Last updated: June 9, 2021
General Privacy Policy
I. GENERAL
At Palmer Hamilton LLC (“us,” “we,” or “INVENTORCLOUD”), we take the security and privacy of user data seriously. We are committed to complying with the privacy laws that apply to our website (www.inventorcloud.org), and your use of the programs, products, services and projects offered through our website (“the Platform”). This Privacy Policy along with our Terms of Use which can be found at www.inventorcloud.org/terms-of-use/, detail our data processing activities and our commitment to protecting data that is entrusted to us by you through your use of the Platform. If you are a resident of California, please read the Additional Information for California Residents at the end of this policy.
Users of the Platform (“Users”) fall into three categories:
- “Students” are Users who are enrolled at a school or educational institution and using the Platform under an agreement we have with that school, educational institution or the applicable school district in which such school or education institution is affiliated (collectively, “School”).
- “Educators” are Users who are teachers or administrators of Students using the Platform under an agreement we have with the Student and Educator’s affiliated School.
- “Independent Study Users” are Users who contract with us directly to use the Platform independently of any agreement we may have with a school, educational institution or school district.
We use the term “User Information” in this policy to refer to information that personally identifies a User of the Platform as well as other information we receive or create in the course of a User’s usage of the Platform. We use the term “Student Information” to refer to User Information that specifically pertains to a Student.
II. DATA WE COLLECT
When you register for, access and use the Platform, you or your School may provide us with Personal Data, Device Data and/or Usage Data (as defined below).
Personal Data
For the general purposes of authentication, class roster management, and compliance with applicable laws, we collect information that is used to identify individual Users (the “Personal Data”). Personal Data does not include Data that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person or device.
The Personal Data that we collect from Users includes:
| Personal Data | User type | Purpose | Required? | Stored? |
| First and last name | Students, Educators, and Independent Study Users | Identification | Yes | Yes |
| Email address | Students, Educators, and Independent Study Users | Identification, authentication, notifications | Yes | Yes |
| Telephone number | Students, Educators, and Independent Study Users | Identification, consultation with Educators | Yes | Yes |
| Grade level | Students, Educators, and Independent Study Users | Identification | Yes | Yes |
| Home Address | Independent Study Users | Credit Card Billing | Yes | Yes |
| School name and District Name | Educators | Identification | Yes | Yes |
| School address | Student and Educators | Identification | Yes | Yes |
| Subject matters taught | Educators | Identification, recommendations for curriculum and targeted content | ||
| Age | Independent Study Users | COPPA compliance | Yes | No |
We collect information from you directly when you visit the Platform and register for an INVENTORCLOUD account. Some of this information may be considered Personal Data under various applicable laws. Note that we may de-identify Personal Data so that it is non-personal, such as by aggregating it or converting it to a code. We will treat de-identified information as non-personal to the fullest extent permitted by applicable law.
You have the right to decline to share certain elements of Personal Data that we ask you to provide, but must note that doing so may limit your use of certain features and functionality of the Platform. You may edit certain Personal Data you provide to INVENTORCLOUD at any time by accessing your account through the Platform.
Device Data
Like most web-based services, we (or our Service Providers) may automatically receive and log information from your browser or your device when you use our Platform (“Device Data”). Examples of Device Data we may automatically receive and log when you use the Platform include web browser type, your device’s operating system, and your device’s geolocation, among others.
We take measures to ensure that our Platform and our Service Providers only collect the minimum amount of Device Data needed to deliver the Platform in a seamless way, help us improve our products, and deliver high-quality customer support. The Device Data we collect is analyzed and may be aggregated and combined with similar aggregate Device Data of other users the Platform, as well as associated with the Personal Data of individual Users. If you use INVENTORCLOUD on different devices, we may link the information we collect from those different devices to help us provide a consistent Platform experience across your different devices.
Usage Data
User interactions with our Platform generate data we refer to as “Usage Data”. Usage Data for Students and Independent Study Users may include, for example, the projects a User chooses to complete, when the User starts and stops a lesson, and student responses in the lesson. Usage Data for Educators may include their class rosters. We also may track mouse clicks and taps, mouse movement, webpages entered and exited, the number of pages visited by a User, and the duration and dates of visits.
Usage Data will be used for educational and product development purposes only.
III. HOW WE USE DATA
Personal Data
We and our third-party vendors (“Service Providers”) use Personal Data to: (i) provide and maintain the Platform, (ii) comply with applicable laws, and (iii) promote our products, systems, and tools. Examples of how we may use Personal Data include:
- To authenticate a user’s identity;
- To customize the features that we make available to you;
- To respond to inquiries, send service notices and provide customer support;
- To communicate regarding a payment, and provide related customer service;
- For regulatory purposes and compliance with industry standards;
- To send communications about new features and products;
- To determine if a student is under 13 for the purposes of COPPA compliance;
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Users is among the assets transferred.
Device Data
We use other Device Data to improve the product, deliver a consistent and enjoyable experience, debug, provide customer support, and for aggregate analysis.
Usage Data
We use Usage Data to test and improve our products, services, projects and the Platform. We also use de-identified aggregate Usage Data to develop new products, improve or modify our Platform, conduct analysis and develop business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of, our business.
Cookies and similar technologies
We and our Service Providers use cookies and local storage to help provide you with a better, faster, and safer experience. Cookies are small files that websites place on your computer as you browse the web. Local storage is an industry-standard technology that allows a website or application to store information locally on your computer or mobile device.
Here are some of the ways that we and our Service Providers use these technologies: to log you into the Platform, save your preferences, personalize your experience, and protect against abuse. You may set your browser to reject cookies; however, this may affect some functions of the Platform.
As a general matter, we consciously avoid Personal, Device and Usage Data in cookies and local storage. While we use these technologies to help identify user sessions, the information contained is only meaningful to the Platform itself.
IV. HOW WE SHARE DATA
We do not disclose, share, rent, or sell any User Information to any third parties for commercial uses, such as targeted advertising. We only disclose or share User Information with bona fide Service Providers for purposes related to or arising out of the ordinary course of creation, development, operation, service, and maintenance of the Platform. Such bona fide Service Providers shall only use such User Information for such purposes and not to sell such User Information under any circumstances.
Service Providers who do help us operate our Platform must adhere to privacy and security obligations in a manner consistent with the Company’s policies and practices. Below is a list of our Service Providers with whom we may share User Information and the services they generally provide.
| Service Provider | Purpose of data sharing |
| JetRails | Cloud hosting and data warehousing |
| Google Analytics | Tracking and reporting |
| Hotjar | Survey response collection and feature usage research |
| Taxjar | Sales tax calculation |
| Mailchimp | Marketing |
| Zendesk Chat | Chats |
| WordPress | Website host |
In addition to the Service Providers just listed, we also use vendors to process payment for the Platform such as Stripe, PayPal and Apple. Those vendors use and process your information in accordance with their own terms and privacy policies.
V. EDUCATOR USERS AND STUDENT INFORMATION
If you are a Student using the Platform in connection with an Educator or School, your School and Educator may have the ability to disable your account. Additionally, Educators may create Student accounts on behalf of Students and in so doing, provide INVENTORCLOUD with the Student Information. If you are an Educator, you agree that you will obtain and maintain all required consents from Student Users or their parents or legal guardians (when such Students are under the age of 13 or the age of consent in the state in which the Student resides) to allow: (i) your access, monitoring, use, editing, deleting, and disclosure of their Student Information and our providing you with the ability to do so, and (ii) your Student’s use of the Platform.
If you are a Student using the Platform in connection with a School and do not believe that you, your parent or your legal guardian has provided consent for the School or applicable Educator Users to access, monitor, use, edit, delete, or disclose data related to your Usage Data and Personal Data, please contact us immediately at support@inventorcloud.org.
VI. PRIVACY
INVENTORCLOUD secures User Information both in transit and at rest via encryption. We use modern cryptographic algorithms like AES256 with strict user access control and multi-factor authentication.
VII. DATA RETENTION
We retain User Information to provide the Platform to you and our other Users and to provide a useful user experience. However, we do not retain User Information longer than is necessary to do so. There may be some instances where we retain non-personal data in a depersonalized or aggregated form.
Following the termination of an agreement we may have with a School, a School may request that we delete and/or de-identify certain Personal Data related to its Students and Educators, and we will do so, unless the School or applicable regulations require the retention of such data, in which case the records shall be de-identified upon the expiration of the retention period.
Please note that the requested deletion will be as comprehensive as possible but is always subject to issues outside of our control, including applicable regulations and laws, your actions and the actions of third parties. We may also need to retain a copy of certain information for legal compliance purposes, including, without limitation, to avoid identity theft or fraud.
VII. VIEWING AND CORRECTING INFORMATION
Users may review and correct their User Information by viewing their INVENTORCLOUD account. A parent or guardian may review and correct Student Information in the applicable student’s records by viewing the Student’s INVENTORCLOUD account. Users of the Platform or visitors of the website who do not have an active INVENTORCLOUD account may request to access, correct or delete any of its Personal Data by contacting INVENTORCLOUD in accordance with the Contacting Us section of this Privacy Policy.
IX. USERS UNDER 13 YEARS OF AGE
In accordance with the Children’s Online Privacy Protection Act (“COPPA”), we require parental consent for students under the age of 13 who wish to use INVENTORCLOUD (“Child Users”). INVENTORCLOUD does not knowingly permit Child Users to register directly for our Platform without the consent of a Parent (defined below) or the Child User’s school on behalf of a Parent. If INVENTORCLOUD learns that Personal Data of a Child User has been collected on the Platform without parental consent, then INVENTORCLOUD will take appropriate steps to delete this information. If you are a parent or legal guardian (“Parent”) and discover that your child under the age of 13 has an account with the Platform without your consent, please alert us at support@inventorcloud.org.
There are two acceptable ways for Child Users to sign up for the Platform:
Self registration.
When a Child User registers for our Platform, we ask for a credit card as payment and for verification of parental or guardian consent to collect User Information of a Child User.
School registration.
When the Child User is enrolled at a School, we permit the School to provide the requisite consent for INVENTORCLOUD to collect User Information of a Child User for this purpose, in lieu of parental consent. Schools may provide a Child User with an account by providing the Child User with an account code. When Schools provide access to a Child User in this manner, we do not request additional consent from the Parent, as we require Schools to gather those consents or to consent on behalf of the Child User.
Parents who provide consent under a Child User’s self-registration may review their child’s Personal Data on INVENTORCLOUD, direct us to delete it, and refuse to allow any further collection or use of their child’s information by INVENTORCLOUD by revoking their consent. Parents seeking to revoke their consent, review their child’s information, and request a deletion of their child’s Personal Data should contact us at support@inventorcloud.org.
X. NOTICE OF CHANGES
We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make material changes to this Privacy Policy, we will provide notification via the emails associated with the profiles of our Users or, as applicable, users of our website who provided email addresses as part of their Personal Data. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
XI. CONTACTING US
If you have any questions or comments about this notice, the ways in which INVENTORCLOUD collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights under law, please do not hesitate to contact us at:
Phone: 1-800-788-1028
Website: www.inventorcloud.org/contact
Email: support@inventorcloud.org
Postal Address: Palmer Hamilton, Attn: INVENTORCLOUD, 143 S Jackson Street, Elkhorn, WI 53121
California Privacy Policy
This California Privacy Policy supplements the information contained in the General Privacy Policy and applies solely to all Users who reside in the State of California. The information concerning the information we gather and how we use it should be the same in both the General Privacy Policy and the California Privacy Policy; but to the extent that they are inconsistent, then Users who reside in the State of California should rely upon this California Privacy Policy.
INVENTORCLOUD is adopting this California Privacy Policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Policy.
Where noted in this California Privacy Policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B Personal Information”) from some its requirements.
C1. INFORMATION WE COLLECT
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”).
In particular, we collected the following categories of Personal Information from consumers within the last twelve (12) months:
| Category | Examples | Collected |
| Identifiers. | Real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. | Yes |
| Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | Name, signature, education, employment. Some Personal Information included in this category may overlap with other categories. | Yes |
| Commercial information. | Records of projects purchased by each Independent Study User. | Yes |
| Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | Yes |
| Professional or employment-related information. | Current or past job history or performance evaluations. | Yes |
| Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | Yes |
We obtain the categories of Personal Information listed above from the categories of sources described in Section 2 of the General Privacy Policy (Data We Collect).
We may use or disclose the Personal Information we collect for one or more of the following purposes set forth in Paragraph 3 of the General Privacy Policy (How We Use Data).
C2. SHARING PERSONAL INFORMATION
In the preceding twelve (12) months, we have disclosed the following categories of Personal Information business purposes:
We disclose your Personal Information for a business purpose to the service providers set forth in Section 4 of the General Privacy Policy (How We Share Data).
If you are registered through your School, then we may disclosure your Personal Information to your School.
We do not sell Personal Information, and in the preceding twelve (12) months we have not sold any Personal Information.
C3. YOUR RIGHTS AND CHOICES
The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes California residents’ CCPA rights and explains how to exercise those rights.
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months (the “right to know”). Once we receive your request and confirm your identity (see “Exercising Your Rights to Know or Delete”), we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting that personal information.
- The categories of third parties with whom we share that Personal Information.
- If we disclosed your Personal Information for a business purpose, a list of disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
- The specific pieces of Personal Information we collected about you.
We do not provide a right to know disclosure for B2B Personal Information.
Right to Delete
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions (the “right to delete”). See “Exercising Your Rights to Know or Delete” to submit a deletion request. Certain information may be exempt from such requests. For example, we may retain certain information for legal compliance and to secure our services. We may need certain information in order to provide the services to you; if you ask us to delete it, you may no longer be able to use the Platform.
We do not provide these deletion rights for B2B personal information.
Exercising Your Rights to Know or Delete
You can submit a right to know or right to delete request described above at https://inventorcloud.org/contact, or by sending an email to: support@inventorcloud.org.
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. To designate an authorized agent please send a written request to INVENTORCLOUD at 143 S Jackson Street, Elkhorn, WI 53121.
You may also make a request, as a parent or legal guardian, to know or delete on behalf of your child by sending a written request to INVENTORCLOUD at 143 S Jackson Street, Elkhorn, WI 53121.
You may only submit a request to know twice within a 12-month period. We will take reasonable steps to verify your identity before responding to a request.
Requests by a User to know or delete must be verified through your password protected account.
We will only use Personal Information provided in the request to verify the requestor’s identity or authority to make it.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact support@inventorcloud.org.
C4. Non-Discrimination
The CCPA further provides you with the right not to be discriminated against (as provided in applicable law) for exercising your rights.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
California’s “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.
