Information that SBBO collects from you (including Personal Information)
Cookies and Tracking Technologies on the SBBO Site
How your information is used
How your information is shared
How to manage your Personal Information
Storage & Security
INFORMATION THAT SBBO COLLECTS FROM YOU (INCLUDING PERSONAL INFORMATION)
SBBO directly collects information when you:
sign up for an SBBO user account and create an SBBO user profile;
enroll and participate in online courses;
purchase a product or service (for example, Verified Certificates);
send email messages to SBBO (including messages to learner support);
participate in user surveys; and
participate in public forums, webinars, and other interactive experiences on the SBBO Site.
SBBO also indirectly collects usage information about your visit to the SBBO Site, as explained in the section below titled Cookies and Tracking Technologies.
SBBO does not itself collect or store financial account numbers or identification issued by a governmental entity, employer, or other authority. Instead, if you choose to make a purchase on the SBBO Site, for example a Verified Certificate, you will be directed to SBBO ’s third-party payment processor and SBBO ’s third-party ID verification service provider. If you do not wish to submit the required authentication or payment information, then you will not be able to obtain a certificate via the SBBO Site.
SBBO requires your Personal Information only in limited circumstances when you:
sign up for an SBBO user account (name, username, email address);
purchase a Verified Certificate (so that SBBO ’s third-party vendor can authenticate your identity) or other product or service (so that SBBO ’s third-party vendor can process payment);
participate in remote proctoring or other course facilitation processes (so that SBBO’s third-party vendor can monitor and assess the integrity of your course activity); or
earn a Verified Certificate (the certificate will have your name on it).
To the extent that SBBO associates the information that SBBO collects directly or indirectly with an individual (for example, you), the association is based on Personal Information in your account profile.
You may voluntarily choose to share additional Personal Information on the SBBO Site, for example:
in your SBBO account profile (and you may display a limited or full profile to other SBBO Site users);
in applying for financial assistance; or
when participating in a course, forum, webinar, or other interactive experience on the SBBO Site (noting that in some cases, this information is shared with a third party that provides tools or other assistance for the SBBO Site or a course).
SBBO encourages you to use discretion before voluntarily sharing additional Personal Information on the SBBO Site. (If you later choose to delete your SBBO account, deletion of your Personal Information will be subject to the process and limits outlined below.)
Members do not receive your Personal Information unless and until you enroll in a course. If you enroll in a course, the Member that offers the course will receive Personal Information from your SBBO account profile plus the information that SBBO collects about your activity and performance in the course in which you enrolled.
based on your cookie settings, SBBO tracks information indicating, among other things, which pages of the SBBO Site were visited, the order in which they were visited, when they were visited, and which hyperlinks and other user interface controls were used;
SBBO may log the IP address, operating system, and browser software (including mobile use and device type when you use SBBO native mobile apps) you used when accessing the SBBO Site, and SBBO may be able to determine from an IP address your Internet Service Provider and the geographic location of your point of connectivity; and
SBBO may track and collect information from emails that SBBO sends to you, for example whether you opened the email or clicked on any links from the email.
SBBO also partners with third parties to help us track and understand your activity on the SBBO Site, how you interact with SBBO ’s social media, and how you find or may be referred to the SBBO Site. Individual Members may separately use Tracking Technologies within their courses and email communications to understand your activity within a course and how you find or may be referred to a course on the SBBO Site.
when necessary for system administration, security, and integrity to ensure the SBBO Site works properly for you. Without these technologies, the SBBO Site may not function correctly;
to enable analytics, performance and functionality, to help SBBO and Members gather information about how visitors use the SBBO Site and monitor SBBO Site performance, and to enhance your experience by recognizing and remembering whether you have visited the SBBO Site before and may have any personal preferences; and
to support marketing by enabling SBBO and Members to deliver content relevant to your interests on the SBBO Site and third-party sites based on how you interact with SBBO or Member advertisements or content. SBBO and Members use “first-party” cookies, which means cookies served by SBBO or an individual Member, and also “third-party” cookies, which means cookies served by third parties that help SBBO and Members track this information.
You have some options for managing Cookies and other Tracking Technologies. These include:
Modifying your browser settings: You should be able to control how and whether your web browser accepts Cookies by adjusting its privacy and security settings. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new Cookies, how to receive notification of new Cookies, and how to disable existing Cookies. If you reject SBBO ’s Cookies, many functions and conveniences of the SBBO Site may not work properly.
Opting-out of certain third-party tracking and advertising: Some of the third parties used by SBBO or a Member for Cookies and Tracking Technologies offer the ability to opt-out from their tracking by following processes described on their websites. A list of some such third parties is maintained and available at the SBBO learner Help Center and includes, for some, links to applicable opt-out processes. Neither SBBO nor any Member is responsible for the effectiveness of any third-party opt-out options.
HOW YOUR INFORMATION IS USED SBBO and Members use information, including Personal Information, to carry out the following purposes:
Operate and improve the SBBO Site – This includes creating and improving features that support the SBBO community and enable SBBO Site usage at scale. This also includes personalizing the SBBO Site, so you’re learning experience is tailored to your interests and needs.
Create, administer, provide, and teach courses – This includes creating and improving the delivery of massive open online courses and programs on SBBO. This also includes personalizing courses, so you’re learning experience is tailored to your interests and needs and assessing your performance and awarding certificates.
Offer and improve products and services – This includes enabling you to navigate the SBBO Site, to enroll and participate in courses and programs on the SBBO Site, to learn effectively in such courses and programs, and to purchase or obtain products and services on the SBBO Site such as Verified Certificates.
Develop and maintain the security and performance of the SBBO Site – This includes tracking SBBO Site outages and creating software solutions, detecting violations of the Honor Code and Terms of Service, and monitoring uses, misuses, and potential misuses of the SBBO Site.
Communicate with you – This includes answering your course and platform questions, notifying you of course and SBBO Site maintenance and updates, marketing to you about course offerings, programs, news, and related products and services of SBBO or SBBO affiliates, and as permitted under applicable law, sending you communications about products or services of selected business partners that may be of interest to you.
Support scientific research including, for example, in the areas of cognitive science and education – This includes collaborating to enable and conduct research about how learners access and master course materials online, with the goal of improving course outcomes.
Track SBBO Site usage against goals and mission – This includes performing analytics to evaluate access to and performance in courses and course-related products and services and to report aggregate usage information (not Personal Information) to business partners and external audiences.
Exercise, enforce, and comply with legal rights and obligations – This includes responding to subpoenas, court orders, or other legal process; and investigating, preventing, or taking action regarding illegal activities, suspected fraud, security or technical issues, or to protect the rights, property, or safety of SBBO, Members, or others, and as otherwise required by applicable law.
SBBO or a Member may also seek your consent for additional uses of information, including Personal Information, and will use it only for the purpose described to you. All use of Personal Information is subject to applicable law.
HOW YOUR INFORMATION IS SHARED SBBO and Members share information, including Personal Information, with third parties for the following purposes:
With other learners in courses that you take and with other visitors to the SBBO Site, to create an interactive learning environment, support class participation, and share course information – This includes sharing comments, coursework, or other information or content that you submit to a portion of the SBBO Site designed for viewing by other class members or for public communication. This also includes providing opportunities for you to communicate with other users who may have similar interests or educational goals, for instance, recommending specific study partners or connecting potential student mentees and mentors. In such cases, SBBO and each Member that offers a course in which you enrolled may use all information collected about you to determine who might be interested in communicating with you but will only provide others your username (for clarity, no disclosure of your real name or email address).
With employers, government programs, institutions, or other enterprises that sponsor your enrollment in a course for training or other educational purposes – If an entity pays for or otherwise sponsors your Verified Certificate or course participation, SBBO will share information with the entity as needed to confirm your enrollment, participation, progress, and completion status in that course.
SBBO or a Member may also seek your consent for additional disclosures of information, including Personal Information, and will share it only as described to you. In addition, SBBO or a Member may share with the public and with third parties, including but not limited to researchers and business partners, information and Personal Information that is de-identified or aggregated in a manner that does not personally identify you.
HOW TO MANAGE YOUR PERSONAL INFORMATION You can manage your Personal Information through learner features on the SBBO Site and requests to the SBBO learner support team. If your request involves information controlled by a Member, SBBO learner support will notify and coordinate with the appropriate Member to address your request. SBBO will provide support to the extent required by applicable law (for example, learners in the European Union) and more broadly when possible, as a courtesy in our sole discretion. SBBO will notify you if SBBO is unable to meet a request that is not legally required. Similarly, Members will only be obligated to comply with requests to the extent legally required but may choose to comply with other requests in their sole discretion.
Access and correct your Personal Information Much of your Personal Information is available in your SBBO account. Your name, email address, and other identifiable profile information is editable through the profile settings in your SBBO account except as noted below. Your account dashboard lists all current and archived courses in which you have enrolled and includes links to any Verified Certificates you may have earned. The dashboard also contains copies of your answers and other participation and performance in courses. Please contact SBBO learner support to access and update this or other information. If your request involves information controlled by a Member, SBBO learner support will notify the appropriate Member of your request.
Exceptions: Usernames cannot ever be changed. This is an SBBO system restriction. Because usernames identify you in courses and elsewhere on the SBBO Site, SBBO encourages you to use discretion in choosing your username. If you want to protect your identity, do not use your real name or a name identifiable to you as your username.
SBBO does not track or index every time or every place on the SBBO Site when or where a learner may volunteer Personal Information, so neither SBBO nor Members will be able to help you locate or manage all such instances. SBBO encourages you to use discretion before volunteering Personal Information on the SBBO Site.
Restrict or object to the processing of Personal Information If you want to manage emails and other communications to you, you may update your preferences in your SBBO account dashboard, follow the steps described in links at the bottom of email messages, or contact SBBO learner support. You may object to, or request that SBBO or a Member stop, its use of your Personal Information for other purposes by contacting the SBBO learner support team. If your request involves information controlled by a Member, SBBO learner support will notify the appropriate Member of your request. Please note that if you choose to restrict SBBO ’s or a Member’s ability to process Personal Information, and the processing is otherwise required to provide you with various services and products offered on the SBBO Site, you may not be able to establish an SBBO user account or enroll for a course, and SBBO or a Member may not be able to provide you with those services or products.
Delete account and Personal Information To request deletion of your SBBO account and Personal Information, you should click the button labeled “Delete my account” in your SBBO account settings. Because deletion on the SBBO system is a permanent action and cannot be reversed, SBBO may ask you to complete a process that aims to confirm your authority to manage the SBBO account affected by your request.
With respect to your SBBO account, SBBO will permanently:
deactivate your SBBO account,
remove the active profile,
retire your username, and
remove you from SBBO email lists.
With respect to your Personal Information, SBBO will permanently delete your SBBO account profile Personal Information from the SBBO Site.
As noted above, to the extent that SBBO associates the information that SBBO collects directly or indirectly with an individual (for example, you), the association is based on Personal Information in your SBBO account profile. By erasing the Personal Information in your SBBO account profile, the remaining information about your activity on the SBBO Site will no longer be associated with you, except as noted below.
These changes will be applied to data stores that are used for operation of the SBBO Site including course administration by Members. If you enrolled in any courses on the SBBO Site, the SBBO learner support team will share your request with the Members that offered those courses.
Exceptions: Deletion will not apply to historical activity logs or archives unless and until these logs and data naturally “age-off” the SBBO system. SBBO does not track or index every time or every place on the SBBO Site when or where a learner may volunteer Personal Information, so neither SBBO nor Members will be able to help you locate or manage all such instances. SBBO encourages you to use discretion before voluntarily sharing your Personal Information on the SBBO Site.
SBBO will archive course data (in a manner and to the extent permitted under applicable law) to serve its mission to enable scientific research on cognitive science and education. These archives are used to produce encrypted research data packages for Members, and Personal Information may not be deleted from research data packages retained by Members.
SBBO and each applicable Member cannot always delete records of past interactions and transactions. For example, records relating to previous purchases on the SBBO Site must be retained for financial reporting, audit, and compliance reasons.
SBBO and each Member will retain and use Personal Information as necessary to comply with its legal obligations, resolve disputes, enforce its agreements, and as otherwise permitted by applicable law.
Data retention SBBO will retain your Personal Information for as long as your account is active or as needed to provide you with services; to maintain a record of your transactions for financial reporting, audit, and compliance purposes; and to comply with SBBO ’s legal obligations, resolve disputes, enforce its agreements, and as otherwise permitted by applicable law. If you enroll in a Member’s course, such Member will also retain your Personal Information for as long as needed to provide you with services; to maintain a record of your transactions for financial reporting, audit, and compliance purposes; and to comply with its legal obligations, resolve disputes, enforce its agreements, and as otherwise permitted by applicable law. Upon your request that SBBO deactivate your account and delete your information, SBBO will follow the process described above, including without limitation archiving your course data (in a manner and to the extent permitted under applicable law) to serve its mission to enable scientific research on cognitive science and education. These archives will be used to produce encrypted research data packages for Members, and each such Member may also keep and use course data for scientific research.
STORAGE & SECURITY SBBO stores information, including Personal Information, on its own servers and also on servers of companies that SBBO hires to provide services. Each Member also stores information, including Personal Information, on its own servers and/or on servers of companies that the Member hires to provide services. In each case, information may be stored in the United States and in other countries where SBBO or a Member operates, and in countries where SBBO and each Member’s respective service providers operate. If you are in the European Union, Switzerland, or other regions with laws governing data collection and use, you acknowledge that SBBO and each Member may transfer, process and store your personal information in the United States and other countries, the privacy laws of which may be considered less strict than those of your region.
SBBO controls its own copy of information collected through the SBBO Site and has an information security program designed to protect information in its possession or control. This is done through a variety of privacy and security policies, processes, and procedures. SBBO uses administrative, physical, and technical safeguards that reasonably and appropriately protect the confidentiality, integrity, and availability of the information that it collects, receives, stores, or transmits. Nonetheless, no method of transmission over the Internet, or method of electronic storage, is 100% secure; and therefore, SBBO cannot guarantee its absolute security. While SBBO works hard to ensure the integrity and security of its network and systems, SBBO cannot guarantee that its security measures will prevent “hackers” or other unauthorized persons from illegally accessing or obtaining information.
If SBBO learns of a security breach involving its copy of your Personal Information, SBBO may attempt to notify you electronically so that you may take appropriate protective steps. By using the SBBO Site or providing Personal Information to SBBO, you agree that SBBO can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the SBBO Site. If a security systems breach occurs, SBBO may post a notice on the SBBO homepage (www.sbboeducation.org) or elsewhere on the SBBO Site and may send an email to you at the email address associated with your SBBO account. Depending on where you are located, you may have a legal right to receive notice of a security breach, involving your Personal Information, in writing.
If a Member learns of a security breach involving that Member’s copy of your Personal Information, the Member may attempt to notify you electronically so that you may take appropriate protective steps. By enrolling in a Member’s course on the SBBO Site or providing Personal Information to the Member, you agree that the Member can communicate with you electronically regarding security, privacy, and administrative issues relating to your course enrollment and participation. If a security systems breach occurs, the affected Member may post a notice on the SBBO site and/or send an email to you at the email address associated with your enrollment in the Member’s course on the SBBO Site. Depending on where you are located, you may have a legal right to receive notice of a security breach, involving your Personal Information, in writing.
CONTACT INFORMATION If you have privacy concerns, have disclosed data you would prefer to keep private, or would like to access the Personal Information that SBBO maintains about you, please contact us at email@example.com. You may also write to us at: ATTN: PRIVACY, SBBO Inc., 1550 Katy Gap Rd, Ste. 2906, Katy TX 77494 USA. If your request involves a Member, SBBO will notify the appropriate Member of your request.
GLOSSARY Cookies are unique identifiers usually in the form of small data files placed on your device that send certain information about your activity on the SBBO Site or in an email communication back to SBBO or the authorized third party that served the cookie. SBBO or third parties may also use Flash cookies.
SBBO Site consists of all content and pages located within the SBBO .org web domain and all SBBO mobile applications.
Member is each educational institution or other leading global institution or entity that provides courses through the SBBO Site.
Personal Information is information that specifically identifies you or that, when combined with other information, could be used to identify you.
Tracking Technologies are web beacons, clear gifs, pixels, and similar technologies that are also unique identifiers used to track your online activity but are not stored on your device. Verified Certificate is a virtual certificate that shows that you have successfully completed your SBBO course or program and verified your identity using your webcam and your acceptable form of photo ID.
Effective Date: October 25, 2018