Privacy Policy

Blackboard Web Community Manager Privacy Statement Effective on December 30, 2019 If you are a Californian resident, please read our separate California Consumer Privacy Notice to learn about Blackboard’s privacy practices. Contact your School to learn about your School’s privacy practices. Blackboard Inc. (“Blackboard”) is committed to protecting your privacy. This Privacy Statement applies to Personal Information collected on the Web Community Manager (formerly known as "Schoolwires") websites, applications or associated web-based environments, including mobile applications (collectively, the “Solution”) provided and hosted by Blackboard for your school, school district or other organization (“School”). Schools use the Blackboard Solution to provide customized websites, applications and other programs to the School’s end users, which could include teachers, parents, students and others. This Privacy Policy pertains only to the Personal Information that Blackboard collects from you or that is provided to us by the School or your users in connection with the School’s use of the Solution, where we serve as the supplier that processes this data on the School’s behalf. “Personal Information” is information that can identify a specific individual. When you or your School use Blackboard’s solution, Blackboard needs to use your data to host and provide the Solution to you and the School. Blackboard collects, uses and retains your Personal Information as a service provider to the School in accordance with our contractual agreements with the School. This Privacy Statement explains how Blackboard processes your Personal Information on the School’s behalf. Your School may further use such data for its own purposes and Blackboard does not have control over such use. Please see the School’s privacy policy or contact your School for more information about its privacy practices. Blackboard Web Community Manager is certified under the iKeepSafe COPPA Safe Harbor Program Seal which covers data that is collected by Blackboard through the Solution.

1. Information We Collect When Hosting a School’s Solution Blackboard has been retained by the School to provide and host the Solution on the School’s behalf and under the School’s control. The School customizes the content, controls who can register for and use the various features of the Solution and who can access the Personal Information posted or maintained on the Solution. Subject to the particular policies and functionality selected by the School, Blackboard may collect Personal Information from the users of the School’s Solution, which could include School administrators, teachers, and other individuals associated with the educational institution providing the Solution, students, parents and guardians who use the Solution provided by the School, and visitors to the School’s websites and online services offered through the Solution (collectively referred to as “users” or “you”). We do not collect, maintain, use or share Personal Information collected through the Solution for any purpose beyond what is needed to provide the functionality of the Solution and as otherwise described herein or as authorized by our agreement with the School. The type of information Blackboard may collect when we host the School’s Solution could include: Information you provide. You may visit portions of the Solution as a guest without registering. Registration, however, will give you access to certain features as well as the ability to personalize content. When you register, we will collect certain Personal Information on behalf of the School, which could include your name, contact information, and e-mail address, and could include demographic information such as your education level, gender and interests. Depending on the portions of the Solution your School has purchased, and the settings and functionality established by the School, we may collect additional information such as your mobile phone number, and any other information the School has configured the Solution to request. Your School may elect to provide Personal Information to us on your behalf in order to use certain features and functions of the Solution. By way of example, a School-designated official may input registration information for you, either manually or through a system feed. After registration, the site administrator for the school may decide to assign to you a role(s) or group(s). Based upon your designated role(s) or group(s), you may have access to additional information or services. If you have questions concerning your role(s) or group(s), please contact the School. Your School may provide additional information to us in other situations, for example, in connection with a customer support request or a content submission request. We use this information to operate, maintain, and provide to you and other users the features of the Solution, including to provide you with the features of the Solution selected and controlled by the School. We may use this information to communicate with you, such as to send you email messages, push notifications, text messages, and to permit other Users of the Solution to contact you, to improve and develop our product and services, to improve customer service, and for other systems maintenance purposes. Please see Section 4 for information on how we collect and process Student Data through the Solution. Information we collect from third party services and social media sites. We may collect information about you from third party services that you connect to the Solution or interact with through the Solution, such as liking or sharing content on Facebook, Twitter or other third party social networks. We may collect information that a third party service provides to us when you access your account through the third party service, for example if you use a single-sign on like G Suite Google Apps for Education or PassKey Manager™ or similar solution to access your account. These services will authenticate your identity and provide you the option to share certain Personal Information with us, which could include your name, email address, address book and contacts, or other information. The data we receive is dependent on that third party’s policies and your privacy settings on that third party site, as well as the features, functionality and third party integrations offered by your School through the Solution. Information collected through your use of the Solution. In addition to the information you actively provide, we also collect information about how you use the Solution, your actions taken through the Solution, your communications with others through the Solution, and any additional data or information that is generated by your use of the Solution. Depending on the features and functionality utilized by a School, users may be able to post, download or upload various pieces of content and/or information on or through the use of the Solution, and/or interact with third party social media services or other collaboration or communication tools, or communicate with one another. For example, teachers or administrators may post blogs, announcements and other information and content directly onto the Solution, and/or users may chat with each other, or send instant messages, text messages or e-mail, via technology which may now or in the future be made available over the Solution, and may share information, photographs, images or recordings with each other or with others in the community. The use of these features is controlled by the School and not by Blackboard. Blackboard has no practical ability to restrict the information, conduct, communications, or content which might be posted on or exchanged through the use of its technology Solution, nor can Blackboard ensure prompt removal of any such communications, information or content after transmission or posting. If you are concerned about any information or content that may be posted, transmitted or accessed on the Solution, please contact the School.

2. Information Collected Through Cookies & Other Tracking Technology Like most websites and online services, we and our third party partners automatically collect certain types of usage information when you visit the Solution, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, Flash cookies (locally stored objects), embedded scripts, location-identifying technologies, and similar technology (collectively, “tracking technologies”). These tracking technologies collect information about how you use the Solution (e.g., the pages you view, the links you click, and other actions you take on the Solution), information about your browser and online usage patterns (e.g., IP address, browser type, browser language, referring / exit pages and URLs, pages viewed, whether you opened an email , links clicked), and information about the device(s) you use to access the Solution (e.g., mobile device identifier, mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, and depending on your mobile device settings, your geographical location data (which could include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device), or we may be able to approximate a device’s location by analyzing other information, like an IP address. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Solution. Although we do our best to honor the privacy preferences of our visitors, we are not able to respond to Do Not Track signals from your browser at this time. These tracking technologies (including cookies) allow us to provide you with a better user experience and to enable your School to provide a better user experience through the Solution. For example, data collected through tracking technologies can be used to: (a) remember information so that a user will not have to re-enter it during subsequent visits; (b) provide custom, personalized content and information; (c) to identify and contact you across multiple devices; (d) to provide and monitor the effectiveness of our Solution; (e) perform analytics and detect usage patterns on the Solution; (f) diagnose or fix technology problems; (g) detect or prevent fraud or other harmful activities or to protect the rights, property and personal safety of Blackboard, our Schools or our users; and (h) otherwise to plan for and enhance the Solution. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Solution, as some features and services on our Solution may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us and your School to know whether you have accessed our e-mail and performed certain functions with it. Please note that deleting cookies does not delete Local Storage Objects such as Flash objects or HTML5 cookies. For information on disabling Flash cookies, go to Adobe’s web site http://www.adobe.com or by clicking here [https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html]. Please be aware that if you disable or remove cookies, Flash cookies, or HTML5 cookies on your device, some parts of our Solution may not function properly, and that when you revisit the Solution your ability to limit cookies is subject to your browser settings and limitations. Tracking Technologies set by a School. Note that your School may engage with third parties to enable certain functionality or usage analytics, and such third-parties may set tracking technologies to facilitate these services. For example, Google Analytics may be used to track visitor activity on the Solution. Blackboard does not control these third party partners engaged directly by a School as part of the School’s Solution. Please review your School’s privacy policy or refer questions to your School. Please see Section 5 below to learn more about third party tracking technologies used for interest-based advertising.

3. How Information Collected Through the Solution is Shared Information sharing directed by School. Blackboard processes and shares Personal Information under the direction and control of your School. Depending on the features and functionality selected by your School, the Solution may facilitate the exchange of information between and among users and third parties, and your School may adjust features, settings and permissions which govern how Personal Information is accessed and shared among users and third parties. For example, your School may maintain social commenting features to enable users to communicate with teachers, parents, or community members. Similarly, your School can control which individuals can be registered to use certain Solution features and which individuals or groups are granted privileges to access, view or use Personal Information collected, exchanged or maintained on the Solution. Users who have been assigned administrative privileges by your School have access to all registered user information on their Solution, and may be able to grant access rights to other users. Your School may integrate third party features or permit third party partners to collect Personal Information on the Solution in order to provide a service, such as social networks, content providers, or educational partners. Additionally, your School or its authorized users may provide consent or authorization for us to share Personal Information with a specific individual or third party upon request. Accordingly, we share Personal Information as needed to provide these features and functionality of the Solution and as directed by the School and its authorized users. Contact your School for more information regarding information access and sharing controlled by your School. Other instances in which information may be shared. In addition to the information sharing practices discussed above, Blackboard may share or disclose Personal Information collected through the Solution in the following ways: With service providers and advisors. Blackboard utilizes other companies to provide services on its behalf, including but not limited to customer support, web analytics, hosting, coordination of mailings and event management. These companies are permitted to access information only as needed to perform those services. Blackboard requires these companies to maintain the confidentiality of Personal Information and prohibits them from using the information for any other purpose than helping us provide the Solution to you and your School, or performing business services on our behalf. With law enforcement, regulators and other parties for legal reasons. Personal Information may be disclosed to such third parties as required by law or subpoena or if we believe in good faith that disclosure is reasonably necessary to (i) comply with legal process, (ii) enforce the Terms of Use or our agreements, (iii) respond to claims that any content provided by using the Solution violates the rights of third parties, or (iv) protect the rights, property, or personal safety of Blackboard, its users, or the public. With third parties in connection with a business transaction. Blackboard may share Personal Information other than Student Data, as defined below, with other parties in connection with any company transaction, such as a merger, sale of all or a portion of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of bankruptcy or related or similar proceedings. We will not share Student Data with a third party pursuant to such a transaction unless the party agrees to honor the privacy commitments made in this Privacy Policy or we will use our best efforts to provide your School with notice and an opportunity to opt-out of the transfer of Student Data by terminating your School’s Solution accounts before the transfer occurs. Additionally, Blackboard may share Personal Information that has been de-identified or aggregated to determine the demographic composition of our user base, to distribute statistics and general marketplace information about Blackboard’s products and services, and to perform research and improve the Solution and our other services. This de-identified or aggregate information does not reasonably identify specific users.

4. Student Data Collected Through the Solution Blackboard takes its responsibilities to protect the Personal Information of students it maintains on the School’s behalf very seriously. Through the provision of the Solution to your School, we may collect or have access to student data (“Student Data”), which is a type of Personal Information which is directly related to an identifiable current or former student. Blackboard considers Student Data to be strictly confidential. Our collection, use and sharing of Student Data will be limited to the purpose of providing the Solution and as otherwise described herein. We work closely with your School to uphold our obligations under data protections laws relating to the privacy of Student Data, which include, in the U.S., the provisions of the Family Educational Rights and Privacy Act (“FERPA”), the Children’s Online Privacy Protection Act (“COPPA”) and applicable state laws relating to student privacy, and with other state, federal and international laws which may apply. Reviewing, modifying or deleting Student Data. Student Data is controlled by your School and Blackboard processes Student Data on your School’s behalf. If you have any questions about reviewing, modifying, or deleting Personal Information of a student, please contact your School directly. Questions we receive regarding Student Data will be referred to your School as we require your School’s authorization for Blackboard to update or delete information contained in School accounts. We will promptly respond to all requests from your School to provide access to, correct, or delete Student Data.

5. Children’s Privacy Blackboard does not knowingly collect any information from children under the age of 13 unless and until your School has provided appropriate consent and authorization for a student under 13 to use the Solution and for Blackboard to collect this information. Your School controls the use of such information. We rely on your School to obtain any necessary parental consent before permitting a child under 13 to access or provide information through the Solution, and to otherwise comply with the privacy obligations under COPPA and other applicable (state) laws, including to provide notice and a means for a parent to access information collected from a child and to request such information be modified or deleted. If you have any questions regarding the collection and use of Personal Information from a child under 13 through the Solution, please contact your School. Please contact us at privacy@blackboard.com if you believe we have inadvertently collected Personal Information from a child under 13 without proper consents so that we may delete such information as soon as possible. Certain deletion requests may require your School’s authorization.

6. Third Party Tracking & Online Advertising Blackboard does not authorize third party ad networks, social media companies, or other third party services to collect information about visitors to the websites, applications or other online services Blackboard provides and hosts for your School through the Solution, for interest-based advertising purposes, except and unless at the direction of your School. Blackboard does not share or sell Student Data for marketing or targeted advertising purposes. PLEASE NOTE: Your School may permit third party ad networks, social media companies, and other third party services to collect information through tracking technologies on the School’s Solution so that they may play or display interest-based ads on the School’s websites, on other devices you may use, as well as on other websites, apps or services. Your School, and not Blackboard, is responsible for the collection of information by third parties that it authorizes to collect information through the School’s Solution for interest-based advertising purposes. Please refer your questions to your School or review your School’s privacy policy to learn more about if and how your School engages in interest-based advertising or other third party tracking practices, and about the choices you may have to limit such tracking. Notwithstanding the above, it is Blackboard’s policy to prohibit third parties from collecting information from students or children under 13 for interest-based advertising purposes on any website or online service hosted by Blackboard through the Solution. Please contact Blackboard at privacy@blackboard.com if you believe third party ad networks, social media companies or other third party services are collecting such information through our Solution in a manner which may be inconsistent with this policy. In some cases, we may need to refer these questions to your School. To learn more about interest-based advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at ww.aboutads.info/choices.

7. Communications Interactive Communications. Depending on the features and functionality selected by your School to offer through the Solution, you and other registered users may be able to collaborate and communicate through email, phone, chat, or other communication method. These communications are directed and controlled by the School and by users. You should contact your School with questions regarding communications you receive through the Solution. EAlerts. The E-Alert feature is a Solution feature available on certain platforms. There are two types of E-Alerts: (1) Broadcast E-Alerts are used by School administrators to send messages to a specific group or multiple groups of users; and (2) Content E-Alerts are messages to users when certain changes are made to one or more homepages or sections to which they subscribe. These E-Alert communications are directed and controlled by the Schools and by authorized School users, who control whether to send an E-Alert and the contents within the message. You may be able to opt-out of E-Alerts through options in your account settings. Otherwise, you should contact your School with questions regarding E-Alert communications you receive through the Solution. Blackboard Communications. From time to time, Blackboard may send communications to you and other users. It may be necessary for Blackboard to send out a service-related announcement. For instance, if our service is temporarily suspended for maintenance, we might send administrators and other designated School users a notification email. For example, Blackboard may send promotional emails to School administrators or other decision-makers. You may opt-out of receiving future promotional emails by clicking on the unsubscribe link in the email.

8. Access to Your Information You may be able to access or change the information collected during registration by choosing the "edit Personal Information" option or other similar functionality offered in the Solution. To access or change your Personal Information, log in to your account through the Solution. For data not available through such an account, please contact your School’s administrator. If a request is made to Blackboard, we will refer the request to your School and look to the School to validate the request before we can make changes to an account.

9. Data Retention & Security Data Retention. We retain Personal Information on behalf the School only as necessary to provide the service requested, comply with our legal obligations, resolve disputes and enforce our agreements, all in compliance with applicable laws. When a School administrative user deletes your account, the information contained in your user account is no longer available except to the extent it is stored in backed-up data repositories, which are destroyed pursuant to our standard data retention schedule. Please contact your School if you have questions about data retention and deletion. Any request we receive to delete Personal Information may require authorization from the School providing the Solution. Data Security. The School will remain responsible for the privacy and security of your Personal Information, including Student Data, that it collects and processes through the Solution, and for compliance with applicable data privacy laws that may apply to the collection, processing and disclosure of information through the Solution. Blackboard maintains administrative, technical and physical procedures to protect Personal Information. Security safeguards may include but are not limited to data encryption, firewalls, data use and access limitation, and physical access controls to buildings. Data Storage and Transfer. Unless and except to the extent limited in our agreement with your School, your information may be stored and processed in the United States or any other country in which Blackboard or its subsidiaries, affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including your Personal Information, to a country and jurisdiction that are not considered to have equivalent data protection laws as your jurisdiction. Blackboard complies with applicable data transfer requirements. Blackboard is Privacy Shield certified and additionally uses EUapproved standard contractual clauses to legitimately transfer EU Personal Information to jurisdiction that are not considered equivalent. Please refer questions to your School to determine how your School protects EU Personal Information, if any, which may be stored or maintained by Blackboard or its other service providers in the United States or elsewhere outside of your jurisdiction.

10. Links to Third-Party Websites & Services The Solution may provide links to third-party websites or services that are not governed by this Privacy Policy. To the extent that any linked thirdparty websites or services you visit are not owned or controlled by Blackboard, we are not responsible for those websites’ or services’ content or information practices. We encourage you to review the privacy policies of any site or service before providing any Personal Information.

11. Changes to the Blackboard Web Community Manager Privacy Policy We reserve the right to change this Privacy Policy from time to time in our sole discretion. We will post changes on this page and indicate the “last modified” date at the top of this page. Please check back often for any updates. Your continued use of the Solution after any change in this Privacy Policy will constitute your acceptance of such change. We will not make any material changes to this Privacy Policy that relate to the collection or use of Student Data without first giving notice to the School and providing a choice before Student Data is used in a materially different manner than was disclosed when the information was collected.

12. Contact Information If you have any questions, suggestions or concerns regarding the collection and processing of your Personal Information, please contact your School directly. If you are unable to resolve your questions or concerns with your School, please contact us at privacy@blackboard.com.

General Counsel Blackboard Inc. 1111 19th Street, N.W. Washington, DC 20006

Phone: 202-303-9372 privacy@blackboard.com In addition, if you have any complaints related to this privacy policy and/or the privacy practices, you can reach out to COPPAPrivacy@ikeepsafe.org.