COPPA Privacy Policy

(FOR SCHOOLS AND PARENTS)

Effective Date: May 2018

Securly, Inc. (“we” or “us”) recognizes the importance of privacy. This COPPA Privacy Policy (“COPPA Policy”) is designed to comply with the Children’s Online Privacy Protection Act (“COPPA”) and contains important information for schools and parents about how we collect, use and disclose the personal information we collect from your students and your child or children including a child or children under 13 years old. For purposes of this Policy, “child” or “children” means a child or children including a child or children under 13 years old. “Student” or “students” means a student or students including a child or children under 13 years old. Unless otherwise specified, for the purposes of this COPPA Policy, “you” and “your” refers to the school, district, or educational institution (“school”) contracting with Securly for the provision of the Services or to you as the parent of a child or children using our Plug N’ Play Hub.

At Securly, we offer:

  • cloud based web filtering;
  • cyber-bullying and self-harm detection;
  • at school and take home policies for school issued devices;
  • our website www.securly.com;
  • the Parent Portal; and
  • the Plug N’ Play Hub for home use,
each as applicable (collectively, the “Services”).

COPPA

Under COPPA, we are required to obtain consent to the collection of personal information online from children under 13. When schools use our Services, the school (including a teacher, administrator or school district) is required to consent to the collection and use of personal information from students as part of signing up to use the Services. When parents use the Services independent of a school, they are required to provide consent to the collection and use of personal information from children as part of the Services.

Your Consent

By using the Services, you consent to the collection and use of the personal information, anonymous information, and aggregate information about your students or child as described in this COPPA Policy, and you confirm you are authorized to consent to the collection and use of this information. Use of the Services by your students or child, and any dispute over privacy, is subject to this COPPA Policy and our Terms of Service including its applicable limitations on damages and resolution of disputes. The Terms of Service are incorporated by reference into this COPPA Policy. Any personal information we collect about other users will be treated in accordance with the Securly Privacy Policy and our Terms of Service.

We only collect personal information belonging to a student or child through the Services where you have consented (via the terms described in a separate agreement) for that student or child to use the Services and disclose personal information to us.

The personal information of your students or child will not be used for any other purpose without your consent. You may withdraw your consent to our processing of the personal information of your students or child at any time. However, withdrawing consent may result in your students’ or child’s inability to continue using some or all of the Services.

Information We Collect About Your Students

Personal information of your students or child may be collected directly from you or your students or child, from third parties, and automatically though your student’s or child’s use of the Services. Such information may include, but is not limited to, personal information we collect from your students or child, and the online activity, social media usernames and activity, electronic communications, and general web browsing activity of the student or child.

Information We Collect Directly

We collect students or child’s mobile device ID; device name and model; and operating system type, name, and version of school issued devices.

Information We Collect Automatically

In order to provide our Services and to understand a student’s or a child’s activity while using our Services, we may automatically collect the following information about a student or child through cookies, web beacons, and other technologies: information regarding your student’s or child’s personal computing device, browser type, browser language, operating system, Internet Protocol (“IP”) address, and the actions your student takes while using the Services including while online (such as the web pages viewed or blocked, the length of time your student or child visited a website, links clicked and messages sent or posted).,.

For more information about how we collect information automatically from users of our website and other services, read the Securly Privacy Policy.

Information that We Collect About Students from Social Networking Sites

If you permit your students or child to use Facebook, Twitter or other social networking sites (“Social Networking Sites”), we will collect your students’ or child’s Social Networking activity including posts to your students’ or child’s pages including Facebook wall, Twitter Tweets, Google+, and other messaging activity for purposes of providing the Services including as applicable for detection of cyber-bullying or self-harm protection. If your students or child is permitted by you to use Social Networking Sites, we will collect your students’ or child’s activity on those sites even if your students or child has chosen to not make that activity public.

We store your students’ or child’s Social Networking activity with other information that we collect from your students or child.

How We Use Your Student’s Information

We use student personal information we collect in the following ways:

  • To provide our Services including to respond to customer service and technical support issues and requests. If a student or child 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 or child documenting the error. 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).
  • To track the online activities of your student or child including the information your student or child distributes, displays, or share, and to provide you with reports and logs regarding the same. In the case of schools, such reports may include class or school-wide student activity reports, to allow you to conduct comparative analyses of your students.

We do not use student personal information in the following ways:

  • We do not collect a student’s or a child’s personal information for the purpose of sale of such information in any way or for building student or child profiles for commercial purposes not related to the provision of the Services.
  • We do not use your students’ personal information for advertising.

We may use aggregate or de-identified information about students and children for the following purposes:

  • To monitor and analyze the Services and for technical administration;
  • To better understand how students and children access and use our Services;
  • To improve our Services; and
  • For other research and analytical purposes.

When your students or child use the Services on a personal computing device owned by you, we may use geolocation information to determine their current location. Such information is specific to the device only, and is not specific to the student or child. We may also use elements of your student’s or child’s usage and analytics Information (such as IP address) to determine their generalized location.

How We Share Your Student’s Information

  • Service Providers. From time to time we may employ third parties to help us provide the Services, or to perform Services (e.g., hosting) that may involve their access, use or storage of personal information on our behalf. We may disclose the information we collect from students or children to such third party vendors, service providers, contractors or agents who perform contractually defined functions on our behalf. These third parties may have limited access to databases of user information solely for the purpose of helping us provide you the Services and we have put in place contractual and other organizational safeguards requiring them to take steps to ensure a proper level of protection of your students’ personal information. These third parties are required to treat personal information in accordance with our privacy and security policies and commitments. Except as explained above, we do not disclose or transfer your students’ personal information to third parties except for authorized educational/school purposes or as directed by the schools that have engaged us to provide Services. We prohibit these third parties from using the personal information we collect about your students or child for any purpose other than providing the contracted service.
  • Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the personal information we have collected to the other company, provided the successor entity is subject equivalent privacy and security commitments as Securly for the previously collected personal information and the information disclosed continues to be used for only educational/school purposes.
  • In Response to Legal Process. We also may disclose the personal information we collect in order to comply with the law, a judicial proceeding, court order, subpoena or other legal process.
  • To Protect Us and Others. We also may disclose the personal information we collect 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 this COPPA Policy, or as evidence in litigation in which Securly is involved.
  • With Schools and Parents. You are able to log in to view information about your students’ or child’s use of the Services.
  • Aggregate and De-Identified Information. We may also use and share aggregate or de-identified information about students or children with third parties for research and analytical purposes.

Information Your Students Share with Third Parties

Your students or child may be able to voluntarily share personal information with third parties, including Social Networking Sites, 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 your students or child 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. For information they may use and disclose about your students or child, including any information your students or child may make public, please consult their respective privacy policies. We have no control over how any third party site controls the information that it collects from your students or child.

Security

The security of your students’ or child’s personal 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, disclosure, alteration, and destruction. We have implemented technical, contractual, administrative, and physical security steps and other organizational safeguards designed to protect personal information. This includes the use of authentication technologies, encryption where appropriate, and a securely configured network.

We have implemented procedures limiting the dissemination of personal information to only such designated service providers and staff as are reasonably necessary to carry out that member of the staff’s or vendor’s specific role. Please be aware that despite our best efforts, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

If we learn of a security breach that poses a serious risk of harm, we will attempt to notify you electronically (subject to any applicable laws) so that you can take appropriate protective steps; for example, we may post a notice on the Securly website or elsewhere on the Service, and may send email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

Your Rights to Review, Delete and Control Our Use of Your Students’ and Child’s Personal Information

We will make every reasonable effort to keep personal information accurate and up-to-date, and we will provide you with mechanisms to review, update, and correct your students’ or child’s personal information as appropriate and/or desired. You have a right to control the personal information we have collected from your students or child, to review it, to delete it, and to tell us to no longer use it.

Notwithstanding the foregoing, personal information belonging to students or children will be deleted in all cases including personal information held our third party service providers when it is no longer needed for the purpose for which it was collected or when you terminate our Services pursuant contractual agreement. All retained personal information will remain subject to the terms of this Privacy Policy. If you would like a student’s or child’s personal information to be deleted, or if you would like to obtain a copy of your student’s or child’s personal information, please contact us at support@securly.com.

If we learn we have collected personal information about a student or child without proper consent, we will delete that information as quickly as possible.

Changes to this COPPA Policy

This COPPA Policy is current as of the Effective Date set forth above. We may change this COPPA Policy from time to time, so please be sure to check back periodically. We will post any changes to this COPPA Policy on our Site. If we make any changes to this COPPA Policy that materially affect our practices with regard to the personal information we have previously collected from your students or child, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.

FERPA and COPPA Compliance Statement for Schools

We are committed to complying with the Family Education Rights and Privacy Act (“FERPA”) and COPPA in all applicable respects with regards to the collection, use, disclosure, and retention of the personal information of your students.

We have contracted with you, as an operator defined under COPPA, in order to collect personal information from your students, for the use and benefit of the students and the school in the educational context as authorized by you, and for no other commercial purpose.

Contact Us

If you have any questions, comments, concerns or suggestions with regards to the Services, the use of students’ information or this COPPA Policy, please contact:

Vinay Mahadik
Privacy Director
Securly, Inc.
111 N. Market Street, 4th floor, Suite 400 
San Jose, California 95113 
United States

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.