privacy policy

Last updated date: July 22, 2022

This Privacy Policy is part of the EducationSuperHighway Terms of Service located at: https://www.educationsuperhighway.org/terms-of-service/

privacy policy

overview

Any data collected through EducationSuperHighway products and services will support our mission to close the digital divide for the 18 million households that have access to the Internet but can’t afford to connect. GetACP.org is an online tool that helps users determine if they qualify for the federal Affordable Connectivity Program (ACP), what identification they will need to apply, and which home Internet plans are free or low cost with the ACP benefit. We collect data so that we can:

  • Build a public-private partnership to close the broadband affordability gap.
  • Identify unconnected households on a recurring basis.
  • Help states design their broadband plans for the American Rescue Plan Act (ARPA) and the new initiatives created by the Infrastructure Investment & Jobs Act (IIJA).
  • Launch demonstration projects and playbooks for states, cities, school districts, housing authorities, and other trusted institutions to help households sign-up for the Affordable Connectivity Program (ACP) and home broadband service.
  • Deploy free Wi-Fi to low-income apartment buildings.

 

Data in public reports will be aggregated by geography (e.g., zip code, city, region, state) as well as other characteristics (e.g., socioeconomic composition) and presented with grouped statistics.

  • We will share detailed data with governmental organizations such as the Federal Communications Commission (FCC), U.S. Department of Education (DOE), and state education agencies and their intermediate units, and state, city and local government entities upon request and within their respective jurisdictions.
  • School districts will have access to aggregate national and regional data and anonymized data within their geographic areas. They will not be given identifying data for specific users without the explicit permission of participating users.
  • We will not sell personal data to any entity.

Introduction and Definitions

The term “ESH,” “we,” “our,” and “us” includes EducationSuperHighway and our affiliates and subsidiaries. The terms “you” and “users” shall mean all end users of EducationSuperHighway products and services. The Privacy Policy explains how ESH may:

  • collect,
  • use, and
  • disclose

data we obtain through ESH products and services.  By using any ESH products and services, including those listed below, you agree to ESH’s Terms of Service and understand our data use practices, as set forth in this Privacy Policy.

ESH Products and Services” includes https://www.educationsuperhighway.org/bridge-to-broadband, GetACP.org, and https://map.educationsuperhighway.org/, and any related products, mobile applications or Internet services under ESH’s control, whether partial or otherwise, in connection with providing such services. 

The https://map.educationsuperhighway.org/ allows users to visualize homes of students that lack connectivity and potential broadband solutions for those homes. In connection with the mapping tool, school districts may share with us student personal data, which we use as a service provider to the school district, solely to provide the mapping services to it. Such data is not subject to this Privacy Policy. 

Through GetACP.org, you may input personal information to help determine whether you qualify for the Affordable Connectivity Program (“ACP”) and/or Lifeline National Eligibility Verifier (“Lifeline”), including your zip code, the number of individuals in your household, income level, the type of government-issued ID you may use to apply for ACP or Lifeline (but not the ID or ID number itself), whether you are enrolled in certain federal benefits programs, such as SNAP, MEDICAID, WIC, Survivor Benefits, Federal Housing Benefits, or Federal Pell Grant, and whether a dependent receives free lunch at school through the federal school lunch program. When you choose to use GetACP.org, the service generates a checklist of items you will need to submit an ACP application to the U.S. Government. If you elect to have this checklist sent to your email address and/or phone number, then ESH will retain your email address and/or phone number and use it for the purposes outlined in this Privacy Policy. If you elect to use our integrated chat feature, then any personal information you enter into the chat will be retained by ESH and used for the purposes outlined in this Privacy Policy. 

You can request assistance with questions related to ACP or Lifeline enrollment by completing the online form available at https://www.educationsuperhighway.org/acpbenefit/. By completing this form you consent to provide your PAI (as defined below) to ESH to help facilitate your household’s ACP or Lifeline enrollment; and for ESH to contact you via the phone number you choose to provide, in order to secure additional information about your household’s enrollment in these programs.  In addition, through our K-12 Bridge to Broadband program https://www.educationsuperhighway.org/bridge-to-broadband, we work with states and school districts to connect student households for remote learning and homework. The states and school districts share student addresses with us, and we share the addresses (without student names attached to them) with Internet Service Providers, to determine whether the ISPs currently serve each address or can serve it. We then identify the unconnected addresses to the relevant state or school district. We receive and share student addresses subject to data privacy agreements and other contractual obligations (including compliance with the Family Educational Rights and Privacy Act), and such data is not subject to this Privacy Policy. 

PAI” is short for Personal and/or Applicant Data and means data that alone or in combination with other data may be used to readily identify, contact, or locate you, such as: name, address, email address,  phone number, preferred language, or information collected to help determine your household’s eligibility for ACP or Lifeline. We do not consider PAI to include data that has been aggregated or anonymized so that it does not allow a third party to identify a specific individual or applicant.

Our Products and Services Collect Your Data

We may collect personal and/or applicant data when:

  • you visit educationsuperhighway.org and the other websites and applications listed above;
  • you provide it to us; or
  • we obtain it from public sources.

We also collect user data, such as data about your usage statistics, when you use ESH products and services.

Registration and Account Data. You may need to register to use ESH products and services. To register, you may need to provide PAI, such as your name, email address, and password.

Using ESH Products and Services. We collect data, including PAI, that you provide to us when you use ESH products and services or submit an inquiry to us. We may also collect PAI about school officials from public sources, such as from the U.S. Department of Education. This PAI may include your name, school address, and school contact data.

Cookies, Automatic Data Collection, and Related Technologies. ESH products and services collect and store data that is generated automatically as you use it, including your preferences and usage statistics.
When you visit web sites and services provided by ESH, we and our third-party service providers may receive and record data in our server logs from your browser, including your IP address, and from cookies and similar technologies. Cookies are small text files placed in visitors’ computer browsers to store their preferences and collect data about site use. Most browsers allow you to block and delete cookies. However, if you do that, ESH products and services may not work properly. ESH does not use cookies for any advertising purposes. We do not currently respond to browser do-not-track signals.

We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of our online services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/‌partners/ and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

how we use your data

Through EducationSuperHighway’s K-12 Bridge to Broadband program, data on home internet access for students is collected to help school districts and state departments of education identify home connectivity solutions.


Internal and Service-Related Usage. We use data, including PAI, for internal and service-related purposes only and may provide it to our service providers such as Amazon Web Services to allow us to facilitate ESH products and services. We may use and retain any data we collect to provide and improve our services.

Communications. We use your data to communicate with you. We may contact you using the data you provided to us or that we have obtained from public sources for informational, communication, and operational purposes.

Marketing. We will not sell data to any entity. We do not rent, sell, or share PAI about you with other people or non-affiliated companies for direct marketing purposes unless you have given us explicit permission. We may communicate with you to provide you with information we think may be of interest to you related to our nonprofit mission.

Aggregate Data. We may anonymize and aggregate data collected through ESH products and services and use it for any purpose. For example, we may use aggregate and anonymous data to build reports that we distribute to school districts; state departments of education; the FCC; state, city and local government entities; nonprofit and community partners; and other similar organizations.

EducationSuperHighway takes seriously our responsibility to prevent any misuse and unauthorized access or disclosure of personal data. We believe that part of this responsibility is to communicate the following specific policies for use of the data we collect:

  • EducationSuperHighway will use non-personal data to develop analyses, reports, presentations, and policy papers available to the general public.
    We will share detailed data with governmental organizations such as the Federal Communications Commission (FCC); U.S. Department of Education (DOE); state education agencies and their intermediate units; and state, city and local government entities upon request and within their respective jurisdictions.
  • School districts will have access to aggregate national and regional data and anonymized data within their geographic areas. They will not be given identifying data for specific users without the explicit permission of participating users.
  • Research partners may have access to specific non-public parts of our collected data for the purposes of pursuing a specific research goal that advances the EducationSuperHighway mission. Any data shared with a non-governmental agency will be governed by an agreement limiting its use to the specified research project.
  • Third party organizations will not have access to any data beyond what is released by EducationSuperHighway to the general public, other than when we partner with them for research purposes as described above. We will not sell data to any entity. We do not rent, sell, or share PAI with other organizations for direct marketing purposes, unless you have given us explicit permission.

we may disclose your data

We may share your data:

  • with our third-party service providers,
  • to comply with legal obligations, and
  • with your permission.

 

As Required By Law and Similar Disclosures. We may access, preserve, and disclose your PAI, other account information, and content if we believe doing so is required by law or if those actions are reasonably necessary to:

  • comply with applicable law;
  • comply with legal process, such as a court order or subpoena;
  • enforce our Terms of Service;
  • respond to claims that any content violates the rights of third parties;
  • respond to your requests for customer service;
  • respond to law enforcement executing a court order or lawfully issued subpoena;
  • investigate and prevent unauthorized transactions or other illegal activities;
  • protect our or others’ rights, privacy, property, or personal safety; or
    further a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our organization or its assets.

 

We may also disclose your PAI with your permission.

Security of Your Data

We take steps designed to protect your data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any data you provide to us. WE DO NOT ACCEPT LIABILITY FOR UNINTENTIONAL DISCLOSURE.

Update Your Data, Make A Choice, Or Pose A Question

If you would like to update or correct any personal data that you have provided to us through your use of any ESH products or services, or if you have questions about our practices, please send an email to legal@educationsuperhighway.org

If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by clicking the “unsubscribe” link contained in each such email. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.

If you no longer want to receive SMS/text messages from us on a going-forward basis, you may opt out by replying to the SMS with “STOP.”

You may also unsubscribe to email, phone, and SMS/text message communications from us by submitting a request via email to info@educationsuperhighway.org.

Changes to our Privacy Policy And Practices

We may revise this Privacy Policy, so we advise you to review it periodically.

We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective when it is posted. If you are concerned about how your data is used, bookmark this page and read this Privacy Policy periodically.

Contact

EducationSuperHighway

6 Presidio Terrace

San Francisco, CA 94118

legal@educationsuperhighway.org