European Economic Area Privacy Policy

Privacy Policy – European Economic Area – Follett School Solutions

Effective date: March 21, 2019
Last updated date: September 1, 2021

 
INTRODUCTION:

Follett School Solutions, LLC strives to ensure the security and privacy of our customer’s data. To that end, we’re providing this overview of our updated privacy policy. It's more user-friendly and addresses the European Union (EU) General Data Protection Regulation (GDPR). We also appreciate that our customers have requirements under GDPR that are directly impacted by their use of Follett’s products and services. We’re committed to helping our customers stay in compliance with GDPR and their local requirements, and as part of our commitment, we have updated our Privacy Policy applicable to data subjects in the European Economic Area.

Privacy Policy:

Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you. This policy is intended to help you understand:

  1. Information we collect about you and how we collect it
  2. How we use your information
  3. How we disclose your information
  4. We may transfer your information outside the European Economic Area
  5. How long we retain your information
  6. Your choices about how we use and disclose your information
  7. Your rights regarding your personal data
  8. How we secure your information
  9. Your use of third-party websites
  10. Our Website is not intended for children under the age of 16
  11. Our Data Controller Contact Information

Follett School Solutions, and its wholly and majority-owned entities, are committed to protecting your privacy. References in this policy to “Follett School Solutions”, “we”, “us”, and “our” are references to the entity responsible for the processing of your personal data, which generally is the entity that obtains your personal data in the respective case. In the EU, this entity is also referred to as the data controller.

This policy describes the types of information Follett School Solutions may collect from you or that you may provide when you visit our websites, including but not limited to www.follettlearning.com, www.titlewave.com, www.follettcommunity.com, or any other of our websites where this policy is posted (collectively the "Website").  This policy also describes our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy does not apply to information collected by us offline or through any other means, including on any other website operated by a third party, or through any application or content (including advertising) that may link to or be accessible from the Website.

Follett School Solutions provides this policy to explain the type of information we collect, and to inform you of the specific practices and guidelines that secure and protect the confidentiality of your personal data. Please read this policy carefully. If any term in this policy is unacceptable to you, please do not use the Website or provide any personal data. This policy may change from time to time (see Revisions to Our Privacy Policy). 

1. Information we collect about you and how we collect it

We collect several types of information from and about users of our Website, which may include information defined as personal data or personally identifiable information under applicable law (“personal data”). For example, we may collect any of the following information about you:

  • Name
  • Address
  • Email address
  • Phone number
  • User ID
  • Employee ID
  • Student ID
  • IP address
  • Payment processing and order processing information, including credit card and financial account information
  • Course information (which we may receive from your educational institution)

1A. Information you give to us
  
The information you give to us on our Website may include:

  • Information that you provide by filling in forms on our Website.
    • This includes information provided when you purchase goods or services through us or sign up for our newsletters and other types of information material;
    • Information we receive when we process and respond to your inquiries related to products, customer service and technical support; and
    • Information obtained when you provide feedback on our Website.
  • Records and copies of your correspondence with us (including email addresses).
  • Additional personal information including resumes and other non-sensitive information, when applying for a position at Follett School Solutions.

1B. Information we collect about you through our Website

As with many other websites, as you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

  • Details of your visits to our Website, including resources that you access and use on our Website, traffic data, location data, logs, language, date and time of access, frequency and other communication data.
  • Information about your computer, mobile device and internet connection, including your IP address, operating system, host domain and browser type.
  • Details of referring websites (URL).

The information we collect automatically is statistical data that helps us improve our Website and deliver a better and more personalized service, enabling us to:

  • Determine web site traffic patterns.
  • Count web visits.
  • Determine traffic sources so we can measure and improve the performance and security of our site.
  • Help us to know which pages and content are the most and least popular.
  • Observe site search patterns to provide more intuitive navigation cues.
  • Determine user frequency and recency.

Third-party ad servers and analytics providers

Follett School Solutions works with third party network advertisers, ad agencies, analytics service providers and other vendors to serve third party advertisements on and through the Website, to provide us with information regarding traffic on the Website, including the pages viewed and the actions users take when visiting the Website; to serve our advertisements on other websites, within mobile Apps, and elsewhere online; and to provide us with information regarding the use of the Website and the effectiveness of our advertisements. For example, if you click one of our advertisements, our service provider(s) may be able to tell us the advertisement you clicked on and where you were viewing the advertisement; likewise, if you click on an ad you see on our Website, our service provider(s) may be able to tell which page you were visiting on our Website and pass that information to the advertiser. The advertisements you see may be served by one or more third parties, who may use information about your activities on the Website, and other websites and services, to provide you targeted advertising based upon your interests.

These third-party service providers may set and access their own tracking technologies on your device (including cookies and web beacons) and may otherwise collect or have access to information about you including personal data.  These third parties may collect information about you across sites and over time. Cookies and web beacons, including those set by third-party network advertisers, may be used to, among other things, serve you targeted advertisements, prevent you from seeing the same advertisements too many times and to conduct research regarding the usefulness of certain advertisements to you.

While we may use a variety of service providers to perform advertising services, some of these companies are members of the Network Advertising Initiative ("NAI") or the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising.

You may want to visit http://www.networkadvertising.org/managing/opt_out.asp, which provides information regarding targeted advertising and the "opt-out" procedures of NAI members. You may also want to visit http://www.aboutads.info/choices/, which provides information regarding targeted advertising and offers an "opt-out" by participating companies in the DAA Self-Regulatory Program. You may also opt out of tracking and receiving targeted advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at www.aboutads.info/appchoices.  Please note opting out through these mechanisms does not opt you out of being served advertising, you will continue to receive generic ads while visiting the Website and elsewhere online.

Follett School Solutions participates in the Interactive Advertising Bureau (IAB) Europe Transparency & Consent Framework and complies with its Specifications and Policies.  Follett School Solutions uses the Consent Management Platform with the identification number 28.  For additional information you may visit https://iabeurope.eu/tcf-2-0/.

This Website uses web analytics services provided by third parties to help us evaluate your use of the Website, compiling reports on Website activity for Website operators and providing other services relating to Website activity and internet usage. The information generated by the analytics service about your use of the Website may be transmitted to and stored by the third party on servers in the United States.

To opt-out from being tracked by Google Analytics download and install the Google Analytics Opt-out Browser Add-on for your current web browser, visit https://tools.google.com/dlpage/gaoptout?hl=en-GB.

To opt-out from being tracked by Adobe Analytics, visit https://www.adobe.com/privacy/opt-out.html.

Cookies, web beacons and other technologies used on this Website  

Cookies. A cookie is a data file, which we place on a device when it is used to visit the Website or otherwise access our online content. Cookies may be used for many purposes, including remembering you and your preferences, tracking your visits to our web pages, and for displaying offers related to your prior activity on the Website.  

Our Website uses single-session (temporary) and multi-session (persistent) cookies.  Temporary cookies last only as long as your web browser is open, and are used for technical purposes such as enabling better navigation on our Website. Once you close your browser, the cookie disappears.  Persistent cookies are stored on your computer for longer periods and are used for purposes including storing your preferences and settings, sign-in and authentication, and storing information you provide (such as when you add products to a shopping cart on the Website).

We may also use technologies such as cookies to provide you with enhanced online display advertising tailored to your interests.  For additional information on the type of information collected by cookies, including how to opt out of receiving interest-based advertising, please see the “Third party ad servers and analytics providers” section of this Policy.  

A Flash cookie is a data file placed on a device via the Adobe Flash plugin that may be built-in to or downloaded by you to your device. Flash cookies may be used for various purposes, including enabling a Flash feature and remembering your preferences.
If you want to disable the use of cookies or remove them at any time from your computer, you can disable or delete them using your browser (consult your browser's "Help" menu to learn how to delete cookies).  If you choose to disable cookies or to adjust your Flash privacy settings on your device, some features of the Website may not function properly. 

To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.

Web Beacons. Small graphic images or other web programming code called web beacons (also known as "1x1 GIFs" or "clear GIFs") may be included in our web pages and e-mail messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Website, to monitor how users navigate the Website, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Website, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third party service provider is active only while you are connected to the Services, and is deactivated or deleted thereafter.

2. How we use your information

Below please learn how we process information collected about you (including personal data) as well as the corresponding legal basis. We may process your information where the processing is:

  • Necessary for entering into or the performance of a contract with you. For example:
    • To carry out our obligations arising from any contracts entered into between you and us, your organization and us, or between your employer and us, and to provide you with the information, products, and services that you request from us.
  • Necessary for us to comply with a legal obligation.
  • Necessary for the legitimate interests pursued by a third party or us (to the extent it does not infringe on any data subject’s fundamental rights and freedoms). For example:
    • To improve the Website content so it is presented in the most effective manner for you and for your computer.
    • To allow you to participate in interactive features of our service (when you choose to do so).
    • To keep our site safe and secure.
    • To provide you with technical support and to improve our Website and services.
    • To provide you with information that you have requested and respond to your inquiries.
    • To notify you about changes to our service or our Website.
    • If you are an existing customer, to communicate (including by email and/or SMS) with you to provide information about goods and services similar to those that were the subject of a previous sale or negotiations of a sale to you.
    • If you contact us regarding applying for a position, we may use the information for recruiting, talent management and employment purposes (recording, examination, assessment, selection, and conclusion of an employment offer).
    • Subject to applicable law and regulations, in the event of a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, to transfer, sell, or assign to third parties information concerning your relationship with us, including, without limitation, personal data that you provide and other information concerning your relationship with us.
  • Pursuant to valid consent provided by you, to provide you with information about goods or services we feel may interest you.  If you do not want us to use your data in this way, simply do not opt-in when we ask for your consent on the relevant forms where we collect your data. For any other purpose where you have provided valid consent where it is legally required.

3. How we disclose your information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. Subject to applicable law and regulations, we may disclose personal data that we collect, or you provide, as described in this policy:

  • To any member of Follett School Solutions for the foregoing described purposes.
  • To contractors, service providers, and other third parties we use to support our business or in connection with the administration and support of the activities noted above, and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them (e.g., database hosting providers, managed service providers, developers, consultants).
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Follett School Solutions' assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by Follett School Solutions about our Website users is among the assets transferred.
  • To fulfill the purpose for which you provide it. For example, if you ask us to communicate information to a third party dealer or installer who is installing or serving your product.
  • For any other purpose disclosed by us when you provide your information or with your consent when required by applicable law and regulations.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements, including for billing and collection purposes; or to protect the rights, property, or safety of Follett School Solutions, our employees, our customers, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

4. We may transfer your information outside the European Economic Area

The data that we collect from you will be transferred to, and stored at, a destination outside the European Economic Area ("EEA").  It may also be processed by staff operating outside the EEA who work for us or other entities acting as data processors processing data on our behalf. This includes staff engaged in, among other things, the fulfillment of your request or order and the provision of support services. Follett School Solutions has implemented international data transfer agreements on the basis of EU Standard Contractual Clauses in order to provide appropriate and suitable safeguards for personal data being transferred to countries outside the EEA where an adequate level of protection is not already guaranteed. To request a copy contact privacy@follett.com .  We will take all steps reasonably necessary to ensure that your data is treated securely and subject to appropriate safeguards in accordance with this policy and applicable laws and regulation.

5. How long we retain your information

Unless otherwise required by law, Follett School Solutions will erase personal data when it is no longer necessary in relation to the purposes for which it was collected or otherwise processed; when you withdraw your consent (where lawfulness of processing was based on your consent) and there is no other legal basis for the processing; when you object to the processing and there are no overriding legitimate grounds for the processing; when your personal data has been unlawfully processed; and when it is necessary to comply with legal obligations.

6. Your choices about how we use and disclose your information

We strive to provide you with choices regarding the personal data you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Cookie settings. You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Do Not Track. Our system may not respond to Do Not Track requests or headers from some or all browsers.
  • Account Information and Communication Preferences.  You may be able to review and update your account information through the Website, including certain personal data and your communications preferences. You may opt out of receiving marketing e-mails from us by following the opt-out instructions provided to you in those e-mails. Please note that we reserve the right to send you certain communications relating to your account or use of the Website (for example, order confirmations, product service experience or other transactions) and these transactional messages may be unaffected if you opt-out from marketing communications.
  • Sweepstakes, Contests and Promotions. If you choose to enter  sweepstakes, contests or promotions, information such as your name and shipping address, may be disclosed to third parties or the public in connection with the administration of such promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the promotion’s official rules.

7. Your rights regarding your personal data

At any time you may exercise certain rights you may have under applicable law and regulation, including the following rights:

  • The right to request access to your personal data, which includes the right to obtain confirmation from us as to whether or not personal data concerning you is being processed, and where that is the case, access to the personal data and information related to how it is processed.
  • The right to rectification or erasure of your personal data, which includes the right to have incomplete personal data completed, including by means of providing a supplementary statement, and certain rights to request us to erase your personal data without undue delay.
  • The right to restrict or object to processing concerning your personal data, which includes restricting us from continuing to process your personal data under certain circumstances (e.g., where you contest the accuracy of your personal data, processing is unlawful, your personal data is no longer needed for the purposes of processing, or you have otherwise objected to processing related to automated individual decision-making).
  • The right to data portability, which includes certain rights to have your personal data transmitted from us to another controller.
  • Where data processing is based on your consent, the right to withdraw consent at any time.
  • The right to lodge a complaint with a supervisory authority.

Any requests related to the above rights may be made by sending an email to privacy@follett.com . 

8. How we secure your information

We take reasonable physical, administrative, and technical measures to secure the information we collect from and about our customers and Website visitors. However, no method of electronic transmission or method of electronic storage is 100% secure. Therefore, we cannot guarantee the security of any information you submit.  When you enter sensitive information (such as credit card information) on our forms, we tokenize or encrypt that information.

9. Your use of third-party websites

Our Website may contain links or references to other websites outside of our control. Please be aware that this policy does not apply to these websites. Follett School Solutions encourages you to read the privacy statements and terms and conditions of linked or referenced websites you visit. These third-party websites may send their own cookies and other tracking technologies to you, log your IP address, and otherwise collect data or solicit personal data.  FOLLETT SCHOOL SOLUTIONS DOES NOT CONTROL AND IS NOT RESPONSIBLE FOR WHAT THIRD PARTIES DO IN CONNECTION WITH THEIR WEBSITES, OR HOW THEY HANDLE YOUR PERSONAL DATA.  PLEASE EXERCISE CAUTION AND CONSULT THE PRIVACY POLICIES POSTED ON EACH THIRD-PARTY WEBSITE FOR FURTHER INFORMATION. 

10. Our website is not intended for children under the age of 16

Our Website is not intended for children under 16 years of age, and Follett School Solutions does not knowingly collect or use any personal data from children under the age of 16.  No one under the age of 16 may provide any information to or on the Website. If we learn we have collected or received personal data from a child under the age of 16, we will delete that information. If you believe we might have any information from or about a child under the age of 16, please contact us at privacy@follett.com.

11. Our contact information

If you have any questions or comments about these Terms of Use or our Services, please contact us by email at privacy@follett.com  or telephone at 800-350-6418. You also may write to us at Follett School Solutions, Attn: Privacy, 1340 Ridgeview Dr., McHenry, IL 60050. For California residents to exercise your consumer rights by clicking here. For EU citizens to exercise your data subject rights by clicking here. Questions or comments submitted through other means, such as Wall posts, may not be received or addressed.