COPPA Compliance | How Securly protects children's online privacy

Direct Notice: Collection, Use, and Disclosure of Student Information

Securly, Inc. and our affiliates, including Securly Ltd. (collectively “Securly,” “we,” “our” or “us”), comply with the Children’s Online Privacy Protection Act (“COPPA”) in our provision of cloud-based software products and services (collectively the “Services”) to schools, districts, or other educational institutions (collectively “Schools”). This Direct Notice describes how we collect, use, and disclose personal information from children under 13 (“Student Information”) in connection with our Services. Our This link opens in a new tab.Privacy Policy and This link opens in a new tab.Terms of Service provide further details.

We provide our Services for the sole use and benefit of Schools, their students (“Students”) in the educational context as authorized by Schools, and for no other commercial purpose. We are providing this Direct Notice to you as a teacher, official, or other school Employee (“Educator”) authorized to act on behalf of your School.

Consent

Parental consent is required under COPPA for the collection, use, and disclosure of personal information from children under 13. Securly will not collect, use, or disclose, any personal information from children under 13 without the required consent. When your School signs up to use our Services, the School consents, as agent for Students’ parents (“Parents”), to the collection, use, and disclosure of Students’ personal information. Your School is responsible for confirming that it is authorized to consent to the processing of this information and for obtaining any necessary consents from the Parent or Student.

Collection of Personal Information

We collect Student Information from Students as described below. We may also collect Student Information from Schools, Educators, Parents, and third parties as described in further detail in our Privacy Policy.

Students interact directly with some Securly Services. When Students do, we may collect identifiers such as user name or school email and other information related to the purpose of the Services (such hall pass or flex time requests, search queries, and information about how a Student is feeling).

Depending on the Service, Securly may automatically collect some or all of the following information about a Student, in all cases based on policies set by the School:

• Device information. We may collect information about Students’ school-issued or personal devices, including the device hostname, device name and model, operating system type and version, browser type and language, and Internet Protocol (“IP”) address.
• Application usage information. We may collect information about how Students interact with Securly while using the Services, such as which applications are used and for how long.
• Online activities. In accordance with School policies, we may collect information about a Student’s online activities. This may include: web browsing activity (for example, websites and videos viewed or blocked, time spent on a website, links clicked, web searches, AI chat questions); social media usage, including social media posts and messaging activity; the contents of emails, blog posts, and messages; and online interactions with teachers including student/teacher chats, virtual raised hands, and teachers’ response to distracted behavior such as closing a tab on a Student’s device. Based on a Student’s online activities, Securly may identify potential signs of anxiety, depression, cyberbullying, self-harm, and potential violence.
• Geolocation information. We may collect geolocation information (including geo-related elements of device information such as IP address) to determine a rough estimate of the device’s location. Securly also offers Services that allow Schools to enable the collection of precise geolocation information, but only when school-issued devices are reported lost or stolen.
• Audio or video files. Some Services allow Educators and Students to conduct audio and video calls for educational purposes. Securly processes the audio and visual data from these calls solely for the purpose of providing this service. Calls are not monitored, recorded, or stored by Securly.

Disclosure of Personal Information

We may share Student Information as described below. We may also use and share aggregate or de-identified Student data with third parties for research and analytical purposes.

• Service Providers. We may disclose Student Information to third-party vendors, service providers, contractors, or agents (collectively “Service Providers”) who perform contractually defined functions on our behalf. We may engage Service Providers to perform services (e.g., hosting) that may involve their access, use or storage of Student Information on our behalf. Service Providers have limited access to databases of Student Information solely for the purpose of helping us provide the contracted Services, and we have put in place contractual and other organizational safeguards requiring them to take steps to ensure a proper level of protection for Student Information. These third parties are contractually bound to treat Student Information in accordance with our privacy and security policies and contractual commitments. Except as explained above, we do not disclose or transfer Student Information to third parties except for authorized educational/School purposes at the direction of the Schools that have engaged us to provide Services. We prohibit Service Providers from using Student Information for any purpose other than providing the contracted service.
• Schools and Parents. In compliance with COPPA and FERPA, Schools, Educators, and Parents are able to log in to view information about their Students’ use of certain Services.
• Actual Purchasers of Our Company, Business, or Assets. We may disclose Student Information to a third party that acquires or merges with Securly or that acquires substantially all of our assets (including as part of a bankruptcy proceeding), provided the third party is subject to equivalent privacy and security commitments as Securly and the information disclosed continues to be used exclusively for educational/school purposes in compliance with applicable laws.
• Government Entities, Law Enforcement, and Others. We may disclose Student Information to third parties (including law enforcement or other government agencies) to comply with applicable law or regulations, a judicial proceeding, court order, subpoena, or other legal process. In particular, many states have laws that require specific categories of persons, or in some cases any person, to report certain matters pertaining to child safety to relevant state or local authorities. These matters may include any reasonable suspicion of child abuse or neglect or the presence of child sexual abuse material. We may therefore be required by law to report information from certain alerts to relevant state or local authorities in these states. In addition, we may disclose Student Information to third parties where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service, or as evidence in litigation in which Securly is involved.