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Privacy Policy

Gibbs M. Smith, Inc.  

d.b.a Gibbs Smith Education 


This notice applies to all individuals who visit or use any commercial or educational websites or digital applications associated with Gibbs Smith Education (“GSE”). Our commercial website, is not meant for use by minors under the age of 13. We have identified three different areas in which privacy notice is needed, commercial website(s), end-users, and parents. Please see the appropriate section of this notice as Personally Identifiable Information (PII) will be used differently for each area. 

Personally Identifiable Information, or PII, shall mean any information relating to an identified or identifiable natural person (“data subject”) including personal data as defined under applicable local law. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. 


We collect PII and other information when you access our commercial site(s) or interact with us digitally on our commercial site(s). Depending on the transaction or time on a website, we may collect information from the following categories: 

  1. Payment card industry data such as credit card number, billing address, shipping address, etc. if you make an online purchase from us. In addition to your name, we collect payment information through a third-party website, which included billing and shipping information and credit card data to process your transaction. 
  2. Communications: if you communicate with us or receive communication from us regarding technical support, customer service/success, or other assistance, those interactions may be recorded and monitored to deliver the service or information requested by you. 
  3. Name, initials, or white page information: on our consumer site(s), we collect your name, initials, or contact information when/if you choose to create an account or purchase a product on our online store.  

We collect your computer metadata and content to provide, improve, and maintain our products and services. 

When you make transactions or visit our website(s), we collect certain information from you through the use of cookies, web beacons, or other tracking mechanisms. This may include information about your experience, like your IP address, Operating System, pages viewed, and time spent. This allows GSE to collect information about customer usage and online behavior to tailor marketing work and offerings to our customers. 

We also use third-party tracking mechanisms like Google Analytics to customize, maintain, and improve our website(s). You may disable cookies via your browser or third-party mechanisms. However, some features and services may not function properly without them. To learn how to manage your cookies, please follow the instructions for your specific browser. There are websites that will allow you to opt out of the multi-use cookies 

We do not share your personal information with any other entity or business except for the following or potential reasons: 

  1. Sale of our business to another organization. In the event of a sale, merger, or acquisition, we will be able to transfer your PII toa. Separate entity. We will use commercially reasonable efforts to ensure and require protection of your PII only for authorized purposes and by authorized persons in a manner consistent with the choices that you have made when doing business with GSE. 
  2. Law Enforcement. In the event that GSE receives a legal demand for customer data from a law enforcement agency, that request will only by honored if: 
  3. The request complies with all laws and clearly establishes the legal need for disclosure 
  4. The request is related to a specific investigation and specific user accounts are implicated in that investigation 
  5. Whenever legally permissible, users shall receive notice that their information is being requested 
  6. Partnerships with GSE. If we engage in partnerships or legal contracts with other organizations that may use your PII, we will require them to adhere to our current Privacy Policy and Terms of Use as if they were a direct part of GSE should any sharing of PII be needed for the partnership. 


GSE uses industry-standard security measures to protect your PII from unauthorized access and use when you submit personal information (e.g. to complete a purchase), via a website. Your information is protected both online and offline. 


We will retain your data for the minimum amount of time necessary to accomplish the purpose for which it was collected, and no longer. We will retain and use your data as necessary to comply with our obligations, resolve disputes, and enforce agreements. 


GSE only does business in the U.S. and its affiliated territories. We will not, under any circumstance transfer your information overseas, unless it is to complete a scope of work which we have agreed to through a business transaction and agreement and a critical needed vendor to complete that scope of work is located outside the U.S. In that event, we require our vendors use servers housed and maintained by U.S.-based companies (e.g. Amazon Web Services) and strictly maintain our privacy policies and applicable U.S. privacy laws (FERPA, COPPA, etc.). 


GSE is fully committed to protecting the privacy of all end-users. Since GSE is a service provider to your educational institution or school, your educational institution, or school are best able to provide you with a full understanding of their privacy practices and more information on how their end user’s Personally Identifiable Information (PII) is collected, used, and possibly shared. To obtain more detailed information about how PII is collected, used, and shared by your educational institution or school, please contact the appropriate individual at that institution. 

Any PII that GSE collects falls within your educational institutions or school’s Privacy Policy should they require compliance and/or within these categories and ways: 

  1. We may collect your name, initials, and personal contact information if your educational institution or school uses one of our online learning products (e.g. If this is the case, we only retain that information while there is an active service agreement between GSE and your educational institution or school. 
  2. In some instances, we collect PII from third parties who provide single-sign-on functions via Learning Management Systems or related tools (e.g. ClassLink). We only collect and securely store this information within our online system which maintains industry-standard security mechanisms and systems and only for as long as there is an active service agreement between GSE and your educational institution or school.  
  3. We always limit the use, collection, and disclosure of your PII to the minimum level necessary to deliver the service or information requested by your educational institution or school. We do not collect, use, or disclose PII that is not reasonably related to a legitimate business purpose necessary to serve you. 

We will never sell end-user PII or use any PII information from educational records for marketing or sales purposes. 

We only share your PII in order to provide, maintain, or improve our products or services internally, or responding to legitimate legal requests. 


GSE takes your student’s privacy seriously. Any Personally Identifiable Information (PII) we collect is used to directly support the education and the improvement of our products and services in service of your student’s education. We will never market or sell to an end-user (students), and will not use PII for such purposes. Additionally, we securely store and use PII only while an active service agreement between GSE and your student’s school exists and insist that any outside vendors we may use to provide products or services abide by the same standards of practice.