CPM Educational Program ("CPM," "we," or "our") respects your privacy and is committed to protecting it through compliance with this policy. This policy describes the types of information we may collect from you, and our practices for collecting, using, maintaining, protecting, and disclosing that information when you use CPM.org and any related subdomains, including any Licensed Content, functionality, eBooks, and services offered on or through the Website.
1. The Information We Collect About You
We collect information from you when you register on and use the Website. When registering, you may be asked to provide your name, email address, mailing address, phone number, employer (or school and school district), and/or job title. Your school or district may also provide CPM with information to enable access to Licensed Content, including name, email, student number, user ID, grade level, teacher, and class information.
When purchasing items through our online store, you may also be asked to provide payment information. You may visit our website anonymously for some purposes.
We also automatically collect usage details when you visit our Website, such as your IP address and other information collected through cookies. We may also collect, use, and share de-identified Aggregated Data for any purpose — this is not considered Personal Information as it does not identify you.
As you interact with our Website, we may collect Technical/Network Data about your equipment and browsing patterns. We do not use automated technologies to track your online activities across third-party websites.
2. Use of Cookies
Cookies are small files transferred to your computer's hard drive through your browser that enable our systems to recognize your browser and remember certain information about your visit, such as your IP address, the domain from which you accessed the Website, the date and time of your visit, and the pages you visited.
We use this information to understand and save your preferences for future visits and compile aggregate data about site traffic. We may contract with third-party service providers to help us better understand our site visitors — these providers are not permitted to use the information except to help us conduct and improve our business.
The information we collect automatically is statistical and does not include Personal Information. We do not perform any behavioral tracking. For more information, review our Cookie Policy.
3. How We Use and Disclose Your Information
Information we collect may be used to: personalize your experience; improve our Website; provide you with requested information; improve customer service; send periodic emails; allow access to Licensed Content; enable use of eWorkspace; provide eBook previews; and complete orders through our online store.
We may share Personal Information with the following categories of third parties:
- Professional Development/Workshop Online Scheduling Software Services
- Accounting and Administrative Software
- Printer and Shipping Companies
- Specialized Consulting Service Companies
CPM will not provide or sell to any third party any Personal Information in a Student Record, or engage in targeted marketing.
We may also disclose Personal Information as described in this Privacy Policy with:
- Contractors, service providers, and other third parties bound by confidentiality obligations.
- Law enforcement or regulatory bodies to comply with any law, court order, or legal process.
- Parties to enforce our Website policies or protect our or others' rights, property, or safety.
- A successor entity in the event of a merger, acquisition, or similar proceeding.
4. How We Protect Your Information
We implement a variety of security measures and provide training to maintain the safety of your Personal Information when you enter, submit, or access it, and to secure it from accidental loss and unauthorized access, use, alteration, and disclosure.
Although we do our best to protect your Personal Information, we cannot guarantee the security of information transmitted via the Internet to our Website. CPM servers are physically located within the continental United States.
5. Your Rights and Choices
CPM uses Personal Information as needed for the purpose for which it was collected or where you have consented. You can always decline to provide Personal Information, though some features may require it to function.
We provide the following controls over your information:
- Cookies. You can set your browser to refuse cookies or alert you when cookies are being sent. Some parts of the Website may not function properly if cookies are disabled.
- Do Not Track (DNT). CPM does not use automated technologies for behavioral tracking and therefore does not respond to DNT signals.
- Third-Party Advertising. We do not share your Personal Information with unaffiliated third parties for advertising purposes.
- Promotional Emails. You may opt out of promotional emails by contacting us or clicking the unsubscribe link in any marketing email.
- Targeted Advertising. We do not use Personal Information to perform targeted advertising.
- Right to Access and Correct. You have the right to request inaccurate Personal Information be corrected. Contact us at the address in Section 11.
Your State Privacy Rights
Residents of Colorado, Delaware, Indiana, New Jersey, and Oregon have the right to:
- Confirm whether we process their Personal Information.
- Access and delete certain Personal Information.
- Correct inaccuracies in their Personal Information.
- Data portability.
- Opt-out of personal data processing for targeted advertising, sales, or profiling.
- Limit or require consent to process sensitive personal data.
To make a state privacy request or appeal a decision, email us at the address in Section 11. Colorado residents may also contact the Colorado Attorney General with concerns.
Your Rights Under California Law
California residents may request information regarding our disclosure of Personal Information to third parties for direct marketing purposes. As stated above, we do not make such disclosures. California residents under age 18 may request removal of publicly posted content by contacting us directly.
6. Student Records
Control of Student Records
Student records obtained by CPM from a school are, and will continue to be, property of and under the control of the school. Student Records include any information directly related to a student maintained by the school or acquired through instructional software assigned by a teacher or school employee.
Control and Transfer of Student-Generated Records
Students can generate Student Records through eWorkspace. Student-generated records will only be retained by CPM for the duration of the applicable semester, class, or program. After such time, the school will control and retain all related Student Records.
Ability to Correct or Access Student Records
The school is responsible for providing means by which parents and eligible students may review and correct Student Records. To review, correct, update, or delete Personal Information in a Student Record, a parent or eligible student should contact the school directly.
Use and Targeted Marketing
CPM does not use or disclose Student Records for targeted marketing. Student Records are used only to provide students access to the Website pursuant to the applicable license or Purchase Agreement.
Retention and Deletion of Student Records
CPM certifies that Student Records shall not be retained by CPM upon completion of the applicable license or Purchase Agreement. Within one week following expiration of the applicable semester, class, or program, all related data including student Personal Information shall be deleted from CPM's servers using industry best practices.
Schools may submit deletion requests before end of term by contacting us at the address in Section 11. Parents may also submit deletion requests directly to us.
FERPA Compliance
Prior to the transmission of any Student Records, CPM and the school will execute a license agreement or Purchase Agreement in accordance with FERPA, unless the information has been designated by the school as "directory information" under FERPA.
7. Data Retention
CPM will securely maintain Personal Information, other than Student Records, only as long as required to satisfy applicable federal and state record retention requirements. Upon expiration of such period, the data will be securely de-identified or destroyed.
8. Unauthorized Access or Disclosure
In the event of an unauthorized disclosure of Personal Information or Student Records, CPM shall report such disclosure to the affected user(s) — or parent if applicable — within 24 hours of learning the security, confidentiality, or integrity of such Records was, or is reasonably believed to have been, compromised.
If applicable, CPM and the school or school district shall work together to provide notice to the affected individuals.
9. Children Under 13 / Children's Privacy Policy
CPM does not permit children under the age of 13 to create an account without the consent and at the direction of a parent or school. Please contact us if you believe we have inadvertently collected information from a child under age 13 without appropriate consent.
When CPM is used by a school in an educational setting, CPM may rely on the school to provide the requisite consent for collecting information from a child, in lieu of parental consent.
- Information Collected from Children. Children can access many parts of the Website without providing Personal Information. Some features require registration. We only collect as much information as is reasonably necessary for the child to access and use the Website.
- Information Collected Directly. If a school contracts with CPM, the school will provide CPM with Student Records for user account creation, or create accounts for its students directly.
- How We Use Children's Information. We use Personal Information collected from children only to register the child for Licensed Content and provide the Website for the child's use.
- Third-Party Operators. CPM does not use any third-party providers who collect or maintain information from children.
10. International Users
If you are accessing this Website from outside of the United States, your Personal Information may be transferred to and maintained on computers located outside your jurisdiction where privacy laws may not be as protective. By choosing to provide your Personal Information to CPM, you consent to the transfer of that information to the United States and its processing there.
11. Contacting Us
If you have questions or concerns about this Privacy Policy, or wish to correct, update, delete, or limit use of any Personal Information, contact us at [email protected].
12. Changes to Our Privacy Policy
If we decide to change our Privacy Policy, we will post those changes on this page and update the modification date at the top. Your continued use of the Website following the effective date of such update constitutes your acceptance of the revised policy.
We will not make any material changes to our Privacy Policy that relate to the collection of Student Records without first giving notice to the school and obtaining consent before Student Records are used in a materially different manner than was disclosed when the information was collected.
