Information We Collect, How It Is Used and Shared
Our primary purpose in collecting personal information is to help deliver an effective and enjoyable experience while using our Services. Personal information means information that specifically identifies an individual (such as a name, address, telephone number, mobile number, or e-mail address) or other information about an individual that is directly linked to personal information.
When you participate in a LENA program, all of the information we collect during your participation in the program, as described below, is shared with the organization conducting your program.
We may also share your personal information with other third parties if you authorize us to do so as part of any separate consent that you provide to us, when applicable.
We may also share your information if another company acquires our company, business, or our assets.
We do not sell your information to third parties for their commercial use.
For Parents and Children Enrolled In a LENA Program
If you or your child are enrolled in a LENA program, personal information about you and your child is collected. Some information is required, such as your child’s birthdate and gender. This information is used to provide the programs, for example to process the LENA audio data accurately.
In some LENA programs a mobile phone number capable of receiving text messages may be required. This information is used to send you text reminders and notices throughout the program. If you provide us with a texting phone number, that number will be shared with our service provider to send you text messages.
Other personal information may be optional depending on the organization that is conducting the program. This might include your name, your child’s name, your address, your e-mail address, and other household information. This information is used to personalize the LENA program, to provide the LENA program to you and your child, and for potential follow up after the program has ended.
When your child completes a LENA recording, an entire day of audio (sound) is stored on the LENA device. The LENA device cannot play back the audio. It is designed only to connect to a computer for processing. The processing never recognizes words or their meaning; it only counts them. The processed ‘count’ data is collected and is used to produce reports that tell you how much you are talking to and with your child. The reports are associated with you and your child and are personal information. The reports include information and statistics on counts of words, conversational turns, TV/electronic minutes, and other information about the sound environment such as how loud it is. Unless you are participating in a special research study as explained below, we do not listen to the audio data and it is permanently erased after processing.
For certain special research studies, the LENA audio data may be retained to meet the needs of the study. This is rare. Special studies are normally conducted by a university or other research institution and require approval by an Institutional Review Board (IRB). If you are participating in such a study, you will be asked to sign an informed consent form before the study begins. This form will explicitly state what audio will be retained and for what purpose. Please consider any consent carefully before signing.
As part of your participation in a LENA program, you may also be asked to complete a LENA Developmental Snapshot (a “Snapshot”). This is a questionnaire that we use to examine how well your child is doing recognizing and saying words. The Snapshot form contains personal information, including the answers you provide when filling it out. The Snapshot data is used to produce reports in a way similar to the ‘counts’ produced from the LENA recordings. These reports are associated with you and your child and are personal information.
The Snapshot can be filled out on a paper form or online via a web form. For the paper form, after you complete it, after you turn it in to your LENA program coordinator, they (or their administrator) will enter the responses into LENA Online. For the web form, once you answer the questions, you’ll electronically submit the form to LENA Online.
In some LENA programs, your attendance to a class or session may be tracked. This information is used to help evaluate the program. You may also be asked to fill out an additional short questionnaire about your observations during the LENA program. These answers are averaged together with other participant responses to help understand what you’ve observed in yourself, your child, or your family throughout the program. Your answers to the questionnaire are associated with you and your child and are personal information.
In addition, there is often an anonymous evaluation form that you fill out at the end of the LENA program. This form provides feedback on the program and provides an opportunity for you to suggest improvements. Unless you provide personal information in your answers, this form is not personal information.
For Users of LENA Online
If you are a coordinator, educator, manager, administrative staff, or other user that logs in to LENA Online, the information you provide when you obtain your user name and password is collected, this includes your name and e-mail address. If you decide to receive text messages from LENA Online, your texting phone number is also collected. We use this information to configure your LENA Online account, for password resets, and to send you messages from LENA Online via e-mail and through text messages if you have opted to do so.
LENA Online is self-administered by the organization who purchases the LENA Online subscription. Your personal information is inherently shared with that organization. In most cases this is usually your employer. If you have opted to receive texts from LENA Online, your texting phone number will be shared with our service provider to send you text messages. Similarly, if your e-mail address will be shared with our service provider.
When you use LENA Online, we collect non-personal information about your web browser, IP address, computer or phone being used, and other information. For example, we collect the pages you visited, how long you visited those pages, the full clickstreams to/from those pages, and other information about your session. We use this information to understand LENA Online usage and to improve the LENA Online user experience. This information is shared with our service providers who helps us track this information.
For Those Using Our Websites and Online Store
If you sign up for a newsletter, participate in a survey, utilize our contact form, or use other services on our websites, we may collect personal information such as your name, e-mail address, phone number, physical address, payment information, and other information you may provide to us in the online communications you send us (e.g., related to a support or service issue). We use this information for the purpose it was provided, and to follow up with you if needed. When you sign up for a newsletter, webinar, conference, or some other service, your personal information may be shared with our service providers who help us provide that service. When you purchase a product on our online store, your personal information is shared with our service provider(s) who helps us fulfill orders, process payments, and deliver packages.
If you receive an automated e-mail from us, we may receive a confirmation when you open the e-mail. We use this information to make our e-mails more useful and impactful.
Personal information does not include aggregated information or other information which is non-personally identifiable (information that does not reasonably identify you as the source of that information). We may collect and generate non-personally identifiable information through your use of our Services. For example, if you browse our website, use a web form, or utilize our online store, we may collect non-personal information about your web browser, IP address, computer, or phone being used, and other information. We may also collect information regarding the pages you visit, how long you visit those pages, the full clickstreams to/from those pages, and other information about your interaction with our Services. All rights in any non-personally identifiable information we collect or generate will belong to LENA. To the extent permitted by law, LENA may use and share this non-personally identifiable information for any lawful business purpose without any duty or obligation to you or any third party.
Cookies and Web Beacons
Web beacons are small images placed on a web page to monitor the behavior and collect data about the visitors viewing a web page. They can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. We may use web beacons or similar technology on our websites or LENA Online from time to time for this and other purposes.
Collection of Information by Third-Party Sites and Sponsors
Processing In The United States
If you reside outside of the United States and give us personal information through the use of our Services, we will send and store your personal information outside of your country. By using our Services, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.
Retention of Data
If you are enrolled in a LENA program and provide personal information to the organization that is implementing the program, that organization decides how long to retain your data. When that organization is no longer implementing the LENA program (i.e. their agreement with LENA has ended), we will securely delete or reasonably de-identify the data that is stored with us within a reasonable time. We will provide the organization with the ability to download all of their data, including any personal information they collected. The organization may still retain your personal information according to their own privacy and retention policies. In most cases when the organization decides to no longer implement LENA programs, we retain the ‘count’ meta-data from processed recordings and the birthdate for the person who was being recorded. All personal information is reasonably de-identified or deleted. We will retain this information indefinitely unless we have agreed otherwise based on either the consent you sign or the agreement we had with the organization implementing the program you participated in. Any retained data that is non-personally identifiable may be used by LENA for any lawful business purpose.
If you purchase or otherwise use our Services directly, we will retain the information collected to complete the purchase according to our taxing authority rules and laws.
If you sign up for a Service on our websites such as a newsletter or web conference, or use our contact form, we will retain your data indefinitely. If we used a service provider for the service, they may retain your data according to their policies.
You can always choose to not provide your personal information. But, by not providing some information you may not be able to use our Services or to use them to the fullest extent.
If you do not wish to receive further communications from us, you can opt out of e-mail using the unsubscribe link included in our communications, or reply to our text messages with “STOP.”
In LENA Online, you can update your information and preferences using the My Profile page.
Most web browsers support the ability to turn off cookies, delete the cookies after your session, or otherwise manage what cookies are accepted. This can usually be found in the Help feature of the browser.
Reviewing, Correcting, and Removing Your Personal Information
If you or your child are enrolled in a LENA program, please contact the organization who is implementing the program regarding your personal information. If you do not know the organization or how to reach them, please contact us at firstname.lastname@example.org or 866.307.6534.
If you have purchased or otherwise used our Services directly, upon request, LENA will provide you with information about whether we hold any of your personal information. If we hold any of your personal information, you may contact us:
- To review that personal information
- To request that we correct any errors, outdated information, or omissions that personal information
- To request that your personal information not be used to contact you
- To request that your personal information be de-identified or deleted from our records
To exercise any of these rights, please contact us as indicated in the Section titled “How to Contact Us”. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.
LENA takes data security very seriously. We have put in place what we believe to be reasonable organizational, technical, and administrative measures to safeguard against unauthorized access, misuse, loss, disclosure, alteration, and destruction of the personal information under our control. Unfortunately, there is no such thing as “perfect security.” Therefore, while we strive to protect your personal data, we cannot guarantee the security of your personal information. If we are required to notify you about a situation involving your data, we may do so by email, telephone, or mail.
We are System and Organization Controls (SOC) 2 Type II compliant. Each year our security program and security practices are audited by a third party. This audit ensures, among other things, that we are adhering to robust security practices, that we train our employees and hold them responsible, and that we have tight controls inside and outside our organization.
We make extensive use of encryption. We use Secure Sockets Layer (SSL) technology to encrypt your personal information during transmission. We use disk encryption technology to encrypt data in storage (i.e., data at rest).
For our Services, we continue to work on features to keep your information safe in addition to things like deleting the audio file after processing and using unique identifiers in place of your and your child’s name where appropriate.
If you log into LENA Online, it is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when finished.
Our Services are not directed at parents, caregivers, or users under the age of 18. We do not sell products for purchase by children. If you are under the age of 18 and want to participate in or purchase LENA Services, then you will need to have your parent or guardian agree to that on your behalf.
We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
Notice to California Residents
Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with LENA are entitled to ask us for a notice describing what categories of personal customer information we share with third parties for their direct marketing purposes. This notice will identify the categories of information shared with and will include a list of the third parties with which it is shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please contact us as indicated in the Section titled “How to Contact Us.”
How to Contact Us
Updates & Effective Date
Effective: May 17, 2018