PRIVACY POLICY
Privacy Policy Statement
This website is owned and operated by WTSUB. We recognize that visitors to our site may be concerned about the information they provide to us and how we treat that information. WTSUB is committed to honoring our members’ privacy preferences.
This policy covers www.WTSUB.com. We encourage you to take the time to read this privacy policy and those of any website you visit.
Information Collected
Purchases and Registration
To purchase items and register for events on this website you must create an account and provide at minimum your name, address, phone number and email address. For information about the handling of your credit card information, please see the section below titled “Security of Your Information.”
Subscribing to e-News Alerts and Active Advisor News
To sign up for alerts and e-newsletters, you are in most cases only required to provide us with your full name and email address.
We’ve enabled some Google Analytics features based on Display Advertising (e.g., Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager integration, or Google Analytics Demographics and Interest Reporting).
Visitors can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Settings at Google.
Use of Information
Your information will be used to issue invoices, administer accounts, collect and process payments, and to send information to you about WTSUB and our services. You may opt-out of mailings at any time if you do not wish to receive non-business critical information from us. WTSUB will not sell your email address for commercial purposes.
Photography
By providing an image to WTSUB, you are granting WTSUB the rights to use this image in print, electronic, video and social media. This also includes tagging WTSUB in images shared on social media sites. Reproduction beyond usage by WTSUB. is prohibited. Under no circumstances will any images of any children under 13 be published or used by WTSUB without verified parental consent.
How to Opt-Out
E-Newsletters
If at any time you wish to stop receiving an electronic newsletter from WTSUB, you may opt-out by selecting the unsubscribe link located at the bottom of every message, or by contacting us at the1stLight@gmail.com. Please provide enough information for us to be able to identify you and comply with your request.
Security of Your Information
We will take appropriate steps to protect the security of your personal information. We will also protect your personal information in storage. We have implemented security policies, rules, and technical measures to protect the personal data that we have under our control from unauthorized access; improper use or disclosure; unauthorized modification; and unlawful destruction or accidental loss. All our employees who have access to, and are associated with the processing of personal data, are obliged to respect the confidentiality of our visitors’ personal data.
All sensitive information (such as your credit card information) provided to WTSUB through our website is transmitted to our credit card processor using Secure Socket Layer (SSL) encryption. SSL is a proven coding system that lets your browser automatically encrypt, or scramble, data before you send it to us. No credit card information is stored on our site.
Unfortunately, no data transmission over the Internet can ever be 100 percent secure. While we strive to protect your information to the fullest extent, we cannot ensure or completely guarantee the security of such information.
You can also use this handy browser add-on to opt-out of Google Analytics.
Third Party Access to Information
Third party vendors listed below may have access to personally identifying information shared with us via this site. Data shared with vendors is only for the purpose of fulfilling its duties and providing services or for improving services and will not be for commercial use. Data will not be shared with any additional parties other than those listed here without written consent except as required by law.
Vendor / Purpose
Teachable / Learning Management System
Thinkific / Learning Management System
Links to Third Party Sites
We provide links to third-party sites. Since we do not control those websites, we encourage you to review the privacy policies posted on these third party sites.
Questions and Contact Information
WTSUB welcomes comments and questions on this policy. We are dedicated to protecting your personal information and will make every reasonable effort to keep that information secure.
If you have any questions, please contact us:
the1stLight@gmail.com
WTSUB
PO Box 10531
Riviera Beach, FL 33419
The information you provide to us will also be covered by this policy.
Changes to the Privacy Policy
We may change or supplement this Privacy Policy from time to time. We will post an appropriate notice of changes to the Privacy Policy on our site. Privacy Policy changes will apply to the information collected from the date we post the revised Privacy Policy to the Site, as well as to existing information held by us.
Last Revised: May 26, 2023
FERPA
- Purpose
WTSUB Student Data Privacy Policy
The purpose of this policy is to ensure that WTSUB and its member organizations take appropriate steps to protect any personally identifiable information (PII) of students and related data. Although WTSUB is not an educational institution as defined in 34 CFR Part 99, WTSUB is committed to ensuring that all PII is protected and that WTSUB members are made aware of all rights and responsibilities regarding protecting PII.
- Information Collected
Throughout the various platforms and databases that WTSUB uses to register, inform, and provide services to member organizations and individuals, the required data from participants often falls under the definition of “directory information” under 34 CFR § 99.3. This information can include, but is not limited to, a student’s name; address; telephone number; and email address. WTSUB does not request social security numbers. Schools and/or students have the option to enter school-provided student identification numbers. In many cases, under our agreements with member organizations, WTSUB is performing an institutional service or function that a member would otherwise assign to its own employees, under the direct control of the member organization and according to the criteria specified in the member’s annual FERPA notification. As such, WTSUB is acting as a school official and, therefore, is covered under the school official exemption under FERPA at 34 CFR § 99.31(a)(1).
While WTSUB requests information related to ethnicity, socio-economic and other demographics, this information is optional for students to share, and in addition to the questions being optional, most questions contain a “prefer to not respond” answer option. This information is in an aggregated format and does not identify any specific student and is used for analytical purposes only. This allows WTSUB to report on how students at a national or state level responded to the demographic and socio-economic questions. If, at a future point in time, WTSUB collects data containing PII other than directory information, we will follow all applicable regulations regarding the protection and disclosure of that data if the need arises.
If you wish to access, modify, or delete other personal information that you have provided to WTSUB, such as your address, please contact us at the1stLight@gmail.com for assistance.
We will retain your information for as long as your account is active or as needed to provide you services. Please contact us if you wish to cancel your account or request that we no longer use your information to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. Otherwise, WTSUB will download user data on a quarterly basis, retain that data for one year, and then dispose of the previous year’s data.
III. Use of Information
Generic information like names and email addresses are used for members’ personal accounts and to provide specific services. Such information will be used to issue invoices, administer accounts, collect and process payments and send information about WTSUB and our services. Individuals may opt-out of mailings at any time if they do not wish to receive non-business critical information from us.
Demographic information is combined with monitoring trends in individuals registering and participating in WTSUB programs and is not tied to individual accounts. Data is shared only with operation-critical third-party vendors connected directly to the functionality of the online curricular resources and reporting. Data is not shared with other third-party vendors, and contact information is not provided to any commercial or non-commercial entities.
WTSUB takes appropriate steps to protect the security of all personal information that is collected and stored. Security policies, rules, and technical measures are implemented to protect the personal data from unauthorized access, improper use or disclosure; unauthorized modification; and unlawful destruction or accidental loss.
If WTSUB becomes aware of a systems security breach by an unauthorized party or that any user data was used for an unauthorized purpose, we will comply with relevant state and other data breach laws. We will notify users of any breach resulting in an unauthorized release of data electronically, at minimum, and without unreasonable delay so that you can take appropriate steps. The notification will include the date of the breach, the types of information that were subject to the breach, general description of what occurred and steps WTSUB is taking to address the breach.
All employees who have access to, and are associated with the processing of personal data, are obliged to respect the confidentiality of all PII, have undergone background checks, and have received COPPA and FERPA training.
WTSUB does not share PII with any third-party organizations without prior written consent from its members. Even in cases where WTSUB is performing an institutional service or function that a member would otherwise assign to its own employees, under the direct control of the member organization and according to the criteria specified in the member’s annual FERPA notification, WTSUB will still follow all applicable FERPA rules regarding the use and protection against unauthorized disclosure of all PII involved.
Portions of the WTSUB LMS and the Website contain functions for collecting personal information, including names and email addresses, as well as an individual’s or account’s access history. WTSUB may also collect and track other personally identifiable and non-personally identifiable information about you, such as your I.P. address, the type of browser you use, and the website you visited before visiting our website or WTSUB services.
If you are using the WTSUB LMS as an educational institution, student information may be visible during customer support and/or troubleshooting. Personally identifiable information such as Student
Name; Student Email Address; file names; creation dates of files; login dates and times; and third-party applications that students use could be viewed on our service by product support staff.
If you register to use the {WTSUB Service} or express interest in obtaining additional information, WTSUB requires you to provide your contact information, such as your name, school name, address, and email address. WTSUB may also ask for additional personal information, such as title, phone number, or other demographic or socio-economic information. You can opt-out of providing this additional information by not entering it when asked.
- Rights and Responsibilities
While WTSUB is not an educational institution subject to the requirements of the Family Educational Rights and Privacy Act (FERPA), except in cases where members outsource institutional services or functions to WTSUB, we are a national membership organization, with state and local chapters, that serves students attending institutions that are subject to FERPA, including high schools, colleges, middle schools, and other non-federal entities. All member organizations have the right to review student information provided to WTSUB and can request information be deleted or refuse to permit further collection or use of student data that has been provided. Members may make use of this right by contacting the1stLight@gmail.com and making such requests.
In light of this expansive membership, WTSUB is committed to helping member educational institutions stay in compliance with FERPA and its implementing regulations at 34 CFR Part 99. As noted above, the data that WTSUB collects is primarily directory information. Educational institutions that disclose directory information do not have to seek prior written consent from students or parents, as noted in 34 CFR § 99.31(a)(11). However, all educational institutions that might share this information with WTSUB must provide annual notification regarding this disclosure to parents and eligible students, including the right to opt-out of such disclosures. See 34 CFR § 99.37(a). Examples of such notifications can be found on the U.S. Department of Education’s Student Privacy Policy Office’s Website at: https://www2.ed.gov/policy/gen/guid/fpco/index.html.
Although WTSUB often qualifies for the school official exception under 34 CFR § 99.31(a)(1), it will still notify registering individuals when any non-directory information is required, and students or program directors may choose not to provide certain demographic information. Any non-directory information that is collected is used solely for tracking registration and performance trends and is not tied directly to individuals. Any non-directory information submitted by an individual is destroyed once annually or upon school administrator request.
Information provided to WTSUB may be used to transmit, distribute, modify, reproduce, display and store the student data solely for the purposes of providing the services as contemplated by the user’s agreement with WTSUB. Any internal use of information for maintaining, supporting, evaluating, improving, and developing our products, applications, and service, and for enforcing our rights under various agreements, will include all appropriate steps to protect all personally-identifiable information from unauthorized disclosure.
In the event that WTSUB is involved in a merger, reorganization, dissolution, sale of business or assets or similar event, information disclosed to or collected by WTSUB may be transferred to WTSUB’s’ successor, or to the purchaser of such assets, as applicable. You will be notified via email and a prominent notice on our website of any change in ownership or uses of your personal information as well as any choices you may have regarding your personal information. This policy may change from time to time, so please review it frequently for any updates or changes. If we make material changes to this policy, we will notify you via email (sent to the email address specified in your account) or by means of a notice on our website at least 30 days prior to the change becoming effective.
WTSUB conducts regular security reviews of all systems through which student data is collected, maintained and transmitted. Members may request the results of such audits by contacting the1stLight@gmail.com. Additionally, WTSUB ensures that all employees and staff that collect, handle, or transmit student data are trained on all FERPA-related requirements to ensure student data is protected.
- General Statement on Children and COPPA
WTSUB’s Sites and tools are not intended for children under the age of 13. You must be 13 years of age or older to register an account on the WTSUB Sites. To the extent that WTSUB is able to determine the age of users by their submissions to, or communications with, this website, WTSUB will not knowingly collect or post information from individuals under thirteen years of age (“Children” or “Child”) without their parent, guardian, or school’s verifiable consent. In any case, WTSUB will not make public any personally identifying information collected from Children, regardless of its source, to any third party for any purpose whatsoever.
- Questions and Contact Information
WTSUB welcomes comments and questions on this policy. We are dedicated to protecting your personal information and will make every reasonable effort to keep that information secure. If you believe that WTSUB has not adhered to this Privacy Policy, please contact us electronically or via postal mail at the address provided below, and we will use commercially reasonable efforts to promptly determine and remedy the problem.
If you have any questions, please contact us:
the1stLight@gmail.com
WTSUB
PO Box 10531
Riviera Beach, FL 33419
The information you provide to us will also be covered by this policy, and WTSUB will work to reply to your questions or comments within 30 days.