California Privacy Notice

Effective July 1, 2020

This Privacy Notice contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to California residents.

This Privacy Notice describes Instructure’s collection, use, and disclosure of personal information as defined in the CCPA, as well as your rights with respect to that personal information. It applies when Instructure is acting as a “business” as defined by the CCPA, for example, when we collect personal information through our corporate websites, and it pertains to and supplements the Instructure Marketing Privacy Policy.

Instructure also processes personal information through our products on behalf of our customers, in order to provide services to our customers. Under the CCPA, when Instructure acts on behalf of its customers, Instructure processes personal information as a “service provider,” a designation which is not subject to the disclosures and rights set forth in this Privacy Notice. To exercise your rights with respect to that personal information, you must contact the relevant Instructure customer—for example, the school you attended or company you worked for when you used an Instructure product. Instructure will cooperate with that business to fulfill your request if they request that we do so. To learn more about how Instructure treats personal information when acting as a service provider, please view the Instructure Product Privacy Policy.

Consumers with disabilities may access this notice by using a screen reader or contacting Instructure for further assistance.

PERSONAL INFORMATION WE COLLECT, DISCLOSE FOR A BUSINESS PURPOSE, AND SELL

In the past 12 months, we collected, disclosed for a business purpose, and “sold” (as defined by the CCPA and explained further below) the following categories of personal information about California consumers.

Categories of Personal Information

Disclosed for business purposes to the following categories of third parties:

Sold to following categories of third parties:

Personal and online identifiers (such as first and last name, email address, or unique online identifiers)

All categories listed below.

All categories listed below.

Commercial or transactions information (such as products or services purchased, obtained or considered)

All categories listed below.

N/A

Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement)

All categories listed below.

All categories listed below.

Biometric information (such as call recordings)

All categories listed below.

N/A

Geolocation information

All categories listed below.

N/A

Professional or employment-related information

All categories listed below.

N/A

Education information

All categories listed below.

N/A

Inferences drawn from the above information about your predicted characteristics and preferences

All categories listed below.

All categories listed below.

Other information about you that is linked to the personal information above

All categories listed below.

All categories listed below.

CATEGORIES OF SOURCES. We collect this personal information from the following categories of sources:

  • Consumers;
  • Businesses and education institutions associated with consumers;
  • Business partners;
  • Service providers; and
  • Affiliates not under the Instructure brand.

WHY WE COLLECT, USE, AND SHARE CALIFORNIA INFORMATION. We use and disclose all categories of personal information we collect for our commercial and business purposes, as further described in the Instructure Marketing Privacy Policy. These commercial and business purposes for which we use and disclose these categories of personal information include, without limitation

Our commercial purposes, which include:

  • Marketing and advertising, including sending surveys and promotional communications and soliciting feedback;
  • Enabling commercial transactions and sending administrative email;
  • Responding to requests made by consumers including to respond to comments and inquiries; and
  • Operating, maintaining, and improving our websites and services including personalization.

Our business purposes as identified in the CCPA, which include:

  • Auditing related to our interactions with you;
  • Legal compliance;
  • Detecting and protecting against security incidents, fraud, and illegal activity;
  • Debugging;
  • Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
  • Internal research for technological improvement;
  • Internal operations;
  • Activities to maintain and improve our services; and 
  • Other one-time uses.

We disclose the categories of personal information designated above to the categories of third parties listed below for business purposes: 

  • Service providers;
  • Affiliates not under the Instructure brand; 
  • Third parties at your request or direction;
  • Data analytics providers;
  • Partners; and
  • Social networks.

We sell the categories of personal information designated above to the categories of third parties listed below:

  • Advertising/marketing companies;
  • Advertising networks;
  • Business services/agencies;
  • Business to business companies;
  • Marketing data companies;
  • Data analytics providers;
  • Social networks; and
  • Educational institutions & companies.

YOUR RIGHTS REGARDING PERSONAL INFORMATION. California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

  • The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you, the categories of sources from which we collected your personal information, our purposes for collecting or selling your personal information, the categories of your personal information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information;
  • The right to request that we delete the personal information we have collected from you;
  • The right to opt out of our “sale(s)” of your personal information. Please note that if you opt out of certain types of sales, we will be unable to provide you with the services that rely on such sales; and
  • The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below:

OPT-OUT OF PERSONAL INFORMATION DISCLOSURES. As is common with companies with an online presence, we work with third party digital advertising providers, social media companies, and other third party businesses to serve targeted advertising and engage in activities related to digital advertising like analytics and reporting. These companies may collect personal information through our properties, as defined by the CCPA, such as IP addresses, digital identifiers, information about your web browsing and app usage, and how you interact with our properties or ads in order to provide you with relevant ads and for other analytics purposes. These activities may be considered a “sale” under the broad definition of the CCPA.

To exercise the right to opt-out of “sales” of personal information, you may submit a request by clicking the button below:

DO NOT SELL MY PERSONAL INFORMATION

 

VERIFICATION PROCESS AND REQUIRED INFORMATION. Note that we may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled. We will require you to provide, at a minimum, your full name, email address or other contact information, and information about your relationship with Instructure. If we cannot successfully verify your identity, or if the information would be too sensitive to disclose, we may not be able to provide the personal information to you.

AUTHORIZED AGENT. You may designate an authorized agent to make a CCPA request on your behalf by designating such an agent in writing or through a power of attorney. We will require the agent to provide us with proof that you have authorized the agent to make a CCPA request on your behalf prior to processing the request. We may request additional information to verify the request.

MINORS’ RIGHT TO OPT IN. We do not sell the personal information of minors we know to be under 16 years of age.

CONTACT FOR MORE INFORMATION.  For questions or concerns about Instructure’s privacy policy or practices, please contact us at [email protected]