Last modified: June 20th, 2022
· The term “Problematic Internet Use” refers to a range of repetitive impairing behaviors, such as excessive video gaming, cybersex, online buying, gambling, streaming, social media use, online messaging including emails, chats, google or Microsoft documents or similar, online searching for health-related information and inability to control the amount of time spent interfacing with digital technology.
· The term “School” refers to an academic institution that is acquiring the SafeKids Services and that you, or your minor child, attend, but only if the school has provided you, or your minor child (whichever is the student), a School-Assigned Device and you have consented to the implementation of the SafeKids Services with respect to such School-Assigned Device; and
· The term “School-Assigned Device” refers to a desktop, laptop, and mobile device such as a tablet, a smart phone, an e-reader, or a virtual or augmented reality device on which the School has implemented SafeKids Downloadable Software and that is assigned by such School to you or your minor child, whichever is the student at the School.
· The term “SafeKids Downloadable Software” refers to downloadable tools or other software that SafeKids makes available for download specifically for purposes of facilitating access to, operation of, or use of the SafeKids Services, and any enhancements SafeKids may make available to such Software from time-to-time.
· The term “De-Identified Data” refers to information that does not identify and is not linked or reasonably linkable to an individual or a device, regardless of whether the information is aggregated, without reasonable means for reidentification.
INFORMATION WE COLLECT FROM YOUR USE OF OUR WEBSITE
INFORMATION WE COLLECT PROVIDING THE SAFEKIDS SERVICES
We collect information from users of Student-Assigned Devices automatically when such users use their School-Assigned Devices to access the internet, to draft, send or receive emails and chats, and to draft Google and Word documents. Some of this information is of a kind by which the user (you or your minor child, whichever is the student) may be personally identified (“Personal Information”). In this regard, we collect:
· You or your minor child’s name;
· You or your minor child’s guardian(s) contact name, email address and phone number;
· You or your minor child’s school;
· You or your minor child’s grade level;
· You or your child’s classroom and teacher(s);
· You or your minor child’s email address;
· Internet searches, emails and documents drafted, sent or received by you or your minor child; and
· Desktop images of problematic content if the School-Assigned Device uses Windows or MAC;
· Phone numbers of Student-Assigned Devices if the Devices have phone capabilities;
· Comprehensive information about you or your minor child’s use of the internet including: each search request; the time of the search; the category of the search; whether the search triggered a programmatic intervention; each link accessed by you or your minor child; each website visited by you or your minor child including the url and images; you or your minor child’s response to (that is, searches after) programmatic intervention; and other statistics regarding you or your minor child’s internet use; each email received or composed by you or your minor child and any chat activity;
· The devices ip address, browser, and operating system;
· The location from which you or your minor child uses the School-Assigned Device; and
· Information about the network from which you or your minor child accessed the internet.
Internet searches and sites visited may provide sensitive information about you or your minor child even if such as information is not of a kind that can be used to personally identify you or your minor child. For example, a review of internet searches and sites visited may provide information about you or your minor child’s racial or ethnic origin, political opinions, or associations, religious or philosophical beliefs, trade union or association memberships, sexual orientation or practices, criminal record or health or genetic information.
INFORMATION COLLECTED FROM ADMINISTRATORS, COUNSELORS AND TEACHERS
We also collect the name of and contact information (including email addresses) for each of your or your minor child’s teachers and counselors, and for certain of the administrators at your or your minor child’s school upon receipt of consent from such administrators, counselors, and teachers.
HOW WE USE YOUR INFORMATION
We use information that we collect about you or your minor child, or that you or your minor child provide to us, including any personal information, to:
· Provide the SafeKids Services;
· Provide notice to School designated personnel including administrators, counselors, and teachers that you or your minor child has engaged in Problematic Internet Use after you, or your minor child, has ignored multiple solution-generated warnings. For clarity, such notice will identify you or your minor child, describe the Problematic Internet Use, and list sites visited; and
· Provide notice to School designated personnel including administrators, counselors, and teachers that you or your minor child has engaged in Problematic Internet Use that reasonably can be understood to give rise to a risk of self-harm or violence against others (including the intent to acquire or use a weapon). For clarity, such notice will identify you or your minor child, describe the Problematic Internet Use, and list sites visited or searches performed by my child. Moreover, upon receipt of such notice the school may share such disclosure with law enforcement;
· Provide reports to School administrators, teachers, and counselors. Such reports may include the number of search requests, the number of machine-generated interventions, the number of websites visited, and the identity of the websites visited; and
· Respond to law enforcement requests and as required by applicable law, court order or governmental regulations.
We also use the information we collect that has been De-Identified to:
· Evaluate, test, modify and improve the SafeKids Services;
· Test the SafeKids Services;
· Improve SafeKids Services;
· Develop new SafeKids Services;
· Train SafeKids and School personnel regarding the use, maintenance, and support of the SafeKids Services;
· Market the SafeKids Services; and
· Prepare and publish academic and scientific studies, participating in academic and scientific symposia. In this regard, we may disclose de-identified aggregated information to third parties for research and other academic purposes.
We do not currently use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.
DISCLOSURE OF YOUR INFORMATION
We may disclose information that does not identify any individual or device without restriction. Such information includes information about you but only if such information has been De- Identified. SafeKids shall take reasonable measures to ensure that De-Identified information cannot, at any point, be used to re-identify any individual or device. SafeKids shall also take such measures to: (i) process and transfer De-Identified information only in a deidentified form without any reasonable means for reidentification; (ii) avoid attempting to re-identify the information with any individual or device; and (iii) contractually obligate any person or entity that receives the information from SafeKids to comply with these provisions.
In addition, we may disclose personal information that we collect, or you provide:
· With your consent;
· To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
· To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of SafeKids assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by SafeKids is among the assets transferred, but only if the transferee agrees to keep personal information confidential and to use it only for a purpose and in a fashion that SafeKids can use such information;
· To comply with any court order, law, or legal process, including to respond to any government or regulatory request. We will notify you of any communication from a court or governmental entity with respect to your data to the extent legally permissible; and
· If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of SafeKids, the School or students using School Assigned Devices on which the SafeKids Downloadable Software has been downloaded including the notices to School administrators, counselors, and teachers, and in some circumstances, to law enforcement, as described above.
We have implemented technical and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure, considering the state of the technology available in the market, the features of the information we collect and the risks to which the information is exposed, including encryption of all data at rest and in transit. All information that we collect is encrypted and stored on secure servers maintained by Amazon Web Services. Finally, we perform an internal review of our data security policies, procedures, and standards at least annually and whenever there is a material change to our infrastructure. However, although we make reasonable efforts to protect your personal information, due to the nature of the information and the state of the technology, we cannot, and do not, guarantee the security of your information and disclaim any obligation to do so. Any transmission of personal information is at your own risk. If we learn of a security breach, we will attempt to notify you electronically as soon as reasonably possible so that you can take appropriate steps.
DELETION OF PERSONAL INFORMATION
If at any time you wish to have us stop collecting data regarding you or your minor child, and delete such data, notify us at firstname.lastname@example.org and we will promptly comply. However, because we cannot provide the SafeKids Services without such data, upon compliance with such request, we will cease providing the SafeKids Services with respect to you or your minor child.
We will also promptly comply with any Client requests to stop collecting or delete data and cease providing the Safe Kids Services.
We will delete your personal information promptly following the termination or expiration of the Agreement between SafeKids and the School at which you or your minor child is a student assigned a School-Assigned Device. We will also delete your personal information promptly after you or your minor child is no longer a student at the School. We may retain De-Identified Data.
CERTAIN STATE PRIVACY RIGHTS
State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.
Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:
· Confirm whether we process their personal information;
· Access and delete certain personal information;
· Data portability; and
· Opt-out of personal data processing for targeted advertising and sales; Colorado, Connecticut, and Virginia also provide their state residents with rights to:
· Correct inaccuracies in their personal information, taking into account the nature of the information and the purpose for which it is being processed; and
· Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects. To exercise any of these rights please email email@example.com.
Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated address: firstname.lastname@example.org. However, please know we do not currently sell data triggering that statute’s opt-out requirements.
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information.