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privacy policy

Last updated date: July 17, 2023

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 17 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). The GetACP.org (Pre-enrollment Tool) instance also helps users determine what identification they will need to apply and which home Internet plans are free or low cost with the ACP benefit. The GetACP.org (Application Tool) instance is a limited access online tool that allows users to apply for the ACP directly through GetACP.org. This works through a partnership with the Universal Service Administrative Company (USAC), who administers the ACP. Through EducationSuperHighway’s Products and Services, 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, nonprofits, and other trusted institutions to help households sign-up for the Affordable Connectivity Program (ACP) and home broadband or mobile internet service.
  • Deploy free or low cost 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), Universal Service Administrative Company (USAC), U.S. Department of Education (DOE), U.S. Department of Housing and Urban Development (HUD) and other housing authorities, 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 share detailed data with partner organizations, such as nonprofits and trusted institutions, pursuant to data privacy agreements.
  • 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, including personal information. 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, GetACP.org, , https://www.educationsuperhighway.org/learnacp/, https://www.educationsuperhighway.org/acpbenefit/resource-hub/, https://www.educationsuperhighway.org/bridge-to-broadband, and https://map.educationsuperhighway.org/, or other ESH co-branded sites in partnership with our strategic partners such as governmental entities, along with any related products, mobile applications or Internet services under ESH’s control, whether partial or otherwise, in connection with providing such services.

Home Digital Access Map at https://map.educationsuperhighway.org/. This site 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 provided to the school district, solely to provide the mapping services to it. Such data is not subject to this Privacy Policy.

GetACP.org (Pre-enrollment Tool). Through the GetACP.org (Pre-enrollment Tool) instance, you may input personal information to help determine whether you qualify for the Affordable Connectivity Program (“ACP”), such as 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 (but not the ID or ID number itself), whether you are enrolled in certain federal benefits programs, including Lifeline, SNAP, Medicaid, WIC, SSI, Veterans Benefits, Federal Housing Benefits, or Federal Pell Grant, household located on a qualifying Tribal land, participation in Tribal specific qualifying program (Bureau of Indian Affairs General Assistance, Tribal Head Start with relevant income qualifying standard, Tribal Temporary Assistance for Needy Families, or Food Distribution Program on Indian Reservations), whether a dependent receives free lunch at school through the federal school lunch program, your internet status, and your preferred language.

When you choose to use the GetACP.org (Pre-enrollment Tool) instance, 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, including to reach out to you to further support your ACP application process. ESH may also answer your questions about Lifeline. 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.
GetACP.org (Application Tool). Through the

GetACP.org (Application Tool) instance, you may input personal information to help determine whether you qualify for the Affordable Connectivity Program (“ACP”), such as whether you are enrolled in certain federal benefits programs, including Lifeline, SNAP, Medicaid, WIC, SSI, Veterans Benefits, Federal Housing Benefits, Federal Pell Grant, or a Tribal specific qualifying program (Bureau of Indian Affairs General Assistance, Tribal Head Start with relevant income qualifying standard, Tribal Temporary Assistance for Needy Families, or Food Distribution Program on Indian Reservations), your internet status, name, date of birth, address, contact information, the last for digits of your Social Security number (encrypted), government issued ID information, Tribal ID (encrypted), household located on a qualifying Tribal Land, whether a dependent receives free lunch at school through the federal school lunch program, and your preferred language. ESH may also answer your questions about Lifeline. 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 also request assistance with questions related to ACP or Lifeline enrollment by completing the online forms available at https://www.educationsuperhighway.org/getacp-assistance/, https://www.educationsuperhighway.org/live-chat/, or https://www.educationsuperhighway.org/acpbenefit/. By completing these forms you consent to provide your PAI (as defined below) to ESH to help facilitate your household’s ACP enrollment and to discuss questions about Lifeline. This includes ESH’s sharing of your PAI with USAC for purposes of facilitating your ACP application and enrollment, and for ESH to contact you via the phone number or email you choose to provide, in order to secure additional information about your household’s enrollment in these programs.

“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 facilitate your application 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.

K-12 Bridge to Broadband program at https://www.educationsuperhighway.org/bridge-to-broadband. Through our K-12 Bridge to Broadband program, 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.

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;
  • we receive it from a governmental organization in connection with your use of our ESH Products and Services; 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.

If you disclose any data relating to other people to us or to our service providers in connection with our products and services, you represent that you have the authority to do so and to permit us to use the data in accordance with this Privacy Policy.

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, username, organization, address, 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, submit an inquiry to us, or fill out one of our surveys. 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, including your progress through the GetACP.org journey and the unique campaign URL you used to reach GetACP.org. Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, and Internet browser type and version. We use this information to ensure that our online services function properly.

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 pieces of information stored directly on the device that you are using. Cookies allow us to collect information such as browser type, time spent on our online services, pages visited, language preferences, and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of our online services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are using our online services. We may also use cookies or other technologies in online advertising to track responses to our ads. We do not currently respond to browser do-not-track signals.

If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of our online services. You also may not receive advertising or other offers from us that are relevant to your interests or needs.

Analytics

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 https://policies.google.com/privacy 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

To Provide ESH Products and Services. Through GetACP.org, for example, we use your data to facilitate your ACP application, contact you regarding your application, and support your interactions with USAC as you proceed through the ACP enrollment process. When you use the GetACP.org (Application Tool) instance to apply for ACP and choose to submit the Tribal ID or the last 4 digits of a Social Security number for you and/or the Benefit Qualifying Person to support your application, ESH does not store such information but passes it on to USAC via an encrypted transmission, so that USAC can use it to process your application. USAC may use the data we provide them to contact you directly regarding your ACP application and enrollment.

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

Internal and Service-Related Usage. We use your data, including PAI, for internal and service-related purposes and may provide it to our service providers 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, for example, to respond to your questions and provide support for your ACP application. We also use your data to facilitate social sharing functionality that you choose to use. 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. We also use your data to allow you to send and receive messages through our services if you choose to do so.

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.

Business reporting and providing personalized services. We may use your data to analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so that we can improve our products and services. We may also analyze your data to better understand users’ interests and preferences, so that we can personalize our interactions with you.

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 the FCC, USAC, DOE, HUD and other housing authorities; state, city and local government entities, state education agencies and their intermediate units, and school districts; nonprofits and trusted institutions; and other similar organizations.

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 described below.


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 data, including your PAI, with your permission.

  • 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 FCC, DOE, USAC, HUD and other housing authorities; state, city and local government entities, state education agencies and their intermediate units, and school districts; nonprofits and trusted institutions; and other similar organizations. These organizations may use this data for their own purposes, for example, to further the mission to close the digital divide, to support your application for digital access, and to reach out to you directly to facilitate your enrollment in programs you have applied for, such as ACP.
  • 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.

Third-Party Advertising

We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use our online services and other websites or online services. You may receive advertisements based on information relating to your access to and use of our online services and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/.

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.

Third-Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which our online services link. The inclusion of a link on our products or services does not imply our endorsement of the linked site or service. In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Instagram, LinkedIn, Apple, Google, Microsoft, RIM, or any other operating system provider, wireless service provider, or device manufacturer.

Use of Online Services by Minors

Our online services are not directed to individuals under the age of 13, and we do not knowingly collect personal data from individuals under 13.

Jurisdictional Issues

Our online services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States.

Changes to our Privacy Policy And Practices

We may revise this Privacy Policy, so we advise you to review it periodically. The Last Updated legend at the top of this Privacy Policy indicates when it was last revised.

Translation

Non-English language versions of the EducationSuperHighway Privacy Policy are translated by Weglot.

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