Privacy Policy

PRIVACY POLICY

(FOR EDUCATIONAL INSTITUTIONS)

Securly, Inc. (“we” or “us”) is committed to protecting the privacy of your students.  This Privacy Policy describes how we collect, store, use and distribute information through our software and related services (together, the “Services”).  Unless otherwise specified, for the purposes of this Privacy Policy, “you” and “your” refers only to the school, district, or educational institution contracting with Securly for the provision of the Services.

Consent.

By using the Services, you consent to the collection and use of the Personally Identifiable Information of your students as described in this Privacy Policy.   Except as set forth in this Privacy Policy, the Personally Identifiable Information of your students will not be used for any other purpose without your consent.  We do not collect Personal Identifiable Information for the purpose of sale of such information in any way.  You may withdraw your consent to our processing of the Personally Identifiable Information of your students at any time.  However, withdrawing consent may result in your or your students’ inability to continue using some or all of the Services.

Collection of Student Information.

Personally Identifiable Information

The Services track a wide range of data and information that may be used 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 from his or her parent, guardian, school, district, and/or teacher, or if we learn a student under 18 has provided us Personally Identifiable Information beyond what is necessary to provide the Services, we will delete that information as quickly as possible.  If you believe that a student under 18 may have provided us Personally Identifiable Information in violation of this paragraph, please contact us at support@securly.com.  

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.”

Geo-Location 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:

Information Collected

Use

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.

Geo-Location Information

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.

If we plan to use Personally Identifiable Information in the future for any other purposes not identified above, we will only do so after obtaining your written consent.  See further the section of this Privacy Policy entitled “Amendment of this Privacy Policy”.

Disclosures & Transfers.

We have put in place contractual and other organizational safeguards with our agents (see further below) to ensure a proper level of protection of your students’ Personally Identifiable Information (see further “Security” below).  In addition to those measures, we will not disclose or transfer your students’ Personally Identifiable Information to third parties without your permission, except as specified in this Privacy Policy (see further “Important Exceptions” below) or as permitted or otherwise required under the law.

Important Exceptions.

From time to time we may employ third parties to help us provide the Services.  These third parties may have limited access to databases of user information solely for the purpose of helping us provide you with the Services and they will be subject to contractual restrictions prohibiting them from using the information about our users for any other purpose.  Such agents or third parties do not have any rights to use Personally Identifiable Information beyond what is absolutely necessary to assist us.

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.  Notwithstanding the foregoing, please note that this exception does not extend to any Personally Identifiable Information gathered from students under the age of 13.  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 information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.

Security.

The security of your students’ Personally Identifiable Information is important to us.  We use commercially reasonable efforts to store and maintain all Personally Identifiable Information in a secure environment.  We take technical, contractual, administrative, and physical security steps designed to protect Personally Identifiable Information.  We have implemented procedures designed to limit the dissemination of Personally Identifiable Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.

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

You or your students may be able to voluntarily share Personally Identifiable Information with third parties while using the Services.  The privacy policies of these third parties are not under our control and may differ from ours.  The use of any information that you or your students may provide to any third parties will be governed by the privacy policy of such third party or by your independent agreement with such third party, as the case may be.  If you have any doubts about the privacy of the information you or your students are providing to a third party, we recommend that you contact that third party directly for more information or to review its privacy policy.

Retention.

We will keep Personally Identifiable Information only for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you.  We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law.   Please note that if you request that Personally Identifiable Information be removed from our databases, it may not be possible to completely delete all Personally Identifiable Information due to technological and legal constraints (such as if their Personally Identifiable Information appears in another student’s Data).  All retained Personally Identifiable Information will remain subject to the terms of this Privacy Policy.  Notwithstanding the foregoing, Personally Identifiable Information belonging to students under the age of 13 will be deleted in all cases (to the extent that it is reasonably and commercially possible to do so) when it is no longer needed for the purpose for which it was collected.  If you would like a student’s Personally Identifiable Information to be deleted, or if you would like to obtain a copy of your students’ Personally Identifiable Information prior to its deletion, please contact us at support@securly.com.

Amendment of this Privacy Policy.

We reserve the right to make Non-Material Changes to this Privacy Policy, from time to time and in our sole discretion.  As used herein, “Non-Material Change” means (i) a change to the Privacy Policy made purely for the sake of clarification, as well as (ii) a change made to the Privacy Policy that has no substantive impact on collection, use, disclosure, or retention of the Personally Identifiable Information of students, or the rights of schools, districts, teachers, parents or legal guardians in connection with the same.  If we decide to make a Non-Material Change to this Privacy Policy in the future, we will post or provide appropriate notice.  Any Non-Material Change to this Privacy Policy will become effective on the date the change is posted.  

Changes to the Privacy Policy that have a substantive impact on collection, use, disclosure, or retention of the Personally Identifiable Information of students, or the rights of schools, districts, teachers, parents or legal guardians in connection therewith (a “Material Change”) shall not be binding upon you unless accepted and agreed to by you in writing.

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.

 

Contact Us.

If you have any questions, comments, concerns or suggestions with regards to the Services or this Privacy Policy, please contact us at:

Vinay Mahadik

Privacy Director

Securly, Inc.

San Jose, CA

support@securly.com

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.