PRIVACY POLICY

Last modified 08.31.2023

CEV Multimedia, LLC. respects your privacy and is committed to protecting your privacy through our compliance with this privacy policy (this "Policy"). This Policy represents the privacy practices used in our web domain, iCEVonline.com, and its affiliated web domains including aeseducation.com, ctecoding.com, and fouryearplans.com.

CEV Multimedia employs commercially reasonable security measures that comply, in CEV Multimedia’s reasonable discretion and interpretation, with all applicable Federal and State laws and regulations regarding data privacy and security. These measures include appropriate administrative, physical, and technical safeguards to secure data from unauthorized access, disclosure, alteration, and use. Neither CEV Multimedia nor its successors or assigns shall have any liability for the breach of its privacy and security measures or the integrity of its hosting services unless caused by the willful misconduct of CEV Multimedia. CEV Multimedia expressly disclaims any warranty that data exchanges a

We utilize educator's email addresses to deliver our newsletter which is delivered on a bi-weekly basis. The newsletter contains information regarding new features and new lessons added to iCEV. If educators wish to opt out of receiving these newsletters, each email we send contains an unsubscribe link in the footer.

For students who utilize iCEV, we collect the following information:

• First Name
• Last Name
• Login Credentials for iCEV
• Email Address (Not Required)
• One Security Question/Answer Combination

In order to utilize iCEV, students must use an access code provided to them by their instructor. For districts utilizing third-party, single sign-on applications, such as Clever, the administrator of the application must choose to share this information with iCEV for us to gain access.

For subscribers of the Eduthings website (CTECoding.com), the designated subscription administrator provides the following information that is used to provide the subscribed services:

• student demographics
• student enrollment info
• student course history including course schedules and history
• test scores
• Certifications
• WBL
• CTSO participation

Please note that we recognize all data collected regarding teachers, students, and administrators is the property of the district. Also, all data collected is utilized for educational purposes only.

What Do Teachers and Students Do On iCEV?

iCEV is a platform with pre-built courses and lessons that focus on Career and Technical Education subject areas. We have three account access types; each with unique roles:

• Organization Administrator:
  • This is the individual(s) at the district that have been chosen by the district to maintain the account. This individual has access to:
    • Manage Teachers (i.e. add teachers to the platform, delete teachers from the platform, send login credential reset information to teachers)
    • Manage Students (i.e. add students to the platform, delete students from the platform, reset login credential information for students)
    • View Login Reports (i.e. view the number of logins to the platform by teachers and students in their organization, view dates and times of logins to the platform by teachers and students)
    • View Certification Progress (i.e. see progress students have made on industry-based certifications tested for on the platform)
    • View Course Reports (i.e. see the courses teachers have set up, see students enrolled in each course, view course grades)
    • The Organization Administrator role can be set up as Read/Write Access (can add or delete teachers/students) or Read-Only Access (can only view reports).
    • As stated above, the Organization Administrator for the account has been chosen by the district. District personnel who usually perform this function include Career and Technical Education Directors or Coordinators, Curriculum Directors, Instructional Materials Coordinators, and Instructional Technology Coordinators.

• Teacher:
  • Teachers are set-up in the system by the Organization Administrator (unless the district is utilizing a single-sign on application such as Clever)
  • Teachers are invited to join the system by the Organization Administrator entering the teacher's first and last name and email address. The teacher is then sent an email where they will choose their username and password combination and a security question/answer combination. The username must be unique in the iCEV database to be registered.
  • After registering, teachers can add courses to their My Courses page, customize courses by altering the sequence of the lessons in the course or adding lessons to the course and view courses.
  • Courses consist of lessons. Lessons consist of videos and slideshows, lesson plans, project-based learning activity instructions, ancillary learning items such as vocabulary terms and interactive activities and assessments which are automatically graded. Teachers can also view course grades reports which can be filtered by student and by lesson. The grades reports are displayed in either percentage or points basis. The grades reports provide information to the teacher including date and time the activities were submitted by the student and questions answered correctly and incorrectly by the student.
  • All materials that are submitted by students to teachers are completed through the interactive activity and assessments that are pre-built, meaning students cannot complete a project (for example, a slideshow of the proper safety procedures in a science lab) and upload the project for the teacher to view and grade. Therefore, no user-generated content (by either the teacher or the student) is sent through the system. If this changes, we will update this Policy to indicate the changes.

• Students
  • Students are set-up in the system by first being invited by the teacher (unless the district is utilizing a single sign-on application such as Clever). The teacher provides a registration code for the course and sends the students to https://login.icevonline.com/register to complete the registration process. The registration process consists of the student entering the proper registration code, choosing their username and password combination and a security question/answer combination. The username must be unique in the iCEV database to be registered.
  • After registering, students will have access to the courses, lessons and lesson assets (i.e. videos, slideshows, interactive activities and assessments) the teacher chooses to display to the students. The students will also have access to view the grades of the assignments completed on iCEV.
  • As stated above, all materials that are submitted by students to teachers are completed through the interactive activity and assessments that are pre-built, meaning students cannot complete a project (for example, a slideshow of the proper safety procedures in a science lab) and upload the project for the teacher to view and grade. Therefore, no user-generated content (by either the teacher or the student) is sent through the system. If this changes, we will update this Policy to indicate the changes.

For subscribers of iCEV's Eduthings solutions, the roles and capabilities include:

• District Admin: - have access to all settings related to their subscriptions.
• Campus Admin: similar to District Admin but only for specific campuses within their subscription.
• Reporting Admin: a District Admin but only with access to the Analytics section related to their subscription.
• Teacher: - access to enter certification results, career technical student organization (CTSO) participation, work-based learning (WBL) information, viewing reports relevant to their role, managing physical inventory and managing advisory board information.
• Counselor - access to view individual students, entering four-year plans, interventions, checking credits for student graduation readiness, and some reports relevant to their role and subscription.
• Student – access to read or edit their four-year plan, view their course history, take interest inventory and explore career alternatives.

What Data Do We Collect and Why Do We Collect It?

As stated above, we collect limited personal information on each user. In addition to this data, we also collect other information common to websites. This information includes internet protocol addresses, internet service providers, browser and operating software versions and other data to help us improve our services and troubleshoot issues as they arise. In addition, we also utilize cookies which are small files placed on the hard drive of your computer. The cookies we utilize include:

• Google Analytics - we utilize Google Analytics which helps us estimate our audience size and usage patterns and speed up searches.
• HubSpot - we utilize HubSpot on the main domain of iCEV for fillable forms and to help us tweak the content on our main domain to better suit the needs of our visitors.
• ASP.NET – we utilize this as a session tracking code to assist us in determining/identifying the user's session on the server.
• Load Balancer – we utilize a load balancer which sorts our traffic to the most available server for quicker service. This cookie is meant to keep users on the same server between visiting different pages.

You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

How Do We Protect Your Data?

iCEV uses encryption to protect all data according to risks. Encryption is applied to stored data and transmitted data. Passwords are hashed in the database and not stored in clear text. In addition, all team members with access to personal information and data are required to undergo a thorough background check and must also complete professional development programs on data security practices.

In the event of a security breach resulting in unauthorized release of personal data, we will notify affected districts impacted by the breach. In addition, we will place alerts on both our login page (www.icevonline.com/login) as well as each the dashboard for all impacted users with specific details of the breach.

Who Do We Share Your Data With?

Limited data is shared only with trusted third parties. All parties' privacy practices have been reviewed, vetted, and approved by us. Data is only shared for troubleshooting purposes. What third parties are utilized:

• Learnosity – Our assessment technology is powered by Learnosity. No personal information is provided to Learnosity. Each user has a unique ID in our system. This ID is passed to Learnosity to retrieve session activities and scores.
• Kaltura – We utilize Kaltura for streaming video. No personal information is passed to Kaltura as we do not track video usage on an individual basis. Only aggregate video consumption data is utilized.
• Microsoft OneDrive – We utilize OneDrive for delivering Microsoft PowerPoint content (unless the district chooses not to whitelist OneDrive – in this situation we provide the Microsoft PowerPoint content through icevonline.com using an HTML5 player for the slides). No personal information is passed to OneDrive as we do not track Microsoft PowerPoint usage on an individual basis. Only aggregate Microsoft PowerPoint consumption data is utilized.
• Smooth Fusion – We utilize Smooth Fusion for database maintenance and the development of the features on iCEV. In limited cases, Smooth Fusion accesses data to assist in troubleshooting issues.
• Simpatico – We utilize Simpatico to manage icevonline.com servers and load balancers. In limited cases, Simpatico accesses data to assist in troubleshooting issues.
• AWS – server hosting services for AES legacy solutions
• Rackspace –server hosting services for Eduthings solutions
• Google Analytics, LuckyOrange, and Zendesk – used to assist with providing customer support for teachers and admins that use the Eduthings solutions

What Do We Not Do With Your Data?

We do not sell data or any other personal information to any third parties. The only exception to this is in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all the company's assets, personal information, and data may be transferred. In addition, we do not use data to engage in targeted advertising from third parties.

How Long Do We Keep Data?

In the event a district decides not to renew their iCEV access, data is stored for 12 months unless otherwise requested by the district. We utilize 12 months as a threshold due to districts determining after a year of not having access to the product to renew again. This ensures courses customized by teachers will not be lost during inactivity period. However, a district can delete organization data at any time by sending an email request to customersupport@icevonline.com or written request to:

CEV Multimedia
C/O Customer Support
1020 SE Loop 289
Lubbock, TX 79404

To avoid accidental deletion of data, we will confirm the deletion of data with the designated contact for the district.

Can Students or Guardians Review Personal Information in iCEV?

Students and guardians can request to review and, if needed, correct any personal information in iCEV. They can do this by contacting customersupport@icevonline.com.

FERPA and COPPA

iCEV adheres to the rules of FERPA and COPPA regarding all applicable services provided by the organization. iCEV recognizes the importance of controlling personally identifiable information (PII) and reviews controls and capabilities for protecting this data on a regular cadence.

iCEV FERPA Policy

The Family Educational Rights and Privacy Act of 1974 (FERPA) requires that educational services strictly protect the privacy rights of all students who are using or have used our services. This includes parents of students under the age of 18 years old using the service.

By practice and application, students (defined as users) have the right to:

• Inspect and view their records.
• See amendment of education records that are believed to be inaccurate, misleading or otherwise in violation of privacy rights.
• Consent to PII disclosures contained in educational records (except under 34 CFR 99.31)
• File with the Department a complaint concerning alleged failures by the educational agency or institution to comply with the requirements of FERPA under 34 CFR parts 99.63 and 99.64.

To exercise your right to review and/or correct records, as well as requesting amendment, refer to https://www.icevonline.com/privacy-policy Section "Can Students or Guardians Review Personal Information in iCEV?"

iCEV COPPA Policy

The Children's Online Privacy Protection Act (COPPA) is a U.S. federal law that addresses data protection regulations for children under the age of 13. Related to COPPA, iCEV does not market or direct its site or services for purchase by individual students regardless of age. These services do not allow students to register directly with iCEV. Regardless of age, a student must be invited to participate by their district, school, teachers or administrators who have subscribed to associated services in order to obtain a login. The data collected and purpose for data collection is described in this Policy.

To exercise your right to review and/or correct records, as well as requesting amendment, refer to https://www.icevonline.com/privacy-policy Section "Can Students or Guardians Review Personal Information in iCEV?

California Consumer Privacy Act of 2018 Notice ("CCPA")

What is the CCPA?

The California Consumer Privacy Act of 2018, Cal. Civ. Code §§ 1798.100 et seq. ("CCPA") is a law enacted in the State of California with an effective date of January 1, 2020. In November of 2020, California voters approved Proposition 24, the CPRA, which amended the CCPA and added new additional privacy protections that began on January 1, 2023. The CCPA generally expands upon the privacy rights available to California citizens and requires certain companies to comply with various data protection requirements. Please contact iCEV at customersupport@icevonline.com if you would like the detailed text of the law.

The CCPA grants Californian consumers new rights with respect to the collection of their Personal Information and Sensitive Personal Information (as defined herein) and requires companies to comply with certain obligations, including:

-the consumer's right to receive a copy, in a readily usable format, of the specific Personal Information collected about them during the twelve (12) months prior to their request

-the consumer's right to know a business's data collection practices, including the categories of personal information it has collected, the source of the information, the business's use of the information, and to whom the business disclosed the information it has collected about the consumer

-the consumer's right to have such personal information deleted (with exceptions)

-the consumer's right to know the business' data sale practices and to request that their personal information not be sold to third parties

-a prohibition on businesses on discrimination for exercising a consumer right

-an obligation on businesses to notify a consumer of their rights

-the consumer's right to correct inaccurate personal information that a business has about them

-the consumer's right to limit the use and disclosure of sensitive personal information collected about them

-an obligation to disclose how long the business intends to retain a consumer's Personal Information or Sensitive Personal Information

What is Personal Information?

The CCPA defines "Personal Information" as information that "identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular" California consumer or household. Personal information does not include publicly available information or consumer information that is de-identified or aggregate consumer information.

What is Sensitive Personal Information?

The CCPA defines “Sensitive Personal Information” as information that reveals a person's: social security, driver's license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of a consumer's mail, email, and text messages unless the business is the intended recipient of the communication; genetic data; processing of biometric information for the purpose of uniquely identifying a consumer; personal information collected and analyzed concerning a consumer’s health; and personal information collected and analyzed concerning a consumer’s sex life or sexual orientation. Sensitive personal information does not include information that is "publicly available" as defined in 1798.140(v)(1)(L).

How does the CCPA apply to iCEV customers?

iCEV processes data on behalf of its customers who purchase subscriptions to its products. iCEV shall collect, access, maintain, use, process and transfer the Personal Information and Sensitive Personal Information of our customers and our customers' end-users solely for the purpose of performing its obligations under existing contract(s) with our customers; and, for no commercial purpose other than the performance of such obligations and improvement of the services we provide.

iCEV does not "sell" or “share” our customer's Personal Information or Sensitive Personal Information as currently defined under the CCPA, meaning that we also do not share, rent, disclose, release, disseminate, transfer, make available or otherwise communicate that Personal Information or Sensitive Personal Information to a third party for monetary or other valuable consideration or for cross-context behavioral advertising.

iCEV may share aggregated and/or anonymized information regarding use of the service(s) with third parties to help us develop and improve the services and provide our customers with more relevant content and service offerings.

What Personal Information or Sensitive Personal Information Does iCEV Collect, for What Purpose, from Whom, and Do We Disclose it to Service Providers?

Personal Information and Sensitive Personal Information is collected in iCEV's system directly by its customers who use the data in the solutions. It is also collected by iCEV to provide and develop our products and services. iCEV works to maintain the trust and confidence consumers demonstrate when they share their personal information in the solutions. The chart below describes the categories of Personal Information as described in CPPA, the purpose of data collection in iCEV's solutions, the source of the Personal Information, and whether iCEV discloses the Personal Information for business purposes: