- We collect, store, process and share personal information only for the purposes of providing our Services, or as authorized by a student, parent, or school
- We do not sell, use or share personal information or content for marketing or advertising purposes, unless with consent
- We will maintain a comprehensive data security program designed to protect the types of personal information maintained by Higher Ground and its affiliates
- We will delete or de-identify personal information at the direction or request of the student, parent, or school
- We will clearly and transparently disclose our data policies and practices
- We will provide notice before any personal information is used in a materially different manner than was disclosed when the information was collected.
1. Our commitment to your privacy
2. Personal Information
What is Personal Information?
“Personal Information” is information or pieces of information that could allow you or your child to be personally identified such as:
- Child’s name
- Child’s age / DOB
- User name
- Postal address
- Telephone number
- Email address
- Credit and debit card number
- Profile picture
- Social media account id
- Screen name
- Country of residence
- Ip address
- School name and address
- Program preferences
- Browser and device information
- Server log file information
- Information collected through cookies, pixel tags and other technologies
- App usage data
- Demographic information and other information provided by you
- Location information
- Media gallery
- Photos and videos of students
- Photos of student work
- Work Product and Assessment
- Medical records (e.g. immunizations, food sensitivities)
- Emergency contact, medical providers
- Custody information
- Financial information (for families applying for financial aid)
Personal information does not include “aggregate” information. Aggregate information is data we collect about a group or category of products, services or users, from which individual user identities have been removed. In other words, information about how you use a service may be collected and combined with information about how others use the same service. Aggregate data helps us understand trends and our users’ needs so that we can better consider new features or otherwise tailor the Services.
How do we collect Personal Information?
We and our service providers may collect Personal information in a variety of ways, including:
- Through the sites: we may collect Personal Information through the websites, for example, when you sign up for a newsletter, brochure, flipbook, contact forms, or make a purchase.
- Offline: we may collect Personal Information from you offline, such as when you contact our admissions team, or visit one of our schools in person.
- From other sources: we may receive your Personal Information from other sources, such as public databases; joint marketing partners; social media platforms, as well as from other third parties.
- Through your browser or device: certain Personal Information is collected by most browsers or automatically through your device. We use this information, for statistical purposes as well as to ensure that the sites function properly.
- Through server log files: your “ip address” is a number that is automatically assigned to the computer or device that you are using by your internet service provider (isp). An ip address is identified and logged automatically in our server log files whenever a user visits the sites, along with the time of the visit and the page(s) that were visited.
- By telephone: all calls to and from our schools may be recorded for customer service, health, safety, and/or legal compliance purposes.
- Through video recording: classrooms at our schools may be recorded, at the election of the individual classroom teacher, for purposes of professional development, quality assurance, and/or self improvement. These video recordings will be used for internal professional development and will not be shared with outside parties except as required by law. Video cameras may be installed that are not turned on. If they are turned on, the recording will only be saved for a limited period of time and then will be automatically deleted when that time has elapsed.
- From you: Personal Information such as date of birth, gender, address, phone number, email address, and zip code, as well as other information, such as your preferred means of communication, may be collected when you voluntarily provide this information. We collect Personal Information regarding the students at our schools as necessitated to provide Services, or as required by applicable law or licensing regulations. This may include academic or medical information.
How do we use personal information?
We share data within the Services as needed to perform the Services. We only share personal information with third parties in limited circumstances, described below. We will never share or sell personal information to third parties for marketing purposes.
We may use personal information:
- With consent. We share Personal Information with consent and at the direction of schools, students and parents. A User may direct us to share specific information with another individual, for example, if a teacher directs us to send a communication to a parent, or an Enterprise User may be able to control data sharing functionality for all User accounts within that school district/board or school system. Parents of students at a Partner School should contact their child’s school with any questions about Partner School-authorized data sharing functionality.
- With our trusted vendors and third party service providers. We may share Personal Information with certain trusted vendors, third party service providers and individuals to perform tasks on our behalf, but strictly for the purpose of carrying out their work for us, which may include payment systems, business development, software design, hosting, customer support, accounting, and other similar services. Personal Information will be shared with these third parties as reasonably needed to perform their services to us, and under reasonable confidentiality terms.
- Aggregate Data. We will share information in an aggregated and/or anonymous form that does not reasonably identify you directly as an individual. For example, we may share aggregate data with other students, parents or Schools to display statistical data related to students in a particular classroom, school, district/board, or geographic location. We may also use aggregate or anonymized data to study and improve our Services, user functionality, and product offerings.
- We may disclose your Personal Information as required or authorized by law or subpoena or if we have a good faith belief that disclosure is necessary to (i) comply with the law or a judicial proceeding, court order, or legal process served on us; (ii) to comply with or the lawful request of law enforcement; (iii) to enforce or apply our Terms of Service or other agreements or to protect the security or integrity of our Services; and/or (iv) to exercise or protect the rights, property, or safety of our students and their families; HGE and its affiliates, our employees, our Users, or others.
- To respond to your inquiries and fulfill your requests, such as to send you newsletters, information or to respond to your questions and comments.
- To send administrative information to you, for example, information regarding the sites and changes to our terms, conditions, and policies. Because this information may be important to your use of the sites, you may not opt-out of receiving these communications.
- To complete and fulfill your purchase, for example, to process your payments, have your order delivered to you, communicate with you regarding your purchase and provide you with related customer service.
- To provide you with updates and announcements concerning our products, promotions and programs and to send you invitations to participate in special programs.
- To allow you to contact and be contacted by other users through the Sites, as permitted by the applicable site.
- To permit you to participate on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials (including our social media pages).
- For our business purposes, such as analyzing and managing our businesses, market research, audits, developing new products, enhancing our sites, improving our services and products, identifying usage trends, determining the effectiveness of our promotional campaigns, tailoring the sites experience and content based on your past activities on the sites, and gauging customer satisfaction and providing customer service (including troubleshooting in connection with customer issues).
- We use information collected by browsers or your device for statistical purposes as well as to ensure that the sites function properly.
- We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns.
- As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
- Your personal data will be processed by HGE both within and outside the United States, the European Union, and Canada primarily for the purpose of enrollment in our schools and the use of our websites and apps, and for customer service and marketing activities. Because our central offices are located in the United States, and the schools where the students chooses to take the classes are located globally, we may share your personal data with our service providers both within and outside the United States, the European Union, and Canada. The service providers that we share information with are only such that need access to the personal information to process the order that you have placed on the sites, such as transportation assistance, accommodation, or schools, and they will only receive the information necessary for that purpose. No service provider will receive your personal information for their own marketing purposes. Please note that the service providers may change from time to time. HGE processes personal information in compliance with applicable privacy and data protection legislation. By using our sites, you acknowledge and consent to these potential transfers. You should be aware that many countries outside the United States, the European Union, and Canada do not afford the same legal protections to personal information as countries within the United States, the European Union, and Canada. Transfers will be made in accordance with the applicable legislation and we will take all necessary measures to ensure that third parties involved will provide an adequate level of protection. Any future hosting/processing organisation that we use in relation to the sites will be required to do the same.
HOW WE USE AND SHARE STUDENT DATA.
In addition to the actions described above, we may facilitate the sharing of Personal Information with third parties through the Services, though only when instructed and authorized to do so on behalf of the HGE school, Partner School, the student, or parent. We will use personal information about students to provide the Services and permit data sharing among Users authorized to view and access the student Personal Information. Each student and his or her parent will only have access to view or submit information relative to that particular student. Neither students (nor their parents) will be able to view or otherwise access the personal information of other students, with the exception of name, email address, and profile picture. Additional information may be accessible if provided to that student account by the HGE school or the Partner School (for example, a class photo and class roster containing the names and photos of other students may be added by a teacher to a student account). Except for the circumstances noted above, we only share student data for purposes of providing the educational Services to and at the direction of the HGE school or Partner Schools, parents, and students. For HGE students in Canada, the school will exchange Personal Information with the Ontario Ministry of Education in order to assign, update and validate the Ontario Education Number and the Personal Information associated with them.
We use reasonable organizational, technical and administrative measures to protect personal information under our control. Unfortunately, no data transmission over the internet or data storage system can be guaranteed to be 100% secure.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem.
For Canadian users, we store and process your personal information in full compliance with the British Columbia Personal Information Protection Act (PIPA), the Canada Personal Information Protection and Electronic Documents Act (PIPEDA), and provincial Freedom of Information and Protection of Privacy Acts (FOIPPA).
For United States Users, we store and process your Personal Information in compliance with FERPA, state laws relating to student data privacy, and other applicable U.S. law.
4. Access, modification and choices
We give you many choices regarding our use and disclosure of your Personal Information for marketing purposes.
As part of our Services, we may use your Personal Information to communicate with you about your child’s progress at school, your account or transactions with us, or send you information about updates and changes to our Services.
When you provide an email address to invite a friend or colleague or other contact to join the Services, we will use this information to send the invitation, and we may send 1-2 reminder emails if we have not received a response. From time to time, we may also send these individuals email communications letting them know more about our Services. The recipients may unsubscribe from these emails by clicking on the “unsubscribe” button within the body of the email at any time or by email to email@example.com.
If at any time you wish to stop receiving marketing communications from us, the easiest way to do so would be to use the unsubscribe feature in the marketing communication you received. You may also let us know by emailing, calling or writing to us using the contact information listed below in the “contact us” section. In your request, please indicate that you wish to stop receiving marketing communications from us.
In addition, we will not disclose your Personal Information to third parties, including our subsidiaries, for the third party’s direct marketing purposes if we have received and processed a request from you that your Personal Information should not be shared with third parties for that purpose. If you would like to submit such a request, please just let us know by using the “contact us” form. Please clearly indicate that you request that we do not disclose your Personal Information to our subsidiaries and/or other third parties for their direct marketing purposes.
Please note that changes may not be effective immediately. We will endeavour to comply with your request(s) as soon as reasonably practicable and in no event later than 30 days after we received your request. Please also note that if you do opt-out of receiving marketing-related messages from us, we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages.
COMMUNICATIONS WITH STUDENTS
We use Personal Information to facilitate the sending of communications relating to the Services to and from the HGE school or Partner School, student, and parent. We send these communications only on behalf of, and at the direction of the HGE school or Partner School, student or parent. In limited circumstances, we may also send the student notifications regarding the student’s account and use of the Services, but we will never use Personal Information for advertising or marketing purposes without consent. Please note that all Users who have been authorized to have access to a student’s account, which could include a parent, student, school administrator, teacher and/or other User, may be able to view activity and content associated with such student account, including the content of communications.
6. Updates and Corrections
To review, correct, update, suppress, delete or otherwise limit our use of your personal information that has been previously provided to us, please send an email to firstname.lastname@example.org and clearly describe your request. In your request, please make clear what information you would like to have changed, whether you would like to have your personal information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your personal information.
We will try to comply with your request as soon as reasonably practicable. Note that despite our efforts, there may be residual information that will remain within our databases and other records, which will not be removed or changed. Further, please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion (e.G., when you make a purchase or enter a promotion, you may not be able to change or delete the personal information provided until after the completion of such purchase or promotion).
7. Third party sites
We are also not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as facebook, apple, google, microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any personal information you disclose to other organizations through or in connection with the apps or our social media pages.
8. Retention period
9. Children’s Privacy
We do not knowingly collect personal information through the Services from a child under 13 without parental consent. When personal information is collected by a Partner School, we request our Partner Schools to obtain appropriate parental consent and authorization for a student under 13 to use the Service and for us to collect information from such student. Please contact us at email@example.com if you believe we have inadvertently collected personal information from a child under 13 without proper consents so that we may delete such information as soon as possible.
10. Sensitive information
We generally ask that you do not send us, and you do not disclose, any sensitive Personal Information (e.G., information related to racial or ethnic origin, political opinions, religion or other beliefs, health or medical condition, criminal background or trade union membership) on or through the sites or otherwise to us. In specific exceptions, we will make clear how you can do this securely.
11. Links to Other Websites
13. Contact us
Don’t want to be contacted in the future by us;
Would like to find out what information we have about you, would like a copy of the Personal Information which we hold about you (you may be charged an administration fee when we provide you with the requested information to cover our time and postage and handling or retrieval costs)
If you think that any Personal Information we hold about you is inaccurate, incomplete, out-of-date or irrelevant;
14. Service Development
16. Your Comments or Concerns
Our address is:
Higher Ground Education Inc.
10 Orchard Ste 200
Lake Forest CA 92630
Updated: December 5, 2022