Vista Higher Learning Privacy Policy

Welcome to Vista Higher Learning. This Vista Higher Learning Privacy Policy (this “Privacy Policy”) applies to your access to and use of https://www.vistahigherlearning.com (“VHL Corporate Website”),  https://www.vhlcentral.com  (“VHL Central”), and any other website that has a link to this Privacy Policy (collectively, the “VHL Sites”)

Vista Higher Learning, Inc. (“Vista Higher Learning”, “we”, “us”, or “our”) is committed to protecting your privacy through compliance with this Privacy Policy. This Privacy Policy explains our policies and practices with respect to the information you disclose to us, or the information we collect from you, when you use the VHL Sites. Throughout this Privacy Policy, “user”, “you”, or “your” refers to persons who have registered for and/or are using the VHL Sites or, for students who are under the age of 13, to the parents or legal guardians of those students.

Notwithstanding anything to the contrary contained in this Privacy Policy or in our Terms of Use, we will not use the information that you provide or that we collect in any manner that violates the Family Educational Rights and Privacy Act (“FERPA”) and other federal, state or local laws, or any written agreement between you or your institution and VHL. Subject to the foregoing, by accessing or using the VHL Sites, you agree to the Privacy Policy’s terms. If you do not agree to this Privacy Policy and its terms, please do not access or use the VHL Sites. This Privacy Policy is subject to our Terms of Use available here.  

 

What this Privacy Policy Covers

This Privacy Policy applies solely to our use of information collected by, through, or on the VHL Sites and associated products and support services which link to this Privacy Policy. It does not apply to any information we may collect offline or through any other means. This Privacy Policy does not address, and we are not responsible for, information collected by or through third parties, even if their products or services may be linked to or from the VHL Sites. For more information, see “Links to Other Sites” below. Please read the terms of any privacy policies that you enter into with other parties, including your educational institution, as those policies may explain how certain of your information is used by those parties.

 

Information We Collect 

You do not have to provide personally identifiable information to access or use the VHL Corporate Website. However, to take advantage of certain Support or Community features, such as the VHL Blog, you may choose to furnish us with personally identifiable information through the VHL Corporate Website.  

The VHL Corporate Website offers you the opportunity to order learning materials directly from our Vista Higher Learning Store (the “VHL Store”) (https://vistahigherlearning.com/store). If you make a purchase from the VHL Store, you will need to create a VHL Central account, as described below, and your transaction will be processed by a third party payment processor. The payment processor will collect your credit card information and any other information required to process your transaction, such as name, email address, shipping address, and billing address.  Vista Higher Learning is not responsible for the payment processor’s privacy and security practices.   

To make purchases through the VHL Store or to make use of our online learning platform, VHL Central, we require that you create an account by providing certain information from or about you or your students. The first type of information we may collect includes certain personal or identifying information, such as first and last name, email address, birth year, school affiliation including country, state or province, time zone, school type, and full institutional name (optional), and username and password. When you provide us with this information, which is collected on an individual basis, you knowingly choose to disclose it to us.

 

When using our learning materials through VHL Central, we may collect the following additional information:

 

Subject to compliance with the Family Educational Rights and Privacy Act (“FERPA”) and other federal, state or local laws governing the privacy of educational records, your school, school district, or educational institution may provide Vista Higher Learning with certain information for your account, such as your name, email address, and course and section enrollment information. This is discussed further in the section titled “Student Information” below.

Another type of information we collect through VHL Central is user-generated content, which may include profile information, enrollment and login history, audio and video recordings, and scores for practice activities. In addition, VHL Central may offer instructors and students the ability to complete substantive course work, including the ability to upload documents and submit communications. VHL Central may also offer instructors the ability to store student grade information on or through such products.

You may choose not to provide us with some or all of the information described above. However, in some cases, if you choose not to provide us with the required information, you will not be able to access or use some or all of the content or services of the VHL Sites.

 

Use of Cookies and Website Information

Like many commercial websites, we use standard "cookie" technology and web server logs to collect information about how the VHL Sites are used. Cookies are small pieces of data that are stored by your web browser on your hard drive. Cookies allow our web servers to recognize the computers used to access the VHL Sites. Cookies allow you to move from page to page within the VHL Sites by remembering the information about the entire session.

Information gathered through cookies and by our web server logs may include your IP address, the date and time of your visit, the pages viewed, time spent on VHL Central, and the websites visited immediately before and after using VHL Central. This information is collected automatically and contains no personally identifiable information. However, we may tie this information to other information about you that we collect from you or other sources. For instance, we expressly reserve the right to analyze anonymous demographic information and to correlate it to particular individuals in order to investigate potentially unlawful conduct and/or breaches of this Privacy Policy or the VHL Terms of Use. For example, we may report to appropriate school and law enforcement authorities any IP addresses and correlated email address that is associated with multiple unsuccessful code redemption attempts.

We may also use IP addresses and anonymous demographic information in the aggregate to share with advertisers and market researchers, and to improve the design of the VHL Sites to better serve our customers and otherwise for Vista Higher Learning business purposes. While it may be possible to correlate this information to particular individuals, we do not generally do so. We may share this aggregated information with other third parties.

You can configure your web-browser to disable cookies, but doing so may impair your use of VHL Central.

You may occasionally get cookies from companies advertising on our behalf. We do not control those cookies and they are not subject to this cookie policy.

We may also use web beacons or flash cookies. A web beacon or flash cookie (also known as “action tags”, “tracer tags”, or “single-pixel gifs”) is an invisible graphic on a web page that is programmed only to collect information that is not personally identifiable to you about your use of a given website. We do not collect personal information, such as names, e-mail addresses and phone numbers through such web beacons without your express permission.

We may use third-party web analytics services on the VHL Sites, such as Google Analytics. These services help us analyze how visitors use the VHL Sites. The information collected for this purpose (including your IP address and other information collected by automated means) will be disclosed to or collected directly by these service providers. To learn more about opting out of these activities, visit: https://tools.google.com/dlpage/gaoptout 

 

How We Use the Information We Collect 

We may use the information and user-generated content we collect for any business purposes not prohibited by law or this Privacy Policy, including, but not limited to, improving our products and services. For example, information we collect may be used in the following ways:

 

• To facilitate and enable the registration, access, and operation of the VHL Sites;
• To respond to your requests for product support or customer service;
• To develop content and functionality that helps us better serve your needs, such as training opportunities and updates;
• To engage in advertising and marketing activities as permitted by this Privacy Policy;
• To personalize your use of and experience with the VHL Sites; and
• To monitor and improve the overall performance and quality of the VHL Sites, including assessing trends in your use of the VHL Sites or purchases of products or services from the VHL Store.
• To deidentify and aggregate data for legitimate business purposes. 

 

We may also use the information we collect through VHL Central to communicate with you in connection with your use of VHL Central. You may opt-out of receiving these communications at any time. The following options are available to opt-out of receiving these messages:

 

Send email to [email protected] 

 

Send written correspondence to:

Vista Higher Learning

500 Boylston Street

Suite 620, Boston, MA 02116

Call 800-618-7375 or 617-426-4910

By using the "unsubscribe" link on any emailed correspondence from Vista Higher Learning

 

Disclosure of Your Information 

Vista Higher Learning does not sell, trade, or otherwise transfer your personally identifiable information to outside parties except under the following circumstances:

 

• To our trusted affiliates and third party service providers, as further described below, who assist us in operating our business, servicing the VHL Sites, or supporting you with your product experience;
• When we believe in good faith that disclosing such information is necessary or advisable, including, for instance, to comply with any law, court order, or legal process, including responding to any government or regulatory request;
• To enforce our Terms of Use or VHL policies or protect our or other’s rights, property, or safety;
• To a buyer or other successor or assignee in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Vista Higher Learning’s assets; and
• Otherwise as permitted or required by law.

 

Information collected from your use of VHL Central, including user-generated content and other Student Information, may also be made available to school officials, including instructors, who Vista Higher Learning reasonably believes to have a legitimate educational interest in such information and materials. Such information and materials may include a student's first and last name, username, e-mail address, student ID (if provided), the student's substantive course work, any student recorded and submitted communications, uploaded documents, product usage information (including time on site, time spent on each course-related activity, submission dates and times for course activities), score and grade information, login history, account creation date and time, and enrollment history. Additionally, if Vista Higher Learning makes chat rooms, forums, or message boards available by or through VHL Central, it is important to remember that information you choose to disclose in these areas may be viewed, accessed, retained, or re-disclosed by other VHL Central users. We encourage you to exercise caution in deciding whether to disclose your personal information on such forums.

For the avoidance of doubt, Vista Higher Learning will not provide any third party with any personally identifiable information for purposes of engaging in targeted advertising. However, Vista Higher Learning may disclose de-identified, aggregated user information or statistics in order to describe VHL Central to prospective partners, advertisers, and other third parties, and for other lawful business purposes.

 

Third Parties Who May Receive Your Information

Vista Higher Learning may share your information with affiliates and third party service providers who assist us in operating our business, servicing VHL Central, or supporting you with your product experience. You may find a list of Vista Higher Learning’s affiliates and third party service providers here. Vista Higher Learning is not responsible for any third party's implementation of its privacy and security practices.

 

How We Protect Your Information

We have implemented reasonable technical, physical and administrative safeguards to help protect your personally identifiable information against unauthorized access or loss. For instance, Vista Higher Learning provides privacy and information security training to our employees. While Vista Higher Learning strives to protect the personal information of users and takes reasonable steps to ensure the security, integrity and confidentiality of such information disclosed to us, we cannot guarantee the security, integrity or confidentiality of any information disclosed, and you do so at your own risk.

 

Username and Passcodes

When you create a password using VHL Central, you are responsible for keeping this password confidential. Please make every effort to ensure it remains private. Do not share your password with anyone, even on a temporary basis. Vista Higher Learning is not responsible for unauthorized access to accounts gained through the sharing of passwords. If you suspect your password has been compromised, contact Vista Higher Leaning Technical Support immediately.

If you lose or forget your login information, you may contact us and ask us to change your password to a temporary password. You authorize us to, upon request, send your login information to your email address of record. Further, we may provide secondary school instructors with a method of resetting a student's password for students who have indicated to us that they are enrolled at the instructor's school. This means that, if you are a secondary school student, it is possible for instructors at your school to view your VHL Central account. We will not knowingly provide instructor login information to any student.

 

Changes to Your Personal Information

You or your parent or legal guardian may review, correct or delete your personally identifiable information maintained by us through your use of the VHL Corporate Site and/or VHL Store. You may also ask us to stop collecting or using some or all such personally identifiable information. However, please be aware that this may limit or prevent your future use of the VHL Sites. 

To do this, please contact Vista Higher Learning using the contact information provided at the end of this Privacy Policy. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make any corrections.

If your school, school district, or educational institution has provided Vista Higher Learning with your user information in connection with your use of VHL Central, the school, school district, or educational institution is responsible for providing the means by which parents, legal guardians, and eligible pupils may review and correct erroneous personally identifiable information in accordance with applicable law. See the section titled “Student Information” below for more information.

 

Individuals Located in the State of California: Your Choices

If you are a resident of the State of California, please see the Privacy Notice for California Residents below for additional information regarding your rights and choices under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act.

 

Links to Other Sites

Vista Higher Learning may provide links to other websites by or through the VHL Sites. Vista Higher Learning does not endorse and is not responsible for any third party websites, products, services or business practices. Vista Higher Learning assumes no responsibility for the privacy or security of information you provide to any third party through linked websites or any other means. We urge you to review the privacy policy of any website that you visit.

 

Student Information

We may collect certain legally protected information from or about students, such as students’ personally identifiable information, in the course of providing VHL Central and related services (“Student Information”). In general, we consider Student Information to be confidential and do not use such Student Information for any purpose other than to provide and improve VHL Central or on behalf of our users and customers, including (1) to provide adaptive learning or customized student learning (including generating personalized learning recommendations); (2) to make product recommendations to teachers or institution employees; or (3) to notify VHL Central account holders about new education product updates, features, or services. Our collection, use and sharing of Student Information is governed by federal, state and local laws, as applicable, and not by any conflicting provisions contained in this Privacy Policy. This Privacy Policy does not supersede the terms of any agreements between us and any other party.

If you have any questions about reviewing, modifying, or deleting Student Information provided to us by your school or educational institution, please contact your school or educational institution directly.

 

Use of VHL Central by Children under the Age of 13

The VHL Sites are not generally intended for children under the age of 13, except for users of VHL Central in the school setting. If that is the case, the child’s parent or legal guardian or school must assist the child in registering the product or service for use. Any information that may be needed for delivery of the product or service which may not be legally collected from a child under the age of 13 must be provided by the child’s parent, legal guardian, or school with the consent of a parent or legal guardian or school, in each case as may be required by law. If you have reason to believe that we have collected personal information from someone under 13 years of age without having obtained the authorizations described above, please contact Vista Higher Learning.

We encourage parents and teachers to spend time online with children and to monitor their online activities. Please protect your child's privacy by instructing them to never provide personal information via the internet without your permission.

 

Retention

We will retain information collected through VHL Central, including personal data that we process on behalf of a customer, for as long as your account is active or as needed to provide you services. We may also retain this information as necessary to comply with company policy, legal obligations, resolve disputes, or enforce our agreements.

 

International Transfer of Data

Although the VHL Sites might be accessible worldwide, the VHL Sites are not necessarily appropriate for use outside the United States. If you choose to access or use the VHL Sites from outside the United States, you do so at your own initiative and you are solely responsible for complying with applicable local laws. For visitors using the VHL Sites from outside the United States, any data you submit to Vista Higher Learning may be transferred to and stored in Vista Higher Learning’s or its affiliate’s or vendor’s servers, which may be located in the United States, or parts of the world other than the country in which you are located when using the VHL Sites. By using the VHL Sites you hereby expressly consent to any information or personal data collected through use of the VHL Sites to be transferred to and stored in the United States. When we transfer your information to recipient in other countries, we will protect that information as described in this Privacy Policy and will comply with applicable legal requirements.

 

Changes to Our Privacy Policy

Vista Higher Learning reserves the right, in its sole discretion, to change, modify, add or remove this Privacy Policy in whole or in part, at any time. Changes will be effective when notice of such change is posted on the applicable the VHL Sites. Your continued use of the VHL Sites after any changes are posted will be considered acceptance of those changes. Unless otherwise required by law or agreed in writing by Vista Higher Learning, the data collected via the VHL Sites (other than Student Data) belongs exclusively to Vista Higher Learning. Vista Higher Learning is solely responsible for creating and maintaining this policy.

 

Contact Vista Higher Learning

If you have any questions or concerns about Vista Higher Learning's use of non-public personal information or about this Privacy Policy, please contact Vista Higher Learning at:

 

Vista Higher Learning:

500 Boylston Street

Suite 620

Boston, MA 02116

USA

 

Phone:

(800) 618-7375

(617) 426-4910

 

E-mail:

[email protected]

This Privacy Notice for California Residents (this “Privacy Notice”) applies solely to natural persons who are California residents, as defined in Section 17014 of Title 18 of the California Code of Regulations, as that section read on September 1, 2017 (“consumers” or “you”). Any terms defined in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (“CPRA”), (collectively the “CCPA”) have the same meaning when used in this Privacy Notice.  

Information We Collect 

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device (“personal information”).  The categories of personal information collected by us from our consumers within the last twelve (12) months are set out in Exhibit A incorporated in this Privacy Notice. 

As set out in detail in Exhibit A incorporated in this Privacy Notice, we obtain the categories of personal information from the following categories of sources:

Directly from you. For example, from forms you complete or products and services you purchase.
Indirectly from you. For example, from cookies through your use of our website, or from observations during sales interactions.     

Use of Personal Information

As set out in particular in Exhibit A incorporated in this Privacy Notice, we may use or disclose the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to facilitate delivery. We may also save your information to facilitate new product orders or process cancellations.
• To provide, support, personalize, and develop our website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud. 
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns, and monitor and improve our responses.
• To personalize your website experience and to deliver content and product and service offerings relevant to your interests through our website, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our customers is among the assets transferred.
• To personalize delivery of content product and service offerings relevant to instructors and others who influence institutional product selection.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we have collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose but do not sell it. We may also use the information we collect through the VHL Site to offer or furnish additional products and services, such as training opportunities and updates, and engage in advertising and marketing activities. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Disclosures of Personal Information for a Business Purpose

We disclose your personal information for performing a business purpose to the following categories of third parties:

Service providers. You may find a list of Vista Higher Learning’s affiliates and third party service providers here.
School officials, including instructors, who we believe have a legitimate educational interest in such information.
Data aggregators.
In the preceding twelve (12) months, we have disclosed for a business purpose only such categories of personal information as set out in Exhibit A incorporated in this Privacy Notice.

Sale of Personal Information and Sharing of Personal Information for Cross-Context Behavioral Advertising 

We do not sell personal information for monetary or other valuable consideration, or share personal information for cross-context behavioral advertising.

Your Rights and Choices

The CCPA provides you with specific rights regarding your personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request us to disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).

Deletion Request Rights 

You have the right to request us to delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and verify a request from you or your authorized agent, we will delete (and direct our service providers to delete) your personal information from our, and their records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, fulfill the terms of a written warranty, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal lawful uses of that information compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us using one of the following methods:

Calling us at 1-800-618-7375 and submitting a request form as directed.
Visiting https://vistahigherlearning.com/privacyrequest.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include providing your username for, or logging in to an existing system account, such as VHL Central, that is maintained by you.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the date of your verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will provide your personal information in the manner you choose at the time of submitting the request.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. We do not currently provide financial incentives.

Changes to Our Privacy Notice

We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated notice on the website and update the Privacy Notice’s effective date. Your continued use of our website and services following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about the ways in which we collect and use your information described in this Privacy Notice for California Residents, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1-800-618-7375 or 617-426-4910

Website: https://vhlcentral.com/privacyrequest

Email: [email protected]

Postal Address:

Vista Higher Learning, Inc.

Attn: Technical Support

500 Boylston Street, Suite 620

Boston, MA 02116