Date of last revision of this policy: October 1, 2019
Twine is a service that is owned and operated by Aptiris Inc, bringing together a combination of Aptiris-provided Student Information System services (the "Site") with those provided by our partners, Edsby and Websby. We are committed to protecting the privacy of our visitors while they interact with the content, products and services provided by Twine, and proud to be a signatory of the Student Privacy Pledge.
For the purposes of this document the term “Parents” will be used to refer to the parents, guardians, and others such as aunts, uncles, step-parents, grandparents that are specifically approved by someone legally responsible for a child to have access to information in Twine regarding that child.
Twine provides a suite of services to the stakeholders of education organizations including teachers, students, administrators and Parents. Twine is delivered as a “cloud service”, which means the data that Twine stores and the servers that provide the Twine service reside in a commercially run cloud hosting data center that is designed to provide very high levels of security and reliability.
1) Information We Collect and Store
We collect and store three kinds of information on your behalf: i) your personal information, ii) content you provide, and iii) information related to your usage of the Site
i. Your Personal Information.
Our Site has the ability to store your name, userid, password, address, telephone numbers, and email addresses. Most or all of this information is provided by your education organization when your account is created. It is updated from time to time by your education organization as it changes. Parents, Teachers and Administrators may have the ability to enter/modify/update some of the above information directly; that is at the discretion of your education organization. Students are never allowed enter/modify/update their own personal information directly.
ii. Content You Provide
Twine enables you to provide a wide range of digital content including text, images, audio, video, and web links. This digital content can be placed in messages, profiles, private notes, calendar events, gradebooks, and postings in shared places. Twine stores this information on your behalf and tracks the fact that you provided that information. Note that files that you upload into the Site may have metadata associated with them. This metadata is preserved by the Site and will be available to users granted the ability to view or download the file you have uploaded.
iii. Information Related to Your Usage of the Site
Site Access details: Each time you log in to Twine we store information about that session including the time of login, the duration of the session, information about the type of computing device being used, the IP address of the computing device, and the type of browser or application software being used to access Twine.
2) How We Use the Information We Collect and Store
The information we collect and store on your behalf may be provided to third parties, including Edsby and Websby, to extend the suite of services supported by or through Twine on behalf of your education organization. Sharing of such information will be done only at the request and approval of officials at your education organization.
The information we collect and store on your behalf is accessible to authorized employees of your education organization and authorized employees, consultants and contractors of Aptiris Inc.
The information we collect and store on your behalf will be disclosed by us to legal authorities if we are required to do so by law.
We may disclose at our discretion a portion of the information we collect and store in special cases where we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating the terms and conditions of use of this Site, someone who may be causing injury or interference with our rights or property, someone who may be causing interference with the rights, property or rules of the education organization using Twine, or someone who may cause or be at risk of imminent bodily harm.
Twine has the ability to provide you with updates and notifications via email and/or text messaging. You can manage this ability (including turning it off) via the “account settings” facility on the Site.
We may permit certain trusted third parties to track usage, analyze data such as the source address that a page request is coming from, your IP address or domain name, the date and time of the page request, the referring Web site (if any) and other parameters in the URL. This is collected in order to better understand usage of the Site, and enhance the performance of services to maintain and operate the Site and certain features on the Site. We may use third parties to host the Site; operate various features available on the Site; send emails; and analyze data.
We may share the information we collect and store with parent companies, subsidiaries, divisions, and affiliates. We may transfer the information we collect and store and all associated rights, to an entity whose privacy policies are consistent with the student privacy pledge, as an asset in connection with a proposed or actual merger or sale (including any transfers made as part of an insolvency or bankruptcy proceeding) involving all or part of our business or as part of a corporate reorganization, stock sale or other change in control. Should policies of the receiving entity provide lesser protection of customer data, customers shall be given a choice to opt-out of the data transfer.
We use non-identifying and aggregate information to better design the Site and for business and administrative purposes. We may also use or share with third parties for any purpose aggregated data that contains no personally identifiable information.
WE ARE NOT LIABLE OR RESPONSIBLE FOR THE PERSONALLY IDENTIFIABLE OR OTHER INFORMATION YOU CHOOSE TO SUBMIT IN FORUMS SUCH AS A SHARED COMMUNICATIONS PLACE, MESSAGES, CHAT ROOM OR ANY OTHER AREA OF THE SITE THAT IS ACCESSIBLE TO OTHER USERS.
3) How We Protect Your Information
We are committed to protecting the information and content we store on your behalf. We take appropriate security measures to protect your information against unauthorized access, alteration, disclosure or destruction. To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we maintain appropriate physical, electronic, and managerial procedures to safeguard and secure the information and data stored on the Site. For example, staff access to customer data is permission-controlled and only granted to staff whose role requires such access to support our clients; and all data is protected by a variety of industry-accepted technical means including SSL encryption of data in transfer and multiple levels of firewall and packet-inspection security settings.
Customer data, including student personal information, is retained only so long as necessary to provide services. While no computer system is completely secure, we believe the measures we have implemented reduce the likelihood of security problems to a level appropriate to the type of data involved.
Twine does not now nor never has provided any form of advertising to any user on Twine. In addition the company does not sell any data or information about users to any outside company for the purposes of advertising.
5) Accessing and Updating Your Personal Information and Preferences
The “edit profile” and “account settings” facilities in Twine enable you to view and in some cases change your personal information and preferences. Note that in many cases some or all of the personal information displayed comes from your education organization, and changes or updates to your information must be done by them.
6) Children’s Privacy and Parental Controls
Students are not allowed to create accounts on the Site. Student accounts are created under the direction of administrators and/or teachers at the education organization. Students are also not allowed to add to, modify or delete the personal contact information and userid that is provided for them on this site by the education organization.
The Site is designed so that only teachers at the child’s school, designated administrative staff and the child’s Parents have access to the child’s personal information. Other students and other Parents do not have access to the personal information stored for any child.
7) Disclaimer to Security
We are committed to protecting the information and content we store on your behalf. We take appropriate security measures to protect your information against unauthorized access, alteration, disclosure or destruction.
Nevertheless, no security measures are perfect. We cannot guarantee or warrant the security of any information you provide to us or that we store on your behalf. You transmit such information to us at your own risk. We cannot guarantee that only authorized people will have access to the information and content we store and display on your behalf. We are not responsible for breaches in our security caused by third parties violating our terms of service and/or bypassing our security mechanisms.
8) Notification of Changes
9) Contact Information