Last Updated: June 2018
The Coaching Her online solution (the “Site”) was developed from academic expertise to assist those working with students with social, emotional, and behavioral needs. Ultimately, the Coaching Her process identifies evidence-based interventions with the greatest likelihood of helping students succeed in school. The process requires that staff input certain behavior and academic performance information into the system for students in need of interventions. This policy identifies our commitment to protecting this information.
Ensuring the security of personal information about students and users of the Site delivered to us is our paramount concern.
The Site may contain links to other websites for your convenience and information. We are not responsible for the privacy practices or the content of those sites.
2. Privacy and Compliance
We strive to comply with the federal Children’s Online Privacy Protection Act (“COPPA”) and Family Educational Rights and Privacy Act (“FERPA”).
We may collect, use and disclose personal information about individuals who are under the age of 13 solely for educational purposes, for the benefit of users of the Site (and users’ educational institutions) and for no other commercial purpose. (We describe that information in more detail below.) In the Terms of Service for the Site, we expressly prohibit users of the Site from uploading to the Site any personal information on an individual who is under the age of 13 unless the user has obtained verifiable consent for the collection, use and disclosure of personal information on that individual from the individual’s parent or legal guardian.
Consistent with the Federal Trade Commission regulations implementing COPPA, we do not seek or obtain verifiable consent to collect, use or disclose personal information about an individual who is under the age of 13 from the individual’s parent or legal guardian. We solely rely on the assurances each user (and the user’s educational institution) who uploads to the Site personal information about individuals who are under the age of 13 representations and others gives to us that adequate, verifiable consents have been obtained from individuals’ parents or legal guardians and have not been revoked. Each user (and their educational institution) is solely responsible for obtaining verifiable consents for all personal information they upload to the Site.
In the Terms of Service, we describe each user’s right to review, edit and delete personal information the user uploaded to the Site. Generally, we will stop collecting, using and disclosing and we will delete personal information on an individual upon request by the user who uploaded the personal information. This right applies to personal information we collect, use and disclose on individuals under the age of 13 and others and is described in detail in the Terms of Service for the Site.
We are subject to the Minnesota Government Data Practices Act, Minnesota Statutes, §13.01 et seq. We are obligated by Minnesota law to share public data we collect. Public data, which is defined by law, stored on our servers or otherwise in our possession or control is subject to public inspection and disclosure unless exempt by law. When required by law (for example, to comply with a court order or subpoena or as required by Minn. Stat. §13.15 to the Minnesota Commission of Administration or to a state or federal law enforcement agency), we will disclose personal information collected from a user to a government agency, court official or a third party.
NOTICE TO PARENTS AND LEGAL GUARDIANS
3. Security and Notifications
We take commercially reasonable steps, consistent with industry practices, to secure personal information delivered to us and to prevent unauthorized disclosure and access, maintain data accuracy and ensure the appropriate use of all personal information delivered to us.
We do not promise that personal information delivered to us will, at all times, be secure, that our efforts to protect it will be successful, or that it will not be disclosed to or accessed by third parties.
We will notify a user if personal information delivered to us by the user has been disclosed or accessed by a third party in violation of this policy or applicable law. We may not separately notify the subject of personal information delivered to us of unauthorized disclosure or access by a third party to that personal information.
4. Information We Collect
We collect personal information users upload to the Site ("Personal Information") and we collect non-personal information concerning each user's use of the Site ("Site Use Information").
We collect the following Personal Information:
- Name and e-mail address of the user
- Name of user's school and school district
- Any other data a user uploads to the Site
We or a third party contracted by us collect the following Site Use Information:
- Information describing the computer, mobile device or other device used to access the Site, including IP address, geolocation information, unique device identifiers, browser type, browser language and other transactional information
- The internet protocol address (URL or IP address) of the referring site
- Protocol (IP) addresses (the region or general location where your computer or device is accessing the Internet), browser type, operating system and other usage information about the use of the Site,
- The domain name and IP address from which the access occurred, the version of browser used, the capabilities of the browser, and search terms used on our search engines
- The pages visited on the Site
- The date and time of the visit
The Site uses "cookies" and Web beacons, HTML5 local storage and other similar technologies to recognize users. Cookies are pieces of information stored by your web browser on behalf of a web site and returned to the web site on request. A user may not be able to access certain areas of the Site if the user's computer or device does not accept cookies from the Site. The Site do not respond to browser-based "do not track" signals.
6. Our Use of Information We Collect
We use the information to maintain and improve the Coaching Her site and to develop future products and to comply with applicable laws, regulations, rules and administrative agency and court orders.
We use the information to maintain the security and performance of the Site.
We use the information to perform statistical, demographic and other analyses of users of the Site to improve the Site and users' experiences.
We use and disclose aggregated or de-identified information collected from user and users' use of the Site to conduct research projects and for other purposes.
We will not use the information delivered to us to advertise a third party's products or services and we will not deliver the information to a third party to use to advertise products or services.
We may deliver the information, including personal information on individuals, in connection with the sale, license or transfer of all or part of the Site to a third party.
We deliver the information to a third party that has entered into an agreement with us to provide us services in connection with the Site. We generally prohibit third party service providers from disclosing the information to another third party and from using the information for any purpose other than to provide us services in connection with the Site.
We share the information delivered to us with third parties as required by applicable laws, regulations, rules and administrative agency and court orders.
We are not responsible for the personal information you choose to submit in the course of your public activities and we have no responsibility to publish, take down, remove or edit any of your submissions to the Site. We also have no responsibility when you use the Site to share or recommend links to content posted on third-party platforms.
7. Data Ownership
Users (or their educational institution) retain ownership of all personal information they deliver, including all student, teacher, and/or mentor data submitted.
8. User Rights
NOTICE TO CALIFORNIA RESIDENTS
A California resident under the California Shine the Light law, Cal. Code, Civil §1798.83, has the right to receive, at no cost, written notice from us of our delivery of personal information on the resident to a third party in the preceding year. All requests for information under the law should be delivered to the following address:
Education Technology Innovations
224 McNamara Alumni Center
Minneapolis, MN 55455
9. Changes to This Policy