FluencyLink™ Privacy Policy
This Privacy Policy is intended to inform you about the types of information gathered by Cheng & Tsui (“we” or “us”) when you use the FluencyLink™ application, how we use and safeguard that information, and the degree to which you may control the maintenance and sharing of your information.
The FluencyLink service is provided exclusively by:
Cheng & Tsui Co., Inc.
101 Federal St., Suite 1900, Boston, MA 02110 USA
1-617-988-2400
If you, your parent, or legal guardian do not agree with any part of this Privacy Policy, then you may not use or access FluencyLink.
We may update this Privacy Policy from time to time. If you are a registered FluencyLink user, we may attempt to inform you of any material changes by notification to the email address you have provided as part of your registration information. Otherwise, you may view the most recent Privacy Policy within the FluencyLink application or on our website cheng-tsui.com. Your continued use of FluencyLink after a revised version of this Privacy Policy is posted will be considered your acceptance of that revision.
Cheng & Tsui does not knowingly offer services through the FluencyLink application to anyone under the age of 13 years. If you are under 13 years of age, you may use FluencyLink only with the consent and involvement of a parent or guardian.
In case of self-registration by the child below 13 years, the parent/guardian should agree to the Privacy Policy while registering the user so that the registered user account can be activated. For children below 13 years, the parent or guardian's email address captured during child registration by the School is used to notify parents about their child's access to the application. In that initial notice, parents are provided a link to this privacy policy and will be able to give consent for their child to use the application. Only after the parent's consent is their child’s account activated.
Parents and legal guardians have the right to:
● Review any personal information we have collected from their child
● Request the deletion of their child’s personal information
● Refuse to permit further collection or use of their child’s personal information
To exercise these rights, please contact us at https://www.cheng-tsui.com/contact or by emailing support@cheng-tsui.com, and we will fulfill your request within ten business days of confirming your identity.
We collect the following information: name, username / email address. We may also collect certain additional information passively, such as the date and time of visit, time spent on the content, Device ID, the type of browser used (e.g., Chrome, Firefox, Edge), the type of operating system used (e.g., Windows 10, Mac OS) and the ISP from which the user receives Internet access. These different types of information may be combined with one another.
Our collection and use of information complies with the requirements of the Children’s Online Privacy Protection Act (“COPPA”), Protection of Pupil Rights Amendment (“PPRA”), and the Family Educational Rights and Privacy Act (“FERPA”).
COPPA permits an educational institution to provide required consents regarding the collection and use of personal information of students who are under the age of 13. Where an educational institution is the subscriber to FluencyLink, we collect and use student information according to this form of COPPA consent. We share this Privacy Policy with the institution to ensure that it may be assured that our practices comply with COPPA.
FERPA permits an educational institution to provide educational records to service providers without requiring the institution to obtain specific parental consent. In this event, the service provider acts as a type of “school official” by performing services that would otherwise be performed by employees of the educational institution. We fulfill FERPA requirements for qualifying as a “school official” by giving the institution direct control concerning the use and maintenance of the education records at issue and not disclosing or using the information contained in those records other than to provide FluencyLink to the institution. We comply with FERPA by relying on this form of consent.
PPRA requires that schools obtain written consent from parents before minor students are required to participate in any U.S. Department of Education-funded survey, analysis, or evaluation that reveals information concerning the following areas:
We comply with PPRA by requiring institutions to secure and provide us with copies of all such written consents when applicable.
Any of the information we collect, if used, may be used only in the following ways:
● To provide an interactive online learning experience
● To provide content that students and teachers are using for their area of study and instruction, as well as content that users have purchased directly
● To provide controlled interaction with teachers and colleagues
● We may use non-personal information such as information about the pages visited to improve the content and focus area of study, or to analyze site usage and the popularity of certain pages of the content
We use cookies, but we do not pass or capture any personal information apart from username. We do not use cookies (or other non-consensual methods) to acquire contact information about the user or other users of the computer. We do not engage in behavioral targeting of advertisements. We may passively collect information on site usage patterns or through content that users, including child users, access on our application.
We understand how highly our users value the privacy and security of their personally identifiable information. We do not share, rent, or sell information with third parties.
We will disclose information collected from and about you to the following entities for the following purposes: (1) to our related companies, trusted third party service providers and suppliers, to enable them to fulfill a product or service request or to perform a business, professional or technical support function for us; (2) as necessary if we believe that there has been a violation of our Terms of Use or of our rights or the rights of any third party; and (3) to respond to judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law.
We will ensure that any third-party organizations with whom we share student data will have privacy policies that are consistent with this policy.
FluencyLink may contain links to third party websites. These sites may have their own terms of use and privacy policies which do not apply to Cheng & Tsui or to FluencyLink.
We take steps to protect the information provided or captured against unauthorized access and use. The security and confidentiality of the information is extremely important to us.
We use robust security measures to protect user information from loss, misuse and alteration. We use industry-standard practices such as encrypted communications, firewalls and password protection systems to safeguard the confidentiality of your personal information.
Identifiable data will only be kept for as long as necessary to deliver services, after which it will be deleted or de-identified. In the event of an acquisition we will require the acquiring company to act in accordance with this policy. Alternatively, we may allow users the choice to send information to the future entity or have their information deleted.
If you have any questions or concerns about this Privacy Policy, please contact us at https://www.cheng-tsui.com/contact or by emailing support@cheng-tsui.com.