Privacy Policy
One of the major problems in the world of assessment is the lack of transparency. What do testing companies do with the information they gather about test takers? How do they use those data to supposedly “personalize” someone’s lessons or sell those data to universities for marketing purposes?
At Real & Open d/b/a Tiro (we’ll call ourselves “we,” “our,” or “us” from now on), what you create is yours, plain and simple. Our goal is privacy by design, meaning if we don’t need certain info, then we don’t collect it. Understanding how well an assessment describes what a person knows or can do requires purposeful data collection. Below is our Privacy Policy, where we’ll tell you:
- what data we collect,
- how we keep your data private and safe,
- when we automatically delete data,
- how you can delete your data, and
- other legally (and morally) important disclosures.
On the right below is the legal text, with a brief plain-English summary on the left.
Your Personal Info
We only have access to the info you or an educator gives us. We will never sell your info or and we will always protect it from marketing and other commercial uses. You maintain ownership of the intellectual property that you directly create.
There are four subsections: registration, cookies, sharing, and third-party service providers.
Generally speaking, there are four types of information that Real & Open deals with:
- Personal Info – names, e-mail addresses, school names, class names, and the other info that is used to describe an individual who uses our services.
- Assessments created by teachers – the questions, pictures, prompts, and other intellectual property created by teachers, educators, and other test writers.
- Responses from students – the answers, responses, and performances created by students and other people who respond to assessments.
- Analysis data calculated by Real & Open – difficulty scores, Chronbach’s alpha, Guttman scales, student groupings, and all of the other statistical analyses that we calculate based on test takers’ responses to teachers’ assessments, sometimes using the personal information to make the analysis easily understandable.
We require schools, districts, teachers, or other educators (on behalf of the parents or legal guardians of test takers under the age of 13 in the U.S., 16 in the E.U.) to provide consent for the collection of personal information of test takers under the age of 13 in the U.S. or 16 in the E.U. In order to use our services, test takers must use a web link, access code, or assessment prompt delivered by other means provided to them by the test creator or their teacher. Test writers may log into the service using credentials from certain third-party platforms, such as with a Google name and password.
We only have access to and collect information that you voluntarily give us when you use our services, through other direct contact, or when an educator has given consent on behalf of a test taker under the age of 13 in the U.S. or 16 in the E.U. Any personal information we collect is for the use and benefit of the learning process. We will never sell, rent, donate, or otherwise reveal personally identifiable information to any third party. If an educator has entered information about their test takers, that information and data associated with it may be connected to other student records in order to enrich the analytics and directly or indirectly further the test takers’ learning.
Test writers maintain ownership of their intellectual property – the questions, tests, and prompts that they create with our tools. Students and test takers maintain ownership of their intellectual property – the words, multiple choice answers, drawings, and other responses they create with our tools and their teacher’s assessments. We maintain ownership of the analysis data that we calculate based on test writers’ assessments and test takers’ responses. Test writers and test takers may give us joint or full ownership of their intellectual property. This information may be shared in ways that connect assessments, their responses, and corresponding analysis data, but without revealing any information that can be used to positively identify an individual test writer or test taker.
As soon-to-be signatories to the Student Privacy Pledge, we have pledged not to use any data beyond what you have authorized. We won’t sell, share, or disclose your information for marketing or other commercial purposes. As our services are also used by adult test-takers, we extend this protection to them as well. We may disclose personal information when presented with a duly authorized subpoena issues by a court of law, when compelled to do so by a government agency, or in a similar situation. We may disclose personal information when we have decided it is necessary to protect the rights, property, or safety of Real & Open, our employees, or others; or to prevent violations of our Terms of Service or other agreements.
Unless you ask us not to, we may contact you (educators, but never students or minors) via email in the future to tell you about new products or services or changes to this policy. We will provide notification via a pop-up message when you (students or educators) log in to use our services.
Registration
In order to use this website, a test writer must first complete a registration form. During registration, a person is required to give certain information (such as name and email address). This information is used to contact you and provide a secure log-in system to protect other data. At your option, you may also provide additional demographic information. If you are a member of an organization that has a relationship with Real & Open, you may be required to provide additional information in order to fully use our services.
Cookies and Similar Technologies
Would a pernicious tracking device by any other name taste as sweet? A “cookie” is a piece of data stored on your device to help us improve your access to our site and identify repeat visitors. It serves a similar purpose as clear GIFs, “tags,” or “scripts.” While some websites use cookies to track your web habits across multiple sites to serve you better ads and make money, we do not use tracking tools for marketing purposes. For example, when we use a cookie to identify your computer, you would not have to log in each time you visit one of our sites, thereby saving you time. Cookies also help us see how people use our site, which means we can update and change the site to make the experience better for you. We do collect device-specific information, such as operating system, IP address, hardware version, device setting, and web browser. This helps us measure how our services are working to improve your experience. We may also use HTML5 local storage or e-tags.
Some internet browsers may be configured to send “Do Not Track” signals to the online services you use. Because we do not track you across other websites, provide targeted advertising, or actively assist in providing targeted advertising, we do not respond to “Do Not Track” signals.
Typically, tracking technology is deleted if you delete your Internet history, cache, and cookies. Check your browser software for instructions to do this.
We do not allow any outside organization to use cookies to collect data about you, with extremely rare exception. For example, there are some web services we pay to make our products, such as our website hosting company; these partners might use cookies to make sure their services are working properly. We have no access to or control over these cookies. However, we only use web services that have privacy policies in accordance with this privacy policy and practices consistent with our own.
Sharing
We may share aggregated demographic information with our partners and clients in a way that does not personally identify any particular individual. For example, when we conduct our B-Corporation Assessment, we have to report what percentage of our users represent different socioeconomic and racial backgrounds. When an organization uses our services, their contract may include exceptions to this rule. However, in no scenario will personally identifiable information ever be sold, shared, or given for the financial benefit of a third party or for any purpose outside of the realm of education or professional development.
Links and Third-Party Service Providers
Our site contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage everyone to be aware when they leave our site to read the privacy statements of any other site that collects personally identifiable information. We also use certain third party services necessary for the successful use of our services, such as our web hosting service. Please know they have their own Privacy Policies as well. These third parties do not share your information with any other outside parties and do have privacy policies in accordance with this privacy policy and practices consistent with our own.
Your Power
Whenever you want, we will share with you the info we have directly related to you or your child. Whenever you want, you can request for the data to be anonymized or deleted.
Parents and guardians have the right to refuse our services at any time. You can contact us and the appropriate school administrator jointly to review any information we have pertaining to your child and to have it decoupled or deleted.
You know who doesn’t have access to your info? Marketers. Real & Open does not sell any of your provided information to any third party service for any purpose ever. We do not provide data to any party for advertising or other for-profit purposes. We do not present any advertising within our services or otherwise monetize your use of our services.
You may opt out of any future contacts from us at any time. You can do the following at any time by contacting us via our main email address: hello@tiro.org:
- see what data we have about you or your child, if any;
- change or correct any data we have about you or your child;
- decouple any personal information about you or your child from any assessment responses that you or your child have created;
- delete any data we have about you or your child; or
- express any concern you have about our use of your or your child’s data.
We retain information as long as an account remains active. Please know that we automatically delete personally identifiable data about each and every user after two years (i.e. 730 full days) of inactivity or according to the guidelines in a School Agreement. Beyond this two-year limit, we may retain anonymized data necessary to maintaining analysis data; these data cannot be used to identify any individual. We will retain and use information as necessary to comply with legal obligations, resolve disputes, and enforce other agreements.
Your Safety
We are doing our best to keep your data safe and secure.
We take many precautions to protect your information. When you submit sensitive information via our site or services, your information is protected both online and offline.
Wherever we collect sensitive information (such as credit card data or information that can be used to identify a minor), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a lock icon in the address bar and looking for “https” at the beginning of the address of the web page. When we work with vendors or other service providers, your data is encrypted unless it is necessary to share or provide that information to help perform certain actions, such as processing a credit card or sending emails. Generally, these service providers do not have the right to use the information we share with them beyond what is necessary to perform the specific action.
While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (e.g., billing, helping a teacher, working with law enforcement to ensure a child’s safety) are granted access to personally identifiable information. The computers and servers in which we store personally identifiable information are kept in a secure environment.
Unfortunately, there are malicious actors in the world and we cannot fully guarantee that all information we store is always 100% safe. While we do our best to ensure that we do not suffer a security breach, we are not liable if there is an outage, attack, site malfunction, human error, system failure, if one of our necessary third parties is at fault, or any information is misused or mismanaged in any way to your detriment or the detriment of a third party. If we learn of a security breach involving your data, we will notify you via email within 72 hours of identifying the details of the breach so that you can take the appropriate protective steps.
Transfer of Control
In the event that all or a portion of Real & Open or its assets are acquired by or merged with a third party, personal information collected from you would be one of the assets transferred to or acquired by that third party. This Privacy Policy will continue to apply to your information and any acquirer would only be able to use your personal information in line with this policy, unless you give consent to a new policy. We will let you know if such an acquisition has taken place and notify you within 30 days of such a transfer of control, either by posting on our homepage or by emailing you, your child’s educator, or the overseeing educational organization (e.g., school district) directly. If you do not consent to the use of your personal information by a successor company, you may request its decoupling or deletion from that company. In the event that we go out of business or file for bankruptcy, we will protect your information and not sell, share, or give it to any third party.
Your Option to Act
Something wrong? Tell us.
If you think or feel that we are not abiding by this privacy policy or that your information has become compromised, you should contact us immediately via email: hello@tiro.org.
We feel strongly that you should have full control over your information and will work together to redress any complaint.