Updated:  December 1, 2021

 

 

Literary Focus is a service that allows registered parents or guardians (“parents”) to enroll students (“students”) in online small-group classes, and for registered teachers (“teachers”) to provide those classes (“services”). This privacy statement describes what personal information that Literary Focus collects from registered parents, teachers, and students of Literary Focus services, as well as how Literary Focus collects and uses personal information from visitors to our public website (“site”).

 

 

Information We Collect:

 

When you visit our site, we may collect information about you that, alone or in combination, could be used to identify you, your device, or household (“personal data”), as further described below:

 

 

Personal Data That You Provide Through the Site: 

 

We collect personal data from you when you directly provide it to us, such as when you register for a Literary Focus account to use the services. For example, we may collect the following personal data from you:

 

Contact Information:

 

• Name

 

• Email address

 

• Phone number

 

• Postal and billing address

 

Payment Information:

 

• Credit card or other payment information

 

Demographic Data:

 

We collect age, month and year of birth, gender, pronouns, marital status, and similar demographic details, such as when you voluntarily provide information in the “About Me” section of your profile or communicate with us.

 

Sensitive Data:

 

Parents may voluntarily provide sensitive information such as health or disability information included in forms or messages sent to teachers to aid with learning. Teachers and students are otherwise not allowed to have discussions that may elicit or result in sharing of sensitive information.

 

If we suspect that a child is over 18, for safety of other students, we may request that a parent show us a copy of age-identifying documentation, such as a student’s birth certificate, passport, or driver’s license. This documentation could show us sensitive data such as full date of birth, place of birth, and government ID numbers. Other than month and year of birth, we do not record this information.

 

We may also receive sensitive criminal history information about teachers when we receive background reports.

 

Content and Files:

 

• Classes for which you have enrolled

 

• Video of your image and audio of your voice during classes which are automatically recorded

 

• Content and communications that you may include or upload like your profile photo or messages you share with the class

 

• Your voluntarily provided profile picture

 

• Information voluntarily provided in the “About Me” section of your profile

 

• Information voluntarily provided through reviews

 

• Information teachers provide to let us run background checks and background check reports we receive from third parties

 

• Notes you provide to teachers about yourself or your student when enrolling a student in a class

 

 

Passively Collected Data: 

 

When you use or interact with us through our site, we and our third-party partners may collect, receive, and store certain data automatically. For example,

 

Usage data:

 

We collect usage data (such as login times, search terms you used, and pages you viewed), and other information about your device and browser.

 

Identifiers and device information:

 

We collect IP Address, device identifiers such as cookie identifiers (more on cookies below), your device’s operating system type, and browser type. We may use such information and pool it with other information to track usage and device and system data—for example, the total number of visitors to our sites, the number of visitors to each page of our website, and the domain names of your Internet service providers.

 

Cookies:

 

On our site, we and third parties that provide certain functionality to the Literary Focus site may use a technology called "cookies." A cookie is a piece of information that the computer that hosts our site gives to your browser when you access the site. Our cookies help provide additional functionality to our site and help us analyze site usage more accurately. On most web browsers, you will find a “Help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of our site’s features. For more information about our use of cookies, please see the section entitled “Cookie Policy” below.

 

 

Inferred Data: 

 

We may infer new information from other data we collect, including using passive, automated means, to generate information such as your general geographic location (city, state, and country) based on your IP address.

 

 

Aggregated Personal Data: 

 

We may aggregate data, including personal data, and use such aggregated data for any purpose. This aggregate information does not identify you personally.

 

 

Required Personal Data: 

 

Some personal data is required such as credit card payment used by parents to purchase classes and for teachers purchasing curriculum guides. Teachers are also required to let us access personal data relating to background checks. Teachers and students are also required to have their cameras on while teaching or attending a live class to verify their identity and to protect the safety of other students. Nonetheless, there are some instances when you may decline to provide certain personal data.

 

 

Sources of Personal Data:

 

You are the main source of the personal data we have about you. We may also obtain, however, any of the above categories of information from third parties. These third-party sources may include the following:

 

• Third party partners, applications, and services, including social networks you choose to connect with or interact with through our services.

 

• Co-Branding/Joint Partners. Partners with which we offer co-branded services or engage in joint marketing activities.

 

• Service providers that collect or provide data in connection with work they do on our behalf, for example companies that determine your device’s location based on its IP address.

 

• Publicly available sources. Public sources of information such as open government databases and background check services we used for teachers.

 

 

Our Use of Your Personal Data and Other Information:

 

We may use any of the above categories of your personal data in order to do the following:

 

• provide and enhance the Literary Focus site, including troubleshooting, maintaining, improving, and personalizing the site;

 

• business operations, such as processing your payment for Literary Focus services, billing, accounting, improving our internal operations, securing our systems, detecting fraudulent or illegal activity, and meeting our legal obligations;

 

• send you emails or newsletters that you signed up for, including messages about new and recommended classes, groups, events, and other marketing content we may send to parents and teachers;

 

• communicate with you to confirm registration and send updates, provide customers support and security alerts, and other administrative messages;

 

• conduct research and develop new services or features; analyze website usage and usage of the site features, content, and pages; and

 

• conduct background checks if you are a teacher

 

We combine data we collect from different sources to achieve these purposes and to give you a more seamless, consistent, and personalized experience.

 

Literary Focus teachers may access recordings of their classes and may use the recordings to improve their curriculum and classes and may provide the recording to parents and students to view. Literary Focus may also use class recordings to provide feedback to teachers, for customer support, and for compliance purposes.

 

If you are a parent or teacher, Literary Focus may use your contact data for marketing purposes, including to tell you about services and opportunities we believe will be of interest to you. If we do so, each promotional email we send you will contain instructions permitting you to "opt-out" of receiving future promotional information. In addition, if at any time you wish not to receive any future communications or you wish to have your contact information included in our opt-out lists, please contact us at support@literaryfocus.org. Please note that we will continue to contact you via email to respond to requests and provide our services.

 

 

Storage and Transfer of Personal Data:

 

Your information, including personal data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your region. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including personal data, to the United States and process it there.

 

 

Our Disclosure of Your Personal Data and Other Information:

 

We may share your personal data with certain third parties with your consent or authorization and with whom you have intentionally interacted. We may share your personal data as necessary to complete your transactions and provide the services you have requested or authorized. For example, we use third parties to process credit card payments.

 

We may also share data as set forth below:

 

Teachers: 

 

When parents sign up they agree that teachers may receive certain personal data about the parents and their students including classes their student has taken. Teachers receive guidance and restrictions on what they can do with personal data. We act as limited agents for our teachers to process payments from parents for classes.

 

Business Transfers: 

 

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be transferred to a successor or affiliate alone or as part of that transaction along with other assets.

 

Service Providers: 

 

We engage third party service providers to perform certain functions on our behalf (such as payment processing). These third parties may have access to your personal data for the purpose of helping us market, provide and/or improve the site.

 

Legal Requirements: 

 

Literary Focus may disclose your personal data if required to do so by law or when we believe that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Literary Focus, teachers, students, and parents, (iii) operate and maintain the security of our site, including to prevent or stop an attack on our computer systems or networks, (iv) to protect the personal safety of users of the site or the public, or (v) protect against legal liability. Teachers are required to report to Literary Focus any suspected case of child abuse or neglect they become aware of during their work with students. Teachers may also be required to report suspected abuse or neglect to local authorities, and Literary Focus expects all teachers to comply with their individual reporting responsibilities. Literary Focus itself may report instances of suspected abuse or neglect.

 

Third Party Analytics: 

 

Third party analytics vendors also collect personal data through our site including general location data, usage data, and inferences associated with identifiers and device information (such as cookie IDs and IP address) as described in the Cookies section of this statement. Except for data collected from students on the services in student space, these third-party vendors may combine this data across multiple sites to improve analytics for their own purpose and others. For example, we use Google Analytics on our site to help us understand how users interact with our site; you can learn how Google collects and uses information at www.google.com/policies/privacy/partners.

 

Please note that our site includes references or links to or suggestions to engage with third parties whose privacy practices may differ from ours. Teachers may also suggest third party resources for parents and students. If you provide personal data to any of those third parties, or allow us to share personal data with them, that data is governed by their privacy statements.

 

 

Publicly Posted Information:

 

You may be able to share personal data, including communications, with third parties, including with the general public, through use of our site. When you do so, we ask that you avoid sharing personal data and do not share sensitive personal data.

 

We expect everyone to respect the privacy of others and follow our community standards, and other guidelines and restrictions on posting and sharing activities, such as sharing private materials, communications, or information, or sharing other personal data about others that may cause harm, embarrassment, or conflict. You should not encourage your students to reveal any personal data about students or their families.

 

User Profile: 

 

As a user of our services, you will have a user profile that will be publicly available to all users of the service (“user profile”). You are not required to include any personal data on your user profile. But you will have the option to include a variety of types of personal data in your user profile, which may include your first name, last name, biographical information, geographical location, and avatar/personal photograph. Any information published in your user profile becomes available to the public. After publishing, we have no control over how such information is used or its further dissemination. We urge you to think carefully about what, if any, personal data you include in your user profile.

 

Online Classes and Pages: 

 

If you are teachers leading an online class, you may publicly display and share your video and photographic image, name and/or username and certain other information, such as your profile, demographic data, content and files, and general location data (such as the city or state).

 

Public Forums: 

 

Our services provide teachers, parents, and students the opportunity to share information on a variety of topics with other Literary Focus users through discussion boards and public forums (“public forums”). Use of the public forums is entirely voluntary, but please be aware that any information you include in the public forums will become available to all Literary Focus users without restriction. We monitor the content of information that is published in the public forums, but be aware that any information published in public forums becomes available to the public.

 

Messages: 

 

Students can message teachers, and parents and teachers can message each other using the service. Parents have access to messages between their students and teachers. After publishing, posting, or messaging, we have no control over how such information is used or its further dissemination. We urge you to think carefully about what, if any, personal data you share with others on our service.

 

Social Media: 

 

Parents and Teachers may log into the service using a Facebook account. When you login, we will receive your name, profile picture and email address from Facebook, and Facebook will record when we access this data. You will provide your Facebook login information directly to Facebook (and not to Literary Focus). How Facebook uses, stores, and discloses your information is governed by the policies of Facebook; Literary Focus does not have responsibility for the privacy practices or other actions of Facebook.

 

 

Security:

 

We take reasonable steps to protect the personal data provided via the site from loss, misuse and unauthorized access, disclosure, alteration, or destruction. However, the Internet cannot be guaranteed to be fully secure, and we cannot ensure or warrant the security of any content or information you provide to us. You are also responsible for helping to protect the security of your account credentials. For instance, never give out your password, and safeguard your username, password and personal credentials used to access the service, so that other people will not have access to your personal data.

 

 

Do Not Track:

 

Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. While we do not currently support Do Not Track signals, we treat the data of everyone who comes to our site in accordance with this Privacy Statement, whatever their Do Not Track setting.

 

 

Access and Accuracy; Correcting Personal Data:

 

We use reasonable efforts to keep your personal data accurate and up-to-date, and we will provide you with mechanisms to correct, amend, delete, or limit the use of your personal data. As appropriate, this amended personal data will be transmitted to those parties to which we are permitted to disclose your information. Having accurate personal data about you enables us to give you the best possible service.

 

 

Additional Notice for California Consumers:

 

This portion of our Privacy Statement applies to California consumers only:

 

Personal Information Collected on California Consumers in the Last Twelve Months:

 

The “Personal Information,” as defined in California Civil Code § 1798.140(o), we have obtained on California residents within the last twelve months includes the Personal Data we describe above in the “Information We Collect” section.

 

Our Use of Personal Information for Business Purposes in the Last Twelve Months:

 

We use each category of the Personal Information we collect for the purposes disclosed within the “Our Use of Your Personal Data” section. 

 

Disclosures of Personal Information on California Consumers for Business Purposes:

 

Within the last twelve months, we have disclosed personal information with limited third parties described in “Our Disclosure of Your Personal Data” 

 

California Rights and Choices:

 

If you are a California resident, you have certain legal rights related to your personal information. Except as otherwise provided or excepted by applicable law, you may exercise the following rights:

 

A.  Right to Know/Portability:

 

You have the right to request that we disclose to you certain information about personal information we collected about you within the past twelve months. Once we confirm your verifiable request, we will disclose to you:

 

(i)  the categories of personal information we have collected about you;

 

(ii)  the categories of sources from which the personal information is collected;

 

(iii)  our business or commercial purpose for collecting personal information;

 

(iv)  the categories of third parties with whom we share personal information; and

 

(v)  the specific pieces of information we have collected about you.

 

B.  Right to Opt Out:

You have a right to opt-out from future “sales” of personal information. Note that the CCPA defines “sell” and “personal information” very broadly, and some of our data sharing relating to cookie data and other tracking methods used for analytics and advertising purposes described in this privacy statement may be considered a “sale” under those definitions. To opt-out of this limited “sale” of personal information, please visit our “Do Not Sell My Personal Information” page. We do not “sell” the personal information of consumers we know are less than 18 years of age, unless we receive affirmative authorization (the “right to opt in”) from either the consumer who is between 13 and 18 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt into personal information sales may opt out of future sales at any time.

 

C.  Right to Deletion:

You have the right to request deletion of your personal information that we collected from you and retain, subject to certain exceptions. Once we confirm your verifiable request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

 

D.  Right to Non-Discrimination for Exercise of a California Privacy Rights:

We will not discriminate against you because you exercise any of the above rights, or any other rights under the CCPA. Specifically, if you exercise your rights, we will not deny you access to our services, charge you different prices or rates for services, or provide you a different level or quality of services.

 

E.  How to Submit a Request:

You may submit a request to exercise the rights listed above by emailing us at support@literaryfocus.org. In your request, please include (i) full name used to create your account; (ii) email with which you created your account; (iii) phone number in case we need to contact you to securely verify your request; (iv) whether you are requesting how your information is used and/or to delete your personal information.

 

F.  Verifiable Request:

As required under applicable law, we take steps to verify your identity before responding to your request. We may require you to provide information sufficient enough to allow us to reasonably verify you are the person about whom we collected personal information or an authorized representative. We may limit our response to your exercise of the above rights as permitted under applicable law.

 

G.  Agent Authorization and Disability Access:

 

You may designate an authorized agent to make a request on your behalf. As permitted by law, we may require additional verification in response to a request even if you choose to use an agent. You may also make a verifiable consumer request on behalf of your minor child. To access this Privacy Statement by an alternative method, please contact us at support@literaryfocus.org.

 

H.  Responding to Requests:

We will confirm receipt of your request within 10 days from receipt and provide information about how we will process the request, our verification process, and when you can anticipate a response to the request. We will use commercially reasonable efforts to honor your request within 45 days from receipt. If additional time is needed, we will notify you of the same, along with an explanation and anticipated timeline for the extension which shall not exceed 90 days from the date of receipt.

 

 

Other California Privacy Rights:

 

California residents under the age of 18 who are registered users of online sites, services, or applications have a right under California Business and Professions Code Section 22581 to remove, or request and obtain removal of, content or information they have publicly posted. To remove content or information you have publicly posted, please send a detailed description of the specific content or information you wish to have removed to support@literaryfocus.org. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

 

 

European Data Protection Rights:

 

If our processing of personal data is subject to European Union data protection law, you have certain rights with respect to that data:

 

• You can request access to, and rectification or erasure of, personal data;

 

• If any automated processing of personal data is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal data in a usable and portable format;

 

• If the processing of personal data is based on your consent, you can withdraw consent at any time for future processing;

 

• You can to object to, or obtain a restriction of, the processing of personal data under certain circumstances; and

 

• For residents of France, you can send us specific instructions regarding the use of your data after your death.

 

To make such requests, please use the contact information at the bottom of this statement. We rely on different lawful bases for collecting and processing personal data about you—for example, with your consent and/or as necessary to provide the services you use, operate our site and business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests.

 

 

Retention of Personal Data:

 

We retain personal data for as long as necessary to provide the services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations. For example, we keep class recordings for 90 days after the date of the applicable class.

 

 

Cookie Policy:

 

What are cookies?

 

Cookies are small text files containing a string of characters that can be placed on your computer or mobile device that uniquely identify your browser or device. Cookies are used with web beacons and similar technologies. Web beacons are electronic images (also called single-pixel or clear GIFs) that are contained within a website or email and can read cookies they place on your device.

 

What are cookies used for?

 

Cookies and similar technologies allow a site or service to know if your computer or device has visited that site or service before. Cookies can then be used to help understand how the site or service is being used, help you navigate between pages efficiently, help remember your preferences, and generally improve your browsing experience. We and our analytics and advertising partners use cookies and other identifiers, such as IP address, and technologies on our site to collect personal data (such as the pages you visit, the links you click on, and similar usage information) when you use our site, including personal data about your online activities over time and across different websites or online services. We and our analytics and advertising partners may use cookies and similar technologies to provide targeted advertising.

 

 

Changes to Our Privacy Statement:

 

We may change our Privacy Policy at any time. If we decide to change our Privacy Policy in the future, we will post or provide an appropriate notice. If we make material changes to the statement, we will provide notice or obtain consent regarding such changes as may be required by law. The date on which the latest update was made is indicated at the top of this document.

 

 

Contact:

 

Please feel free to contact us if you have any questions about Literary Focus’ Privacy Policy or the information practices of our site. You may contact us as via email at support@literaryfocus.org or via mail at the following address:

Literary Focus
1002 S 800 E
Salt Lake City, UT 84105
United States
801.707.5481

 

 

Children's Privacy Notice:

 

This section explains our information collection, disclosure, parental consent practices, and parental choice procedures with respect to information provided by students including children under the age of 13 (“child” or “children”). This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”), and outlines our practices in the United States regarding children’s personal data. For more information about COPPA and general tips about protecting children’s online privacy, please visit the OnGuardOnline website:  www.consumer.ftc.gov/features/feature-0038-onguardonline.

 

 

Collection: 

 

Literary Focus collects personal data about children directly from parents and, when we have verified parental consent of parents, directly from children. Children are expected to use and select children’s mode, which we call student space, when they use our services and must be in student space to attend online classes and to join online forums with other children in student groups. Children cannot enroll in classes or student groups through the student space. We may allow children to mark classes or student groups they like or want to attend, which parents can see, but can only attend classes or student groups if their parents enroll them. Parents provide us with the child’s name and age. Parents may additionally provide us with descriptions of the type of schooling their child attends, local time zone, and additional notes for the teacher. In addition, children may share information about themselves during online classes. Literary Focus class sessions and student groups take place over online videos in which video images and audio of the children are recorded. We may collect other personal data about children in student space, including passively collected data, as described in our general privacy notice, with the exception that we do not collect payment information from children or allow third parties to use personal data collected through analytics cookies for their own purposes. We also do not condition participation in our services for children on the collection of more personal data than is reasonably necessary.

 

 

Use and Disclosure: 

 

Once we obtain verified parental consent, we may use and share personal data collected from children for many of the same purposes described in the general privacy notice. We may recommend classes and student groups to parents based on children’s previous activities on our site, such as when they are enrolled in classes or student groups. We may send emails to parents about those recommendations. We may also send surveys and information emails to parents and children. We do not, however, send promotional emails to children or allow third party analytics providers to collect personal data for their own uses through Student Space.

 

Literary Focus shares, or allows you to share, the name, age, postal address, local time zone, and any notes parents have provided about their child to the class teacher to allow the teacher to provide classes and deliver supplies to children. Children can also privately message teachers of the classes they’re enrolled in. Parents will get notices of and copies of these messages. Children’s video image and voice audio and potentially background images of their home and family members are shared with the teacher and the rest of the class as they participate in classes. Parents should consider using virtual backgrounds for their children if they have concerns about posting images of their home and family members. Children may also share information about themselves with the teacher and the rest of their class during the class session voluntarily, including content, images, and videos they may upload and share with their class. While Literary Focus expects teachers and all other users to abide by our standards of conduct and we take reasonable steps to monitor certain communications and posts, please note that we are not able to control or monitor all personal data your child may share with teachers or other classmates, nor what those third parties ultimately do with that information.

 

Parents can also enroll children in student group discussion sessions. Teachers may or may not participate or lead student groups but no other adults are allowed to interact with children in student groups. Children interact with other children in group discussion learning sessions on various topics. Children can share messages, posts, and other content with other students. Literary Focus moderates this content for compliance with our community standards and guidelines and for safety reasons. We urge you to talk to your children to follow our community standards when posting content and messages in class or in student groups. You should encourage your children to also think about their own privacy and safety when choosing what to share with others. In particular, children should be encouraged to avoid sharing personal data like their address or contact information with other children in classes or in student groups.

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At times, we may allow children and parents to submit content, including photos and artwork, along with other information about the child (like age, first name or initials and city, state, and country) that you may allow us to display publicly. Parents should review children’s submissions and avoid uploading any private information in the content about the children, family members, or others. Literary Focus is not responsible for what other third parties do with information you choose to share publicly. Some teachers may ask child students and their parents to use third party sites and services. Parents should review the privacy notices for those third party sites and services to understand their privacy practices. We are not responsible for nor do we systematically monitor those third party sites and services.

 

 

Class Video Recordings: 

 

As described above, Literary Focus records video of children and teachers during Literary Focus classes (“class recordings”). The class recordings are made available by Literary Focus to the teacher of the class and may be shared by the teacher for the entire class (and their parents) to view (“permitted recipients”). Literary Focus may also use class recordings to provide feedback to teachers, for customer support, and for compliance purposes.

 

Literary Focus will obtain additional parental consent before we use any class recordings for promotional or other unexpected purposes. We request that our teachers refrain from creating copies of the class recordings or from sharing the class recordings with anyone aside from permitted recipients, and also request that permitted recipients not download or re-share the class recordings. While we expect teachers and permitted recipients to abide by our standards of conduct, please note that we cannot control or monitor what such third parties ultimately do with class recordings.

 

 

Parental Consent: 

 

Literary Focus sends a direct notice with these privacy disclosures and obtains verifiable parental consent before collecting, using, and sharing personal data from your child. Literary Focus requires that you provide your credit card information to verify you and to register your child for and pay for a Literary Focus class. If you do not consent or withdraw consent, then we will not collect, use, or disclose any personal data about your child, and your child will not be allowed to use the services in any way. If you do not provide consent within a reasonable time from the date the direct notice was sent, and are not using our services for any other purposes, such as for teen children, we will also delete your online contact information from our records.

 

 

Parental Choices and Controls: 

 

At any time, you can review and refuse to permit us to collect further personal data from your children in association with your account. You can also request that we delete from our records the personal data we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service. You may review and update certain of your child’s information by logging onto your account. In your account, you can review topics of interest we have inferred based on your child’s likes and past classes. You can choose to opt-out of recommendations based on your child’s activities and instead choose the learning topics you want to hear about. You can contact Literary Focus to request access to, change, or delete your child’s personal data, or revoke consent for our collection, use, and sharing of personal data, by sending an email to us at support@literaryfocus.org. A valid request to delete personal data will be accommodated within a reasonable time. In addition to the foregoing, we will exercise commercially reasonable efforts to delete personal data collected from children when it is no longer needed for the purpose for which it was collected.

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If you have any questions about our Privacy Policy, please contact us here.