Last modified: November 21, 2023
This Privacy Statement aims to clarify how NS4ed, LLC, operating as Pathway2Careers (P2C), safeguards Customer Data – including student educational records and personal information. Our K-12 or higher education institutional customer provides this data for processing when the staff, parents/guardians, and students use mobile services. It also outlines how Pathway2Careers gathers and secures Personal Information when you access our publicly available products or websites, such as https://p2c.org (our “Websites”), collectively referred to as “P2C Products”. The use of the collected information may vary depending on our relationship with you and our contractual commitments to our customers. We have outlined below the potential relationships we may have with you. Whenever “us,” “we,” “our,” “Pathway2Careers”, “P2C”, or “NS4ed” is mentioned in the Privacy Statement, it refers to NS4ed, LLC.
By accessing or using the Services or by otherwise affirmatively stating your desire to use the Services, you signify that you have read, understood, and agree to be bound by this Agreement and to the collection and use of your information as set forth in this Privacy Policy. Otherwise, you may not use the Services. Because our Services change relatively often, the terms in this Agreement and our Privacy Policy may change too. We will notify you via email before any material changes to the terms. Upon making changes, we will update the “Effective Date” found at the top of this page. Your continued use of the Services after any changes constitutes your acceptance of the new terms.
P2C’s Services may be provided directly to the end user or through a third party (school or sponsor). Please note that third parties may have additional terms that govern end-user use of services outside of these Terms, of which P2C has no claim or stakehold.
Client and user trust is paramount to P2C’s values. As a data processor, P2C receives customer/student data from verified users, including staff, faculty, parents/guardians, and students. P2C stores this data on behalf of the customer, adhering to strict controls set through contractual obligations such as data privacy contracts or privacy impact assessments. The customer governs and limits access to these products and services.
Depending on the product or service, Customers may provide student data or employee data. This mix of data supplied is based on the P2C services or products selected by the Customer.
Protecting user data is a top priority for P2C. Per our Privacy Statement, student data is considered equivalent to customer data. Thus, school districts, schools, or higher education institutions own and control all customer data. If applicable laws require it, our customers are responsible for obtaining consent for processing customer data by P2C. P2C respects and adheres to the guidelines set forth by FERPA, the Family Educational Rights and Privacy Act, a federal law regulating information and records access in education. Per FERPA regulations, our customers classify P2C as a “school official” with a legitimate educational purpose for customer data processing. By licensing P2C Products, our customers purchase specific professional services to provide, maintain, and support student data for legitimate educational purposes. P2C strictly processes student data only to provide access to P2C Products and professional services that our customers (school or school districts) have contracted with us to provide. We process such data based on our customer’s instructions and terms specified in our contract and data privacy agreements. P2C does not own or control Customer Data. Therefore, any request for access, review, correction, or deletion must come directly from the customer.
P2C will share personal information in very limited circumstances, as described below. We do not rent or sell information for marketing purposes, and we will never share or sell Student Data with third parties for marketing purposes.
In the course of a visit to p2c.org and any of our sub-domains, we collect a variety of information directly from visitors and customers. Anyone can visit our site without entering any personal information. On certain pages, users may be asked for personal information to provide a service or carry out a transaction that they have requested. The personal information we collect from a user in any of these circumstances may include:
We use Google Analytics, Google AdWords Conversion tracker, and other Google services that place cookies on browsers visiting our websites. These cookies are set and read by Google, and they are used to increase the effectiveness of our websites for our visitors. To opt out of Google tracking, please visit this page.
We may use Google AdWords remarketing to market our sites across the web, which places a cookie on browsers visiting our sites. Google reads these cookies and may serve ads on other sites based on pages and products viewed on our sites. You may opt out of this advertising program by visiting Google’s opt-out page. If you are concerned about 3rd party cookies served by other networks, you should also visit the Network Advertising Initiative opt-out page.
We use the Zoho marketing platform and CRM to collect insights on user behavior and manage our content marketing to subscribers and contacts who provide us with their contact information for communications.
Email addresses supplied for account creation or newsletter subscriptions are securely stored on our servers. Email addresses provided for communication or inquiries are only used for that purpose and may be added to our email marketing list, with an opt-out option available.
Emails provided for newsletters and marketing communications are used to inform subscribers of sales, events, promotions, and other activities that may be of interest. P2C does not sell, rent, lease, or distribute email addresses to third parties for any reason.
With permission, we may use personal information gathered through our website to inform customers of P2C’s products and services. We always provide an opt-out option when collecting information that may be used to contact subscribers. Each email communication includes an unsubscribe link, and we promptly remove unsubscribed users from our relevant lists.
Transaction data (metadata) is generated using P2C products and services. P2C retains control and ownership of this proprietary data found in application access and end-user monitoring logs, network access logs, web usage tools, communication logs, identity and access management logs, and database management system tables. This data is used to determine the health of P2C systems, for troubleshooting, in incident investigations, and for security information and event management.
Transaction Data is stored and maintained separately from Customer and Collected Data and permanently removed on a cycle basis to minimize data, regardless of whether it contains personal data. Except for Service Providers acting as data subprocessors supporting our applications who are granted secure access to Transaction Data, P2C does not share, disclose, nor sell this information.
P2C works with data subprocessors to support the operability of our products. These vendors are held to privacy agreements to ensure data is properly removed as required by law as they aid our efforts to provide Customers with the best products and services.
Under the Family Educational Rights and Privacy Act (FERPA), P2C acts as a “school official” with “legitimate educational interests” or the age of consent in relevant local jurisdictions unless a School has obtained parental consent for the student to use the Service. As we process and collect Student Data under a School’s guidance and authority, we rely on Schools to notify parents of their use of third-party service providers, including Pathway2Careers. Schools must then approve P2C’s collection of Student Data, as allowed by COPPA and other applicable data protection laws. If you suspect that we have unknowingly received information from a child without proper consent, please get in touch with us at hello@p2c.org, and we will remove the data immediately.
P2C maintains strict administrative, technical, and physical procedures to protect information stored on our servers, which are located in the United States. Access to information is limited (through user/password credentials and two-factor authentication) to those employees who require it to perform their job functions. We use industry-standard Secure Socket Layer (SSL) encryption technology to safeguard the account registration process and sign-up information.
P2C adheres to applicable data protection laws and our customer’s requirements by using Amazon Web Services that help us deliver our products and services and operate our business. Amazon RDS has built a robust system that provides data encryption at rest, data encryption in transit, access controls, network isolation, database firewall, database activity streams for internal protection, and compliance frameworks. To learn more about the extensive security measures, visit Amazon RDS Security.
Unauthorized disclosure: If there is any disclosure or access to any personally identifiable Student Data by an unauthorized party that compromises the security, confidentiality, or integrity of the Student Data, we will promptly notify the affected School(s) and will use reasonable efforts to cooperate with their investigation of the incident.
How we use your information depends on our relationship with you. We primarily provide our products to Academic Institutions, such as K-12 schools and higher education, that use our products to amplify teaching, elevate learning, provide professional development opportunities, and improve student outcomes.
If you are an end user of an Academic Institution or Company that uses our products, your institution determines how your personal information is used. This means that your institution’s privacy notice governs the use of your personal information. This privacy notice is intended to provide transparency related to our privacy practices only.
We have provided the following summary to help you understand what we do with the information we process through our Products and the relationship between our users and Products.
Pathway2Careers™ (This suite of solutions includes P2C Math, Career Explorer, Financial Literary, and Design Your Own Course Curricula)
Users: Educators and Students
Personal Information:
Usage Information: Within the platform, educators assign lessons, assessments, and career tools to students, and students submit responses to assigned work. Teachers can also post feedback on the work students review.
P2C Labor Market Navigator
Users: Administrators & Educators
Personal Information:
Usage Information: Teachers and Administrators can access local labor market information specific to their region and review their CTE gap analysis report comparing the school district data to the labor market.
Educate.NS4ed
Users: Administrators & Educators
Personal Information:
Usage Information: This application is designed to assist teachers with professional development by providing training and learning opportunities tailored to specific subjects, grade levels, or other classifications. Personal Information is processed within the application to present learning opportunities, track attendance, monitor progress toward a professional development plan, and schedule courses. Additionally, the application can generate completion certificates for teachers upon successful completion of courses.
Information processed while using our products, such as:
Information you submit when communicating or interacting with P2C:
We collect your information when you:
State laws (including California, Colorado, Connecticut, Nevada, Utah, Virginia, and West Virginia) require us to disclose the following information with respect to our privacy practices. If you are a resident of the states mentioned above, this section applies to you in addition to the rest of the Privacy Statement. Personal information does not include publicly available information or de-identified, aggregated, or anonymized information maintained in a form that is not capable of being associated with or linked to you. Additionally, this does not apply to information about our employees, contractors, or other personnel.
Categories of Personal Information P2C Collects and Purposes for Collection and Use
The types of personal information we collect depend on which Pathway2Careers product(s) and/or Websites you utilize but can include:
Depending on the Pathway2Careers product(s) and/or Websites you utilize, we may collect personal information through the following means:
P2C collects and uses personal information for various purposes, including the following:
P2C does not share personal information with third parties unless necessary for the above-listed purposes. P2C may disclose personal information to the following categories of third parties:
Residents of the aforementioned states have certain rights regarding their personal information under applicable data protection laws. However, please note that P2C may be unable to delete Customer Data when it acts as a data processor under legal agreements with the data controller (our customers).
Residents have the right to request access to the categories and specific pieces of personal information that we collect, use, and disclose. They also have the right to request the deletion of their personal information and to opt out of any sale of personal information that may occur.
To exercise these rights, residents can use our Pathway2Career Products or contact their respective educational institutions, which are licensed to use the applicable Pathway2Career Product(s).
Please keep in mind that the specific procedures for exercising these rights may vary depending on applicable laws and regulations.
For Collected Data where P2C is not acting as a data processor but collects personal information directly from a user, you may submit a request for a copy of the information collected about you in the last 12 months or request deletion of information by contacting us at hello@p2c.org.
P2C Websites provide links to third-party websites or resources, as detailed below. The information practices of those websites are not covered by this Privacy Statement or any other policies or terms applicable to the Pathway2Careers Products or Websites, but P2C still takes steps to protect students using our products. We recommend that you review any terms of use and privacy policies of any linked third-party website before providing any personal information.
Pathway2Careers (P2C) embeds CareerOneStop career videos through YouTube on the Home page, Career Details page, and digital lessons. And P2C Career Story videos through YouTube on the Career Details page and digital lessons.
The “rel=0” parameter has been added to the embed code to limit the recommended videos to the CareerOneStop video’s playlist. The YouTube player provides a link to YouTube, which should be managed by a school’s firewall.
CareerOneStop is sponsored by the U.S. Department of Labor Employment and Training Administration and is a proud partner of the American Job Center Network.
The P2C Career Story videos are managed on a YouTube channel that has the audience set to “made for kids.”
YouTube’s description of the “made for kids” setting (source: https://support.google.com/youtube/answer/9527654?hl=en&ref_topic=9689353&sjid=11884888054949907295-NA#zippy=%2Cif-you-set-a-video-or-live-stream-as-made-for-kids%2Cif-you-set-your-channel-as-made-for-kids):
What happens when your content is set as made for kids?
We limit data collection and use of made-for kids’ content to comply with the law. This means we need to restrict or disable certain features like comments, notifications, and others.
Most importantly, we don’t serve personalized ads on kids’ content, as required by the Children’s Online Privacy Protection Act (COPPA) and/or other applicable laws. Not serving personalized ads on kids’ content may result in a decrease in revenue for some creators who mark their content as made for kids. We recognize that this won’t be easy for some creators, but these are important steps to take to ensure compliance with COPPA and other applicable laws.
Pathway2Careers Self-Designation
We have designated P2C as child directed. This self-designation will ensure Google does not serve personalized ads on these sites or apps, and some features will be disabled in the embedded player.
If you have any questions about this Privacy Policy or the Service, we recommend contacting us by visiting our P2C User Guide and submitting a ticket.
Additionally, P2C can be reached:
By Email: hello@p2c.org
By Phone: 1-833-265-6312