Last updated April 18, 2023.
Conjuguemos is a simple, easy-to-use platform that helps teachers engage their students in the practice of a variety of “foreign” (non-English) languages. Conjuguemos offers vocabulary, grammar, and verb conjugation activities and games in the following languages: Spanish, French, Italian, Portuguese, German, and others. There are also listening activities for Spanish. The typical use of Conjuguemos is the following:
Students can create their own account, but can only tie that account to a class after they receive a unique code from their teacher. Teachers are also able to register students in a variety of ways (manually, by importing from GoogleClassroom, etc). If the school or teacher elects to utilize Conjuguemos with students under a specific age, the school will be responsible for obtaining any necessary parental consent under the applicable laws.
In collecting and processing your personal information, we will comply with the data protection laws and regulations in force at the time. This requires that the personal information we hold about you must be:
First and foremost, you should know that Conjuguemos does not sell or rent any of your, or your students' personal information. While Conjuguemos does not sell/rent personal information, however, non-premium users will see ads that are served via third-party companies. These third-party companies (such as GoogleAds) do collect information on visits. For users that choose to use the site on a free (“unpaid”) basis, however, Conjuguemos will serve ads that are provided by a third-party ad company, Users can opt-out of these ads by purchasing a premium feature to do so. PLEASE READ THE SECTION BELOW “ADVERTISEMENTS” for more details on third-party ads in Conjuguemos.
We use the information we collect from you to provide the Service and offer the best Conjuguemos experience possible. Concretely, the personal information of students and teachers is collected and used for the following purposes:
Your rights relating to your personal information include:
We require that your personal information is accurate. Please let us know if the personal information you provided us for creating your account has changed. If we do not have the correct information, we cannot take responsibility for information-related errors.
We try to be transparent about what information we collect, so that you can make meaningful choices about how it is used. For example, you can:
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
When, as a teacher or school representative, or when acting on behalf of a company or other organization, you create a Conjuguemos account, you provide your first and last name and an email address. We require those data elements for you to enter into the Terms of Service agreement with us, and we process those elements on the basis of performing that contract.
U.S. Educational Institutions and Parental Consent: Consistent with the requirements of COPPA, if you or your school decide to utilize the Service with children under 13, you will be electing to either obtain parental consent or to consent on behalf of the children's parents directly, which is commonly referred to as "School Consent." At the same time, yet subject to exceptions, FERPA prohibits schools from disclosing personally identifiable information from a student's education record to a third party without written consent from the parent or eligible student. Accordingly, schools must either obtain parental consent, or ensure that their use of Conjuguemos meets one of FERPA's exceptions to the written consent requirement. Typically, schools are exempted from obtaining parental consent under FERPA when Conjuguemos is identified as a "school official," meaning Conjuguemos is performing an institutional service or function for which the school would otherwise use its own employees.
European Educational Institutions and GDPR: According to article 8 of the GDPR, minors shall be entitled to give valid consent only if they are 16 years old (unless Member States have set a lower age limit which, nonetheless, cannot be under 13 years old). Under that age limit, processing of personal information related to minors shall be subject to parental consent. Schools are in control of their students’ personal information and are obliged to take all necessary measures for protecting said information. In terms of the GDPR, schools are data controllers and thus determine the purposes and means of the processing of student personal data. As a consequence, schools will also be responsible for informing students and their parents accordingly about what data is collected, which are the purposes of collection, how data is used and to which third parties it is disclosed, including Conjuguemos.
The totality of PII collected is:
Teachers can choose to have their students interact with the site without having students provide any PII. This is done via the PLAY LIVE feature. When using the PLAY LIVE feature, students can access and use the Conjuguemos service without the need to create an account. In this modality, students may have to provide a nickname, and only responses will be collected and processed by the Service. However, this section explains what information Conjuguemos does collect when teachers choose to have their students register with the site.
Conjuguemos collects the minimal amount of information from students necessary to create accounts on our Service: we ask students to provide a unique username, a unique email, a password, their first and last name and a unique code they have been given by their teacher to join a class. Beyond this information, students can submit responses depending on the activities they are assigned, which will remain private between teacher and student. All this information will only be used for the purposes of the school/teacher. In addition, users that choose to use the site on a free (“unpaid”) basis, Conjuguemos will serve ads that are provided by a third-party ad company, and these ads collect information on visits. Users can opt-out of these ads. PLEASE READ THE SECTION BELOW “ADVERTISEMENTS” for more details on third-party ads in Conjuguemos.
We use this information to provide the Service to the child, for security and safety purposes, or as required by law or to enforce our Terms. We will not require children to provide more personal information than is reasonably necessary in order to participate in the Service. If we discover that we have collected information from a child in a manner inconsistent with COPPA, FERPA, GDPR, or any other applicable laws or regulations, we will take appropriate steps to delete the information. We do not disclose any personal information about children to third parties, except to service providers necessary to provide the Service, as permitted by law, or to protect the security of the Service or other users. Information collected from students (including personal information and information collected automatically) is never used or disclosed for third-party advertising, including any kind of first- or third-party behaviorally targeted advertising, and children’s personal information is never sold or rented to anyone, including marketers or advertisers.
No student's profile is made available or visible to the public, or to any other students, through Conjuguemos. Teachers may share their classes, including grades or scores, with other teachers they co-teach with in their school, to help them collaborate. If the teacher chooses to display Conjuguemos in their classroom, either by utilizing the PLAY LIVE feature of the Service or by projecting via a smartboard or interactive whiteboard, students physically present in that classroom may see other students’ names, responses, comments or total scores.
EDUCATIONAL INSTITUTIONS AND TEACHERS SHALL MAKE A RESPONSIBLE USE OF THE SERVICE AND AVOID COMPROMISING CHILDREN'S PERSONAL INFORMATION AT ALL TIMES WHEN DISPLAYING Conjuguemos IN THE CLASSROOM. Conjuguemos SHALL NOT BE HELD LIABLE FOR THE INAPPROPRIATE USE OF THE SERVICE BY THE EDUCATIONAL INSTITUTION OR THE TEACHER.
We only keep a child's personal information for as long as his or her student account is active, unless we are required by law to retain it, need it to ensure the security of our community or our Service, or to enforce our Terms of Service:
After deletion of the student's account Conjuguemos may retain copies and/or backups of the mentioned information for a maximum term of thirteen (13) months. Nevertheless, Conjuguemos shall not be responsible for the accidental loss or destruction of data on behalf of users. Conjuguemos will not be obliged to recover erased data stored in backups when erasure is attributable to users.
EDUCATIONAL INSTITUTIONS UTILIZING THE SERVICE ARE RESPONSIBLE FOR COMPLYING WITH THE RETENTION OF STUDENT EDUCATION RECORDS FOR AS LONG AS LEGALLY APPLICABLE. Conjuguemos SHALL NOT BE RESPONSIBLE FOR ERASURE OF STUDENT PROGRESS DUE TO ACCOUNT DELETION AFTER AN EXTENDED PERIOD OF INACTIVITY OR BECAUSE OF THE TEACHERS' VOLUNTARY ELECTION TO DELETE THEIR ACCOUNTS.
Any parents that want copies of their children's personal information that we may have stored can contact their children's school personnel to that end. At any time, the school can also refuse to permit us to collect further personal information from its students, and can request that we delete the personal information we have collected from them by contacting us at firstname.lastname@example.org. Please keep in mind that deleting records may require us to terminate the account in question. Also remember that before we can share the information with the school, or delete it per your request, we will, by reasonable means, proceed to verify the identity of the requester.
We collect the following types of information about you: (1) information that you voluntarily provide to us by using the Conjuguemos Service (described below under "Information you provide to us"); (2) information collected automatically as result of your use of the Service (described below under “Information collected automatically”); and (3) information obtained through third-party sources (further outlined in “Information Provided by Others”). The types and amounts of information collected will vary depending on whether the user is a teacher or student (e.g. we collect minimal information from students) and how they use Conjuguemos (e.g. if teachers join their school, we may need to collect school address information).
There are currently two categories of users on our Service: teachers and students. We collect and store the following types of information from each type of user:
Our use of the information above is described below in the "How Does Conjuguemos Use the Information it Collects?” section.
IT Admins administering the school's account will have the ability to invite teachers to Conjuguemos via email.
The technologies and information we automatically collect include:
Automated Decision Making (ADM) refers to a decision which is taken solely on the basis of automated processing of your personal data. This means processing using, for example, software code or an algorithm, which does not require human intervention.
Profiling means using automated processes without human intervention (such as computer programmes) to analyse your personal information in order to evaluate your behaviour or to predict things about you which are relevant in the context of using Conjuguemos, such as what kind of videos you used.
As profiling uses automated processing, it is sometimes connected with automated decision-making. Not all profiling results in automated decision-making, but it can.
If you are a teacher, we may use profiling or other forms of automated processing to show you personalized content and make recommendations through the web and/or email based on, but not limited to your usage.
If you are a student (or the parent or legal guardian of a student), we may use profiling or other forms of automated processing to provide your teacher or teachers with analytics on your progress.
In addition to the policy above that applies to all users, we only keep a student's personal information while the student's account is active, unless we are required by law to retain it or need it to ensure the security of our community or our Service, or to enforce our Terms.
Conjuguemos uses a third party advertising companies to serve ads when users visit our Service.
While Conjuguemos offers a Premium/Paid plan, the majority of our revenue comes from advertising. This is because the overwhelming majority of users of Conjuguemos use the site without logging in or creating accounts. For them, this is a free website. Advertising revenue allows us to keep our premium subscription plans affordably priced.
Yes. When teachers/schools pay for a premium subscription, they can choose to purchase the “ad-free” add-on. Once purchased, this will remove all ads from any student or teacher associated with this paid school account. For more information, go to our Pricing page.
Ad companies may use information about your visits to this and other Websites in order to provide advertisements on this site and other sites about goods and services that may be of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, please go to www.networkadvertising.org/choices. If you live in the EU, please see www.youronlinechoices.com.
In the course of serving advertisements to this site, our third-party advertisers may place or recognize a unique "cookie" on your browser.
It is important to us that we keep your information safe and secure. To best provide our services, and keep your information safe, we work with a few other companies. These companies ("third-party service providers", "collaborators" or "agents") will only have access to the information they need to provide the Conjuguemos service.
Your Conjuguemos account is protected by a password. You can help us protect your account from unauthorized access by keeping your password secret at all times. The security of your personal information is important to us. We work hard to protect our community, and we maintain administrative, technical and physical safeguards designed to protect against unauthorized use, disclosure of or access to personal information, such as:
Below is a list of security measures that are provided by the Amazon Web Servers we use to store user data:
Although we make concerted good faith efforts to maintain the security of personal information, and we work hard to ensure the integrity and security of our systems as per best industry standards, no practices are 100% immune, and we can’t guarantee the security of information. Outages, attacks, human error, system failure, unauthorized use or other factors may compromise the security of user information at any time.
Both notifications will be written in plain language, will be titled “Notice of Data Breach” and will present the information described above under the following heading: “What Happened,” “What Information Was Involved,” “What We Are Doing,” “What You Can Do” and “For More Information”. Additional information may be provided as a supplement to the notice.
If for some reason you ever want to delete your account, you may do so by contacting email@example.com and requesting to have your account deleted.
When we delete your account, we delete any personal information that you provided in your profile (such as your name, username, password, email address, and profile photo) and depending on the category of the user you are (i.e., teacher or student) , also questions, responses and comments. Please note that information that you have shared with others, that others have shared about you, or content other users may have copied and stored, is not part of your account and may not be deleted when you delete your account.
We may retain and use de-identified data (i.e., data which has been stripped off of all information that can be used to identify a person) for purposes of research, improvement of our products and services, and/or the development of new products and services. We may also have to retain some information after your account is deleted, to comply with legal obligations, to protect the safety and security of our community or our Service, or to prevent abuse of our Terms. Part of your personal information will also remain in our possession as a copy or backup that is part of our disaster recovery storage system. However, such copies and backups will be kept for a maximum term of thirteen (13) months and they will neither be accessible to the public, nor used by Conjuguemos in the normal course of business.
Access to the Service by the students is subject to the obtaining of a specific code provided by the teacher. The school is, at the same time, responsible for its students' personal information and in control of student academic records. As a consequence, modification or deletion of student personal information that is part of or affects student academic records is subject to the school's discretion.
Conjuguemos SHALL NOT BE RESPONSIBLE FOR THE DELETION OF THE CLASS OR PART OF ITS CONTENT, OR FOR THE ERASURE OR DELETION OF STUDENT PROGRESS OR STUDENT ACCOUNTS, BY ANY OF THE TEACHERS PARTICIPATING IN THE CO-TEACHING CLASS.
You may file a complaint concerning Conjuguemos's processing of your personal data via email firstname.lastname@example.org
Conjuguemos is headquartered and hosted in the United States, as well as most of our service providers (see section Security Measures for further information on Conjuguemos's third-party service providers and the purpose of transfer and processing). Hence, personal data we collect from you will be processed in the United States.
The United States has not sought, nor received, a finding of “adequacy” from the European Union under Article 45 of the GDPR, and the Court of Justice of the European Union (CJEU) declared in its July 2020 Schrems II judgment the European Commission’s Privacy Shield Decision invalid on account of invasive U.S. surveillance programs, making data transfers under the Privacy Shield Framework unlawful. Conjuguemos relies on derogations for specific situations under Article 49 of the GDPR for performing transfers of data to the United States. In particular, Conjuguemos collects and transfers to the United States personal data, with your explicit consent, to perform a contract with you, and/or for reasons of public interest. The latter will apply in those instances where data is processed and logged for the purpose of protecting our community and other users’ personal information from unauthorized access, disclosure and/or manipulation (e.g., advanced attacks).
If your personal data is transferred outside the EU to other Conjuguemos affiliates or to third party service providers in the United States, we will take steps to ensure application of suitable safeguards to protect the privacy and security of your information, and to use it only in consistency with your relationship with Conjuguemos. Please note, however, that the level of data protection in the United States is not equivalent to that in the EU. In particular, it is possible for United States government agencies to access your personal data based on statutory authorizations without you knowing about this. Additionally, there are no comparable options for legal enforcement of your rights in the United States.
Remember, your information is under your control and you may elect to stop using our Services at any time, and at your discretion. See section Conjuguemos Privacy Principles, item “What are my rights when using Conjuguemos?” for further detail on the rights that assist you.
Regarding California AB 1584 (Buchanan) Privacy of Pupil Records: 3rd-Party Digital Storage & Education Software (Education Code section 49073.1), Conjuguemos will adhere to the following:
In compliance with the requirements set forth in New York Education Law § 2-D, Conjuguemos shall incorporate a Data Privacy and Security Plan ("DPSP") to each contract or other written agreement it enters into with an educational agency from the State of New York. Such DPSP shall outline how all state, federal, and local data security and privacy contract requirements will be implemented over the life of the agreement, consistent with the educational agency's policy on data security and privacy. Such plan shall also include, but shall not be limited to, a signed copy of the parents bill of rights for data privacy and security, which shall be provided by the educational agency prior to the commencement of the agreement, and a requirement that any officers or employees of Conjuguemos and its assignees who have access to student, teacher or principal data have received or will receive training on the federal and state law governing confidentiality of such data prior to receiving access.
In attention to the foregoing, Conjuguemos hereby commits to:
When users choose to register on our site, they do so in one of three different roles: student, teacher, or school (a school account is set up by a school administrator). Depending on the role a user chooses, the user will be asked to give us personal information detailed below.
We keep securely the email address and state/location of the person or person allocated by the school as the administrator of the software for the school.
All passwords are encrypted and as soon as the administrator changes it, only the administrator knows what it is.
It is the responsibility of the administrator to ensure no student or any other unauthorised person has access to these logon credentials.
The administrator can add the names, usernames, passwords, and classes of students to the system. He/she can also add teacher details: names, usernames, email addresses and encrypted passwords.
The administrator can also attach students to teachers so that the teacher can see a list of students in that class, with names and usernames. Passwords are hidden.
We keep securely the name, password, and email address of teacher users.
The teacher can add the names, usernames, passwords, and classes of students to the system. Once added, students can change passwords on their own, and the teacher would not have access to these passwords.
Teachers have access to the names and usernames of the students in the classes to which they have been attached by the administrator. They can change their own details and those of the students in those classes. As referenced above, they do not have access to any secret student passwords but may change them, for instance if a student has forgotten theirs.
We keep securely the first name, last name, username, and password of users in student roles.
Students can register themselves with their name, username, and password. They are able to change their password whenever desired, and neither the teacher nor administrator has access to this encrypted password.
Students can choose to register with their email address. The purpose of this is to be able to send them their FORGOTTEN PASSWORD link in case it is necessary. If no email is linked in the student account, a student will have to go to their teacher to reset their password.
We use AWS Servers, where data is encrypted both in transition both in motion and at rest. We also use SSL encryption.
We collect the following data:
Any user can request to have their account deleted. Upon this request, the data for this user will be deleted according to the extent and timing of disposition defined below. To request your account to be deleted, please contact support and state your account information.
An admin user can immediately delete any student, teacher or groups of students from the list, or delete all students and all teachers. On request by the school a member of CONJUGUEMOS can carry out the task for the school. Schools that stop using the software will have all data deleted one year after the end of the subscription - or earlier if requested by the school.
Partial: We delete the name, id, username, password and email for the user. The grades remain in the database, but they are no longer linked to a user.
Disposition is by destruction of data
As soon as commercially practicable
CONJUGUEMOS will not sell, rent or lease your personal information to others. CONJUGUEMOS shares personal information in the following ways:
CONJUGUEMOS shares information on the programs, applications, practice activities, quizzes, and tests you access and the answers, results, and scores on these programs, applications, practice activities, quizzes, and tests with teachers, schools, and school officials designated to have access to this information.
CONJUGUEMOS uses AWS Servers. Contact information: https://aws.amazon.com/contact-us/
Only the school administrators have access to the full data, i.e. the list of students the administrator has assigned to the CONJUGUEMOS license. Class teachers only have access to data for individual classes to which they have been assigned. The owner (Alejandro Yegros) of CONJUGUEMOS is the only CONJUGUEMOS employee to have access to the data. All data is protected by secret usernames and passwords. Passwords are hidden and encrypted, and no one has access to them.
In the extremely unlikely event of data being stolen, the impact will be limited to student names, usernames and classes and some email addresses (if the student user chose to register themselves with one). No student phone numbers, gender information, age, date of birth or address are stored.
The only other data stored consists of the teacher's names, school email addresses and school address.
Any user who suspects that a breach or exposure of data has occurred should immediately provide a description of what occurred via email to email@example.com. We investigate all reported data breaches and exposures to confirm if a breach or exposure has occurred.
Once a data breach or exposure has been confirmed, we will determine how the breach or exposure occurred, the types of data involved, confirm any protective measures around the involved data (such as encryption), and the number of users impacted. We will then communicate with affected parties about the breach or exposure, and work with the appropriate parties to remediate the root cause of the breach or exposure.
The manager of CONJUGUEMOS (Alejandro Yegros) will be enrolled (9/1/2018) in a GDPR course.
California law provides for the ability of minors that are registered users of the website to request and obtain removal of material, information, and content posted on the website. Registered users 17 years of age or younger who are California residents, may request CONJUGUEMOS to remove their own posted content on the website by sending a notice of the request to CONJUGUEMOS at firstname.lastname@example.org. Such request must include the name and user ID and account number of the minor making the request and the posted information, material and content on the website they are requesting to have removed. Upon receipt of such a request, CONJUGUEMOs will remove material, information, and content posted on the website, including answers, results, scores, and other information provided as part of the use of programs, applications, practice activities, quizzes, or tests on the website. Please note that in complying with such a request, the posted information, material, and content will no longer be visible to other users of the website or public, including teachers, schools, and school officials who have set up the programs, applications, practice activities, quizzes, or tests as part of a school program or class activity. The material, information, and content will not be deleted from the CONJUGUEOMO’s server; it will just no longer be visible or accessible by other users or the general public. There are exceptions to complying to the request where the posted information, material, and content will not be removed from visibility to or access by other users, such as where federal or state law requires CONJUGUEMOS or its third parties to maintain the information, material, and content, the information, material, and content is stored on or posted to the CONJUGUEMO’s website by a third party, the information, material, and content is provided and maintained anonymously, the minor fails to follow the instructions regarding removal, or the minor has received compensation or other consideration for providing the information, material, and content.
P.O. Box 86
Newton, MA 02456