Nuventive, LLC (Nuventive) is a Delaware limited liability company with its principal place of business in Pittsburgh, Pennsylvania, USA. Nuventive is an education-focused technology and consulting company. You can find out more about Nuventive on its web site at www.nuventive.com.
Nuventive's iWEBFOLIO® software application is a tool that provides a subscriber with the ability to store, organize, and display the subscriber's personal "learning" evidence to third parties (such as faculty, admissions offices of educational institutions, employers, etc.). Subscribers can create any number of views of the subscriber's work or selected materials (the work or materials that the subscriber wants to display are stored as electronic files in individual electronic portfolios). Each portfolio has its own user-controlled security profile, thus allowing the subscriber to decide who will have access to a specific portfolio.
iWEBFOLIO® is a browser based software tool and Nuventive's servers are located in the United States. All personal information provided to Nuventive is stored and processed in the United States.
It is the intent of Nuventive to be in compliance with the principles of the Personal Information Protection and Electronic Documents Act of Canada, the Safe Harbor Agreement between the United States and the European Commission (Safe Harbor Principles, published by the U.S. Department of Commerce on July 21, 2000), the Data Protection Act 1998 of the United Kingdom, and selected legislation worldwide regarding privacy of data.
Nuventive is responsible for any personal information under its control, including personal information that may be transferred to a third party for processing.
PURPOSES OF COLLECTION
Nuventive will identify the purposes for which it collects, uses and discloses personal information at or before the time of collection. Nuventive will only collect personal information that is reasonably necessary for the purposes that have been identified by it.
Nuventive collects, uses and discloses personal information for the following purposes:
If Nuventive proposes to use or disclose personal information which it has collected for a purpose not previously identified, Nuventive will make a reasonable effort to identify this purpose to the individual from whom the personal information was collected (either orally, in writing, by e-mail, by posting a notice on Nuventive's web site(s) or by any other means deemed appropriate in the circumstances) and obtain such individual's consent before such new use or disclosure. Nuventive will state such new purpose in such a manner that an individual can reasonably understand how his or her personal information will be used or disclosed. Nuventive will document the purposes for which personal information is collected.
CONSENT - USE OF NUVENTIVE AND iWEBFOLIO® WEB SITES AND iWEBFOLIO® SOFTWARE APPLICATION
If you are a Nuventive iWEBFOLIO® subscriber or licensed User, you have provided a Username and Password that allows you to sign in and access iWEBFOLIO®. This Username and Password enables you to log in to Nuventive's iWEBFOLIO® web site, and it also serves as the only means of authenticating your identity on Nuventive's www.iwebfolio.com web site and as an authorized User of iWEBFOLIO®. You should not give your Username or Password to a third party - anyone who has your Username and Password can log in to iWEBFOLIO® and view all information that you have stored in your portfolios.
Depending on the circumstances, Nuventive may obtain consent from individuals by other means, including, in writing, orally, by e-mail or other electronic means. The way in which Nuventive will seek consent, including whether express or implied consent is sought, may vary depending on the sensitivity of the personal information and the reasonable expectation of the individual supplying it.
Nuventive will not, as a condition of the licensing of a product or supply of a service, require an individual to consent to the collection, use or disclosure of personal information greater in scope than that required by Nuventive to fulfill the specified and legitimate purposes for which it was collected.
Subject to legal or contractual restrictions and upon reasonable notice to Nuventive, an individual may withdraw his or her consent at any time by contacting Nuventive's Privacy Officer. Nuventive will inform an individual of the implications of withdrawing consent, including but not limited to the loss or inaccessibility of any personal information or other data that may be stored in iWEBFOLIO®.
LIMITING COLLECTION, USE AND DISCLOSURE
The iWEBFOLIO® software tool permits Users to store information with Nuventive, as part of the use of the tool, and to make such information accessible to third parties chosen by the User. Except for information selected and stored by Users in iWEBFOLIO®, Nuventive will limit its collection of personal information to the amount and type of personal information which it needs for its identified purposes, and Nuventive will only collect personal information by fair and lawful means and not indiscriminately.
Personal information will only be used or disclosed for the purposes for which it was collected, except with the consent of the applicable individual (which consent is implied by use of iWEBFOLIO® for delivery of information to User-selected third parties, including any school or institution with which User is affiliated) or as permitted or required by law.
COLLECTION AND USE OF INFORMATION
In order to ensure that Nuventive's web sites are useful and effective for its Users, Nuventive uses log files to analyze information. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track visitor's movement in the aggregate, and gather broad demographic information for aggregate use. These types of log files are not linked to personal information. Nuventive uses these statistics to improve site content and usability; this information does not identify visitors personally.
Visitors are not required to be Nuventive iWEBFOLIO® subscribers in order to gain access to Nuventive's public web sites, with the exception of specific secured pages. However, when a User enters a Nuventive subscriber Username and Password in order to access iWEBFOLIO® or other secured pages, a "cookie" may be deployed. If the User clicks "Save Login Information", the User Username will be saved in a "cookie" - a small text file stored on the visitor's browser - on the User's computer, so that the User will not have retype the Username the next time the User visits the iWEBFOLIO® web site. In addition, the iWEBFOLIO® web site uses the "Secure Sockets Layer" security protocol ("SSL") - a standard industry security technology that protects web communications. SSL will write a "temporary cookie" to the User's computer. This cookie enables the web site to "remember" this authentication information during movement from one page to another during a session. This makes it unnecessary to log in again on each page. The temporary cookie only saves assigned identification information for the session and contains no personal information. If you have set your Internet web browser to reject cookies, access may be denied to secured areas of Nuventive's web sites.
Nuventive also collects limited personal information from Users and prospective Users worldwide in order to provide iWEBFOLIO® and related services to Users. Examples of this information would be: name, email address, and also other information necessary to process credit card payment for the purchase by Users of subscriptions to iWEBFOLIO®.
In addition, the nature and purpose of iWEBFOLIO® is to organize and store, and subsequently display to User-selected third parties, certain information and files selected by Users, which information is uploaded, in electronic file format, by Users to iWEBFOLIO®. It is the User's choice to include or not include personal information in such files, or to grant permission to third parties to view the User's portfolio. These uploaded files are selected by the User, and can be in virtually any electronic file format (e.g., Word documents, electronic spreadsheets, pdf format files, graphics, video and sound files, and links to other files accessible through the Internet from outside of the iWEBFOLIO® program).
A User's electronic portfolio can be viewed by persons who are given "permission" by the User to view the portfolio, and these permissions may be designated to expire on a date selected by the User, or after a User-determined number of accesses to the portfolio by the person granted such permission. After expiration, clicking on the link embedded in the email will not access or open the portfolio. Permission to view a portfolio is enabled in iWEBFOLIO® by entering the permitted viewer's email address, and the application generates an email message to the permitted viewer, who then can click on an embedded link in the email to open and view the portfolio in the viewer's web browser. (Users should be aware that there are laws that govern unsolicited email communications, and Users should seek the consent of the prospective viewer to receive an email from Nuventive containing a link to iWEBFOLIO®.) The permission granted by a User can permit the viewer to provide feedback to the User in the form of comments that are recorded and viewable in iWEBFOLIO® by the User.
The viewer has the ability to copy or print all or part of the electronic portfolio, or to forward the email (with the embedded link) or any of the files in the portfolio to third parties, who would also have the ability to copy, print or forward the information. Transfer of this data to Nuventive, (i) for storage and display on Nuventive's servers, (ii) by a User to his or her selected permitted viewers, and (iii) by a viewer to provide feedback to a User on the User's portfolio, is allowed through the explicit consent of the Users (as subscribers to or licensees of iWEBFOLIO®), and through adherence of Nuventive to the Safe Harbor Principles. A User who does not desire the transfer of his or her personal information to third parties can prevent such transfer by not including such information in the portfolio, or by not granting any permissions to third party viewers in iWEBFOLIO®.
If the User is a member of a school or institution affiliated group, and uses his or her portfolio to provide access to information to the institution and to administrators, faculty members, students and others who are part of the affiliated group, the institution and all others granted access as part of the affiliated group will be able to view, store and use such information. In addition, if the institution extracts data, including rating data, from the User’s portfolio based on information provided by the User through use of an iWebfolio template, the institution may have access to the User’s demographic data (e.g., student identification number, gender, etc.), which can be matched by the school or institution with the rating data so extracted.
In addition to providing access to any affiliated institution and members of that affiliated group, a User may also grant permission to Nuventive to access and use personal information and other data stored in the User’s portfolios. Nuventive also may access such information for the purposes of obtaining aggregated statistical information regarding use and information stored in iWEBFOLIO®, maintaining iWEBFOLIO®, and responding to service requests, support requests, notices of deficiencies, or operational problems with access to or use of iWEBFOLIO® received from Users or others.
COMMUNICATIONS FROM NUVENTIVE
SUBSCRIBER SERVICES: Nuventive uses personal information Users have voluntarily provided to Nuventive on its web sites, or by other means, to notify Users via e-mail or printed material of Nuventive events or other relevant products and services offered by Nuventive, or to respond to service or support requests. Also, if you are part of a Nuventive user group or committee, Nuventive may include your contact information in its directory of such Users for networking purposes.
NEWSLETTER: In the event that Nuventive publishes a newsletter for Users or User groups, Nuventive may contact Users and request permission to provide Users with the newsletter. In order to provide any newsletter to Users who grant permission, Nuventive may ask Users for certain contact information such as name, address and email address. Out of respect for our Users' privacy, Nuventive will provide a way to opt-out of these communications.
SUBSCRIBER SERVICES: Nuventive uses personal information Users have voluntarily provided to Nuventive on its web sites, or by other means, to notify Users via e-mail or printed material of Nuventive events or other relevant products and services offered by Nuventive. Nuventive communicates with Users on a regular basis to provide requested services, answer support questions and in regards to issues relating to User accounts or licenses. Typically, Nuventive would communicate with Users via email, but such communication may be by other means, such as telephone or mail. Also, if you are part of a Nuventive user group or committee, Nuventive may include your contact information in its directory of such Users for networking purposes. Users who wish to receive marketing information from Nuventive may be requested to signify this to Nuventive at the time of subscribing, or at a later time. If you wish to unsubscribe from receiving marketing materials please inform Nuventive's Privacy Officer.
DISCLOSURE OF INFORMATION TO THIRD PARTIES
Nuventive does not disclose personal information of its Users to third parties, except as authorized by its Users, as disclosed to third party service providers to Nuventive, or as may be permitted or required by applicable law. In circumstances where a User is affiliated with a school or other institution that has an administrative license from Nuventive for use of iWEBFOLIO®, and under that license such school or institution administers an iWEBFOLIO® "tree structure" to facilitate information sharing among students, faculty and other persons affiliated with the school or institution, certain personal information regarding each affiliated User and such User's electronic portfolios may be accessible to the institution and to other affiliated Users. Users may use the permission granting or feedback capabilities of iWEBFOLIO®, which may result in personal information of its Users stored within the iWEBFOLIO® program being disclosed to third parties.
Nuventive may contact Users from time to time and ask Users if they want to receive information about products or services offered by Nuventive, or companies or organizations that are business affiliates or strategic partners of Nuventive. Personal information or other information regarding Users who respond affirmatively will be given to such third party companies or organizations. Users will be given the ability at the time of subscribing, or at such later time as they may be asked if they want to receive such marketing information, to agree to receiving these requests.
Nuventive will retain personal information provided by a User for use with the iWEBFOLIO® software tool for as long as the User continues to subscribe to and remain a licensee of iWEBFOLIO®, and such User maintains such information in the tool. Otherwise, Nuventive will retain personal information provided by the User only as long as is reasonably necessary or appropriate for the fulfillment of the purposes identified. Where personal information is no longer required to fulfill those purposes, Nuventive will use reasonable efforts to have it destroyed, erased or made anonymous.
ACCURACY AND RIGHT OF ACCESS
Nuventive will use reasonable efforts to ensure that other personal information under its control is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used. Upon request, Nuventive will inform an individual as to whether or not Nuventive holds any personal information about such individual and as to its use and disclosure of such information. If it is not possible to provide a list of the specific organizations to whom information has been disclosed, Nuventive will provide a list of organizations to whom information may have been disclosed. Nuventive will provide reasonable access to Users who want to review their personal information maintained by Nuventive, and to correct any inaccuracies or incompleteness in such information.
Access to personal information also may be requested by emailing firstname.lastname@example.org or by mailing a request to Nuventive's Privacy Officer. Individuals requesting access should receive confirmation of a request within 2-3 business days. Nuventive will respond to an individual's request for access within a reasonable time. Nuventive's response will typically be provided at no cost to the individual, however, Nuventive reserves the right, depending on the nature of the request, to charge the individual for its costs to process the request and to receive payment of such costs prior to processing such request. If it is demonstrated that personal information is inaccurate or incomplete, Nuventive will amend the information as required to the extent more accurate information is provided and, if appropriate, will advise third parties having access to the information in question. If a challenge is not resolved to the satisfaction of the individual, Nuventive will record the substance of the unresolved challenge. Nuventive is not responsible for verifying the continued accuracy of Users' personal information.
In certain circumstances, Nuventive may be unable to provide access to some or all personal information under its control. Those circumstances will be limited to those permitted or required by applicable law. Where permitted, the reasons for such refusal will be provided to the individual upon request.
Nuventive's web sites contain "links" to other sites, including sites operated by Nuventive affiliates or their agents. In addition, Nuventive has provided certain links in the "Utilities" section of the www.iwebfolio.com web site, under "Resources", which are available to Users. Licensees also may request that other links be added to the "Resources" available for Users. Subscribing Users have the ability to store their own selected web site links in iWEBFOLIO®, as a link in an electronic portfolio. Nuventive does not control, and is not responsible for, the accuracy, timeliness, security, or the continued availability or existence of this outside information. Information or content provided on other sites linked from Nuventive's web sites, the iWEBFOLIO® program, or in any User's electronic portfolio, is not necessarily reviewed or screened by Nuventive, nor does Nuventive endorse, warrant, or guarantee products or services described or offered on those other sites. Nuventive is not responsible for the contents of any web sites that choose to link to Nuventive's web sites with or without Nuventive's consent.
Other organizations linked to Nuventive's web sites, or through links contained in a User's electronic portfolio, may collect information about you when you view or click on these sites. Nuventive cannot control this collection of information. You should contact these organizations directly if you have any questions about their use of the information they collect.
INFORMATION PROVIDED IN ELECTRONIC PORTFOLIOS TO THIRD PARTIES; RISK OF DISCLOSURE
Please keep in mind that whenever you voluntarily disclose personal information to third parties through electronic communication - by providing email messages, or granting permission to any person to view and have access to your electronic portfolio - that information can be collected and used by others, including making copies or printing of such information and forwarding such information and access to your portfolio to others. By granting and enabling permission for viewers to view your electronic portfolios, such information, including any sensitive personal information, may be stored, copied, printed, used, published and/or forwarded to others by the viewer, and the privacy of such information cannot be protected. By including sensitive information, such as that pertaining to racial or ethnic origins, political or religious beliefs, financial information, or health or sex life, in any electronic portfolio, you are providing explicit consent to the disclosure of that sensitive information to any viewers that have been granted permission to view your portfolio. Also, you may receive unsolicited messages from viewers and other parties who obtain access to the information contained in your electronic portfolio.
Access to a User's iWEBFOLIO® portfolios, maintained by Nuventive, is password-protected so that only the subscribing User may create and manage the User's portfolios. As described above, however, permitted viewers will have access to any portfolio that they are given permission to view, and viewers may have the ability to provide feedback to the subscriber who created the portfolio.
Nuventive may store and process personal information provided by Users, through such Users' subscription to or use of iWEBFOLIO®, in the United States or any other country where Nuventive, its affiliates, agents or transferees are located. Nuventive staff will have access to Users' portfolios for service, support and maintenance purposes. Schools or other institutions that have an administrative license from Nuventive have the ability to organize and administer a tree structure, which permits access to User portfolios by the institution and by other persons affiliated with the school or institution.
A subscribing User may edit the User's own information stored in the User's portfolios at any time by logging in with his or her Username and Password. Nuventive strongly urges subscribing Users to not divulge their Username and Password to anyone, and to not enable any login storage feature of any web browser or software program, which would permit anyone with access to the subscriber's computer to have access to the subscriber's personal iWEBFOLIO® account. Nuventive also urges Users to log out of iWEBFOLIO® and completely close their web browser window when they have finished visiting the iWEBFOLIO® web site. This is to ensure that others cannot easily access personal information if the computer is shared or is used at a public place like a library or school computer center.
Subscriber credit card and payment information is not stored in a database or on any servers connected to the Internet. This is to provide the best protection of subscriber payment information. Credit card data transmission in the subscription process is encrypted using SSL or other encryption techniques.
Nuventive has physical, electronic and procedural safeguards in place, including an Information Security Policy, to protect personal information provided to Nuventive or stored in iWEBFOLIO® from loss, theft, misuse and unauthorized access, disclosure, copying, use, alteration and destruction. Although there cannot be a guaranty of the security of personal information provided by Users to Nuventive or stored in iWEBFOLIO®, Nuventive believes that its security policies and safeguards are reasonable and appropriate to adequately protect such information, regardless of the format in which such information is held. Nuventive intends to review and update its security policies and safeguards on a regular basis. Nuventive requires that its employees keep all personal information confidential and comply with its Information Security Policy and privacy practices. Nuventive uses reasonable efforts to ensure that upon disposal or destruction of personal information, confidentiality of the information is maintained.
OPTING OUT OF THE RELEASE OF PERSONAL INFORMATION
ENFORCEMENT/COMPLAINTS; LEGAL DISCLAIMER
Although Nuventive makes every effort to preserve the privacy of Users, Nuventive may need to disclose personal information when required or permitted by law, for instance, where it has a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on Nuventive or applicable to Nuventive's web sites or software programs.
The Privacy Officer's responsibility is to investigate any of your concerns or complaints, and, in consultation with and in conjunction with Nuventive's legal advisors, to recommend and implement any and all appropriate corrective or remedial action.