Bedford, Freeman & Worth High School Publishers
Privacy and Cookie Notice
Effective Date: December 27, 2018
Bedford, Freeman & Worth High School Publishers (“BFW Publishers”) (referred to herein as "we" "us" or "our") respects your concerns about security and privacy and values the relationship we have with you. This Privacy and Cookie Notice ("Notice")
applies to personal information we collect through any online interface (e.g., website, mobile application or other interactive service) that contains a link to this Notice authorized by BFW Publishers (each, a "Site", and, collectively, the "Sites").This
Notice also applies to personal information we receive outside of our Sites, e.g., contact information we receive during on campus visits, business meetings or through publicly available websites or publications.
This Notice describes the types of information we collect on the Sites, how we may use the information, with whom we may share it, and the choices available to you regarding our use of the information. We also describe the measures we take to safeguard
the information and tell you how to contact us about our privacy practices.
European Union (EU) Individuals only: if you are in the EU, when we use personal data about you related to us offering you products or services or where we follow your actions within the EU ("EU Processing") we will do so as relevant
EU law allows including by providing further information about that EU Processing in the sections of this Privacy Notice marked "Note to EU Individuals only". Subject to those sections, the rest of this Privacy Notice still applies to
you, but these sections do not information about you. See the apply to anyone else.
1. Information We Collect
We may collect both Personally Identifiable Information and Non-Personally Identifiable Information. For purposes of this Notice, “Personally Identifiable Information” means any information or combination of information that identifies you personally.
“Non-Personally Identifiable Information” means information that does not identify you personally or contain direct personal identifiers about you.
Personally Identifiable Information that we may collect includes:
- contact information, such as your first and last name, postal address, e-mail address and telephone number;
- registration information such as a username, password, user ID, or the name of your school or institution;
- payment-related information (including debit or credit card-related information);
- information that personally identifies you in any comments or content that you voluntarily provide on or through our Sites (such as through blogs, forums, discussion groups, social networking platforms, or contest and sweepstakes entries);
- instructor educational information, such as your school name and location, course information, and the textbook or product you are using when combined with information that personally identifies you;
- information concerning your interests and product preferences when combined with information that personally identifies you;
- transaction information associated with any purchases made on our Sites, including information in connection with customer service requests; and
- student ID, polling responses, survey and questionnaire responses, attendance data, participation and performance points, analytics and usage data, location and subscription information, and remote ID when the information is linked or linkable to information
that personally identifies you.
Some of the Personally Identifiable Information we collect is “Student Data”: information that we collect, process, and maintain on behalf of an educational agency or institution for legitimate educational interests and that is directly related to or
contains personally identifiable information about a “Student.” A “Student” is a person using our learning platform at the direction of an educational agency or institution. For example, Student Data includes a Student’s first name, last name, email address,
a Student number assigned by the educational agency or institution or that is otherwise part of the educational record, and school test results.
Non-Personally Identifiable Information that we may collect includes information about your device or internet browser, information obtained from cookies that have been placed on your device or internet browser at our Site, demographic information, aggregated
information, anonymous or de-identified information about how you use our Sites, including the transactions you perform using our Sites, and other information obtained through your access to or use of a Site that does not identify you personally. We may
supplement the information we collect from you with information we receive about you from other sources.
In addition, when you visit our Sites, we may collect certain information by automated means, such as cookies and web beacons. The information we collect in this manner includes IP address, browser characteristics, device characteristics, operating system,
language preference, referring URLs, information on actions taken on our Sites, and dates and times of website visits. By collecting this information, we can better understand activity on our Sites, learn how to best tailor our Sites to our visitors.
While we generally examine such information only in the aggregate, such information could be linked back to individual IP addresses or other information about you. See the
Cookies and Online Tracking section below for more information.
Note to EU Individuals only: We will only retain your personal data obtained through EU Processing for as long as necessary to fulfill the purposes of use (see the
How We Use The Information We Collect section below), including as necessary for addressing any legal, accounting, or reporting risks or requirements related to them, for example the limitation period for which legal claims can be made in court and
archival purposes. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes of use and whether we
can achieve those purposes through other means.
Note to Canadian Individuals only: We only retain personal information for as long as necessary to fulfill the purposes for which it was collected, or to otherwise meet a valid legal or business requirement or need.
2. How We Use The Information We Collect
We collect both Personally Identifiable Information and Non-Personally Identifiable Information when you apply for, obtain, or use our products and services, to make inquiries about our products and services, or to provide information and feedback about
our products and services.
Except as noted below in this section under NOTE FOR STUDENT DATA, we may use the information we collect to:
- create and manage your account;
- communicate with you about your account, including your subscription status;
- to process and administer your payments;
- deliver products and services you or your school or institution has purchased or rented;
- offer and provide products, services and tailored information to you, including newsletters;
- permit you to participate in, and to communicate with you regarding, blogs, forums, and discussion groups;
- interact with you or to permit you to interact with our social media accounts;
- communicate with you about, and administer your participation in, special events, programs, surveys, contests, sweepstakes, and other offers or promotions, to the extent permitted by law;
- display content on our Sites, such as stories, product reviews and photos;
- respond to and communicate with you about your requests, questions and comments;
- process claims we receive in connection with our products and services;
- operate, evaluate and improve our business (including developing new products and services; managing our communications; determining the effectiveness of our sales, marketing and advertising; analyzing and enhancing our products, services and Sites;
and performing accounting, auditing, billing, reconciliation and collection activities);
- perform data analyses and other processing (including market and consumer research, learning efficacy research, trend analysis and anonymization);
- protect against, identify and prevent fraud and other criminal activity, claims and other liabilities;
- protect against online piracy and other unauthorised use (see "Anti-piracy measures" below); and
- comply with and enforce applicable legal requirements, relevant industry standards and our policies, including the provisions of this Notice and any applicable Terms, and where otherwise permitted or required by applicable law.
We also may from time to time acquire from third parties information on individuals who may be interested in our products. We may use this information for marketing and advertising. However, we do not combine that information with Student Data.
We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.
NOTE FOR STUDENT DATA: WE DO NOT USE STUDENT DATA FOR MARKETING OR ADVERTISING, EXCEPT AS PERMITTED BY LAW, E.G., WITH THE OPT-IN CONSENT OF THE STUDENT OR GUARDIAN, AS APPLICABLE. HOWEVER, MACMILLAN MAY PLACE CONTEXTUAL ADVERTISING ON PAGES USED BY STUDENTS THAT ARE NOT BASED ON THE USE OF STUDENT DATA AND DO NOT TARGET STUDENTS IN VIOLATION OF ANY APPLICABLE LAWS.
Note to EU Individuals only: Our EU Processing for the above purposes will be on the basis that it is necessary: (i) for our legitimate interests where these do not override your own interests, rights and freedoms and our legitimate interests are the operation of the Sites, the provision of our products and services, anti-piracy enforcement and our other business activities in an effective and efficient manner, including the registration and management of users and accounts, the administration and processing of orders
and payment, the provision of service and marketing communications, and the promotion and support of our business and our brand and to provide you with, or to engage with you in order to be able to provide others, with interesting, engaging and appropriate
content, events and activities; (ii) to perform a contract we have entered into or are about to enter into with you personally; or (iii) to comply with legal and regulatory requirements and requests. In rare, emergency situations we may use your personal
Cookies and Online Tracking section above); (ii) to send you marketing emails (see the
Your Choices section below); and (iii) where you are asked to provide sensitive data as part of a survey request that we provide on behalf of your school/educational institution; and we will inform you specifically when we seek to obtain consent from
you as well as your ability to withdraw that consent at any time. In some cases there may be overlap between these different bases. In compliance with the above, please note that we may undertake some EU Processing without your specific knowledge or consent
where this is required or permitted by law, but if you would like more information about our EU Processing please contact us at any time. Unless otherwise required or permitted by law, before we begin EU Processing of your personal data for a purpose
unrelated to those above, we will notify you and explain the legal basis which allows us to do so.
3. Cookies and Online Tracking
A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Your browser may tell you how to be notified when you
receive certain types of cookies or how to restrict or disable certain types of cookies. For more information on cookies and how to disable them, you can consult the information provided by the Interactive Advertising Bureau at www.allaboutcookies.org.
Please note, however, that without cookies you may not be able to use all of the features of our Sites.
Our Sites use two kinds of cookies: session cookies and persistent cookies. Session cookies exist only for as long as your browser remains open. Once you close your browser, they are deleted. Persistent cookies, in contrast, last beyond each visit to
the Sites and remain on your hard drive after you close your browser. The cookies used on the Sites include those that are strictly necessary cookies for access and navigation, cookies that track usage (performance cookies) and remember your choices (functionality
cookies), and for visitors to our catalog and store Sites, cookies that provide you with targeted content or advertising (described more below under “interest Based Advertising”). Your browser may tell you how to be notified when you receive certain types
of cookies or how to restrict or disable certain types of cookies. Please note however, that without cookies, you may not be able to use all of the features of our Sites.
We may use the information we obtain from cookies for the following purposes:
- to recognize your computer when you visit the Sites;
- to track you as you navigate the Sites, and to enable the use of e-commerce capabilities;
- to improve the Sites’ usability;
- to analyze use of the Sites;
- to manage the Sites;
- to personalize the Sites, including for visitors to our catalog and store Sites;
- to enable targeted advertisements that may be of particular interest to you (excluding Students); and
- to recognize you when you move between devices so that your work can be synchronized.
We also may use “web beacons” on some of our Sites. A web beacon, also known as a pixel tag or clear GIF, may be used to transmit information collected through cookies to our service providers’ servers. These web beacons enable our service providers
to compile information about your browsing activity on the Sites.
On some of our Sites, as set out below and where permitted by law, we partner with third party companies who may utilize cookies, web beacons or other technologies to provide: personalized content; advertisements about our goods and services that may
be of interest to you; or to serve advertisements about other products; on our Sites . The third parties may use these technologies to collect information about you when you use the Sites. They may collect information about your online activities over
time and across different websites and other online services, as well as across different devices. They may use this information to provide you with interest-based advertising and content or other targeted advertising and content. They may also use persistent
identifiers to track your Internet usage across other websites in their networks beyond the Sites. Such third parties may, with sufficient data from other sources, be able to personally identify you, unknown to us.
browser (as explained above):
see here. To opt-out, see here.
here.To opt-out of cookies, please see here and go to the footer option “Cookie Settings.”
- Google ("Google":) supports ad personalization (e.g., provided by DoubleClick) which uses personal information such as, but not limited to, geolocation and search terms, in order to serve the user ads on non BFW Publishers sites. For more information
opt-out, see here.
please see here.
- Twitter ("Twitter"): tracks website activity on the Student Store site and retargets users by collecting device information, tracking pixels, as well as personal information such as user emails. For more information on their privacy practices and their
- Optimizely ("Optimizely"): helps determine how new features on BFW Publishers sites are performing by collecting user data such as device information, IP address, referral page, interaction data, crash data, other technical information, and location
- New Relic ("New Relic"): tracks website activity and provides analytics to us and to users as part of our service by collecting website browsing data, session information, and personal data including IP address. For more information on their privacy
how to opt-out, please see here.
You can also obtain more information about interest-based advertising, and how to opt-out of receiving interest-based ads from participating third-party providers and ad networks through the following:
For Users in the U.S.:
For Users in the EU:
http://www.youronlinechoices.eu(European Interactive Digital Advertising Alliance)
For Users in Canada:
http://youradchoices.ca/choices/(Digital Advertising Alliance of Canada)
Opting out of participating providers and ad networks does not opt you out of being served advertising. You may continue to receive generic or contextual ads on our Sites.
To successfully opt-out, you must have cookies enabled in your web browser. Please see your browser’s instructions for information on cookies and how to enable them. Your opt-out only applies to the web browser you use, so you must opt-out of each web
browser on each device that you use. Once you opt-out, if you delete your browser’s saved cookies, you may need to opt-out again.
NOTE FOR STUDENT DATA: While some of our Sites collect information for third party advertising purposes as described above, we do not collect or use Student Data for these purposes, nor do we deliver targeted advertising to Students. We may, however, display to Students contextual advertisements on our Sites and engage in other advertising activities, as permitted by law, e.g., with the appropriate opt-in from the Student or parent/guardian, as applicable.
We also use third-party web analytics services on our Sites, such as Google Analytics and ClickTale. These service providers help us analyze how users use our Sites. The information collected for this purpose (including your IP address and other information
collected by automated means) will be disclosed to or collected directly by these service providers. These service providers may retain and use Non-Personally Identifiable Information collected from users of our Sites in connection with their own businesses,
including in order to improve their products and services. To learn more about opting out of data collection through Google Analytics or Click Tale, click the links below:
as a result.
You may also be able to limit the association of your mobile device with your online activities by resetting the advertiser ID on your Apple or Android device. For more information about how to change these settings go to:
The Sites may also offer you the ability to interact with plugins from the following social and other sites: Facebook, LinkedIn, Twitter, and YouTube, in order to allow you to follow us or share your experiences with your online social network. These
services collect persistent identifiers through your browser or mobile operating system. If you have previously provided personally identifiable information to these third-party sites, that third-party may recognize you here. Your use of social network
by third-party plugins. If you engage with our content on or through third-party social media sites, you may allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture)
to deliver the content or as part of the operation of the plug-in or application. For more information on their privacy practices please see Facebook, LinkedIn, Twitter, and Youtube.
These Sites are not designed to respond to "do not track" signals received from browsers.
5. Links To Other Websites
Our Sites may contain links to other websites for your convenience and information. These may include, for example, some of the blogs and forums you may access through our Sites. These websites may be operated by companies not affiliated with us. Information
you submit through these third party websites will be subject to their privacy policies. We suggest you review their privacy policies to understand how they may collect, use, and share your information. We are not responsible for the content of any websites
that are not affiliated with BFW Publishers , any use of those websites, or their privacy practices.
6. Children’s Privacy
These Sites are intended for people 13 years of age and older. If you are under 13, please do not submit any personal information to us through the Sites. If you are under the age of 18, please review this Notice with your parent or guardian before submitting
any information to us.
Note to EU Individuals only: We do not knowingly conduct EU Processing of the personal data of children in the EU under the age of 16 without parental consent.
7. How We Protect Personal Information
To protect Personally Identifiable Information, we apply administrative, technical, and physical security measures. Unfortunately, no data transmission or storage system can be guaranteed to be absolutely secure, and we disclaim any representation or
warranty that our information security systems or those of our service providers and joint marketers are absolutely invulnerable to breach or compromise.
We have procedures to deal with any suspected data security breach and will notify you and/or any applicable regulator or supervisory authority or other governmental entity where we are legally required to do so.
8. Marketing/Your Choices
NOTE FOR STUDENT DATA: We do not use Student Data to target marketing to you. We may display to Students contextual advertisements on our Sites and engage in other advertising activities, as permitted by law, e.g., with the appropriate
opt-in from the Student or parent/guardian, as applicable. When we have the appropriate consent to market to you (directly or through your parent/guardian/authorized legal representative, if applicable), you may subsequently withdraw your consent by contacting
us through one of the means listed under the
How To Contact Ussection below and specifying that you wish to withdraw your prior consent for use of Student Data for marketing purposes.
With respect to non-Student Data, we give you the option of requesting that we not share your personal information such as your email address for marketing use with third parties that are unrelated to us by common ownership. Click here to send us an
e-mail with your name and e-mail address(es) if you DO NOT want us to share your personal information with unrelated third parties for their own marketing use.
With respect to non-Student Data, we give you the option of requesting that we not use your information for marketing purposes, or share your information with related companies for their own marketing purposes. Click here to send us an e-mail with your
name and e-mail address(es), if you DO NOT want us to use your information for marketing purposes, or share your information with related companies for their own marketing purposes.
Please be aware that we are able to process an opt-out request only for a specific e-mail address. So, if you have more than one e-mail address or if you have changed your e-mail address, your opt-out request may not be processed for any e-mail that
you have not identified in your opt-out request. If you believe you have opted out, but continue to receive e-mails from us, please contact us by one of the means listed under the
How To Contact Ussection below, and we will endeavor to resolve the issue. Please note that the foregoing opt-out covers email marketing communications only and you may continue to receive transactional e-mail as it pertains to your purchase of products
or services from us and support issues related thereto.
With respect to non-Student Data, if you receive a marketing email from us, you can follow the unsubscribe link included in each of our email marketing communications to opt-out of receiving such marketing emails.
In some instances, you will be required to opt-in to receiving marketing email communications in order to receive such emails, in which case you consent to receiving such communications from us. You may withdraw your consent to receiving communications
from us at any time by clicking “unsubscribe” at the bottom of the e-mail communications, or sending us an email with your name and email address at
Note to EU Individuals only: You have legal rights in respect of our EU Processing of personal data (please see the end note to the
Access and Correctionsection below), including the right to ask us not to use your personal data for marketing purposes at any time. If you have opted in, you can subsequently withdraw your consent to marketing whether by us or by third parties at
any time by using the link above.
9. Notice to California Residents
California’s “Shine the Light” law, Civil Code Section 1798.83, requires certain businesses to respond to requests from California customers asking about the business’ practices related to disclosing personal information to third parties for the third
parties’ direct marketing purposes or to provide an opt-out for such sharing of information to third parties for the third parties’ direct marketing purposes. Please see our opt-out mechanism above under the
Marketing/Your Choicessection above that will enable you to notify us if you would like to opt-out of such sharing of your information with third parties.
10. Access and Correction
Subject to applicable law, you may: (i) have the right to access certain Personally Identifiable Information we maintain about you and obtain a copy of that information; (ii) update or correct inaccuracies in your Personally Identifiable Information;
(iii) object to our use of your Personally Identifiable Information; and (iv) request deletion your Personally Identifiable information from our database. To exercise these rights, please contact us as indicated in the
How To Contact Ussection of this Notice. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information, which may require you to provide us with Personally Identifiable
NOTE FOR STUDENT DATA: To request access to and correct Student Data, we may refer such request to your respective Institution or University for it to address such request.
Note to EU Individuals only: You have legal rights in respect of our EU Processing of personal data, including the right to: (i) request access to the personal data that we hold about you and, in some cases and where technically feasible,
you have the right to have your personal data transferred to a third party in a machine-readable format; (ii) ask us to limit or cease using or erase the personal data that we hold about you in certain circumstances and in responding to such requests,
we will explain to you the impact of such restrictions or deletions, for example, on our ability to provide all the functions of the Site to you; (iii) ask us to rectify any inaccurate data we may hold about you - and you can inform of us of any changes
to your personal details for us to make; (iv) where relevant, object to us using your personal data on the basis of our legitimate interests (see the
How We Use Your Informationand the
Marketing/Your Choicessection); and (v) lodge a complaint about us to the relevant supervisory authority for personal data, e.g., in the UK this is Information Commissioner’s Office (https://ico.org.uk/). You may act on your rights at any time by
contacting us using the details set out in this Notice and we will comply with your requests unless we have a lawful reason not to do so and within a reasonable period and, in any event, we will respond to you (even if we require an extension of time)
within one month of the original request. Prior to meeting such requests, we may require you to confirm your identity by providing approved identification. We will not charge you unless your request is manifestly unfounded or excessive, in which case
we may refuse to comply.
11. International Data Transfers
The Sites are designed for and targeted to U.S. and Canadian audiences and governed by and operated in accordance with the laws of the U.S. and Canada.
Please note that any information that you provide to us is being transferred to or collected in the U.S. and U.S. law governs. U.S. law may not provide the same level of data or privacy protection as your home territory outside the U.S.
BY CONTINUING TO USE THESE SITES AND/OR SUBMITTING YOUR PERSONALLY IDENTIFIABLE INFORMATION, YOU CERTIFY THAT YOU MEET AGE AND OTHER ELIGIBILITY REQUIREMENTS FOR THE SITE AS SET FORTH IN THIS NOTICE AS WELL AS THE TERMS AND CONDITIONS, AND CONSENT TO COLLECTION, USE, DISCLOSURE, STORAGE AND TRANSFER OF YOUR PERSONNALLY IDENTIFIABLE INFORMATION OUTSIDE THE EEA, SWITZERLAND, CANADA, OR ANY OTHER NON U.S. JURISDICTION IN ACCORDANCE WITH THIS NOTICE.
Note to EU Individuals only: Notwithstanding the foregoing, where we are conducting EU Processing we will ensure appropriate safeguards are put in place to protect your personal data which give personal data the same protection it has
in Europe, as applicable see https://ec.europa.eu/info/law/law-topic/data-protection_en.
12. Anonymous Registration
If you are a Student using our Sites as part of a required course adoption and you do not want to provide us with your name, you may register under an alias. You will need to create an alias and create and open an e-mail account under that alias with
process, which you will complete under your alias. IT IS CRITICAL THAT YOU MAKE SURE YOU INFORM YOUR INSTRUCTOR OF YOUR ALIAS SO THAT HE/SHE HAS ACCESS TO YOUR WORK. Do NOT provide Macmillan Learning with any information that would enable us to link your
alias to your real name.
13. Business Transactions
We may transfer any information we have about you as an asset in connection with a proposed or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of us or as part of a corporate reorganization
or other change in corporate control. We cannot guarantee such entity will have the same privacy practices or follow the practices described in this Notice. However, we will provide such entity with this Privacy and Cookie Notice so that they are aware
of the terms hereunder.
14. Updates To Our Online Privacy Notice
Changes to this Notice will become effective when those changes are posted to the Sites or otherwise notified to you as required by applicable law. Your continued use of the Sites subsequent to any such notified change to this Notice constitutes your
acceptance of the change subject to the contents of the specific notification. We indicate the effective date of this Notice (and any updates) at the top of the Notice.
16. Canadian Residents
If you are a resident of Canada, the following Canadian-specific provisions apply to our processing of your personal information in lieu of and in addition to the relevant sections of the Privacy Notice. In the event of any inconsistency, this Section
References to “we”, “us”, “our” in the Privacy Notice are references to the BFW Publishers entity responsible for the processing of your personal information.
Personally Identifiable Information means all information about an identifiable individual. Non-Personally Identifiable Information means information that is non-identifiable. To the extent Non-Personally Identifiable Information can be used, alone or
in combination with other information, to identify an individual, we treat it as Personally Identifiable Information.
We collect and use Student Data for the purposes of providing services to Students on behalf of our educational institution clients. We may also contact Students by email to obtain feedback on our products and services. We may use non-Personally Identifiable
Information to improve our Sites and product and service offerings.
Legal Requirements: We and our Canadian, U.S. and other service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order (which may include lawful access by Canadian, U.S. or other foreign
governmental authorities, courts or law enforcement agencies), to other organizations in the case of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by
applicable Canadian, U.S. or other law.
17. Notice to New Zealand and Australian Residents
i. No Exclusion
None of the provisions of this Notice are to be read as excluding any applicable mandatory or non-excludable law.
ii. Personal Information
“Personally Identifiable Information” means information about an individual who is identified or reasonably identifiable.
“Non-Personally Identifiable Information” means any information about an individual where that individual is not identified or reasonably identifiable.
iii. Information We Share
You also consent to us providing your personal information to authorized third parties, who may use that information to market products and services to you.
iv. International Data Transfers
We will take all reasonable steps, using such security safeguards as it is reasonable to take in the circumstances, to ensure that your personal information is held securely and protected (including against unauthorized access, loss and misuse).
If it is necessary for the information to be given to a third party (as permitted under this policy) we will take reasonable steps to minimize the risk of unauthorized use or disclosure.
iv. Failure to Provide Personally Identifiable Information
In some cases, you may wish not to provide us with Personally Identifiable Information. If however, you fail to do so, in some cases we may not be able to provide you with products, services or assistance, or to respond adequately to you.
1 BFW Publishers and Bedford, Freeman & Worth High School Publishers are assumed names of Bedford, Freeman & Worth Publishing Group, LLC.
2 Behavioral advertising is omitted in areas of the Sites which are created for Students.