How FocalPoint Protects Personal Data
Thank you for choosing to be part of our community at FOCALPOINTK12, INC. (“FocalPoint”, “Company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy or our practices with regards to your personal information, please contact us at info@focalpoint.education.
When you visit our website, mobile applications, and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Sites or Apps and our services.
This privacy policy applies to all information collected through our website (such as www.focalpoint.education and sub-sites), mobile application, ("Apps"), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the "Sites").
Please read this privacy policy carefully, as it will help you make informed decisions about sharing your personal information with FocalPoint.
WHAT INFORMATION DO WE COLLECT?
Personal information you disclose
We collect personal information you provide to us such as name, address, contact information, passwords and security data, payment information, and social media login data.
We collect personal information you voluntarily provide to us when registering at the Sites or Apps, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Sites or Apps (such as posting messages in our online forums or entering competitions, contests or giveaways) or otherwise contacting us.
The personal information we collect depends on the context of your interactions with us and the Sites or Apps, the choices you make and the products and features you use. The personal information we collect can include the following:
Name and Contact Data: We collect your first and last name, email address, postal address, phone number, and other similar contact data.
Credentials: We collect passwords, password hints, and similar security information used for authentication and account access.
Payment Data: We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your questions.
Social Media Login Data: We provide you with the option to register using social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the Information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS" below.
All personal information you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Sites or Apps.
We automatically collect certain information when you visit, use or navigate the Sites or Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites or Apps and other technical information. This information is primarily needed to maintain the security and operation of our Sites or Apps, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
Information collected through our Apps
We may collect information regarding your Geo-location, mobile device, and push notifications when you use our apps. Specifically, if you use our Apps, we may collect:
Geo-Location Information: We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
Mobile Device Data: We may automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information, and IP address.
Push Notifications: We may request to send you to push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
Information collected from other sources
We may collect limited data from public databases, marketing partners, social media platforms, joint marketing partners, social media platforms (such as Facebook), as well as from other third parties. Examples of the information we receive from other sources include: social media profile information (your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links).
HOW DO WE USE YOUR INFORMATION?
We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Sites or Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive
To facilitate account creation and login process: If you choose to link your account with us to a third-party account *(such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and login process. See the section below headed "HOW DO WE HANDLE YOUR SOCIAL LOGINS" for further information.
To protect our Sites: We may use your information as part of our efforts to keep our Sites or Apps safe and secure (for example, for fraud monitoring and prevention).
For other Business Purposes: We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites or Apps, products, services, marketing, and your experience.
WHAT IS YOUR POLICY ABOUT CHILDREN’S DATA?
Our websites are not directed to children under the age of 13. Moreover, FocalPoint will not knowingly send or direct marketing communications to students or anyone under the age of 18.
FocalPoint does not knowingly collect any information from children under the age of 13 unless and until our client (typically state or local education Agencies) have obtained appropriate parental consent for the student to use our website, Apps or related services. Because FocalPoint collects and uses Student Data at the direction of and under the control of an Agency, FocalPoint relies on each Agency to provide appropriate notice to parents of the Agency’s use of third-party service providers such as FocalPoint, and for the Agencies to provide consent, if necessary, and authorization for FocalPoint to collect student data, as permitted by the Children’s Online Privacy Protection Act (COPPA). Please contact us immediately at info@focalpoint.education if you believe FocalPoint as inadvertently collected personal information of a child under 13 without proper consent so that we may delete such data as soon as possible.
WILL YOUR INFORMATION BE SHARED WITH ANYONE?
We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.
We may process or share data based on the following legal basis:
Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
Vendors, Consultants, and Other Third-Party Service Providers: We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. We may allow selected third parties to use tracking technology on the Sites or Apps, which will enable them to collect data about how you interact with the Sites or Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Business Partners: We may share your information with our business partners to offer you certain products, services or promotions.
WHO WILL YOUR INFORMATION BE SHARED WITH?
We only share and disclose your information with the following third parties. We have categorized each party so you can easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.
Allow Users to Connect to their Third-Party Accounts and Google account
Web and Mobile Analytics Google Analytics
DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.
HOW DO WE HANDLE YOUR SOCIAL LOGINS?
If you choose to register or log in to our websites using a social media account, we may have access to certain information about you.
Our Sites or Apps offer you the ability to register and login using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public.
We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the Sites or Apps. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.
HOW LONG DO WE KEEP YOUR INFORMATION?
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than one year past the termination of the user's account.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
HOW DO WE KEEP YOUR INFORMATION SAFE?
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites or Apps is at your own risk. You should only access the services within a secure environment.
WHAT ARE YOUR PRIVACY RIGHTS?
You may review, change, or terminate your account at any time. If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can log into your account settings and update your user account. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites or Apps. To opt-out of interest-based advertising by advertisers on our Sites or Apps, visit: http://www.aboutads.info/choices/.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:
Note your preferences when you register an account with the site.
Access your account settings and update preferences.
CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.
DO WE MAKE UPDATES TO THIS POLICY?
Yes, we will update this policy as necessary to stay compliant with relevant laws. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.
HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may email us at info@focalpoint.education or by post to:
FocalPoint Education
3000 Northwoods Pkwy, Suite 150
Peachtree Corners, GA 30092
Phone: +1 866.377.4265
