Blackboard Privacy Statement

How We Use Your Information Depends on Your Relationship With Us

Vendors, Partners & Other Types of Disclosures

Client Engagement & Marketing

Childrens Privacy

Security

Data Transfers & Additional Regional & Country Information

Your Rights

Contact Us

Summary

Introduction

How We Use Your Information Depends on Your Relationship With Us

Vendors, Partners & Other Types of Disclosures

Client Engagement & Marketing

Childrens Privacy

Security

Data Transfers & Additional Regional & Country Information

Your Rights

Contact Us

This summary highlights the key points of our Privacy Statement. You can find details for each point by clicking on the links.

We care about your privacy and have a dedicated data privacy program. We do not and will not sell or rent your data unless this is required in the context of a change to our business structure.

Learn more about our approach to data privacy.

This Statement applies to our Blackboard websites as well as to the products and services mentioned in section 3.C. For all other products and services, your institutions privacy statement governs.

Learn more about how we use personal information

We share personal information with vendors that help provide our products and services. We also share personal information with partners and other third parties in certain circumstances.

Learn more about how we share personal information

We conduct marketing to promote our products and services. This marketing is aimed at staff of our current and potential clients and partners. We do not use or disclose student information for behavioral targeting of advertisements to students.

We do not knowingly collect any personal information from children under the age of 13 without consent.

Learn more about how we use childrens personal information

We employ a variety of physical, technological and administrative security safeguards designed to protect personal information.

Learn more about our security safeguards

We may transfer your information to locations outside of your country.

Learn more about data transfers and country-specific privacy information

if you want to exercise your privacy rights, have a complaint, or want to ask a question.

Learn more about your rights and how you can contact us

This Statement was last updated on May 24, 2018. Whats new?

We care about privacy.We believe that privacy is a fundamental right for all individuals. Our clients entrust us with the personal information of their employees and their users, who are often students. We take the obligations that are attached to this information very seriously. We therefore have a dedicated data privacy program with privacy by design at heart. You can learn more about our data privacy program by visiting ourPrivacy Center.

Our business model is different from that of companies that collect your personal information to monetize such data. We collect and use personal information to allow us to provide our products and services to our clients and end users. In most cases, we do this at the direction of our clients. We do not and will not sell or rent your data to third parties unless this is required in the context of changes to our business structure such as a merger or acquisition. SeeVendors, Partners & Other Types of Disclosuresfor more details on how we may disclose personal information in the context of changes to our business structure.

We are EU-U.S. Privacy Shield certified, a proud signatory of the Privacy Pledge, and a member of the Future of Privacy Forum.

Who we are.When we refer to us, we, our, or Blackboard in this Statement, we mean Blackboard Inc. and its affiliates.

This Statement governs all our services that we provide directly to you.Whether you are browsing our websites, receive our newsletters, or use an online trial version of our products, this Statement governs the use of personal information for all our products and services that we provide directly to you as a so-called data controller.

When your institutions privacy statement/policy governs.If you are an end-user of our client and we are providing our products and services to you on our clients (your institutions) behalf, we are considered a data processor. In this case your institutions privacy statement governs the use of personal information. Our Privacy Statement does not supersede the terms of any agreements between us and your institution (or any other client or third party), nor does it affect the terms of any agreement between you and your institution.

Changes to this Statement.From time to time we will need to update this Statement to reflect changes to our products and services, the way we operate, or to meet new legal and regulatory requirements. You will find the latest version of this Statement at. We will explain changes to this Statement on theWhats new?page.

What personal information we collect and how we use it will depend on your relationship with us. Please click on the plus symbol to collapse or expand the relevant section below to learn more. The other sections in our Statement apply to all our activities.

Blackboard has various websites for different services (for example,Blackboard HelpandBlackboard Community) and geographies that are accessible to anyone. You generally can visit our websites without having to log in or otherwise identify yourself. On some of our websites, you may need to log in to benefit from the service or to make use of all the functionalities and be able to communicate with us or other Blackboard users, such as with Blackboard Community and Behind the Blackboard.

Some of our websites require you to sign up for an account. When you do, we ask you for information, such as your name and email address, that we need to set up your account. Often you can also voluntarily provide additional information, such as a photo or biographical information, to make better use of our websites. We also collect information you provide by completing forms or surveys on our websites. If you provide additional content through user forums, for example, when you communicate with others on Blackboard Community, we may link this information with your personal information if you are logged in.

We collect information about the pages you visit and how you access and use our websites using cookies and third-party analytics tools. This information includes information about the device(s) you use to access the websites including unique device identifiers, IP address, operating system, browser, and cookies. Depending on your device settings, we may also collect information about your geographical location. Learn more about our use of cookies in our

We receive information from affiliates in our Blackboard group of companies, our partners, and other third parties that we use to enhance the website experience and promote our products and services. For example, we will receive information from some third parties about how well an online marketing or email campaign performed.

We use this information to provide and improve our website services as follows.

Analytics and marketing.We analyze usage information for sales and marketing purposes and for trends about our visitors and their demographics and how they use our websites. This analysis is necessary to further our legitimate interest in understanding our users and how they interact with us and our websites, improving our websites and communication with you (including for marketing purposes).

Personalization.For some of our websites we also use your information to personalize the pages, which is necessary to provide more contextually relevant information as you browse our websites. For example, if you have indicated your primary industry or your job title, we may present content related to your role or industry as your browse our websites and return to them.

Communication.If you use Behind the Blackboard, Blackboard Community, or other websites with logins, we use the contact details you provided to communicate with you and to let you communicate with us and other Blackboard users. Typically, we use information in this way because it is required to provide this service to you and because it is in our legitimate interests to ensure our services are being offered in a manner that meets our high standards.

We keep website usage information for as long as it is necessary for the purposes described above. This period of time will vary depending on the services and websites you use and how you interact with us. Account information is kept until you delete the account and for a limited period afterwards. Where you provide information in forms, the information is kept only as long as required. For example, we may need to keep a record of the correspondence with you if you have made a complaint for as long as it is necessary to protect us from any legal claim. Similarly, if you unsubscribe from receiving marketing communications from us, will keep a record of this to ensure you do not receive such communications in the future.

Third-party tools.Where we use third-party tools (for example to understand how our websites are used and make sure you see relevant ads and campaigns on other websites), these third parties will have access to some of your personal information. This includes analytics tools such as Google Analytics and advertising tools such as Facebook Business.

Learn more aboutand about our use of cookies in ourCookie Statement.

Partners.We share personal information with resellers of our products and services and other partners, who may use such information for marketing.Learn more about sharing with partners.

Vendors.We also share information with our vendors and service providers and other third parties for legal or business purposes.Learn more about how we ensure your information is protected by our vendors.

Your institution decides how your personal information is used.We provide most of our products and services to end-users of an institution as a so-called data processor on behalf of our clients (for example, school, districts, universities, and corporations). This means that the main responsibility for data privacy compliance lies with your institution as the data controller. It also means thatyour institutions privacy statement governsthe use of your personal information (instead of ours). Your institution determines what information we collect through our products and services and how it is used, and we process your information according to your institutions instructions and the terms of our contracts with your institution.

Read your institutions privacy statement.The following section is mainly for informational purposes and describes how your information is generally used when we provide products and services to you on behalf of a client. How your information is used depends on your institution, so you should read your institutions privacy statement.

For our Web Community Manager product, please read the separateWeb Community Manager Privacy Policy.

Information your institution provides to us.

Typically, our products and services integrate with your institutions systems. As such, your institution will provide us with information about you to set up and maintain your account or for us to be able to provide the product or service. This includes information in the following data categories:

The exact data elements will depend on the product, but often we receive your name, email address, student ID, account credentials, and courses you are enrolled in when we initially set up the products and services for your institution. We will receive regular updated information to keep your account information accurate and up to date.

For some products, such as Connect and ConnectTXT, we also receive your phone number to send you text (SMS) notifications.

Application, enrolment, and financial aid information.

If we provide Student Services, such as enrollment helpdesk or admission and financial aid support, on behalf of your institution, your institution will make this type of information available to us to provide these services. We generally dont store this information but may have access to your institutions systems that store such data.

Depending on the products and services you use, we will collect the following data categories directly from you:

We collect your first and last name, email address, and similar contact data when you provide or update this information in our products. In many products and services, you can choose to provide more information for your account profile, such as your photograph and other biographical content, which may be shared with others through the products and services. In some products, you can choose to provide your phone number to receive notifications via text (SMS). In our Mobile Learn App you can also give us permission to access your contact list on your mobile device. This allows us to match your contacts to users in Learn and display their photo from the users contact list in discussion boards.

Our products and services often integrate with your institutions systems and rely on the credentials your institution uses. Where this is not the case, we will collect passwords, password hints, and similar security information that we use for authentication and account access.

We collect data about your responses to quizzes, your assignments and other course work, and files you submit or upload as well as your activity and actions within our products and services. In some products, you can also provide comments in discussion forums and chats and send messages to your peers and instructors. If you are an instructor, we also collect information about your grading, feedback and assessments, and similar actions within our products.

Some of our products allow you (as a student or instructor) to submit audio and video feedback, and we collect the related information, including metadata.

If we provide financial aid support on behalf of your institution, we will collect financial information that is required to help you with the related applications.

For some of our products and services, such as Cashnet, we collect data necessary to process your payments, including your credit card number and the security code associated with your credit card. We maintain the applicable Payment Card Industry (PCI) compliance levels for such data.

When you or your institution contacts us for support, we may collect limited information about you that you or a representative of your institution provides to us. We use this information only to assist with client support cases on behalf of your institution. When you contact us, your phone conversations or chat sessions with our client support teams may be monitored and recorded for training and quality purposes. Some of our products and services such as the Blackboard App also have feedback functionality that collects limited information about your device, the product, and your institution such as your user ID and school ID when you provide feedback.

We collect information on how you use our products and services. Depending on which product or service you use, this may include the following data categories:

Our Collaborate product allows for virtual classroom sessions to be recorded. There is an indicator if the session is being recorded.

For some of our Campus Enablement products and services, such as access cards and Attendance, we will collect information about which premises, classes, and events you have visited and attended on behalf of your institution, as well as the time and date of such visits. Additionally, we may collect precise geolocation data when you use the mobile apps for some of our Campus Enablement products. You will be asked if you want to enable location data before we collect such information from your device.

Our Mass Notification and Connect products will collect information on how you react to our notifications. For instance, we record if you listened to our phone call, if we left a voice message, or if the phone call was unanswered.

We collect device and usage information when you access and use our products and services, including information that your browser or the mobile app sends when you are using it. This data may include your unique device identifier, Internet Protocol address, your browser type and configuration, the date and time of your use of the product or service, language preferences, and cookie data. Learn more about our use of cookies in our

We may receive information from affiliates in our Blackboard group of companies, our partners, and other third parties. For example, we may receive limited personal information from our other products or from third-party services that integrate or complement our products to ensure a seamless experience.

Information from social media sites.

When you interact with our products and services through social media services, such as when you log in through Facebook, use Cloud/Social Profile, or share Blackboard content on Facebook, Twitter, or LinkedIn, we may receive information from these social media companies. For instance, when you login to a service like CourseSites using a social media account, the social media company will authenticate your identity and provide you the option to share certain personal information from your social media profile with us, which could include your name, email address, age, gender, position, and profile picture. If your institution has enabled Cloud Profiles or Social Profiles, you can also connect your Blackboard profile with your Facebook and Twitter account and use information from those accounts for your Blackboard profile. The data we receive is dependent upon the social media service and your privacy settings with the social media service.

Our Social Media Manager product allows institutions to collect public social media posts and comments with matching keywords and hashtags to give an institution visibility into social conversations taking place about them. Social Media Manager will retain this information for the institution even if the original content was deleted.

On behalf of your institution.We use your information on behalf of and under the instruction of your institution, which is the data controller. We use the information in accordance with our agreement with your institution to operate, maintain, and provide the features and functionality of the products and services. Your institution determines how your information is used.

Analytics.Providing our products and services to your institution may include analytics functionalities. Among other things, such functionalities can indicate your performance compared to that of your peers, project your future performance, and provide this information to instructors and other staff of your institution so they can support you.

Please read your institutions privacy statement for more details on how your institution uses your personal information.

Product enhancements and research.Where the agreement with your institutions gives us the permission, we may also use:

Your personal information to evaluate and improve our products and services and develop new products and services

De-identified information for other purposes such as carrying out research and analyzing trends to better understand how users are using our products services and how we can further improve them

When we use information for these purposes, we will implement appropriate safeguards. This may include removing or hashing direct identifiers (e.g., your name, email address, and device ID) from the data set before carrying out research and analysis.

We share your information in accordance with our agreement with your institution. Generally, this includes the sharing of data within and outside of Blackboard.

Your information will be accessed only by those who have a need to know to provide the products and services to your institution and improve them. For instance, our technical teams and client support teams may have access to your information when we set up the product for your institution or when software or database changes are required for support and maintenance purposes.

Much of the personal information we collect and use about you is shared with your institution that uses our products and services and with other institutional users. What information is shared depends on the product functionality, settings, and instructions of your institution. Please read your institutions privacy statement to learn more.

We use vendors to help us provide our products and services to you on behalf of your institution. For example, IBM, Amazon Web Services, and Microsoft help us host our products and services. Where we use third-party tools (for example to understand how our products and services are used), these third parties will have access to some of your personal information. This includes analytics tools such as Google Analytics (

Your institution may ask us to share such information with additional parties or it may share your information further. Please read your institutions privacy statement.

Learn more about how we share information.

If you are using online trial versions of our products, such as Learn, Collaborate, or Moodlerooms, we are providing these products and services directly to you as the data controller. Similarly, if you are using our Open Education service directly with us (instead of as instructed by your institution), we are considered a data controller. In these instances, we are directly responsible for data privacy compliance andthis Privacy Statement governshow your information is used.

Depending on the products and services you use, we will collect the following data categories directly from you:

We collect your first and last name, email address, and similar contact data when you provide and update this data in our products. In many products and services, you can choose to provide more information for your account profile, such as your photograph and other biographical content, which may be shared with others through the products and services. In some products you can choose to provide your phone number to receive notifications via text (SMS).

We collect passwords, password hints, and similar security information that we use for authentication and account access.

We collect data about your responses to quizzes, your assignments and other course work, and files you submit or upload as well as your activity and actions within our products and services. In some products you also can provide comments in discussion forums and chats and can send messages to your peers and instructors. If you are an instructor, we also collect information about your grading, feedback and assessments, and similar actions within our products.

Some of our products allow you (as a student or instructor) to submit audio and video feedback, and we collect the related information, including metadata.

When you contact us for support, we may collect limited information about you that you provide to us. We use this information only to assist with client support cases. When you contact us, your phone conversations or chat sessions with our client support teams may be monitored and recorded for training and quality purposes.

We collect information on how you use our products and services. Depending on which product or service you use, this may include the following data categories:

Our Collaborate product allows for virtual classroom sessions to be recorded. There is an indicator if the session is being recorded.

We collect device and usage information when you access and use our products and services, including information that your browser or the mobile app sends when you are using it. This data may include your unique device identifier, Internet Protocol address, your browser type and configuration, the date and time of your use of the product or service, language preferences, and cookie data. Learn more about our use of cookies in our

We may receive information from affiliates in our Blackboard group of companies, our partners, and other third parties. For example, we may receive limited personal information from our other products or from third-party services that integrate or complement our products to ensure a seamless experience.

Information from social media sites.

When you interact with our products and services through social media services, such as when you log in through Facebook, or share Blackboard content on Facebook, Twitter, or LinkedIn, we may receive information from these social media companies. For instance, when you log in to a service using a social media account, the social media company will authenticate your identity and provide you the option to share certain personal information from your social media profile with us, which could include your name, email address, age, gender, position, and profile picture. The data we receive is dependent upon the social media service and your privacy settings with the social media service.

To provide features and functionality.We use your information to operate, maintain, and provide to you the features and functionality of our products and services, as well as to communicate directly with you (for example, to send you email messages and push notifications) to allow you to communicate with others in the product and service. Typically, it will be necessary for us to use your information in this way in order to provide you with the service you request or because it is in our legitimate interests to ensure our products and services are being offered in a manner that meets our high standards.

Analytics.Some of our products, such as our Learn trial version, include analytics functionalities. Among other things, such functionalities can indicate your performance compared to that of your peers and project your future performance. Typically, it will be necessary to use your information in this way to provide this functionality or because it is in our legitimate interests to ensure this functionality operates to our high standards.

Improve our products.We use de-identified information to understand and improve our products and services. We carry out research and analyze trends typically because it is in our legitimate interests to better understand how users are using our products services and how we can further improve them. When we use information for these purposes, we will implement appropriate safeguards. This may include removing or hashing direct identifiers (e.g., your name, email address, and device ID) from the data set before carrying out research and analysis.

Marketing.When you use our trial versions, we may use your information for marketing purposes.Learn more about marketing.

We share information to provide the products and services to you and further improve them.

Your information will be accessed only by those who have a need to know to provide the products and services. For instance, our technical teams and client support teams may have access to your information when software or database changes are required for support and maintenance purposes.

We use vendors to help us provide our products and services to you. For example, IBM and Amazon Web Services help us host our products and services. Where we use third-party tools (for example to understand how our products and services are used), these third parties will have access to some of your personal information. This includes analytics tools such as Google Analytics (

). We may also share that you have registered for a trial version with the relevant channels partners in your country or region.

Learn more about how we share personal information.

This section provides more information on how we protect your information when we engage vendors, how we share information with our partners, and in which other scenarios we may share your information with third parties.

We use vendors to help us provide our products and services to our clients and you or to perform work on our behalf. Where this requires access to personal information, we are responsible for the data privacy practices of the vendors. Our vendors must abide by our strict data privacy and security requirements and instructions. They are not allowed to use personal information they access or receive from us for any other purposes than as needed to carry out their work for us.

In some countries and regions, our products and services are offered through channel (or reselling) partners (see the list of our channel partners).We will share information with them that is necessary for them to offer and provide our products and services to our current and prospective clients.

Some of our products allow you to access functionalities or content provided by our content and technology partners. For example, Blackboard Learns integration with Dropbox Education allows institutions and users to store and share content using Dropbox functionalities. With your or your institutions permission, we will share information about you, such as your name, email, or student ID, that is required for you to access these partner functionalities or content from our products and services.

We will also share your information where required in the following circumstances.

W