messages will thus be unaffected if you choose to opt-out of marketing communications.
We do not use CAI Applications to knowingly market to children under the age of 13. If a parent or guardian believes that the data about his or her child is incorrect, he or she should contact the instructor who is employing the CAI Application in their teaching.
Note for those located in the European Union (EU)
If you reside or are located in the EU, you may have additional rights over the personal data that we collect, as defined under the General Data Protection Regulation (GDPR). A detailed description of these rights and U-M’s approach to GDPR compliance can be found in U-M’s Notice Specific to Persons in the EU. Additionally, all requests concerning access to PII or use restrictions, as well as further inquiries about data use and retention, can be submitted to firstname.lastname@example.org.
If you have any questions regarding privacy while using the CAI Application, or have questions about our practices, please contact us via email at email@example.com. You may also submit general data privacy inquiries to U-M’s Privacy Office at firstname.lastname@example.org.
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