Last modified: November 21, 2023
P2C’s Pledge to Your Privacy
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.
- We will collect, use, share, and retain Student PII only for purposes authorized by the educational institution/agency, teacher, or parent/student.
- We will disclose clearly in contracts or privacy policies, including, in a manner easy for institutions and parents to find and understand, what types of Student PII we collect, if any, and the purposes for which the information we maintain is used or shared with third parties.
- We will support access to and correction of Student PII by the student or their authorized parent, either by assisting the educational institution in meeting its requirements or when the information is collected directly from the student with student/parent consent.
- We will maintain a comprehensive security program that is reasonably designed to protect the security, confidentiality, and integrity of Student PII against risks – such as unauthorized access or use, or unintended or inappropriate disclosure – through the use of administrative technological, and physical safeguards appropriate to the sensitivity of the information.
- We will provide resources to support educational institutions/agencies, teachers, or parents/students to protect the security and privacy of Student PII while using the educational service.
- We will require that our vendors with whom Student PII is shared to deliver the educational service, if any, are obligated to follow these same commitments for the given Student PII.
- We will allow a successor entity to maintain the Student PII in the case of our merger or acquisition by another entity, provided the successor entity is subject to these commitments for the previously collected Student PII.
- We will incorporate privacy and security when developing or improving our educational products, tools, and services and comply with applicable laws.
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.
Collected Data from Websites
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:
- contact details, such as a user’s name, company/organization name, e-mail address, telephone and fax numbers, and physical address;
- information about the user’s company/organization and role;
- country of residence;
- email marketing preferences;
- information used to customize and facilitate the use of our websites;
- inquiries about and for our services;
- information that aids us in identifying the services that best meet visitors’ needs;
- event and service registration information;
- feedback from users about our websites and our products and services in general;
- the content of a testimonial, rating, review, comment, or other user-generated content that may be posted publicly on our sites. We also collect and securely store information about our customers from sources other than our own.
- Web Server Log Files – As is common with websites providing e-commerce services, a record of all visits to P2C’s site is stored on our web servers. These log files include data that is not associated with any visitor’s identity that is not used to associate with personally identifiable information provided by any visitors to our sites. Information collected in these logs includes details such as a visitor’s IP address, browser type, referring page, and time of visit. We also collect information about visits to our sites, including what pages are viewed, the number of bytes transferred, the links clicked, the materials accessed, and other actions taken within P2C’s sites/subdomains. We use the information collected in our server logs to analyze how visitors use our sites, improve our systems’ efficiency, and enhance the quality of the user experience on our sites. This data is useful in analyzing the performance of the hardware and software that run our sites and supporting site security analysis. P2C uses the Zoho CRM and marketing platform to securely retain data. All users have a “right to be forgotten” and may request so by calling our offices at 833.265.6312 or emailing firstname.lastname@example.org.
- Cookies – Many of the advanced functions available to users of our sites require the use of files called cookies, which store a small digital record of user preferences and recent activity on our visitors’ computers. While cookies are not required to browse our site, they are an integral part of the browsing. We may use session cookies to store elements of user profiles to ease movement around our site and other information useful in administering the session. We may also use this information to make our websites easier to use by eliminating the need for customers to enter the same information repeatedly or by customizing our site to their particular preferences or interests. Our sites also may contain electronic images known as tracking pixels that allow us to count the number of users who have visited those pages. We may include tracking pixels in promotional e-mail messages or newsletters to determine whether messages have been opened and acted upon.
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 – P2C values its customer’s privacy and takes measures to ensure their personal information is secure. When registering an account, we collect the email address and password provided by the customer. For added protection, passwords are encrypted and securely stored.
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 email@example.com, 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.
Privacy Details by Product
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
- First & Last Name
- Email Address
- Username & Password
- Academic Institution
- Submitted classwork
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
- No personal data is captured while using this product.
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.
Users: Administrators & Educators
- First & Last Name
- Email Address
- Username & Password
- Academic Institution
- Submitted classwork
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:
- Your interactions with other users, for example, teacher feedback
- How you use our products, such as the date and time of your visits
- We collect your information when you use our products
Information you submit when communicating or interacting with P2C:
- Contact information
- Email content
We collect your information when you:
- Request assistance from our help desk
- Provide feedback on our products
- Sign up for and attend a conference, webinar, or P2C-hosted event
- Participate in surveys
Information, including personal information, from and about your device, such as:
- Browser type, settings, and preferences
- Operating system
- Location information (e.g., state)
- Persistent identifiers
- Internet Protocol (IP) address
- Domain name
- Unique device identifiers
Additional Privacy Disclosures per State-Specific Privacy Laws
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:
- Primary identifying information (e.g., name, address, email, phone number)
- Demographic data (e.g., age, date of birth, gender)
- Device information and other unique identifiers (e.g., device ID, IP address, cookies)
- Network activity
- User-generated content, including student-generated content
Depending on the Pathway2Careers product(s) and/or Websites you utilize, we may collect personal information through the following means:
- Directly from you (e.g., upon creating an account)
- Automated data collection technologies (e.g., cookies, pixels)
- Other sources (e.g., data analytics providers)
P2C collects and uses personal information for various purposes, including the following:
- Administration of Pathway2Careers Products
- Improvement of Pathway2Careers Products
- Communications with you
- Legal obligations
- Security, fraud prevention, and troubleshooting
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:
- Service providers and partners. Our service providers help us provide services to our customers via our Pathway2Career Products. These service providers support activities such as data security, cloud hosting, information technology, customer support, usage and analytics, email delivery, application performance monitoring, error and crash reporting, and user identity and authentication. In addition, we engage in product partnerships and integrations that offer certain features to users as requested by our customers. Under data privacy agreements, these third parties may require access to your personal information.
- Administrative and legal reasons. We may share personal information with third parties based on a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to meet any applicable law, regulation, legal process, or enforceable governmental request; enforce applicable Terms of Service, including investigation of potential violations; detect, prevent, or otherwise address fraud, security or technical issues; or protect against harm to the rights, property or safety of Pathway2Careers, our users or the public as required or permitted by law.
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 firstname.lastname@example.org.
Links to Other Sites
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.
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.
- Governing Law: All matters relating to these Terms, and any dispute or claim arising therefrom or related thereto, shall be governed by and construed in accordance with the internal laws of the State of Tennessee without giving effect to any choice or conflict of law provision or rule.
- Forum: Any legal action or proceeding arising out of or relating to these Terms shall be instituted exclusively in the United States District Court for the District of Tennessee or the courts of the State of Tennessee covering east Tennessee, as appropriate.
- Waiver of Trial by Jury: To the extent permitted by law, you knowingly, voluntarily, unconditionally, and intentionally waive your right to a trial by jury in any action or legal proceeding arising out of or relating to our services.
- Waiver of Class Action: You agree that by accessing or using our services, you are waiving the right to participate in a class action. You further agree that you may bring claims against P2C arising out of or relating to our services only in your individual capacity and not as a plaintiff or class member in any purported class, representative, or collective proceeding.
- Prevailing Party: In any action or proceeding between you and P2C (and our affiliates and subsidiaries, and our and their respective officers, directors, employees, and agents) in connection with these Terms, your access to or use of the Services, or your dealing with P2C (and our affiliates and subsidiaries), the prevailing party will be entitled to recover its reasonable attorney fees and costs from the other party.
Additionally, P2C can be reached:
By Email: email@example.com
By Phone: 1-833-265-6312