StrongMind (“StrongMind,” “we” or “us”) knows the importance of online safety and protecting the privacy of the students, parents and education professionals who utilize our platform(s) and/or service(s). We take our responsibility seriously and have adopted policies that ensure that every interaction a user has with any of our products and/or services follows the best practices and industry standards to safeguard data and the overall user experience. Please take a moment to familiarize yourself with our policies.
1. HOW INFORMATION IS COLLECTED AND USED.
Information about Schools: In some instances, Schools will be requested to provide information about the School. An example of the type of data a School would be asked to provide is the following:
- School name
- School district
- School URL
- phone number
- information relating to the School’s information systems (SIS), learning management system (LMS) and/or courseware providers.
We may also gather information provided by a School if the School sends us a message, posts content to our website or through our Service, or responds to emails or surveys.
StrongMind will keep records of activities related to the use of the Product(s) and/or Service(s) used. This information allows StrongMind to provide, operate, maintain, and improve the features and functionality of our products and/or service(s), to analyze our product(s) and service(s) offerings and functionality, and to communicate with our Schools and website visitors.
Student Data: We may have access to personally identifiable information about students (“Student Data”) through the SIS and/or LMS and/or courseware. We consider Student Data to be confidential and do not use such data for any purpose other than to provide the courses and other services on the School’s behalf.
The Schools may also provide students information to create accounts on student(s) behalf, allowing student(s) access to StrongMind’s Product(s) and/or Service(s) via the StrongMind platform which has been authorized by the School, often at a School facility or from a student’s personal computer. The School is responsible for providing each student with login credentials and confirms that it has obtained appropriate parental consents, as needed, before the student is permitted to access the StrongMind platform.
StrongMind has access to Student Data, as requested by the School and only for the purposes of providing Schools and students the ability to use the StrongMind Product(s) and/or Service(s). StrongMind will not use Student Data for any purposes other than those authorized pursuant to StrongMind’s contract with the School.
Students or parents should direct questions about the School’s use of technology service providers like StrongMind to their School administrator. If a Student contacts StrongMind with a question about our Service, we will collect personal information from that Student only as necessary to respond to the Student’s request and direct the Student to contact the Student’s School, and we will then delete or anonymize the personal data of the Student after providing our response.
Automatically Collected Information: Like many websites, StrongMind may use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s storage device for record-keeping purposes. Cookies are used for two purposes: First, StrongMind utilizes persistent cookies to save your login information for future logins to the Website. Second, StrongMind utilizes session ID cookies to enable certain features of the Products and/or Service’s, to better understand how you interact with them and to monitor aggregate usage by users and web traffic routing. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the any of the Product(s) and/or Service(s) and then close your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from any websites you visit. If you do not accept cookies, however, you may not be able to use all features of the Product(s) and/or Service(s).
2. HOW WE SHARE YOUR INFORMATION
StrongMind only shares personal information in a few limited circumstances, described below. We never rent or sell information for marketing purposes.
In limited circumstance, we may share information with others as follows:
- We may share information with technology service providers (e.g., web hosting and analytics services), but strictly for performing their work for us.
- In the event of a change of control: If we sell, divest or transfer our business, we will not transfer personal information of our customers (including Student Data) unless the new owner intends to maintain and provide the same Product(s) and/or Service(s), and provided that the new owner has agreed to data privacy standards no less stringent than our own.
StrongMind never sells School or Student Data for any reason, does not allow third party advertisers to collect information about the users of our Site(s), Product(s) or Service(s), and never shares such information with outside third parties unless expressly authorized to do so by the School or the affected student or parent.
3. PROCESSING OF PERSONAL DATA:
Roles of the Parties: The parties acknowledge and agree that with regard to the Processing of Personal Data, School acts as the Data Controller and StrongMind acts as the Data Processor. Each party will comply with all laws, regulations and rules applicable, including Data Protection Laws and Regulations.
School’s Processing of Personal Data: School shall, in its use of the Product(s) and/or Service(s), process Personal Data in accordance with Data Protection Laws and Regulations. For the avoidance of doubt, School’s instructions for the Processing of Personal Data shall comply with Data Protection Laws and Regulations. School shall have sole responsibility for the accuracy, quality, and legality of Personal Data and the means by which School acquired
Personal Data: StrongMind shall only process Personal Data on behalf of and in accordance with a School(s) instruction and shall treat Personal Data as Confidential Information. School(s) could ask StrongMind to process Personal Data for the following purposes: (i) Processing in accordance with the Agreement(s); (ii) Processing initiated by users in their use of the Product(s) and/or Service(s); and (iii) Processing to comply with other reasonable instructions provided by School(s) (e.g., via email) where such instructions are consistent with the terms of the Agreement.
Purpose, Object and Duration of the Processing: The purpose and object of the Processing is to enable StrongMind to access the Personal Data required for the provision of the Product(s) and/or Service(s), as specified in the Agreement and any Addendum(s), on behalf of and for the benefit of the School. The Processing shall commence on the Effective Date and continue for the duration of the Agreement and/or Addendum(s).
4. HOW WE STORE AND PROTECT YOUR INFORMATION
Storage of Data: Any information collected through the StrongMind Product(s) and/or Service(s) is stored using on premise hardware and cloud-based service(s)/ solution(s) with an additional offsite data center in order to protect school and student data and support disaster recovery.
Comprehensive Information Security Program: StrongMind takes actions designed to ensure the security and confidentiality of Student Data, and maintains strict administrative, technical and physical procedures to protect information stored in our servers. Access to information is limited (through user/password credentials) to those employees who require it to perform their job functions. Security safeguards include but are not limited to data encryption, firewalls, and physical access controls to building and files.
In the event of any unauthorized release, disclosure or acquisition of Student Data, StrongMind maintains policies and procedures for identifying and mitigating data security breaches. StrongMind will conduct an investigation to determine the nature and scope of any unauthorized release, disclosure or acquisition, and StrongMind will promptly notify School officials, affected students, parents and/or legal guardians of unauthorized access to Student Data to the fullest extent required by applicable law.
5. YOUR CHOICES ABOUT YOUR INFORMATION
Correction, Deletion and Blocking: To the extent School, in its use of the Product(s) and/or Service(s), does not have the ability to correct, amend, block or delete Personal Data as required by Data Protection Laws and Regulations, StrongMind shall comply with any commercially reasonable written request by School to facilitate such actions to the extent StrongMind is legally permitted to do so. To the extent legally permitted, School shall be responsible for any costs arising from StrongMind’s provision of such assistance.
Data Subject Requests: StrongMind shall, to the extent legally permitted, promptly notify School if it receives a request from a Data Subject for access to, correction, amendment or deletion of that person’s Personal Data. StrongMind shall not respond to any such Data Subject request without School’s prior written consent except to confirm that the request relates to School. StrongMind shall provide School with commercially reasonable cooperation and assistance in relation to handling of a Data Subject’s request for access to that person’s Personal Data, to the extent legally permitted and to the extent School does not have access to such Personal Data through its use of the Product(s) and/or Service(s). If legally permitted, School shall be responsible for any costs arising from StrongMind’s provision of such assistance.
6. COMPLIANCE WITH FEDERAL AND STATE LAWS.
StrongMind is committed to compliance with all other federal and state laws and regulations governing student data privacy, including the federal Family Educational Rights and Privacy Act (“FERPA”), the California Student Online Personal Information Protections Act (“SOPIPA”), the Connecticut Student Data Privacy laws (C.G.S. §§ 10-234aa through 10-234dd), and other similar state laws.
7. OTHER WEBSITES AND SERVICES
StrongMind is not responsible for the practices employed by websites, applications or services linked to or from our Product(s) and/or Service(s). We recommend that the School review the privacy policies of other applications before authorizing a third party to access data through the Service.
8. STUDENT PRIVACY PLEDGE
StrongMind has signed the Student Privacy Pledge, a pledge in which signatories agree to “safeguard student privacy regarding the collection, maintenance, and use of student personal information” (http://studentprivacypledge.org/). View the pledge here.
ATTN: Privacy Inquiry
2501 N. Arizona Ave.,
Chandler, AZ 85225
email at [email protected].