Privacy and Security update (Dec 2021)
Book Creator has achieved full certification from iKeepSafe.org of compliance with COPPA, FERPA, California Education Code 49073.1 and SOPIPA. This is the most secure level of certification available for educational technology products.
For non-US users
This policy is for users of Book Creator outside of the US. We have chosen to provide a separate US specific policy so that we can refer to legislation such as COPPA and FERPA, whereas this policy is written in the language of GDPR. Your rights and data privacy are equivalent across the policies, and the features and behaviour of Book Creator are consistent across geographies. We just wanted to make the policy easier to read!
Book Creator is run by Tools for Schools Limited (we, us, our) and we collect and use information in order to run and manage Book Creator. This policy sets out how we do this and applies to anyone who uses Book Creator, whether by uploading book content or creating and using an account. Please read it carefully and if you are under 13, please ask a parent or guardian to read it for you.
Who do we collect information from?
We may collect information from teachers, parents, family members, guardians and students who create an account with Book Creator or upload content to Book Creator. We might also collect anonymous information about users before accounts are created or content is uploaded.
What information do we collect about you?
We may collect the following personal data about you when you set up your Book Creator account or in connection with the management of your account (Account Data):
- Your name, email address, a password and the school that you are from. You provide this information when you sign up for a Book Creator account.
- Information you choose to send to us, for example in an email.
- Some technical information about how you use Book Creator, for example the type of device you are using, your operating system, IP address, uniform resource locator (URL), clickstream and length of visit.
- If you sign into Book Creator using a Google or Office 365 account, we will receive your full name and profile picture from your account provider.
When collecting Account Data, we will act as the data controller. This means that we decide how and why we use your Account Data and we are legally responsible for the use of your Account Data.
We may collect the following personal data about you when you create and upload book content (Book Data):
Any personal data that you upload as book content which may include:
- text which includes information about you;
- a video or photo which shows you; and/or
- audio files which include information about you.
Sometimes we might be given personal data about you by someone else who is using Book Creator. For example, someone might upload a photo of you to one of their books. It is that person’s responsibility to make sure that you don’t mind them doing this.
When collecting Book Data, we will act as the data processor on behalf of your school. This means that your school or teacher decides how and why the Book Data should be used and is responsible for obtaining any consent from you which might be required for the use of the Book Data. We process Book Data only on your school or teacher's instructions, for example to create and publish books that your teacher has decided you should create.
We will only collect the minimum data necessary to run and manage Book Creator.
How do we use your information?
We will only use your personal information where we have a legal basis for doing so as set out in the data protection legislation. We rely on the following legal bases to use your Account Data in order to provide our services.
In order to perform the service under the contract we have entered into with you (i.e. the contract to provide your account and allow you to use Book Creator, we use your Account Data to
- provide Book Creator and make sure you can use it properly and effectively;
- manage and administer your account;
- respond to any questions, requests or complaints we receive from you;
- communicate with you about Book Creator if we need to;
We will also use your Account Data where it is needed to protect your interests (or someone else’s interests) or where it necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests to:
- investigate potential illegal activities on Book Creator (as it is in our interests to ensure Book Creator is used legally); and
- analyse use of Book Creator and improve Book Creator by resolving any technical issues (as it is in our interests to make sure we are providing the best possible product).
Where we use information about you for analysing and improving Book Creator, you have a legal right to object to this processing as it is based on our legitimate interests. If you raise an objection we will carry out an assessment to determine whether we have an overriding legitimate ground which enables us to continue to process your personal information for these purposes.
We will never use your information to target advertising at you based on your behaviour. We will not build a personal profile of you other than for supporting authorised educational or school purposes, or as authorised by you (or by a parent or guardian if necessary). We also won’t use your information for any purposes except those above without letting you know and getting your permission if necessary.
Who do we share your information with?
We don’t sell your information.
We don’t share your information except:
- with third party service providers, such as hosting providers or an email service, so that they can provide services to us. In cases where we share student personal data with these third parties they will be obligated to comply with the commitments in this policy. We maintain a list of these third party service providers;
- if we have a legal obligation to disclose the information (for example, if a court orders us to); or
Other people might be able to see Book Data that you create, as well as your name, if they are invited to view the books. For educational usage it is the teacher’s responsibility to invite people to view books. People will be invited by a private link so the information cannot be viewed publicly unless someone chooses to make it public. Published books can be removed at any time by the teacher through Book Creator.
All information collected through Book Creator is stored in Google Cloud and hosted in the USA. We take reasonable steps to protect your personal data when it is transferred to Google Cloud. We have signed EU model contact clauses with Google. This means it safeguards your personal data appropriately. You can see a copy of the model contract clauses.
Information about other people
Sometimes you might want to upload information about other people to Book Creator as part of book content you create, for example, a photo or audio recording of someone else. Please do not do this unless you have that person’s consent (or their parent’s or guardian’s consent, if applicable).
We have strict security measures in place to try to protect your information and make sure that it is not lost, damaged or accessed by anyone who should not see it. Your data is transmitted securely over SSL and stored in Google Cloud using Google’s security model – https://cloud.google.com/security. Additionally, we conduct regular security audits on these services and access to this data is restricted to only authorised employees of Tools for Schools with suitable training and background checks.
In the unlikely event of an unauthorised disclosure of your data we will notify you by email (or by telephone where possible) and act in accordance with our legal requirements to resolve such disclosure and prevent any future unauthorised disclosure.
You can ask us for a copy of your Account Data and other information we hold about you as data controller and we will try and send this to you as soon as possible (but within one month of receipt of the request). You also have a right to ask us to send you the Account Data that you have specifically provided to us in a common electronic format.
You can also ask us to correct any Account Data we hold about you that is inaccurate.
You can request that we erase your Account Data and/or Book Data at any time.
You can also ask us to restrict our processing of your Account Data (which means that we will only store your Account Data and not do anything further with it) in certain circumstances, such as where you think your Account Data is inaccurate and we need time to verify the data.
If you would like to exercise any of these rights, please email us at [email protected].
We don’t keep your information for longer than we need to for the purposes listed in this policy.
We will only keep your information for as long as your account is open and you can ask us to delete your account, Account Data and Book Data at any time.
We have the right, after notifying you, to delete any books and information stored on bookcreator.com if you haven’t used your account for over 12 months. You can download books at any stage and it is your responsibility to download books if you do not want to lose that content.
You can block cookies through your browser settings, but if you do you might not be able to use Book Creator properly.
Most cookies used expire when you close your browser, but some are stored for longer than this, for example cookies we use to remember your app settings.
Changes to this policy
From time to time we may need to change this policy. We will not reduce your rights under this policy, use your data for purposes not covered by it, or lessen the security of your data without your consent. We will post any changes within the policy, so you should check the policy regularly for any changes. If the changes are significant we will provide a more prominent notice, and option to consent to the changes, within Book Creator and will provide you with advance notice of the changes by email.
Should you have any questions relating to this policy, please contact us at [email protected] or alternatively in writing at Tools for Schools Limited, 31 – 34 High Street, Bristol, BS1 2AW, United Kingdom or by phone on +1 (877) 366-5116.
Effective date: 19th April 2018