Compliance

Compliance

Last updated: August 11, 2024

Last updated: August 11, 2024

Family Educational Rights and Privacy Act (FERPA) Notice

1.1: In accordance with the Family Educational Rights and Privacy Act (“FERPA”), Secant’s privacy policy affirms the following:


(a) We do not disclose information pertaining to the student’s educational record and “directory information” to external non-educational parties without the express consent of the student’s parents;


(b) as a parent, you have the right to request corrections to your child’s educational records if you believe them to be inaccurate, incomplete, or misleading; failure to do so on our part entitles you to arbitration measures as they may apply;


(c) we must inform you of your FERPA rights annually.


(d) reasonably sound information security practices have been implemented to the best of our ability to protect user information;


(e) information may be released without consent to the following parties as defined in FERPA:


  1. School officials with legitimate educational interest;

  2. Other schools to which a student is transferring;

  3. Specified officials for audit or evaluation purposes;

  4. Appropriate parties in connection with financial aid to a student;

  5. Organizations conducting certain studies for or on behalf of the school;

  6. Accrediting organizations;

  7. To comply with a judicial order or lawfully issued subpoena;

  8. Appropriate officials in cases of health and safety emergencies; and

  9. State and local authorities, within a juvenile justice system, pursuant to specific State law.

Children's Online Privacy Protection Rule (COPPA) Notice

1.1: Secant offers an educational platform to help students study and learn. Although our primary audience is older students, our service may have younger users. This notice supplements our privacy policy and is meant to help parents and guardians understand what information we collect from Secant students who are younger than the age of 13 (hereinafter, “children” or “child”).


1.2: We have two methods of obtaining parental consent:


(a) where children use Secant as part of their school, we rely on these schools for our collection and processing of children’s personal information on behalf of parents;


(b) we ask schools to provide our privacy policy and this notice to parents of those students and to obtain parental consent to use our platform.


1.3: In the event children come to our site to use our platform for personal use, we require that they set up their Secant account through an established Google account. Google provides verified parents/guardians the ability to approve or deny sign-ins to other apps and shares our terms of service and privacy policy (which includes a link to this notice).


1.4: Parents’ consent is required for the collection, use, or disclosure of children’s personal information. We will not collect, use, or disclose your child’s personal information if you or your child’s school tells us you do not consent to the collection, use, or disclosure of your child’s personal information. However, do note that such a request may impair the quality and rendering of the Services provided.


1.5: Prior to obtaining parental consent, we may collect a limited amount of information from your child in the form of using a persistent identifier (such as a cookie ID) to support our internal operations, such as maintaining and analyzing the functioning of our website and services, performing network communications, authenticating users, and protect the security or integrity of our users, websites, and online services.


1.6: Personal Information We Collect Directly from Your Child:


(a) name and contact Information. When your child signs up for our Services, we collect your child’s name, username, and email address;


(b) demographic Data. In some cases, such as when children register for their accounts or participate in surveys (if applicable), we may request they provide their age, gender, and similar demographic details;


(c) other profile information. We collect information about your child’s interests, biographic information, education level, intended use of our service, and classes for their profile;


(d) content and files. We collect content and files your child inputs or uploads, such as their classroom assignments, notes, posts on message boards, ratings and reviews of content, profile picture, and other content and messaging, for example. If your child emails us or otherwise communicates with us (for example, to ask for technical or customer support), we collect and retain those communications;


(e) account access information. We collect information such as a username in combination with a password or access code or other credential to allow access to your child’s Secant account;


(f) device information and identifiers. When your child visits our websites or uses our services, we collect their IP address and information about their device, including device identifiers, and mobile IDs, device type, and your child’s device’s operating system, browser, and other software including type, version, language, settings, and configuration;


(g) usage information. We collect your child’s activity on our websites, apps, and services, including the URL of the website from which they came to our sites, pages visited, length of time spent on a page, access times and days, and other actions taken on our sites and services;


(h) geolocation data. Depending on your child’s device and application settings, we collect geolocation data (city, state, and country) when your child uses our apps or online services;


(i) classroom/student records: Your child’s educators may disclose information about your child’s academic performance and activities to us as part of their use of our websites, apps, and services;


(j) name and contact information, profile information, content and files: Your child’s educators may also provide us with any of the information we would otherwise collect from your child. In addition, where your child connects to our services using other accounts, such as Google, or integrates other services (such as Youtube, Google, OpenAI) we may receive any personal information that you permit these organizations to share with Secant.


1.7: Secant may, from time to time, send your child email communications about their account and for other administrative reasons, for which we will contract with third parties to perform these communication services on its behalf and may disclose a child’s information to such third parties.


1.8: In addition, personal information regarding a child may be disclosed in the course of a child’s participation in certain interactive features, such as message boards and sharing classroom materials and other child-created content. Content created by children may be shared with other Secant users, and children’s profile information may be disclosed to other Secant users depending on their privacy settings.


1.9: For school accounts, your child’s school may have or request access to all of your child’s personal information.


1.10: We share information as directed by users (e.g., to post comments), as needed to provide the services (e.g., to facilitate payments for child users who are not using our service through their schools), and with your children’s teachers or tutors and with other students when children use the classroom feature, and in the event of in-school use, we share student information with their school. We share student-generated flashcards and notes with other Secant users. In addition to disclosures otherwise described in this Notice, we share information about a child with affiliated entities or with third parties where the disclosure is reasonably necessary: to comply with law, including, for example, to comply with a court order or subpoena; to enforce our Terms of Service or site rules; or to protect the safety and security of our websites and services. For more information on our uses and disclosures of personal information, please see our privacy policy.


1.11: We rely on schools to authorize our collection, use, and disclosure of your child’s personal information. To provide your consent, your school should provide you with a consent form. Fill out the form and return it to the school. If you do not provide consent within a reasonable time from the date the school provided notice of our collection, use, and disclosure of your child’s personal data, we will delete any of your online contact information we have in our records for the purpose of obtaining consent.


1.12: To provide consent via Google, your child will need an established Google account, where you have followed Google’s verifiable parental consent process. Google will present options to you as the verified parent to approve your child’s use of Secant. If you do not provide consent within a reasonable time or if you deny your child’s use of Secant, we will delete the child’s information.


1.13: You have the right to revoke your consent to our collection, use, and disclosure of your child’s personal information. If you revoke consent, your child will not be able to use Secant. In addition, you have the right to access and review your child’s personal information and to update or correct that information. You may also request that we delete your child’s personal information. Deleting your child’s personal information may result in the termination of the child’s account. In the event we need to keep personal information for compliance with legal obligations, to prevent fraud, and ensure the safety of our services and guests, we will continue to protect the information. We delete data when a parent, school, or user requests within the timeframes required under applicable law. When we no longer need your child’s personal information, we will use commercially reasonable efforts to delete their personal information. For example, we delete data after a period of inactivity after which it is unlikely the child will resume use of their account, so long as we are not under contractual or other legal obligations to retain such data.


1.14: Further information regarding COPPA and your rights can be found at the Federal Trade Commission’s Website here.


1.15: If you have questions about our collection, use, and disclosure of your child’s personal data, or if you would like to request access to, correction, or deletion of your child’s personal data, please contact us at: team@secant.app. Please include “COPPA Question” or “Student Record Request” in the subject line of your email.

Student Online Personal Information Protection Act (SOPIPA) Notice

1.1: In accordance with the Student Online Personal Information Protection Act (“SOPIPA”), Secant’s privacy policy affirms the following:


(a) there is no data collected in order to provide targeted ads;


(b) there are no advertising profiles being created for neither students nor teachers;


(c) student and teacher information is not being sold in any capacity to third-parties with the intent of profit;


(d) reasonably sound information security practices have been implemented to the best of our ability to protect user information;


(e) disclosure of information is only in cases of the law requiring as such, or as part of maintenance, development, or corporate transactions.


(f) information is only shared with educational researchers & agencies, or for processing the data to provide the Service;


(g) only de-identified and aggregated data is used to continue development of the Service.


1.2: If any disputes are not satisfactorily satisfied with us with regard to the Student Online Personal Information Protection Act (“SOPIPA”), you may contact the California Privacy Protection Agency at 2101 Arena Blvd, Sacramento, CA 95834, or by telephone at (279) 895-1412.

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