Privacy Policy

Introduction

At StrongMind (‘the company’, ‘we’, or ‘us’), we respect your privacy and are committed to protecting it as described in this privacy policy (‘Policy’ or the ‘Privacy Policy’). This policy describes the types of information we may collect from you or that you may provide when you use our product, StrongMind (‘the product’, ‘the service’, ‘the website’, ‘the app’, or ‘product’), and our practices for collecting, using, maintaining, protecting, and disclosing that information. Your use of the Product and Services and any information you provide on the Services are subject to the terms of this Privacy Policy, which is incorporated into and subject to our Terms of Service.

Personal information that we collect

Data Collection

For the purpose of this section, Personal Information is defined as information that identifies, relates to or could reasonably be linked with or describes an individual or household, either directly or indirectly. We collect Personal Information you provide to us, as well as Personal Information collected automatically and from third-party sources as described below.

• Data you provide to us: We collect information created or uploaded to the product by users through their use of our Products and Services. For example, during the account creation process, we will collect certain information to establish and manage your and your student’s account effectively, including your student’s name, address, proof of residency, and transcripts. Additionally, we collect information about classes and students that teachers or administrators enter into the product, as well as any other content that you choose to provide through your use of the service.
• Data from third-party sources: We allow teachers, administrators, parents, and guardians to add information about students and classes, such as transcripts and student records, directly into the product manually or using third-party tools utilized by schools. The data collected from these tools, including information provided by teachers, administrators, and all student records, is used solely for the purpose of delivering and supporting the service.
• Data collected automatically: When you use our services, we may use cookies and similar technologies that collect certain technical and usage information to deliver the services and better understand how you use the product. For more information on cookies and similar technologies, please see the Cookies section below.

We collect Identity and Demographic data solely as a School Official under FERPA and only at the direction of the subscribing school. This data is used exclusively to provide the contracted educational services. We do not sell student data, nor do we use it for targeted advertising or to build profiles for non-educational purposes.

How we use your personal information

We limit the collection of data to what is needed to support the features and functionality of the product and fulfill product requirements. We use the collected data for the following purposes:

• provide the Service to you and to improve the Service
• operate, improve, and personalize the services we offer, and to give each user a more consistent and personalized experience when interacting with us
• charge you for purchase and delivery costs through one or more third party payment processors
• provide customer service or otherwise communicate with you about the Service and our services
• maintain the security of your data and compliance with applicable laws
• detect fraud or illegal activities or to comply with our legal obligations
• complete any other business or commercial purpose you have requested or to which you have consented

StrongMind is a digital platform for online classes, curriculum, online teachers, and digital communities for students. When students under 18 years of age use StrongMind, their account registration is established and managed by their parent or guardian. Students who are 18 years of age or older may be permitted to register and manage their own accounts with StrongMind.

StrongMind requires all users of the platform to be registered users in order to access the services. Those accounts are managed by account administrators. Once registered, students have the ability to collaborate with teachers and other students through moderated community posts, and with their teachers via private messaging. To support the safety and educational experience of student users, we review and monitor interactions between users within our platform. Furthermore, the service does not allow interactions between non-authorized users, nor does it enable external sharing or posting of information through the services.

We may use algorithms or automated means to provide information and content to our users, including minors. Use of these automated means includes, but is not limited to, promoting, ranking, or filtering information or content. User information such as age, class grade level, and academic performance are used to provide the appropriate content to users. Algorithms and automated means are only used to provide the services.

The student facing StrongMind service is free of advertising, including contextual and personalized ads. We may, with your consent, send teachers, school leaders, and parents first-party marketing communications about our services, from which you can opt out at any time.

How we share your personal information

With Third Party Service Providers Performing Services on Our Behalf

We share your personal information with our service providers to perform the functions for which we engage them. For example, we may use third parties to host the Site or assist us in providing functionality on the Site, and to process payments. We establish contractual limitations with third party sub processors that restrict the extent and purposes for which they may process any personal information we disclose to them. These third parties are permitted to process personal information solely on our behalf and in accordance with our instructions. They are also required to implement and maintain security measures that provide a level of protection equivalent to those we uphold.

For Other Purposes You Direct or To Which You Consent

We may share information with other third parties when you consent or direct us to do so. For example, if you refer friends to use the Site we may share with that friend information about you to let them know who the referral came from.

De-Identified or Aggregated Information

We may share information on a non-personally identifying aggregate basis for any lawful purpose.

For Legal Purposes

We also may share information that we collect from users as needed to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose personal information as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also share personal information as required to pursue available remedies or limit damages we may sustain.

Changes of Control

We may transfer information, including your personal information, in connection with, or during negotiation of a merger, sale of company assets, financing, acquisition or other change of ownership or control by or of us or any affiliated entity (in each case whether in whole or in part).

For the avoidance of doubt, we never sell personal data from our service and we do not share data with third parties for their own marketing, advertising purposes, or creating advertising profiles.

Your Choices

To use our Products and Services, users are required to create an account. During the account creation process, we will collect certain information to establish and manage your account effectively. Your account enables you to personalize your experience, monitor your activities, and access, manage, and control both your personal data and any information you provide to us. Please note that when an educational institution administers the services student users and their parents may need to contact their educational institution in order to access or request information.

We may contact teachers and administrators directly to market and promote our services; however, we will never use student records for this purpose. You can stop receiving promotional email communications from us by clicking “unsubscribe” in such communications or contacting us directly. We make every effort to promptly process all unsubscribe requests.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or other online services that are not associated with us. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions.

Cookies

Our Product may use cookies to help you personalize your online experience. A cookie is a text file that is placed on your device browser that stores preferences to facilitate and enhance your experience. For example, if you register with our Product or Services, a cookie helps our product to recall your specific information on subsequent visits.

For clarity, we do not use third-party cookies on our service for personalized advertising or to track users and display personalized advertisements on other third-party websites or services. You can find a list of the types of first and third party cookies we use below:

Necessary cookies: Enable the core operation of our Products and Services and cannot be switched off in our systems. They include cookies that we use to help control secure areas of our site and to make sure it is accessible to you. You can set your browser to block or alert you about these cookies, but some parts of the site will not work as a result.

Analytics cookies: These cookies allow us to collect information about patterns of behavior among people using the site. Analytics cookies allow us to count site visits and understand traffic sources so we can measure and improve the performance of our site. We never collect any information from analytics cookies that could be used to personally identify you.

Do Not Track

The Service does not currently take any action when it receives a Do Not Track request. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, visit www.donottrack.us.

Security

We are dedicated to safeguarding the security of information obtained through the services, including personal information. When we collect information from you, we implement reasonable and appropriate administrative and technical safeguards to help protect it from unauthorized access, use, or disclosure. For example, all data is encrypted during transmission and at rest.

While we implement robust security measures, please be aware that no system is completely secure, and we cannot guarantee absolute security of your information. In the event of a data breach, we will make reasonable efforts to notify affected users in accordance with applicable laws and regulations.

We retain personal information only as long as necessary for the purposes for which it was collected in compliance with applicable laws. If a school cancels or terminates their account, user data associated with that account will be deleted. In some cases, we may retain personal data beyond the length of time that you have an account with us in order to resolve disputes, comply with legal and compliance obligations, or otherwise. We may retain and use de-identified or aggregated data that can no longer reasonably identify you for as long as necessary for our business purposes.

Your Privacy Rights

Except as otherwise provided, this section applies to residents of states where they have privacy laws applicable to us that grant their residents the rights described below.

For purposes of this section, “personal information” has the meaning given to “personal data”, “personal information” or similar terms under the applicable privacy laws of the state in which you reside. Please note that not all rights listed below may be afforded to all users and that if you are not a resident of the relevant states, you may not be able to exercise these rights. In addition, we may not be able to process your request if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to it.

In some cases, we may provide a different privacy notice to certain categories of residents of these states, such as job applicants, in which case that notice will apply with respect to the activities it describes instead of this section.

Verification: Upon receipt of your request, we will initiate the identity verification process to confirm that you are the individual for whom we hold information in our system. This verification procedure necessitates your cooperation in supplying relevant information, allowing us to compare it with the details you previously furnished. Depending on the nature of your request, we may request specific information to align with our existing records, or we may reach out to you using a previously provided communication method (such as phone or email). In certain situations, alternative verification methods may be employed based on the circumstances.

Any personal information disclosed in your request will solely be utilized for the purpose of confirming your identity or validating your authority to make the request. We will make every effort to minimize the need for additional information for verification purposes. However, should it be impossible to verify your identity with the existing information in our records, we may request additional details to ensure the security and prevent fraud. Any supplementary information you provide for verification will be promptly deleted upon the completion of the verification process.

Authorized Agents: Your authorized agent may be able to make a request on your behalf. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.

Correction: You can request that we correct inaccurate personal information that we have collected about you.

Deletion: You can request that we delete your personal information. Please note that once we process a deletion request, we may be unable to provide access or support to any past products or services.

Users may submit a request in writing to access their data, request modifications, make corrections, and delete their user data.

In certain circumstances, we may process data and provide our services to a school or educational organization under a contract that establishes the institution as the primary controller of the student data we process. In this case, students and parents should contact their specific educational institution to exercise rights regarding the access, deletion, or de-identification of personal information.

Student and Children’s Privacy

We comply with the U.S. Children’s Online Privacy Protection Act and Family Educational Rights and Privacy Act, and describe our practices regarding the personal information of all students under the age of 13 below. Our service is designed to be used by teachers, administrators, and students in an education context. As part of our services, we may process student records and data from children 13 years of age and under, as provided to us by schools and teachers.

When we provide services on behalf of a school, the school provides consent for StrongMind to collect and process information from students under the age of 13 as permitted by the Children’s Online Privacy Protection Act. As described in the notice we provide to schools, we collect, maintain, use and share student records only for authorized educational purposes. Student records that we process on behalf of schools will remain under the control of the respective school. To request access to, modification of, or deletion of student records, please contact the school that maintains those records directly.

When we provide services on behalf of a parent to a child under the age of 13, we will first obtain verifiable parental consent in accordance with the Children’s Online Privacy Protection Act. We collect personal information from children under 13 only to the extent necessary to provide the service requested. We use, maintain, and share this information strictly for the purpose for which consent was given, and we do not knowingly use it to market to children. Parents have the right to review their child’s personal information, request that it be deleted, and refuse to permit its further collection or use.

We are committed to protecting the privacy and data of students and children and do not require more information about students or children than is reasonably necessary to provide the service. In addition:

• We collect, maintain, use and share student records only for an authorized educational purpose.
• We do not use or disclose student records for targeted advertising or any other commercial purposes unrelated to education.
• We do not build a personal profile of a student other than to deliver our service.

Changes To This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will update the date of this Privacy Policy and post it on the Services or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Services after the effective date of any modified Privacy Policy indicates your acknowledgment that the modified Privacy Policy applies to your interactions with the Services and our business.

How to Contact Us

If you have questions or concerns regarding this Privacy Policy, please contact us using the means described in this section. A grievance or remedy mechanism is available for users to file a complaint in the event their content or account is restricted or removed. Please use the information below to contact us.

Email: [email protected]
Address: 2501 N Arizona Ave., Chandler, AZ, 85225-1385