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Privacy Policy
Effective date: October 1st, 2024
Our role in your privacy
At Coursewand, your privacy is critically important to us. We have a few core principles:
- We collect only the personal information necessary to provide our services.
- We store your personal information for only as long as it serves a purpose.
- We offer transparency on how we gather, use, and share your information.
- We aim to protect your data from unauthorized access and government overreach.
This policy applies to all information collected when you use:
- Our websites (coursewand.com, and others related to Coursewand).
- Any other products, services, or features accessible through our platforms.
Our responsibilities
As a Coursewand customer or a visitor to our website, we act as the "data controller" of personal data. This means we determine how and why your data are processed.
Your responsibilities
- Read this Privacy Policy
- If you are our customer, please also check the contracts - including the Terms of Service available upon request at info@virtue.company.
- If you provide us with personal information about other people, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. By submitting the information, you confirm that you have the right to authorise us to process it on your behalf in accordance with this Privacy Policy.
When and how we collect data
If you are only a visitor to our website, please know that we do not collect any personal data before you request a demo of Coursewand. We use the privacy-friendly Google Analytics to carry out site measurement absolutely anonymously.
From the moment you request a demo of Coursewand, we start collecting data. Sometimes you provide us with data, sometimes data about you is collected automatically.
Here’s when and how we do this:
WE COLLECT
You request a demo of Bearer
We call you
You use Bearer
You receive emails from us
You chat with us for customer support
You opt-in to marketing messages
You request a demo of Coursewand
You use Coursewand
You receive emails from us
You chat with us for customer support
You opt-in to marketing messages
Types of data we collect
Your name, email address, role in your institution, etc.
Contact details
Your payment information, account ID, credit/debit card details, etc., all through Stripe.
Financial information
Function calls made from your interactions, json Data passed through functions, and other get requests made to our servers while using our AI tool.
Metadata from interactions
We track how many times you use Coursewand by using session logs.
Usage data
Your URL clickstreams (the path you take through our site), pages viewed, page response times, download errors, how long you stay on our pages, what you do on those pages, how often, and other actions.
Data on how you use Coursewand.com
We don’t collect any "sensitive data" about you (like racial or ethnic origin, political opinions, religious, trade union membership, genetic data, biometric data, health data, data about your sexual life or orientation, and offenses or alleged offenses).
What about really sensitive data?
Data that is classified as sensitive, such as university-protected information or high-impact research data, is processed securely using our vetted private models. We work with institutions to ensure data classification compliance and prevent unauthorized use or exposure. We implement strict de-identification processes for all data, ensuring it cannot be traced back to individual students or users. This data undergoes regular audits to confirm that it meets FERPA compliance and cannot be re-identified.
How do we handle sensitive data in general?
Coursewand is a product directed to and intended for use only by those who are 18 years of age or over. We do not target Coursewand at children, and we do not knowingly collect any personal data from any person under 16 years of age.
What about children’s data?
How and why we use your data
Data protection law means that we can only use your data for certain reasons and where we have a legal basis to do so. Here are the reasons for which we process your data:
Private Model Improvement
All data provided by institutions is securely processed within private models and is never used to train public models. We ensure that data inputted by universities or organizations is strictly confined to the systems under their control, with no external data reuse.
Removing Hallucinations
We continuously work to eliminate any AI hallucinations (incorrect information) that occur. If hallucinations are identified or reported, we use the provided data to promptly correct them. However, we also encourage users to engage with the information and verify its accuracy to ensure all critical points are covered. Human oversight remains essential to ensure the reliability of AI-generated results.
User Account Management
Login and authentication, processing payments.
Improving our Website Performance
Landing-page analytics, testing copy, images, marketing, and page insights
Legal Basis:
Legitimate InterestsCustomer Support
Notifying you of any changes to our service, solving issues via live chat support, phone or email including any bug fixing.
Legal Basis:
Legitimate InterestsMarketing Purposes (With your Consent)
Sending you emails and messages about new features, products and services, and content.
Legal Basis:
ConsentHere is what each of these "legal bases" mean:
Consent
You have given clear consent for you to process your personal data for a specific purpose.
You can change your mind!
If you have previously given consent to our processing your data you can freely withdraw such consent at any time. You can do this by emailing us at info@virtue.company
If you do withdraw your consent, and if we do not have another legal basis for processing your information, then we will stop processing your personal data. If we do have another legal basis for processing your information, then we may continue to do so subject to your legal rights.
Legitimate interests
Processing your data is necessary for our legitimate interests or the legitimate interests of a third party.
These legitimate interests are:
- Delivering, developing and improving the Coursewand service.
- Enabling us to enhance, customise or modify our services and product.
- Determining whether marketing campaigns are effective.
- Enhancing data security.
- Gaining insights from your behaviour on our models.
Your privacy choices and rights
YOUR CHOICES
If you choose to do this, you can continue to use the website and browse its pages, but we will not be able to process transactions without such data.
You can choose not to provide us with personal data
You can block cookies by activating a setting on your browser allowing you to refuse cookies. You can also delete cookies through your browser settings. If you turn off cookies, you can continue to use Coursewand but certain services may not be provided to you.
You can turn off cookies in your browser by changing its settings
We will inform you (before collecting your data) if we intend to use your data for marketing and if third parties are involved. You can opt out from marketing by emailing us at info@virtue.company.
You can ask us not to use your data for marketing
Your Rights
You can exercise your rights by sending us an email at info@virtue.company
This includes the right to ask us supplementary information about:
- The categories of data we’re processing
- The purposes of data processing
- The categories of third parties to whom the data may be disclosed
- How long the data will be stored (or the criteria used to determine that period)
- Your other rights regarding our use of your data
We will provide you with the information within one month of your request, unless doing so would adversely affect the rights and freedoms of other (e.g. another person’s confidentiality or intellectual property rights). We’ll tell you if we can’t meet your request for that reason.
You have the right to access information we hold about you
We may use your data to determine whether we should let you know information that might be relevant to you (for example, tailoring emails to you based on your behavior). Otherwise, the only circumstances in which we will do this is to provide the Coursewand service to you.
You have the right to make us correct any inaccurate personal data about you
You can do this by asking us to erase any personal data we hold about you, if it is no longer necessary for us to hold the data for purposes of your use of Coursewand.
You have the right to be "forgotten" by us
Please tell us first, so we have a chance to address your concerns. If we fail in this, you can address any complaint to the DPF, either by calling their helpline or as directed on their website here.
You have the right to lodge a complaint regarding our use of your data
How secure is the data we collect?
We have physical, electronic, and managerial procedures to safeguard and secure the information we collect.
And please remember:
- You provide personal data at your own risk: unfortunately, no data transmission is guaranteed to be 100% secure
- You are responsible of your username and password: keep them secret and safe!
- If you believe your privacy has been breached, please contact us immediately on info@virtue.company.
We use industry-standard encryption where applicable, including AES-256 for data at rest and TLS 1.2 for data in transit, depending on the services integrated. We regularly review and update our security practices to meet evolving industry standards.
Where do we store the data?
The personal data we collect is University data is securely stored within AWS Amazon Cloud in the U.S. As we operate from the U.S., all data processing is conducted within the country, ensuring that your data remains secure and compliant with U.S. regulations.
By submitting your personal data, you consent to the storage, processing, and transfer of this data within the United States. Should we need to transfer your data to a third-party service provider, we ensure that your privacy rights are protected in accordance with this Privacy Policy and U.S. data protection laws.
How long do we store your data?
We will archive and stop actively using any personal identifiable information about you within 3 months from the last time you used Coursewand. We will delete your personal data from our archives no later than 1 year from the last time you used Coursewand or as agreed with you in a separate contract.
Data deletion is managed securely using certified processes to ensure that all personally identifiable information (PII), even in de-identified form, is fully removed after the retention period. Institutions can request customized retention periods to meet specific compliance requirements.
Third parties who process your data
Tech businesses often use third parties to help them host their application, communicate with customers, power their emails etc. We partner with third parties who we believe are the best in their field at what they do. Third-party providers, such as Google Drive and M365, are evaluated to ensure they can be configured to meet FERPA and GDPR compliance standards.
When necessary, we may share your data with trusted third-party providers to help us deliver our services effectively. Your data is shared only when strictly required and in accordance with the safeguards and best practices outlined in this Privacy Policy. When personal data is transferred to third parties, we ensure that appropriate data protection measures are in place.
This includes adhering to relevant data protection laws and implementing encryption for all data transfers. For transfers outside the U.S., we take steps to ensure compliance with applicable international data protection standards and safeguards, including securing agreements with third-party providers to protect your data in line with this Privacy Policy.
Cookies
How can I block cookies?
You can block cookies by activating a setting on your browser allowing you to refuse the setting of cookies. You can also delete cookies through your browser settings. If you use your browser settings to disable, reject, or block cookies (including essential cookies), certain parts of our website will not function fully. In some cases, our website may not be accessible at all. Please note that where third parties use cookies we have no control over how those third parties use those cookies
When you interact with Coursewand as a user, we (and these third parties) will issue cookies unless you adjust your browser settings to refuse them. These may be ‘session’ cookies, meaning they delete themselves when you leave Coursewand, or ‘persistent’ cookies which do not delete themselves and help us recognise you when you return so we can provide a tailored service.
FERPA Compliance
While Coursewand does not directly handle student records, we are committed to ensuring that any educational data we process adheres to the principles of the Family Educational Rights and Privacy Act (FERPA). We have implemented the following safeguards to ensure the privacy and protection of sensitive information:
- We use third-party service providers such as Google Drive and M365 for document storage. While these services can be configured to comply with FERPA when used appropriately, the responsibility for maintaining compliance lies with the educational institutions.
- All educational data used within Coursewand is solely for model building and course-specific improvements. No student-specific information is collected, stored, or used for any other purpose. Since we do not interact with student records, all data passed through our system is anonymized or pseudonymized in accordance with privacy standards, ensuring compliance with FERPA’s core principles.
We are in the process of developing an incident response plan to address data breaches or unauthorized access. Once implemented, this plan will include notifying affected institutions and users in a timely manner and providing detailed logs to assist with mitigation and recovery efforts. In the meantime, we work closely with institutions to ensure appropriate measures are in place to manage any security risks.