(FOR EDUCATIONAL INSTITUTIONS)
Collection of Student Information
Personally Identifiable Information
The Services track a wide range of data and information you may use to identify your students individually. Such information may include, but is not limited to, your students’ online activity, social media usernames, electronic communications, and general web browsing activity. Any information that may be used to identify, contact, or locate your students individually is referred to herein as your students’ “Personally Identifiable Information.” We only collect Personally Identifiable Information through the Services belonging to a child under 18 where that student’s school, district, and/or teacher has consented (via the terms described in a separate agreement) for that child to use the Services and disclose Personally Identifiable Information to us or where the parent or legal guardian of a child has signed the child up to use the Services. If we learn we have collected Personally Identifiable Information about a student under 18 without proper consent, we will delete that information as quickly as possible.
Data, Diagnostic & Login Information
Your students may be able to transmit, distribute, display, or share information, data, text, graphics, video, messages or other materials using our Services (this is collectively referred to below as “Data”). Some of this Data may be stored and maintained on our servers. If a student runs into technical errors in the course of using the Services, we may request your permission to obtain a crash report along with certain logging information from the personal computing device utilized by the student documenting the error (“Diagnostic Information”). Such information may contain information regarding the device’s Operating System version, hardware, and browser version (and .NET version information in case of Windows systems). Additionally, certain login information may be maintained in a cookie stored locally on the personal computing device utilized by your student (i.e. not on a server) in order to streamline the login process (“Login Information”).
Usage and Analytics Information
As your students use the Services, we may also collect information through the use of commonly-used information-gathering tools, such as cookies, log files, and Web beacons. Such Information may include standard information regarding your student’s personal computing device, browser type, browser language, Operating System, Internet Protocol (“IP”) address, and the actions your student takes online (such as the web pages viewed and the links clicked) or while using the Services. Collectively, this information is referred to as “Usage and Analytics Information.”
When your students use the Services on a device owned by you, we may use GPS technology (or other similar technology) to determine their current location. Such information is specific to the device only, and is not specific to the student. We may also use elements of your students’ Usage and Analytics Information (such as your IP address) to determine their generalized location. Such information is collectively referred to as “Geo-Location Information.”
Use of Student Information. We use the information we collect in the following ways:
|Personally Identifiable Information||We use Personally Identifiable Information solely for the purpose of administering our Services to you. This includes using such information to track the online activities of your students and to provide you with reports and logs regarding the same. Such reports may include class or school-wide student activity reports, to allow you to conduct comparative analyses of your students.|
|Data, Diagnostic Information and Login Information||We use Data, Diagnostic Information and Login Information solely for the purpose of administering our Services to you. This includes using such information to track the online activities of your students and to provide you with reports and logs regarding the same. Such reports may include class or school-wide student activity reports, to allow you to conduct comparative analyses of your students.|
|Usage and Analytics Information||
We use Usage and Analytics Information for the purpose of administering our Services to you. This includes using such information to track the online activities of your students and to provide you with reports and logs regarding the same. Such reports may include class or school-wide student activity reports, to allow you to conduct comparative analyses of your students.We may also use Usage and Analytics Information in a de-identified, anonymous manner to monitor and analyze use of the Services, for the Services’ technical administration, to increase the Services’ functionality and user-friendliness, and to verify users have the authorization needed for the Services to process their requests.
We may use Geo-Location Information for the purpose of administering our Services to you.We may also use Geo-Location Information in a de-identified, anonymous manner to monitor and analyze use of the Services, for the Services’ technical administration, to increase the Services’ functionality.
Please note that as an authorizing school, district, or educational institution, you will be able to view all activity and content associated with your students’ account, including, but not limited to, their Personally Identifiable Information.
Disclosures & Transfers
Being an Internet based service, we rely on cloud-service providers (e.g. Amazon Web Services) to host some of our data and in delivering our service. These service providers do not have access to our data, and are contractually prevented from accessing our data without our explicit consent. We have put in place contractual and other organizational safeguards with our agents and service providers requiring them to take steps to ensure a proper level of protection of your students’ Personally Identifiable Information (see further “Security” below). These third parties are required to treat Personally Identifiable Information in accordance with our privacy and security policies and commitments. Except as explained above, we do not disclose or transfer your students’ Personally Identifiable Information to third parties except for authorized educational/school purposes or as directed by the schools who have engaged us to provide the Services.
We may disclose Personally Identifiable Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of the Services, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. We may also disclose Personally Identifiable Information when we believe in good faith that such disclosure is required by and in accordance with the law.
We may also disclose Personally Identifiable Information in connection with a corporate re-organization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the successor entity is subject to equivalent privacy and security commitments as Securly for the previously collected Personally Identifiable Information and the information disclosed continues to be used for only educational/school purposes.
The security of your students’ Personally Identifiable Information is important to us. We have implemented a security program that is reasonably designed to protect the information we collect from loss, misuse, and unauthorized access or disclosure, We have implemented technical, contractual, administrative, and physical security steps designed to protect Personally Identifiable Information we collect from loss, misuse, and unauthorized access or disclosure,. This includes the use of authentication technologies, encryption where appropriate, and f a securely configured network. For example, we have implemented procedures limiting access to Personally Identifiable Information to only such designated staff or third party vendors as are reasonably necessary to carry out that member of the staff’s or third party vendor’s specific role.
Please note that you are also responsible for helping to protect the security of your students’ Personally Identifiable Information. For instance, never give out your personal credentials when you are using the Services, so that other people will not have access to your students’ Personally Identifiable Information. Furthermore, you are responsible for maintaining the security of any personal computing device on which you or your students utilize the Services.
Sharing Information with Third Parties
Access and Accuracy
You have the right to access the Personally Identifiable Information we hold about your students at all times. Upon receipt of your written request, we will provide you with a copy of your students’ Personally Identifiable Information, although in certain limited circumstances we may not be able to make all relevant information available to you, such as where that information pertains to or otherwise belongs to another user (for example, through a separate account owned and managed by a student’s parent or legal guardian). In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.
We will make every reasonable effort to keep Personally Identifiable Information accurate and up-to-date, and we will provide you with mechanisms to review, update, correct or delete your students’ Personally Identifiable Information as appropriate and/or desired.
FERPA and COPPA Compliance
We are committed to complying with the Family Education Rights and Privacy Act (“FERPA”) and the Children’s Online Privacy Protection Act (“COPPA”) in all applicable respects with regards to the collection, use, disclosure, and retention of the Personally Identifiable Information of minors. However, please note that as a school, district, or educational institution, you may also possess certain legal obligations with respect to such Personally Identifiable Information. Please consult with your own legal counsel to ensure your compliance with applicable federal and state laws, as we do not take any responsibility for your failure to comply with the requirements of FERPA or COPPA.
San Jose, CA
1 (855) 732-8759 (ext. 101)
If you have a complaint concerning our compliance with applicable privacy laws, we will investigate your complaint, and if it is justified, we will take appropriate measures.