Last Updated: February 9, 2021
- 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)
IMPORTANT NOTICE FOR USERS
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 firstname.lastname@example.org.
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.
71 West 23rd Street, 15th Floor
New York, NY 10010
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.
STORAGE AND TRANSFER
Our servers are located in the United States, Canada, Australia and Ireland. We have office
locations in the United States and India. Clients located in the EEA will have their data stored in
Ireland. Watermark relies upon the Standard Contractual Clauses, in their current form, as the
transfer mechanism for transfers of data from the EEA.
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.
“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
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
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.
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 email@example.com. We will respond to your request within a reasonable timeframe. In addition, if you are a resident of the EU, you can object to processing of your personal
information, ask us to restrict processing of your personal information or request portability of
your personal information.
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 firstname.lastname@example.org.
Similarly, if we have collected and process your personal information with your consent, then
you can withdraw your consent at any time. Withdrawing your consent will not affect the
lawfulness of any processing we conducted prior to your withdrawal, nor will it affect
processing of your personal information conducted in reliance on lawful processing grounds
other than consent.
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 email@example.com.
Watermark Insights, LLC
71 West 23rd Street, 15th Floor
New York, NY 10010