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How the data will be encrypted (described in such a manner as to protect data security): Processor uses encryption technology to protect data while in motion or in its custody from unauthorized disclosure as specified in Education Law §2-d.All data is stored in the continental United States. Processor maintains two geographically separate data centers (East Windsor, NJ and Secaucus, NJ) which are interconnected via high speed private links.

We utilize Amazon Web Services (AWS) cloud services for delivering our content to customers. Our platform is a hybrid cloud-based and physical data center platform fully hosted by Processor. [NYC DOE comment: requests for copies of student data or to challenge the accuracy such data should be directed to your child’s school, or to Whether the Protected Information will be stored in the US or outside of the US (and if outside of the US, where), and the security protections taken to ensure such data will be protected (described in such a manner as to protect data security): Processor’s products require a minimal amount of PII to be collected and stored for proper use of the program.

If and how a parent, student, eligible student, teacher or principal may challenge the accuracy of the student data or teacher or principal data that is collected: Pursuant to its contractual obligations, the Processor will work with the NYC DOE in processing challenges to the accuracy of student data in the custody of the Processor.

When the non-disclosure agreement with the NYC DOE starts and ends and what happens to Protected Information upon expiration of the agreement: When the Agreement terminates between the NYC DOE and the Processor, upon written request, the Processor shall return to the NYC DOE or, if agreed to by the NYC DOE, destroy the remaining PII that the Processor still maintains in any form.

How you will ensure that the subcontractors or other authorized persons or entities that you will share the student data or teacher or principal data with, if any, will abide by data protection and security requirements required by your non-disclosure agreement with the NYC DOE: Processor requires any and all subcontractors, persons or entities with which the Processor may share the PII to commit contractually that they will abide by the terms of the Agreement and/or the data protection and security requirements set forth in Education Law §2-d.

Your information may be combined in an aggregate and de-identified manner in order to maintain and/or improve our services. We do not collect, use, or disclose PII that is not reasonably related to the purposes described within this notice without prior notification. Except as described in this notice, we limit the use, collection, and disclosure of your PII to deliver the service or information requested by you. We will also process your PII to meet our legitimate interests, for example to personalize your experience and to deliver relevant content to you to maintain and improve our services to generate and analyze statistics about your use of the services and to detect, prevent, or respond to fraud, intellectual property infringement, violations of law, violations of our rights or Terms of Use, or other misuse of the services.

Processor will use PII to provide the requested service or to process transactions such as information requests or purchases in order to meet our contractual obligations to you.

The exclusive purposes for which Protected Information will be used:

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