Last Updated: November 25, 2019

Watermark Holdings, LLC (“Watermark”) has prepared this Privacy Policy to describe our practices regarding the personal information that may be collected from users of our websites, applications, and other related services (“Services”). Our Services include:

  • Assessment & Accreditation Planning (AMS, P&SS, Tk20)
  • Course Evaluation & Institutional Surveys (EvaluationKIT)
  • Curriculum & Catalog Management (SmartCatalog)
  • ePortfolios & Student Assessment (LAT, Tk20, LiveText, Via)
  • Faculty Activity Reporting (Digital Measures)
  • Learning Outcomes Measurement (Aqua)

The use of personal information collected through our Services shall be limited to the purposes described in this Privacy Policy. Our products and services, as well as our privacy policies, are regularly audited and inspected by both employees and external consultants to ensure that we meet privacy expectations and requirements. This Privacy Policy describes how Watermark collects and uses the personal information you provide. It also describes the choices available to you regarding the use of your personal information, and your ability to access, update and correct your personal information.

IMPORTANT NOTICE FOR USERS

This Privacy Policy does not govern the collection, use, or disclosure of personal information through the Service by the educational institution which has given you access to the Services, or which is providing a course evaluation or survey you are taking via the Services. Please contact your educational institution to better understand its specific privacy practices.

PRIVACY SHIELD

Watermark Holdings, LLC complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Data transferred from EU and Switzerland to the United States, respectively. Watermark Holdings, LLC has certified to the Department of Commerce that its business websites and services, www.watermarkinsights.com, EvaluationKIT (evaluationkit.com) and Digital Measures (www.digitalmeasures.com), adheres to the Privacy Shield Principles, and as such are committed to subject all Personal Data received from the EU or Switzerland in reliance on this policy to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List: https://www.privacyshield.gov/list.

Watermark Holdings, LLC’s business websites, as well as the Services for EvaluationKIT and Digital Measures, are responsible for the processing of personal data they receive, under each Privacy Shield Framework, and subsequently transfer to a third party acting as an agent on its behalf. Watermark Holdings, LLC’s business websites, as well as the Services for EvaluationKIT and Digital Measures, comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

Residents of the EU and Switzerland have the right to access the personal information that Watermark Holdings, LLC’s business websites, as well as the Services for EvaluationKIT and Digital Measures, maintain, and in some cases, may have the right to correct or amend information that is inaccurate or has been processed in violation of the Privacy Shield Principles, to the extent allowed by law. To exercise this right, contact us at privacy@watermarkinsights.com.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Watermark Holdings, LLC’s business websites, as well as the Services for EvaluationKIT and Digital Measures, are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Watermark Holdings, LLC’s business websites, as well as the Services for EvaluationKIT and Digital Measures, may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Residents of the EU and Switzerland with inquiries or complaints regarding this Privacy Policy should first contact Watermark Insights at:

privacy@watermarkinsights.com
71 West 23rd Street, 15th Floor
New York, NY 10010
212.868.2700

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

EvaluationKIT has also taken a stand for safeguarding student data and privacy and want to make sure that educators and end-users know that we have taken the Student Privacy Pledge, put forth by the Future of Privacy Forum (FPF) and the Software & Information Industry Association (SIIA). Learn more at: https://studentprivacypledge.org.

THE DATA YOU PROVIDE THROUGH OUR SERVICES

Watermark collects information under the direction of its client educational institutions and has no direct relationship with the individuals whose personal data it processes. Watermark works with its clients to help them provide notice to users concerning the purpose for which personal information is collected. Watermark may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our clients.

In order to gain access to our websites and take advantage of the Services, you will need to provide information as part of a registration process. The requested personal information may include, but is not limited to the following: first and last name, username, phone number, e-mail address, physical address, gender, race, date of birth, and which courses a user is enrolled in.

You may ask Watermark to correct, amend, or delete data, or withdraw consent for further contact, by directing a query to the educational institution that is Watermark’s client (the data controller). If you are an individual user who has questions or would like to make changes to your personal information, please contact the educational institution through which you use our Service.

Watermark will retain personal information we process on behalf of its client organizations for as long as needed to provide services and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

THE DATA YOU PROVIDE ON OUR CORPORATE WEBSITES

We may collect the following personal information from you, including, but not limited to:

  • Contact Information such as name, email address, physical address, phone number, job title and department
  • Information about your institution such as institution name, number of enrollments, and current learning management system
DATA COLLECTED VIA TECHNOLOGY

To make our Services more useful to you, our servers or authorized third parties may collect information from you, including browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, unique device identifiers, information about how you use our Services and/or a date/time stamp for your visit to analyze trends in the aggregate and administer the site.

Watermark and our partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level.

In accepting this Privacy Policy, you consent to our placement and continued use of cookies on your device. To learn more about cookies, including how to delete cookies, please visit http://www.allaboutcookies.org/.

“COOKIES” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and integrated experience with our application.

USE OF YOUR INFORMATION

We use the information we collect from our corporate websites in the following ways:

  • Respond to your request for more information and demonstration scheduling
  • Send you marketing communications
  • Respond to your questions and concerns
  • Providing and improving the Services
DISCLOSURE OF YOUR PERSONAL INFORMATION

We will share your personal information with third parties only in the ways that are described in our privacy policy. If we transfer personal information to a third party that is acting as our agent, we will require that the third party agree to confidentiality requirements. We do not sell personal information to third parties.

THIRD PARTY SERVICE PROVIDERS

We may share your personal information with third party service providers that we work with for the sole purpose of providing you with the Services that we offer. These third party services may include, but are not limited to:

  • To host our website and application
  • Provide email services on our behalf
  • Providing customer service
  • Sending marketing communications
  • To deliver a better customer experience
EDUCATIONAL INSTITUTIONS

We may share your information with the educational institution which is linked to your use of the Services. For example, this would apply if your educational institution uses our Services as a course evaluation and survey platform and has given you access to the Services.

LEGAL DISCLOSURE

In certain situations, Watermark may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

USER ACCESS AND CHOICE

Upon your request, Watermark will provide you with information about whether we hold any of your personal information. You may ask Watermark for access to your personal information, or to request a correction or deletion of your personal information by contacting us at privacy@watermarkinsights.com. We will respond to your request within a reasonable timeframe.

We partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third-party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.

If you wish to subscribe to our marketing emails, we will use your name and email address to send the newsletter to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page, or you can contact us at privacy@watermarkinsights.com.

SECURITY

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. Our data is hosted in the United States with robust physical, technical, and procedural safeguards to protect your personal information, including the use of firewalls, standard SSL/TLS encryption, and backup servers. All user accounts require authentication. If you have any questions about the security of your personal information, you can contact us at privacy@watermarkinsights.com.

CONTACT US

Please direct all inquiries regarding the Privacy Policy as follows:

EMAIL
privacy@watermarkinsights.com

MAIL
Watermark Insights, LLC
71 West 23rd Street, 15th Floor
New York, NY 10010

PHONE
212.868.2700

CHANGES TO THIS PRIVACY POLICY

Watermark may change this Privacy Policy from time to time. If we make any changes to this Policy, we will change the “Last Updated” date at the top of this document. If such changes are material, either a notice of the changes will be posted along with the revised Privacy Policy, or we will notify you via email, prior to the change becoming effective.