PRIVACY POLICY

This Privacy Policy applies to the web-based Brookes Online Training website located at my.brookesonlinetraining.com (the “Site”), which is owned and operated by Paul H. Brookes Publishing Co., Inc. (“Brookes Publishing Co.”). Brookes Online Training is a web-based content delivery platform designed to provide instructional modules, courses, and content. Brookes Publishing Co. respects the privacy of our customers, web site visitors, and Brookes Online Training users (“Users”), and we understand how important it is to protect their personally identifiable information and the information they manage. This Privacy Policy identifies the information that is collected on this Site and explains how it is used and how it is protected.

Please read this Privacy Policy carefully before using this Site. Your use of the Site is also subject to the Terms of Use and to the individual End User License Agreements (“EULAs”) for the courses or other online content available on the Site. Brookes Publishing Co. may, from time to time, change, amend, modify, or update this Privacy Policy and the Terms of Use without notice to you and at its sole discretion. Any such revisions or changes will be considered effective from the date they are posted on this Site. Your continued access or use of this Site constitutes acceptance of the latest version of this Privacy Policy by you and your institution. It is your responsibility to regularly check the Privacy Policy and Terms of Use, which are accessible from the login page of my.brookesonlinetraining.com.

If you have questions or concerns regarding this Privacy Policy, please submit a ticket through the Site at Contact Us.

COLLECTING AND USING INFORMATION

This Site hosts a variety of trainings, courses, and informational modules (“Content”) for Users. Content can only be accessed with a username and password and is intended to be used by early childhood educators, psychologists, speech language, occupational, and physical therapists, and other interested parties. The portion of the Site that contains User test results, User certificates issued after successful Content completion, User-posted information, or other personal information about or from a User, is restricted to access by the individual User and/or supervising personnel of that User (“Account Supervisor”). The Site is not intended to be used by any persons under the age of 18. Brookes Publishing Co. will not sell, share, or rent any information collected on this Site in ways different from what is disclosed in this statement.

User Data

In order to access the Content available on this Site, you must become a User. You may become a User after you have purchased Content or if you are employed by or otherwise appropriately affiliated with (e.g., as a third-party contractor or consultant) an organization that has purchased or otherwise licensed subscriptions to use the Site or Content, after you are provided access rights and privileges by the Account Supervisor for that organization. (User roles are defined in the Terms of Use and/or in the End User License Agreement for particular Content.) Before using the Site and to obtain a username and password, you must provide certain information that can be used to personally identify you (“Personal Information”); the specific Personal Information you must provide is determined by whether you are a “purchaser” or a member of a “purchasing organization.”

• Purchaser: Whether you are an organization or individual, if you have purchased a subscription to access Content, you must provide your full name, title, mailing address, telephone number, valid e-mail address, and, if purchasing a subscription, your financial information* (e.g., credit card number). (*No financial information is stored in the Site but must be provided to Brookes Publishing Co. as part of the customer service ordering process outside the Site.) Personal Information is used to register the Purchaser as a Account Supervisor; set up and maintain your account; and contact you regarding the account renewal.
• Member of a purchasing organization: If you are affiliated with a child care center, Early Head Start or Head Start program, school, school district, home visiting program, early intervention program, physician’s office, health clinic, or other organization that has purchased a subscription to use the Site and Content, you must provide your full name and e-mail address to the subscribing organization's Account Supervisor. The Account Supervisor may request additional information from you at his or her discretion. The Personal Information you provide to the Account Supervisor is used to register you as a User for particular Content; set up and maintain your User profile; and determine which features and information you are authorized to access, view, complete, update, modify, or otherwise use.

Brookes Publishing Co. only uses the financial information you provide for billing purposes and your name and e-mail address to send e-mail alerts and updates related to Brookes Online Training. If you desire, you may opt-out of receiving e-mail alerts and updates by creating a ticket at Contact Us, or selecting the opt-out option included at the bottom of each e-mail.

If you are a purchaser, you will likely receive catalogs by postal mail from us throughout the year. On rare occasions, we share small segments of our list of customers with related publishers and nonprofit organizations. If you wish to be removed from our postal mailing list, please call toll-free 1-800-638-3775; fax to 410-337-8539; or write to Brookes Publishing Co., P.O. Box 10624, Baltimore, MD 21285-0624, U.S.A., Attention: Customer Service. We will be happy to remove you from any list that we generate from our customer records, but please be aware that we may not be able to remove your name from lists that we purchase from outside vendors. We will make every effort to make your name inactive if you so request.

If you are a member of a purchasing organization, the Personal Information you provide will be accessible by that organization. In some cases, a purchasing organization may have purchased subscriptions to Content as part of an agreement negotiated by a larger entity. For example, a district or state may elect to purchase subscriptions to Content at a rate negotiated by district/state-level personnel or corporate officers in order to achieve cost savings and/or to facilitate data management and reporting. In cases such as this, the Personal Information you provide is accessible by the larger entity(ies) as well as the purchasing organization.

Username and Password

Your username and password enable you to log in and access Content in accordance with the access rights Brookes Publishing and your Account Supervisor grant you. Brookes encourages Account Supervisor and their purchasing organizations to employ best security and privacy practices and require Users to regularly change their passwords. Do not disclose, share, or allow any third party to use your username and/or password. If you become aware that your username and/or password has been stolen or is being misused, notify the Account Supervisor at your organization immediately, or if you are an individual purchaser or an Account Supervisor, notify Brookes Publishing Co. directly. If you have lost or forgotten your password, please use the secure automated mechanism available in the Site for re-issuing passwords for Users in the event they are lost or forgotten.

User Data

Depending on the individual User's role and access rights and the features within specific Content options, Users may use the Site to view, interact with, complete courses, modules, or other content, and/or modify his or her information for his or her personal profile and for sharing with his or her Account Supervisor (“User Data”). Each User’s role and access rights are determined by the purchasing organization’s Account Supervisor and are not assigned or modified by Brookes Publishing Co.

Completing some Content options requires the collection of User-generated answers to questions and other input. Using the full range of the Site’s features may require the collection of additional information. Brookes Publishing Co. will not share, rent, or sell personally identifiable User Data except as permitted by this Privacy Policy. Brookes Publishing Co. will only access personally identifiable User Data when a support query initiated by a User and/or Account Supervisor absolutely necessitates it. All User Data are stored and transmitted securely in the Site; please see the SECURITY section below for details.

User Data in Reports

Depending on your role, Users and Account Managers may use the Site to create, view, interact with, and/or modify reports generated from User Data (“Reports”). The Reports include but are not limited to test and/or certification scores and other progress reports for individual Users that enable Users to see their own results or their Account Managers (and purchasing organizations) to see their results. Reports de-identified of personal User Data may be shared with Brookes Publishing Co. and/or the author/developers of individual Content options.

Archived User Results

A User’s profile will hold information about the User’s results from various Content options, depending on the features of the specific Content. For example, upon successful completion of a Training module, a copy of the User’s certificate of completion will remain stored in the User’s profile (“Archived User Results”). The Archived User Results will remain in the Site's database, and Users may access but not modify their own Archived User Results.

Inactive Users

If for any reason an Account Supervisor desires to make a User inactive (e.g., the User resigns and/or transfer to a different program and is no longer employed by the purchasing organization) but wishes to retain the User Data and/or Archived User Results for viewing and reporting purposes, the Account Supervisor may elect to mark the User inactive. The User Data and Archived User Results will remain in the Site’s database, and the Account Supervisor may access the Archived User Results. Archived User Results will not be included in aggregate reports of User Data. Inactive Users may be reactivated if needed. Brookes Publishing Co. uses User Data for inactive Users no differently than we use active User Data.

Permanent Data

Test results and certificates remain a permanent part of the User’s profile.

Survey Data

From time to time, Brookes Publishing Co. may request information from Users via surveys. Participation in these surveys is completely voluntary, and the User therefore has a choice whether to disclose any information. Survey information will be used to monitor or improve the use and user satisfaction of the Site or to gather aggregate data about our customers.

Termination of Subscription

If a purchasing organization elects to terminate its account (see Terms of Use) and/or its access to any and/or all Content options, all User Data and User information and results associated with the Content being terminated will be deleted from the Brookes Online Training database (“Terminated Date”). Brookes Publishing Co. does not retain Terminated Data, nor can we recover or restore Terminated Data. Before terminating your account, you may elect to export any Reports currently available in your account at no charge. If you determine after deactivating your account that you need to download additional data, please create a ticket through the Site at Contact Us. In certain situations, Brookes Publishing Co. may be able to assist Users in downloading their Data; a modest fee may be charged for this service depending on the scope of the request.

If a purchasing organization allows its account to expire but does not notify Brookes Publishing Co. of its intent to terminate, your User Data will continue to be maintained for a limited period of time to facilitate the renewal of your subscription(s). See Terms of Use for details.

SECURITY

This Site uses robust security measures, provided by a Tier 1 managed host, to prevent unauthorized access to the Site and to safeguard the User Data, User information and results, and other data used by the Site and ensure their confidentiality and correct use.

Access Security

Users may only gain access to the Site's Content by providing a valid username and password combination, which is encrypted during transmission via Secure Sockets Layer (SSL), the industry standard security protocol. Secure pages can be recognized by the lock icon by the URL bar of the web browser.

Brookes encourages Account Managers and purchasing organizations to employ best security and privacy practices and require Users to regularly change their passwords. Do not disclose, share, or allow any third party outside of your subscribing site to use your user name and/or password. If you become aware that your user name and/or password has been stolen or is being misused, notify the Account Supervisor at your organization immediately. Brookes Online Training provides a secure automated mechanism for re-issuing passwords for Users in the event they are lost or forgotten. If an Account Supervisor loses or forgets his or her user name or password, he or she should contact Brookes Publishing Co. immediately.

Data Security

Brookes Publishing Co. takes precautions to protect the confidentiality and security of the data collected and stored in the Site's database by using industry-recognized security safeguards such as firewalls, coupled with carefully developed security procedures to protect your information from loss, misuse, or unauthorized alteration. Regular backups of the Site and all data are made; all data are backed up in full both locally and remotely on a daily basis. Backed-up data are stored at a secure site for a period of 30 days. Brookes Publishing Co. also encourages Account Managers to use the Site's free data exporting functionality for Reports and maintain regular data backups.

Physical Security

Access to the personal information—not just the sensitive information—that you provide during the registration process or put on the Site (with the exception of information on surveys, which you voluntarily submit at your own risk) is restricted to only staff of Brookes Publishing Co. and any outside contractor who need the information to perform a specific job. Our databases and the servers on which we store Site information are kept in a secure Tier 1 data center that includes physical security, conditioned power, environmental controls, uninterruptible power supplies, diesel generator, and fire suppression technologies. Our databases and customer service systems are protected by employee-specific passwords. Furthermore, all employees and outside contractors are kept up-to-date on our security and privacy practices. Each year, as well as any time policies are added or modified, our employees are notified and/or reminded about the importance we place on privacy and what they can do to ensure that our customers' information is protected.

LOG FILES AND IP ADDRESSES

This Site's log files collect anonymous data such as IP addresses, browser types, referring pages, pages visited, and time spent on the Site. Collection of IP addresses is for system administration purposes, such as monitoring the level of activity on the Site. All other anonymous data are used only in aggregate by Brookes Publishing Co. for internal review to improve the Site and its services.

LINKS TO OTHER SITES

This Site may contain links to other web sites or refer you to other resources. Brookes Publishing Co. is not responsible for the accuracy or completeness of the content or the privacy practices of other sites we may link to. We encourage users to be aware when they leave our Site and to read the privacy statements of every web site they visit that collects personally identifiable information. This Privacy Policy applies solely to information collected by Brookes Publishing Co.

MAINTAINING, CORRECTING, AND UPDATING INFORMATION

Users of the Site are responsible for creating and managing all User Data and other data provided for accessing and using the Site and its Content. If you wish to correct or change your personal User Data, you may do so by logging into the Site and updating or correcting the User Data stored on your account page.

INFORMATION FROM STUDENTS

Brookes Publishing Co. respects the sensitive nature of students’ privacy on-line. The Services offered on this Site are intended to be used by teachers, specialists, school and education administrators, and other child care providers. They are not intended for use by persons under the age of 18. If we learn that a user is under 18 years of age, we will promptly notify the purchasing organization's Account Supervisor and delete any personally identifiable information provided by that User.

FERPA COMPLIANCE

FERPA: The Family Educational Rights and Privacy Act (FERPA) is a federal law that protects the privacy of student education records. This law applies to all schools that receive funds under an applicable program of the U.S. Department of Education. If this law applies to your organization and you are a User, you must be aware of your obligations under, and respect the terms of, this law. For more information on FERPA, follow this link: http://www.ed.gov/policy/gen/guid/fpco/ferpa/index.html.

LEGAL DISCLAIMER

Although Brookes Publishing Co. makes every effort to honor and protect our users' privacy, we may need to disclose the data we collect and we reserve the right to do so if required by law or in the good-faith belief that disclosure is necessary (a) to obey the law or comply with legal process served on us or our affiliates; (b) to protect and defend our rights or property or the rights and property of other users of the Site; or (c) to act in an emergency to protect the personal safety of users of the Site or the public.

QUESTIONS?

Thank you for taking the time to read this Privacy Policy. We take your privacy seriously, so please let us know if you have any questions or comments regarding our Site or this policy. Please submit any questions through the Site at Contact Us.