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Privacy Policy for Everway Products

ISMS 1.18 : Issue 1 Rev 31 : Auth OG

At Everway, we are committed to safeguarding and preserving the privacy of our website visitors, customers and product users. This Privacy Policy explains what happens to any personal data that you provide to us or that we collect from you while you purchase or use our software or visit our site.

Everway have signed the Student Privacy Pledge, and implement FERPA, COPPA, and comply with the California Consumer Privacy Act (CCPA), the Australian Privacy Act and the General Data Protection Regulation (EU GDPR) compliant data policies. All data stored by Everway is stored according to our Information Security Policy.

It is a requirement of using Everway products that end-users are made aware of this Privacy Policy. In a school/college type environment where acceptance/consent dialogs would be detrimental to the student's user experience these are not shown 'in program' and should be made available to the students or employees by the institution or organization using the product.

It is also important that we are clear with you of the two main groups of people we collect personal information from. Firstly, there is the personal data of the Customer that actually purchases the product or service from Everway and, secondly, there is the personal data of the User of the product or service that has been purchased. Sometimes these are the same person i.e. someone purchasing a single user license from the website will likely be both the Customer and the End User of the product. However, sometimes the Customer making the purchase may not be the person that will be using the product e.g. a Customer purchasing the product on behalf of a school where the product is to be used by the school's students. The personal data of Users of the products and services are described below in the various sections for each of our products and services.

With regard to Customer personal information:

What data do we collect?

Everway collects customer data to enable us to process orders, for billing purposes, support purposes and to be able to provide updates on our products and services to our customers. This data could include:

• First name and Last name
• Job title
• Address
• Email address
• Telephone number

Where do we store your data?

Customer Data is stored in our CRM (Salesforce), and this information is stored in Amazon Web Services (AWS) data centers. The location of storage is based on the customer's location. If you are based in North America, your data will be stored within the US. For Customers based anywhere else in the world, your data will be stored in the EU.

For our Lingdys products, customer data is stored in our CRM (SuperOffice), and this information is stored by Visma IT and Communications AS in Norway. Legal documents, such as contracts, are saved in SuperOffice which are stored by Microsoft Corporation (Microsoft Azure) data centres in the EU.

For MyAccount and products on MyAccount; customer data is stored in both our CRM (Salesforce) and our own database. Both of which are hosted by Microsoft Corporation (Microsoft Azure) data centres in the US.

With regard to End-user personal information

Everway product End-user personal information is stored in AWS and Microsoft Corporation (Microsoft Azure). We have entered into Standard Contractual Clauses with AWS and Microsoft Azure to ensure we comply with the EU and UK GDPR rules on international transfers.

User settings

We use cookies, local storage, your Google™ or Microsoft™ account, and our servers to store a user's settings, such as the currently selected voice, and any document annotations.

Your Google or Microsoft account and personal information

You are uniquely identified by your Google or Microsoft email address. This information is used to determine the status of your current license. No other Google or Microsoft profile information is collected. You have a right to request erasure of this data.

Google Calendar Data Handling (Everway Tasks)

If you choose to connect your Google Calendar to Everway Tasks, the application will request access to your Google Calendar data. This section explains how we handle your calendar information.

What calendar data do we access?

When you connect your Google Calendar, Everway Tasks accesses the following information from your Google Calendar:

• Calendar events - Event titles, descriptions, start times, end times, and availability status
• Calendar metadata - Calendar names, timezone settings, and calendar list information
• Profile information - Your name, email address, and profile picture (used for account identification)

How do we use your calendar data?

Your calendar data is used exclusively to provide the following features within Everway Tasks:

• Display your calendar events - Your Google Calendar events are displayed in the Everway Tasks schedule view so you can see your existing commitments alongside your tasks
• Identify available time slots - The application analyzes your calendar events to identify free time slots for scheduling tasks
• Sync tasks to your calendar - When you schedule a task for a specific time, Everway Tasks can create corresponding events in your Google Calendar
• Update calendar events - If you modify a task's scheduled time in Everway Tasks, the corresponding calendar event is updated in your Google Calendar
• Delete calendar events - If you delete a scheduled task, the corresponding calendar event is removed from your Google Calendar

Where is your calendar data stored?

Everway Tasks is an offline-first application. All calendar data is stored locally on your device:

• Browser storage - Calendar events are temporarily cached in your browser's IndexedDB and localStorage for offline access and performance
• No server storage - Your calendar data is never transmitted to or stored on Everway's servers
• Client-side only - All calendar data processing occurs entirely within your browser on your device

Access tokens used to authenticate with Google Calendar are stored locally in your browser and are used only to make API requests to Google's servers. These tokens are automatically refreshed when needed, but refresh tokens are not stored.

Data sharing and transfers

We do not share, sell, or transfer your calendar data to any third parties. Your calendar data:

• Is not shared with advertising platforms, data brokers, or information resellers
• Is not used for advertising purposes, including retargeting or personalized advertising
• Is not used to determine credit-worthiness or for lending purposes
• Is not transferred to third parties except as necessary to provide the calendar integration features (i.e., API requests to Google's servers)

Human access to your data

Everway employees do not have access to your calendar data. All calendar data remains on your device and is only accessed through the application interface when you are actively using the calendar features.

Data retention and deletion

Calendar data cached in your browser is retained only as long as necessary to provide the calendar features. You can delete this cached data at any time by:

• Disconnecting your Google Calendar in the application settings
• Clearing your browser's local storage and IndexedDB data

When you disconnect your Google Calendar, all locally cached calendar data is removed from your device. You can also revoke access to your Google Calendar at any time through your Google Account settings.

Limited Use Requirements

Everway Tasks' use of information received from Google Calendar APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. Specifically:

• Calendar data is used only to provide or improve user-facing features that are prominent in the Everway Tasks user interface
• Calendar data is not transferred to third parties except as necessary to provide the calendar integration features
• Calendar data is not used for serving ads or determining credit-worthiness
• Calendar data is not sold to third parties

Your rights

You have the right to:

• Connect or disconnect your Google Calendar at any time through the application settings
• Revoke access to your Google Calendar through your Google Account settings
• Request deletion of any locally cached calendar data
• Request information about what calendar data is stored locally on your device

To exercise these rights or if you have questions about how your calendar data is handled, please contact us at dataprotection@everway.com.

Students and Personally Identifiable Information

Where possible the only student information that we store is the student's Login ID. We need to store this so that we can store the user's preferences and data, and to confirm that they are a licensed user. You are uniquely identified by your login address. A de-identified version of this information is used to determine the status of your Everway Product current license. No other Google or Microsoft profile information is collected. We may keep this de-identified data indefinitely however this does not prevent your right of erasure of your information should you request it.

Verifiable Parental Consent

In order to remain compliant with COPPA the licensee (The School District, School or Teacher) must obtain verifiable parental consent to store the following student information on the online platform. Where student information is shared with Everway by a School District, School or Teacher, Everway accepts that consent is authorized by that institution in lieu of parental consent.

Additional Data Stored by Fluency Tutor for Google

Because Fluency Tutor has a teacher dashboard and displays class rosters, and individual student running records some additional information is stored. This is stored in compliance with our Information Security Policy, encrypted in transit and at rest. The data which is stored is:

• The Teacher or Student first and second name
• The Teacher or Student email address
• Their Google Profile image (if the school policy permits access)
• Audio recordings of the student
• Their running record (WCPM and teachers comments)

Additional Data Stored by WriQ

Because WriQ has a teacher dashboard and displays class rosters, and individual student writing records some additional information is stored. This is stored in compliance with our Information Security Policy, encrypted in transit and at rest. The data which is stored is:

• The Teacher or Student first and second name
• The Teacher or Student email address
• Their Google Profile image (if the school policy permits access)
• Audio recordings of notes created by the teacher
• Their writing scores record (WriQ scores, document metrics and teachers comments)
• An encoded string containing student writing and the types of errors in the document.

Additional Data Stored by EquatIO Mathspace

Because Mathspace has a teacher dashboard and displays class rosters, and individual student Math documents some additional information is stored. This is stored in compliance with our Information Security Policy, encrypted in transit and at rest. The data which is stored is:

• The student first and second name
• The student email address
• Their Google Profile image (if the school policy permits access)
• Teacher feedback for Mathspace assignments (Assignment score and teachers comments)
• The students Mathspace documents

Additional Data Stored by ReachDeck/Browsealoud

By default, Browsealoud does not capture any end user information. However, administrators may log into the ReachDeck/Browsealoud portal to manage their subscription. In this instance we collect the following additional information:

• The portal user's email address

Additional Data Stored by ReachDeck Auditor

The Auditor feature does not process or store any personally identifiable information.

Additional Data Stored by ReachDeck Editor

Whilst the ReachDeck Editor does not request personal information, the purpose of the product is to help the User improve the readability of their content. Therefore the user will be entering information into this product. The information entered is sent to Everway for processing, however it is not stored and is deleted immediately after processing.

Additional Data Stored by OrbitNote

When using the OCR Scanning feature, PDFs that are sent for OCR are stored by Everway for 24 hours to ensure repeated requests are cached for optimum performance. After this period, the PDF is automatically deleted.

The PDFs are stored in compliance with our data procedures (See GDPR Compliance & International Data Transfers section) and are encrypted at rest during this period.

Data Shared by Edulife

Edulife doesn't share, transfer or disclose personal data to any third-parties outside of the synchronization between school systems and their respective Google Accounts.

Required Permissions

Applications that integrate with a Microsoft, Chrome or a Google account must declare their intent by requesting permissions. These permissions to your browser and account must be granted in order to integrate with your Microsoft, Chrome or Google accounts. Below is a list of these permissions and why they are required. At no time will Everway request or have access to your Microsoft or Google account password.

Read&Write for Windows, Mac, Google & Edge

Read&Write for Google Chrome Extension permissions

• Read and change all your data on all websites - Used by the reading and prediction features etc. to read and modify content.
• Know your email address - For licensing, storing settings
• Manage your apps, extensions and themes - Used to integrate with other Everway extensions such as WriQ.

Read&Write for Google Chrome, Google Drive permissions

• Connect itself to Google Drive - We need your permission to open the PDF, KES and EPUB files from your Google Drive menus.
• See, edit, create, and delete only the specific Google Drive files you use with this app - We need your permission to open the PDF, KES and EPUB files from your Google Drive in our accessible viewers.
• See, edit, create, and delete all of your Google Drive files - Used to create the collected highlights, vocabulary, voice notes and practice reading aloud files.
• See, create, and delete its own configuration data in your Google Drive - Used to store the location of the voice notes folder
• View your Google Drive apps - Used to create the voice notes folder.

Read&Write for Android

• Data collected: Email address - For licensing, storing settings

Google Drive Open with PDF and Epub viewers

• View your email address - For licensing, storing settings, and the annotations that you make on PDF and EPub Files.
• View basic information about your account - For licensing, storing settings, and annotations.

Screenshot Reader Extension

• Read and change all your data on the websites that you visit - Used to read the content on the page using the screenshot reader

Read&Write for Microsoft Edge Extension permissions

• Read your browsing history - Required to identify if we can display the toolbar.
• See your email address - For licensing and storing settings.
• Manage your apps, extensions and themes - Check if other Everway extensions are installed.
• Read and change content on websites you visit - Used by the reading and prediction features etc. to read and modify content.

Microsoft Account permissions

• Read your profile - For licensing and storing settings
• View your email address - For licensing and storing settings
• View your basic profile - For licensing and storing settings
• Sign you in - For licensing and storing settings

Google Documents integration

• View and manage your documents in Google Drive - We need permission to make a new Google Doc for you when we create the collected highlights and vocabulary documents.
• Connect to an external service - We need permission to connect to the Everway Vocabulary service. This service provides dictionary definitions, and symbols to be used in Vocabulary Worksheets.

Microsoft OneDrive integration

• Read your profile - Read and Write by Everway will be able to read your profile.
• Maintain access to data you have given Read and Write by Everway access to - Allows Read and Write by Everway to see and update the data you gave it access to, even when you are not currently using the app. This does not give Read and Write by Everway any additional permissions. Used to create the folders and files for collected highlights, vocabulary, voice notes files and practice reading aloud.

DataDesk permissions

• View your Google Classroom classes - Used by DataDesk to display the list of your classes if logged in as a teacher.
• View your Google Classroom class rosters - Used to get a list of students for each class.
• View the email addresses of people in your classes - Used to toggle a student's features and to retrieve analytics.

Read&Write Admin Tool permissions

• View groups on your domain - Used to select Google groups to sync with Read&Write licensing.
• View users on your domain - Used to get the students within the selected groups to send to our licensing service. All user data is hashed before sending on. This encrypted hash cannot be decrypted by Everway or anybody else. We use the hashed value to identify users within Read&Write.

Read&Write Admin Tool Microsoft Account permissions

• Read your profile - For licensing and storing settings
• View your email address - For licensing and storing settings
• View your basic profile - For licensing and storing settings
• Sign you in - For licensing and storing settings

OrbitNote

OrbitNote Microsoft Permissions

OrbitNote needs your permission to:

• Have full access to all files you have access to - OrbitNote will be able to read, create, update and delete all OnedDrive files that you can access.
• Read your profile - OrbitNote will be able to read your profile
• Maintain access to data you have given OrbitNote access to - Allows OrbitNote to see and update the data you gave it access to, even when you are not currently using the app. This does not give OrbitNote any additional permissions

Google Drive Permissions

OrbitNote will only interact with the files you choose on your Google Drive. OrbitNote does not scan or interact with Google Drive files unless instructed to do so by the User.

• See and download all your Google Drive files - Used to open PDFs directly from Google Drive on a User's request.
• See, edit, create and delete all of your Google Drive files - Used to Upload PDFs to Google Drive on a User's request.
• View your Google Drive apps - Used to Check the required Everway Apps are installed.
• Manage your coursework and view your grades in Google Classroom - Used to check if a PDF is part of your active coursework within Google Classroom.
• View coursework and marks for students in the Google Classroom classes that you teach or administer - Used to check the status of PDFs within your Google Classroom classes.
• View your coursework and grades in Google Classroom - Used to check if a PDF is part of your active coursework within Google Classroom.
• View your Google Classroom classes - Used to check if a PDF is part of your active coursework within Google Classroom.
• Manage your Google Classroom classes - Used to check if a PDF is part of your active coursework within Google Classroom.

EquatIO

EquatIO Chrome Extension Permissions

• Read and change all your data on the websites you visit - We read the browsing history so we can access the URL so we know which Google Apps integration to insert the math into. This is required for us to drop the toolbar on top of Google Apps. This is required for us to drop the floating toolbar onto any web page.
• Know your email address - Your email address is required for licensing.

Basic account info

• View your email address - Your email address is required for licensing
• View your basic profile info - Your email address is required for licensing

Google Apps Permissions

• View and manage your Google Docs documents - This may be required to insert math into the currently opened Google Doc
• View and manage your Google Slides presentations - This may be required to insert math into the currently opened Google Slide
• See, edit, create, and delete your spreadsheets in Google Drive - This is required for us to replace EquatIO Image URLs with images of math inside the currently opened Google Sheet. This may be required to insert math into the currently opened Google Sheet
• See, edit, create, and delete all your Google Forms forms - This is required for us to add your generated math questions into the existing Google Form

Equatio's use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.

ReachDeck / Browsealoud

ReachDeck / Browsealoud Portal

• View your email address - Your email address is required for licensing

Global Tasks

• In order to sign in and use the product, you must use your Google account. When you do this, we receive information about you from Google, namely your name and email address.
• Information you give us. You may give us information about you from time to time, for example if you email us with questions or comments in relation to the Product. The information you give us may include your name, address, e-mail address and phone number.
• We also use Google Analytics to track and report your use of the Product so that we can understand how the Product is used and continuously improve it.

MyAccount/All Products

• Your basic information is required for licensing. We have access to name, address and phone number.
• The personal information that is collected and processed when setting up a MyAccount account/profile are: Email, First Name, Last Name, Title, Organisation, Country, Address, City, State, Postal Code, Phone, Fax, Time zone, State Standards, Technology Usage Level
• Product access for teachers depends on the parameters set when the licence is purchased. Teachers will have access to certain or all products. Users, namely students, will have access to products that have been assigned to them.
• Personal data and product alignment - Personal data that is further processed is dependent on what products are being used and who uses them. Further information may be processed as per product
• Administrators have access to all the settings for teachers and students. They have access to personal information belonging to teachers and students.
• Teachers have access to all student personal information.
• Students can only access their own personal information.

Data privacy

Everway employees will only access content on our servers with the express permission of the provided administrator or contact at the time of purchase for a site or group license. Similar express permission from a single user license owner or trialist must be provided.

Disclosing your information

We will not disclose your personal information to any other party other than in accordance with this Privacy Policy and in the circumstances detailed below:

• Where we are legally required by law to disclose your personal information.

Scraping Content

We do not scrape any personal content. Our systems are not designed to associate personal information with your activities.

We don't sell your personal data to other companies.

We never sell any personal information. Occasionally our products need to send your personal data (such as name, email,) to 3rd parties. These 3rd parties are our Hosting and Services providers. For Example, we use Amazon Web Services to host Fluency Tutor and WriQ. The database needs to store Student information so that we can display it for you and help you track progress. These data sharing partners do not disclose your personal information, and they store it with the same level of security or greater than we do as laid out in our Information Security Policy. No ad companies collect data through our service.

We do not display advertising, therefore, no data is collected through our software for ad targeting. We do not operate any referral program and do not display any sponsored links.

We take steps to protect personal information.

We take reasonable steps to secure your personally identifiable information against unauthorized access or disclosure. We encrypt transmission of data on pages where you provide payment information. However, no security or encryption method can be guaranteed to protect information from hackers or human error.

Information we collect may be stored or processed on computers located in any country where we do business.

Your rights to the personal information we may hold on you

You have the right to request the amending, erasure or a copy of your personal information that we may collect and store while you use our products. A Data Subject Access Request may be made via this form. Alternatively you may telephone using the numbers on our 'Contact Us' page or email to dataprotection@everway.com. We will respond to a request within these time limits:

United Kingdom 30 days, US 45 days, Canada 30 days, Australia 30 days.

Monitoring usage

Our software uses tracking software to monitor visitors to better understand how they use it. This is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your computer's hard drive in order to track and monitor your engagement and usage of the website but will not store, save, or collect personal information. You can read Google's privacy policy here for further information http://www.google.com/privacy.html.

Google Analytics is a web analytics tool that helps website owners understand how visitors engage with their website. Google Analytics customers can view a variety of reports about how visitors interact with their website so they can improve it. Google Analytics collects information anonymously. It reports website trends without identifying individual visitors.

Privacy Policy and Choices

Enforcement

We regularly review our compliance with our Privacy Policy. If we receive a formal written complaint, we will follow up and contact the person who made the complaint.

Changes

We do update this Policy from time to time, so please review this Policy regularly.

Questions and Complaints

Our Head of Operational Compliance is responsible for ensuring Everway's compliance with this policy and applicable privacy laws.

Customers and end users should direct any complaints, concerns, or questions regarding Everway's compliance in writing to the Head of Operational Compliance at dataprotection@everway.com in the first instance.

If following our review, you are not satisfied with our response, you also have the right to lodge a complaint with the supervisory authority in your country of residence, place of work or the country in which an alleged infringement of data protection law has occurred.

Please see details below for further information on your rights and how to complain:

• Australia - https://www.oaic.gov.au/
• Denmark - https://www.datatilsynet.dk/
• North America - https://www.dol.gov/
• Norway - https://www.datatilsynet.no/en/
• Sweden - https://www.imy.se/en/
• UK - ICO website

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