Privacy and Cookie Notice

1. Information We Collect

“Personal Information” is any information that can be used to identify, locate or contact you. It also includes other information that may be associated with your name or other identifiers. We collect the following types of Personal Information:

• Contact Information that allows us to communicate with you, such as your name, username, mailing address, telephone numbers, email address or other addresses that allow us to send you messages.
• Relationship Information that helps us do business with you. For students, this includes your school affiliation, and graduation date, your courses of study, grades, learning style and how you engage with our products and content (including comments or content that you voluntarily provide on or through our Sites such as through blogs, forums, discussion groups, social networking platforms, or contest and sweepstakes entries), and similar information that can help us tailor our content and offer you personalized instruction. For professionals, this includes your professional credentials and affiliations and the products and services that may interest you or your school. If you are an instructor, we also collect information about the types of courses you teach, your teaching style and student engagement, and similar information that can help us tailor our content and improve your effectiveness in the classroom.
• Transaction Information about how you interact with BFW Publishers, including your purchase history, information about your use of our Sites and content (including time spent on material and results of in-product assessments), customer account information and information about how you use our websites and applications. If you purchase products from us online, our credit card processors will also collect payment card information as needed to process your payment.

In many cases, we collect Personal Information directly from you. We will ask you for Personal Information when you interact with us, such as registering on our Sites, visiting with us at tradeshows, signing up to receive materials electronically, or making a purchase. We may collect additional information about you from your school, such as information about the classes you are teaching, and from third party data suppliers who enhance our files and help us better understand our customers. We may collect and track your engagement with our marketing communications and videos that we send to you (as described in the section Cookies and Online Data Collection Tools). We may also collect publicly-available information from social media sites, such as Twitter, Facebook or LinkedIn.

When you use our Sites, we collect Transaction Information about your session and your activity. In addition to any information that you submit during these sessions, we use cookies and other technological tools to automatically collect information about your computer and your use of our Sites. We may collect or infer information about you, such as your engagement with our products and with others in your classes. In most cases we use this information in an anonymized or aggregated manner, but we treat this information as Personal Information when it is associated with other data elements that allow us to identify you. For more information about cookies and other technologies, please see the section Cookies and Online Data Collection Tools below.

We also collect Personal Information when you contact us, such as for customer service purposes or to exercise your privacy rights.

2. How We Use Information

We use your Personal Information to:

• Provide you with the products, content or services selected by you or your institution and for related activities, such as customer service, account management, support and training, reporting and to provide other services related to your account, including managing your privacy choices and communications preferences,
• Provide you with marketing communications and offers for products and services from BFW Publishers and our partners, including personalized offers based on your usage of our products or Sites,but we do not use any Personal Information of our high school student users to do any targeted advertising or marketing,
• Provide you with additional information that may be of interest, such as study tips for students or teacher guides for professionals,
• Administer surveys, sweepstakes, special events and other promotions,
• Determine if you are eligible for certain products, services or offers, such as rebates or content guides offered to professionals and students for certain courses,
• Enable you to participate in blogs, discussions groups and similar forums.
• Understand how you use our products, content and services, including associating you with different devices that you may use to access our content, for analytics and product development purposes as well as personalize offers that we make to you and to create de-identified datasets, and
• Manage our everyday business needs, such as payment processing and financial account management, contract management, website administration, business continuity and disaster recovery, security and fraud prevention, corporate governance, reporting and legal compliance.

If you access, rent or purchase materials from our Sites, we may also use your Personal Information in connection with our anti-piracy measures. Our materials include a digital watermark that is linked to the name and email address in your BFW Publishers account to allow us to identify the source of any materials which are used in ways not permitted by the Terms of Use. This helps us prevent online piracy and other unauthorized use.

We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection. If you do not provide us with this personal information, we may not be able to offer you the services described above.

3. Why We Share Information

We may share your Personal Information as follows:

• If you are affiliated with an educational institution, we may share your Personal Information, including related School Data with your school and (if you are student) with your instructors and school administrators. For example, we provide educational institutions with reports about how their instructors and students use our products, including information that compares instructors and students within a school. If you are a student, your instructors have access to all School Data, including the information generated by your use of the products for a class. We may also provide Personal Information to your school as needed to investigate possible academic fraud or cheating. Your school uses your Personal Information in accordance with its own privacy policies.
• We may share your Personal Information with our affiliates, which may only use your Personal Information for the purposes listed above.
• We may also share your Personal Information with our service providers**, who are bound by law or contract to protect your Personal Information and only use your Personal Information in accordance with our instructions.
• We may share your Personal Information with third party partners that provide services to you through our Sites, but only to the extent you have a relationship with such partner or you authorize the sharing. For example, you may be able to purchase third party applications (through our Sites or otherwise) which are compatible and/or packaged with our products or services. Information may be shared between us and the provider of such third party application in order to enable certain functionalities or depending on the settings you choose. We will maintain any information we receive through such third party in accordance with this Notice. However, the third party’s use of your information is governed by such third party’s own privacy policies. Additionally, we may share certain Transactional Information with our partners as needed to validate referrals and operate the platforms.
• We may disclose Personal Information where permitted by law, such as for payment processing, as needed to affect the sale or transfer of business assets, to enforce our rights, including Terms of Use or Service, protect our property, or protect the rights, property or safety of others, or as needed support external auditing, compliance and corporate governance functions. We will also always disclose Personal Information when required to do so by law, such as in response to a subpoena, including to law enforcement agencies and courts in the United States and other countries where we operate.

Please note that we may also use and disclose information about you that is not personally identifiable. For example, we may publish reports or create products that contain de-identified, aggregated or statistical data. These reports and products do not contain any information that would enable the recipient to contact, locate or identify you.

4. Cookies and Online Data Collection Tools

When you visit our website or use our mobile applications, we collect certain Transaction Information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons. In many cases, the information we collect using cookies and other tools is only used in a non-identifiable way, without any reference to Personal Information. For example, we use information we collect about all website users to optimize our websites and to understand website traffic patterns.

In some cases, we do associate the information we collect using cookies and other technology with your Personal Information. This Privacy Notice governs how we use that information when we associate it with your Personal Information.

Cookies

A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. For more information on cookies and how to disable them, you can consult the information provided by the Interactive Advertising Bureau at www.allaboutcookies.org. Please note, however, that without cookies you may not be able to use all of the features of our Sites.

Our Site uses two kinds of cookies: session cookies and persistent cookies. Session cookies exist only for as long as your browser remains open. Once you close your browser, they are deleted. Persistent cookies, in contrast, last beyond each visit to the Sites and remain on your hard drive after you close your browser. The cookies used on the Sites include those that are strictly necessary cookies for access and navigation, cookies that track usage (performance cookies) and remember your choices (functionality cookies), and for visitors to our catalog and store Sites, cookies that provide you with targeted content or advertising (described more below under “Interest Based Advertising”). Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note however, that without cookies, you may not be able to use all of the features of our Sites.

We may use the information we obtain from cookies for the following purposes:

• to recognize your computer when you visit the Sites;
• to track you as you navigate the Sites, and to enable the use of e-commerce capabilities;
• to improve the Sites’ usability;
• to analyze use of the Sites;
• to manage the Sites;
• to personalize the Sites, including for visitors to our catalog and store Sites;
• to enable targeted advertisements that may be of particular interest to you (excluding Students); and
• to recognize you when you move between devices so that your work can be synchronized.

Flash Cookies

We may also use Flash Cookies (also known as Local Stored Objects) and similar technologies to personalize and enhance your online experience. A Flash cookie is a small data file placed on a computer using Adobe Flash technology. The Adobe Flash Player is an application that allows rapid development of dynamic content, such as video clips and animation.

We use Flash cookies to personalize and enhance your online experience and to deliver content for Flash players. We may also use Flash cookies for security purposes, to gather certain website metrics and to help remember settings and preferences. Flash cookies are managed through a different interface than the one provided by your web browser. To manage Flash cookies, please visit Adobe’s website at https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. If you disable Flash cookies or other similar technologies, please be aware that you may not have access to certain content and product features.

Pixel Tags and Web Beacons

We also may use “web beacons” on some of our Sites. A web beacon, also known as a pixel tag or clear GIF, may be used to transmit information collected through cookies to our service providers’ servers. They allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, (including marketing communications from us), or click on and/or watch a marketing video that we sent to you, the pixel tags and web beacons generate a notice of that action (e.g. that you have opened the email; that you have watched the video). These tools allow us to measure response to our communications and improve our web pages and promotions. They also enable our service providers to compile information about your browsing activity on the Sites.

Server Logs and Other Technologies

We collect many different types of information from server logs and other technologies. For example, we may collect information the device you use to access our website, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the IP address of the device you use to connect to the Internet. An IP address is a unique identifier that devices use to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you came to BFW Publishers and the website you visit after you leave our site.

5. Interest-based Advertising

On some of our Site, as set out below and where permitted by law, we partner with third party companies who may utilize cookies, web beacons or other technologies to provide: personalized content; advertisements about our goods and services that may be of interest to you; or to serve advertisements about other products; tracking your engagement with marketing emails and videos we send to you; on our Sites. The third parties may use these technologies to collect information about you when you use the Sites. They may collect information about your online activities over time and across different websites and other online services, as well as across different devices. They may use this information to provide you with interest-based advertising and content or other targeted advertising and content. They may also use persistent identifiers to track your Internet usage across other websites in their networks beyond the Sites. Such third parties may, with sufficient data from other sources, be able to personally identify you, unknown to us.

Some of our advertising and content partners that may access and use cookies and other data through our Sites are set out below with information about their privacy and opt-out practices, and you can also delete and/or block specific cookies from your browser (as explained above):

• AddThis: provides personalized ads to users by collecting personal data such as IP address, device information, and other personal information such referring URL. For more information on their privacy practices and their use of cookies, please see here. To opt-out, see here.
• Marketo: provides users with a more personalized functionality on our sites by collecting information such as browser data and internet device information. For more information on their privacy practices and their use of cookies, please see here. To opt-out of cookies, please see here and go to the footer option “Cookie Settings.”
• Google: supports ad personalization (e.g., provided by DoubleClick) which uses personal information such as, but not limited to, geolocation and search terms, in order to serve the user ads on non BFW Publishers sites. For more information on their privacy practices and their use of cookies, please see here. To opt-out, see here.
• LinkedIn: allows us to retarget BFW Publishers site users on non-BFW Publishers sites by collecting personal information including IP address. For more information on their privacy practices and their use of cookies, please see here. To opt-out, see here.
• SurveyGizmo: prevents us from duplicating surveys provided to users by collecting personal information such as IP address, device information, and referral source. For more information on their privacy practices and their use of cookies, please see here.
• GoToWebinar/LogMeIn: provides scheduling for user requested demos by collecting personal information including IP address. For more information on their privacy practices and their use of cookies, please see here. To opt-out, see here.
• Twitter: tracks website activity on the Student Store site and retargets users by collecting device information, tracking pixels, as well as personal information such as user emails. For more information on their privacy practices and their use of cookies, please see here. To opt-out, see here.
• Facebook: allows us to serve users personalized ads which uses personal data based on browsing behavior on our sites. For more information on their privacy practices and their use of cookies, including how to opt-out, please see here and here.
• Optimizely: helps determine how new features on BFW Publishers sites are performing by collecting user data such as device information, IP address, referral page, interaction data, crash data, other technical information, and location data. For more information on their privacy practices and their use of cookies, please see here. To opt-out, see here.
• Instana: tracks website activity, infrastructure monitoring and provides analytics to us as part of our service by collecting website browsing data, session information, and personal data including IP address. For more information on their privacy practices and their use of cookies, please see their Privacy Notice and Cookie Notice. To Opt-out, see here.
• New Relic: tracks website activity and provides analytics to us and to users as part of our service by collecting website browsing data, session information, and personal data including IP address. For more information on their privacy practices and their use of cookies, please see here.
• WebEx: provides online meetings with instructors and faculty and other educators by collecting personal information such as IP address and web browsing data. For more information on their privacy practices and their use of cookies, including how to opt-out, please see here.
• HotJar: tracks website activity on Catalog and Student Store in order to learn visitor behaviors, such as time spent on a task or product use information. For more information on their privacy practices and their use of cookies, please see here. To opt-out, see here.

You can also obtain more information about interest-based advertising, and how to opt-out of receiving interest-based ads from participating third-party providers and ad networks through the following:

For Users in the U.S.:

• https://www.networkadvertising.org/optout_nonppii.asp (Network Advertising Initiative)
• https://www.aboutads.info/choices(Digital Advertising Alliance)

For Users in the EU and UK:

• https://www.youronlinechoices.eu (European Interactive Digital Advertising Alliance)

For Users in Canada:

• https://youradchoices.ca/choices/ (Digital Advertising Alliance of Canada)

For Users in Australia:

• https://support.google.com/ads/answer/2662922?hl=en-AU (Google)
• https://www.oaic.gov.au/privacy/your-privacy-rights/advertising-and-marketing/targeted-advertising/ (Office of the Australian Information Commissioner)

For Users in New Zealand:

• https://support.google.com/ads/answer/2662922?hl=en-NZ (Google)

Please note in respect of each of the territories above: opting out of participating providers and ad networks does not opt you out of being served advertising. You may continue to receive generic or contextual ads on our Sites. Additionally, to successfully opt-out, you must have cookies enabled in your web browser. Please see your browser’s instructions for information on cookies and how to enable them. Your opt-out only applies to the web browser you use, so you must opt-out of each web browser on each device that you use. Once you opt-out, if you delete your browser’s saved cookies, you may need to opt-out again.

For the MacmillanLearning.co.uk site

Please note: The following is a complete list of the cookies on MacmillanLearning.co.uk, including marketing and analytics cookies. We will only implement cookies (except for the essential cookies which are necessary for the proper and optimized functionality of our site and user experience) if you have provided your consent through our cookie banner. You can refuse consent through the cookie banner or using your browser instructions as set out above.

MacmillanLearning.co.uk Cookies:

CPHPSESSID is an essential cookie and provides the PHP session ID, used to maintain the user’s session with the server.

Macmillaninternational_currency; Macmillaninternational_country_code; Macmillaninternational_country_price_code; Macmillaninternational_loc are essential cookies and are used to maintain a user’s selected region on the site, which dictates the location, currency and country codes that’re used to show region specific title data / pricing.

_chckd is an essential cookie to determine if the user has seen the cookie consent banner and dictates whether it should show or not.

id_token is an essential cookie for the Macmillan login required to access the account section of the site and to make sample requests.

id_token_metadata is an essential cookie for the Macmillan login required to access the account section of the site and to make sample requests.

Google Analytics is a non-essential cookie used to distinguish users and track the pages they visit on this website.

Google Tag is a non-essential cookie used to distinguish users and track events such as clicks and downloads on this website.

_mkto_trk Marketo is a non-essential marketing cookie, known as a Munchkin Cookie, used to track users who visit our site so that we can react to their visits with automated marketing campaigns and for reporting purposes.

6. Analytics

We use third-party web analytics services on our Sites, such as Google Analytics and ClickTale. These service providers help us analyze how users use our Sites. The information collected for this purpose (including your IP address and other information collected by automated means) will be disclosed to or collected directly by these service providers. These service providers may retain and use Non-Personal Information collected from users of our Sites in connection with their own businesses, including in order to improve their products and services. To learn more about opting out of data collection through Google Analytics or Click Tale, click the links below:

• Google Analytics: https://support.google.com/analytics/answer/181881?hl=en
• ClickTale: https://www.clicktale.net/disable.html

You can withdraw your consent and opt-out of the use of cookies and online tracking at any time by following the links above or you can delete and/or block specific cookies from your browser but some features of the Sites may not function fully or correctly as a result.

You may also be able to limit the association of your mobile device with your online activities by resetting the advertiser ID on your Apple or Android device. For more information about how to change these settings go to:

• Apple: https://support.apple.com/kb/HT4228
• Android: https://www.google.com/policies/technologies/ads/

These Sites are not designed to respond to "do not track" signals received from browsers.

7. Social Media Interactions and Interest-based Ads

Our websites may enable you to interact with us and others via social media platforms, such as Facebook, Twitter, YouTube, LinkedIn and Instagram. While we respect each social media platform’s privacy policies, we may collect Personal Information about you and your friends if you choose to use these tools. For example, the Sites may also offer you the ability to interact with plugins from these platforms, in order to allow you to follow us or share your experiences with your online social network.

Social media platforms collect persistent identifiers through your browser or mobile operating system. If you have previously provided personally identifiable information to these platforms, the platform operators may recognize you here. Your use of social network plugins is subject to each social media site’s privacy policy. If you engage with our content on or through third-party social media sites, you may allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture) to deliver the content or as part of the operation of the plug-in or application. For more information, please read the privacy policies posted by the social media platforms that you use.

As noted above, we may also display interest-based ads to you when you are using social media platforms, but we do not use any Personal Information of our high school student users to do any targeted advertising or marketing. These platforms allow us to personalize the ads that we display to you. We do not share any of your Personal Information with these platforms, although we may convert your email address into a unique number which can be matched by the platform with its user to allow delivery of the advertising. Although we do not provide any personal information to these platforms, they may gain insights about individuals who respond to the ads we serve.

8. Links To Other Websites

Our Sites may contain links to other websites for your convenience and information. These may include, for example, some of the blogs and forums you may access through our Sites. These websites may be operated by companies not affiliated with us. Information you submit through these third party websites will be subject to their privacy policies. We suggest you review their privacy policies to understand how they may collect, use, and share your information. We are not responsible for the content of any websites that are not affiliated with BFW Publishers, any use of those websites, or their privacy practices.

9. Children’s Privacy

These Sites are intended for people 13 years of age and older in the US and 16 years of age and older in other countries. If you are under this age for your respective territory, please do not submit any personal information to us through the Sites. If you are under the age of 18, please review this Notice with your parent or guardian before submitting any information to us.

10. How We Protect Personal Information

We use reasonable administrative, technical, and physical security measures to help protect your personal information against unauthorized access or loss. Unfortunately, no data transmission or storage system can be guaranteed to be absolutely secure, so we also have procedures to deal with any suspected data security breach and will notify you and/or any applicable regulator or supervisory authority or other governmental entity where we are legally required to do so.

11. Marketing/Your Choices

You can always limit the information you provide to us. You can also limit the communications that we send to you.

To opt-out of emails, simply click the link labeled “unsubscribe” at the bottom of any email we send you. To revoke permissions that you may have given to send text messages, text STOP in response to any message. Please be aware that if you unsubscribe or opt-out of texts, we process an opt-out request only for that specific e-mail address or telephone number. So, if you have more than one e-mail address or if you have changed your e-mail address, your opt-out request may not be processed for any e-mail that you have not identified in your opt-out request. You can also Click here for help opting-out of receiving marketing communications from BFW Publishers and its affiliates. Please include your name, address and the e-mail address(es) and/or phone number(s) that you want to opt-out.

If you believe you have opted out, but continue to receive e-mails from us, please contact us by one of the means listed under the How To Contact Us section below, and we will endeavor to resolve the issue.

Please note that even if you opt-out of commercial emails, we may still need to contact you with important transactional information about your account. For example, even if you opt-out of emails, we may still send you activity confirmations.

If you have previously opted-in to receiving marketing communications, you may withdraw your consent at any time by clicking “unsubscribe” at the bottom of the e-mail communications or by visiting this link and unsubscribing there.

12. Access and Correction

We respect your right to reasonably access and correct your Personal Information. If you have an online account, you can log into your account at any time to access and update the information you have provided to us. Additionally, BFW Publishers complies with all laws regarding access and correction.

Subject to applicable law, you may: (i) have the right to access certain Personal Information we maintain about you and obtain a copy of that information; (ii) update or correct inaccuracies in your Personal Information; (iii) object to our use of your Personal Information; and (iv) request deletion your Personal Information from our database. To exercise these rights, please contact us as indicated in the How To Contact Us section of this Notice. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information, which may require you to provide us with Personal Information.

13. International Data Transfers

Your personal information may be transferred to, stored at or processed in European Economic Area (EEA), the United Kingdom (UK), the the United States and other countries (including Argentina and India) which may not have equivalent privacy or data protection laws. However, regardless of where your personal information is transferred, we will protect it in accordance with this Privacy Notice.

BY CONTINUING TO USE THESE SITES AND/OR SUBMITTING YOUR PERSONAL INFORMATION, YOU CERTIFY THAT YOU MEET THE AGE AND OTHER ELIGIBILITY REQUIREMENTS FOR THE SITE AS SET FORTH IN THIS NOTICE AS WELL AS THE TERMS AND CONDITIONS.

14. Pseudonymous Registration

If you are a Student using our Sites as part of a required course adoption and you do not want to provide us with your name, you may register under an alias. You will need to create an alias and create and open an e-mail account under that alias with a third-party email service. Next, when you register on our Sites, you will do so by providing your alias and the email address you’ve opened under that alias. You will be required to accept this Notice and the applicable Terms of Use as part of the registration process, which you will complete under your alias. IT IS CRITICAL THAT YOU MAKE SURE YOU INFORM YOUR INSTRUCTOR OF YOUR ALIAS SO THAT HE/SHE HAS ACCESS TO YOUR WORK AND CAN ASSOCIATE YOUR ALIAS WITH YOUR NAME AS IT APPEARS IN OTHER SCHOOL DATA.

15. Updates to Our Online Privacy Notice

From time to time, we may update this Privacy Notice to reflect new or different privacy practices. We will place a notice online when we make material changes to this the Privacy Notice. Changes to this Notice will become effective when those changes are posted to the Sites or otherwise notified to you as required by applicable law. Your continued use of the Sites subsequent to any such notified change to this Notice constitutes your acceptance of the change subject to the contents of the specific notification. We indicate the effective date of this Notice (and any updates) at the top of the Notice.

16. How to Contact Us

To access, update or correct inaccuracies in your personal information or if you have any questions about this Notice or the manner in which we or our service providers treat your personal information, or if you would like us to update your preferences, please contact us by e-mailing us at PrivacyIsImportant@bfwpub.com

17. School Data Privacy Statement

This privacy notice applies to the personal information pertaining to students that we receive from schools or that we maintain on behalf of schools (collectively, “School Data”), such as information about class rosters and data from students who use our learning platforms at the direction of an educational agency or school.

BFW Publishers is committed to protecting the privacy and security of all School Data that we process as a “data processor” or “service provider” to your school in order to provide the services to you and your school, pursuant to applicable laws. For example, if your school is based in: i) the United States, your student records may be protected by the Family and Educational Rights Privacy Act (FERPA) or the California Consumer Privacy Act (CCPA); ii) Canada, your information held by public bodies may be protected by The Freedom of Information and Protection of Privacy Act (FIPPA), or iii) the European Economic Area or the UK, your School Data may be protected by the General Data Protection Regulation (GDPR) and the UK GDPR respectively. For information on your school’s privacy policies, please contact the administration.

If you use our products and platforms in your courses at your school, we only use your personal information in the School Data as needed to:

• Provide you with the products, content or services selected by you, your instructors or your school and for related activities, such as customer service and “helpdesk” functions,
• Assure academic integrity, such as in connection with investigations and anti-plagiarism program,
• Understand how you use our products, content and services, including associating you with different devices that you may use to access our content, for analytics and product development purposes, and to create de-identified datasets,
• Send end-of-course surveys, and
• Manage our everyday business needs, such as website administration, business continuity and disaster recovery, security and fraud prevention, corporate governance, reporting and legal compliance.

We will only use School Data for other purposes with the consent of your school and (if applicable) with your consent. Please note that we may publish reports or create products that contain de-identified, aggregated or statistical data, such as benchmarking reports that reveal how students generally engage with our platforms. These reports and products do not contain any information that would enable the recipient to contact, locate or identify you or your school.

We do not use School Data for targeted marketing purposes. This means that we do not select or deliver ads to you in our educational products and services based on your School Data obtained or inferred over time from your use of our educational products and services. We may deliver generic or contextual ads to you while you use our educational products or platforms, but we do not target these ads based on your School Data.

All School Data may be shared with your school (including with your instructors and school administrators). Your instructors generally have access to all School Data, including the information generated by your use of the products for a class, and we may provide other information to your school as needed to investigate possible academic fraud or cheating. Your school uses the School Data in accordance with its own privacy policies.

We may share School Data with our affiliates, which only use the School Data for the purposes listed above, and with our service providers, who are bound by law or contract to protect the School Data and only use it as needed to provide the services requested. We will also disclose School Data when required by law, such as in response to a subpoena, including to law enforcement agencies and courts in the United States and other countries where we operate.

If you have questions about your privacy rights, please contact your school’s administration. If you believe that BFW Publishers has not handled your personal information properly, you may also contact the BFW Publishers Privacy Office via email to PrivacyIsImportant@bfwpub.com

18. Important Information for EEA and UK Residents

BFW Publishers is providing this supplemental privacy notice to give individuals in the European Economic Area (EEA) and the United Kingdom (UK) the additional information required by the EU General Data Protection Regulation (GDPR) and the UK GDPR respectively. These provisions, together with the statements in the BFW Publishers Privacy Notice, explain our practices with regard to EEA and UK personal data.

This supplementary privacy notice applies when BFW Publishers is acting as a data controller (i.e., when BFW Publishers exercises overall control of the personal data being processed and so, under EEA and UK law, is ultimately in charge of and responsible for the processing). BFW Publishers is data controller for the Contact Information, Transaction Information, Relationship Information as described in the “Information We Collect” section of the Privacy Notice.

When BFW Publishers processes School Data and personal data related to the instructor’s use of the product, BFW Publishers is a data processor under EEA and UK law and, it only processes the data in accordance with the school’s instructions (unless required otherwise by law). Accordingly, students and instructors should refer to their school’s privacy notice for more information about how it handles such personal information. If you wish to exercise any of your rights under EEA law or have any questions regarding such personal information, please contact your school.

1. Information about BFW Publishers

BFW Publishers is a group name for Bedford, Freeman &Worth Publishing Group, LLC (Bedford St. Martin’s, WH Freeman and Company, Worth Publishers, Late Nite Labs, iClicker, Sapling Learning), Skyfactor, Intellus Learning, and Hayden-McNeil LLC.

Our sister company Macmillan Publishers International Limited (MPIL), located in the UK, and Macmillan Learning Party Limited (MLPL), located in Australia, act as our service providers and our data processors. Accordingly, if MPIL and/or MLPL process the Contact Information, Transaction Information and Relationship Information in providing services on our behalf it does so in accordance with our instructions and in accordance with this privacy notice (unless required otherwise by law).

BFW Publishers is based in the United States. Our representative in the EEA is:

Our representative in the EEA is:

2. The Purposes and Legal Basis for Processing, including Legitimate Interests

The BFW Publishers Privacy Notice explains the reasons why we process your Personal Information. We only process Personal Information when we have a legal basis for the processing, such as where it is necessary:

• To fulfill a contract with you or your school, and for closely-related purposes, such as payment processing and financial account management, contract management, website administration, business continuity and disaster recovery, security and fraud prevention, corporate governance, reporting and legal compliance, and
• With your consent (or provided you have not objected, as may be appropriate under applicable law), such as to provide you with marketing communications, in relation to the use of cookies, or where you are asked to provide special categories of data as part of a survey request that we provide on behalf of your school/educational institution.

We may also process your Personal Information for the purposes of our legitimate interests (or for the legitimate interests of your school, provided that our interests shall not outweigh your rights and freedoms. In particular, we may process your Personal Information as needed to:

• Protect you, us or others from threats (such as security threats or fraud) piracy or cheating,
• Comply with the laws that are applicable to us around the world,
• Enable or administer our business, such as for quality control, consolidated reporting, and customer service,
• De-identify it to create anonymized and/or aggregated datasets,
• Manage corporate transactions, such as mergers or acquisitions, and
• Understand and improve our business or customer relationships generally.
• If you are an instructor or school administrator only (provided you have not objected and if otherwise permitted under applicable law), send you information about our educational resources and services that may be of interest to you.

We may disclose your Personal Information to related companies and to third parties as described in the Privacy Notice; however, we do not share your Personal Information with third parties for them to market their products or services to you without having obtained your prior opt-in consent. If you give consent for such sharing, you may revoke it at any time. (See the Marketing/Your Choices section of the Privacy Notice.)

We do not knowingly collect Personal Information from or of children under the age of 16 without parental consent.

3. Automated Decision-Making and Profiling

We may use profiling and analytics to understand how individuals interact with our educational materials, such as assess engagement and improve learning outcomes, and product development purposes. For example, we may use analytics to study the amount of time that individuals spend on specific content items and we may infer engagement from this this process. These analytics also help us understand and improve our materials, as can determine what materials are more or less accessible to students. We may also use analytics for course integrity purposes, such as to identify individuals that may be cheating.

We will not make automated-decisions using Personal Information about you that may significantly affect you, unless (1) the decision is necessary as part of a contract that we have with you, (2) we have your explicit consent, or (3) we are required by law to use the technology.

4. When You are Required to Provide Personal Information to BFW Publishers

In most cases, you are not required by law to provide any Personal Information to BFW Publishers. You are required to provide certain Personal Information to enable us to enter into a contract with you so that you can use our products and services. Our registration forms indicate which data elements are required for our contracts. If you do not provide these data elements, we cannot do business with you.

If you are a student who is required to use our products for school, you can create a pseudonymous account using an alias by following the instructions in the Privacy Notice.

5. Your Rights

As noted in the BFW Publishers Privacy Notice, you always have the right to object to our marketing communications. To opt-out of emails, simply click the link labeled “unsubscribe” at the bottom of any email we send you. To revoke permissions that you may have given to send text messages, text STOP in response to any message.

BFW Publishers also respects the rights of EEA and UK residents to access, correct and request erasure or restriction of their personal information as required by law. This means:

• You generally have a right to know whether or not BFW Publishers maintains your Personal Information. If we do have your personal information, we will provide you with a copy (subject to the rights of others). If your information is incorrect or incomplete, you have the right to ask us to update it. In some cases, you may have the right to receive information that you provided to us back in a machine-readable format.
• You have the right to object to our processing of your Personal Information, including withdrawing any consents for processing that you may have given us at any time.
• You may also ask us to delete or restrict your personal information.

To exercise these rights, please contact us via email to PrivacyIsImportant@bfwpub.com or write us at the address above, and a member of our Privacy Team will assist you. Please understand that we may need to verify your identify before we can process your request. Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process your Personal Information.

If you believe that we have processed your Personal Information in violation of applicable law, you may file a complaint with the BFW Publishers Privacy Office (PrivacyIsImportant@bfwpub.com) or with a supervisory authority.

Students: please contact your school if you would like assistance exercising any of your individual rights.

6. International Transfers

As noted in the Privacy Notice, your Personal Information will be transferred to, stored at and processed in the United States and other countries which may not have equivalent privacy or data protection laws to the EEA and the UK.

For our Personal Information submitted to and processed on our ML.CO.UK site, which is housed in Scotland, some of such data will also be housed in the EU and/or UK.

We have safeguards in place to protect your Personal Information to provide your Personal Information with the same protection as it has in the EEA and UK.

Please contact us via email to PrivacyIsImportant@bfwpub.com if you would like more information about cross-border transfers.

7. Data Retention

We will retain your Personal Information for as long as the information is needed for the purposes set forth in Section 2 above and for any additional period that may be required or permitted by law.

You may request that we delete your Personal Information by contacting us via email to PrivacyIsImportant@bfwpub.com.

Students: please contact your school if you would like to request deletion of any School Data.

8. How to Contact Us

Please contact us if you have any questions or comments about our privacy practices or this Privacy Notice. You can always reach us via email to PrivacyIsImportant@bfwpub.com. You can also reach us via mail to the addresses given above.

19. Your California and Nevada Privacy Rights

California’s “Shine the Light” law, Civil Code Section 1798.83, requires certain businesses to respond to requests from California customers asking about the business’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes or to provide an opt-out for such sharing of information to third parties for the third parties’ direct marketing purposes. Nevada’s online privacy law (NRS 603A.340) requires businesses to offer consumers a right to opt-out of the sale of their personal information.

BFW Publishers does not share California consumer personal information with third parties for marketing purposes without consent. BFW Publishers also does not sell any Nevada personal information. However, BFW Publishers’s websites do use cookies, and third party partners may collect technical information from visitors to our websites. You can learn more about these cookies and exercise your rights to opt-out by visiting our Cookie Policy.

California or Nevada customers who wish to request further information about our compliance with these laws or have questions or concerns about our privacy practices may contact us at PrivacyIsImportant@bfwpub.com or by writing to: