Privacy Policy

PLEASE READ THE FOLLOWING CAREFULLY

This website located at www.NovareEdu.com (the “Site”) is brought to you by Novare Education, LLC (“Novare Education”). At Novare Education we are serious about protecting your privacy, and this Privacy Policy discloses how we collect, protect, use, and share the personal information gathered on this Site and through our learning management system and authentic assessment services (“Services”).

This Privacy Policy may be revised from time to time through an updated posting and we will indicate the last revision date, and therefore you should check the Privacy Policy periodically. We will also send registered users of our Services an email notice of any changes. Revisions are effective upon posting and your continued use of this Site and/or our Services following the posting of revisions will indicate your acceptance of such revisions. If you have any questions concerning this Privacy Policy, please contact us at privacy@NovareEdu.com.

What Personal Information Is Collected

You can generally visit our Site without revealing any personally identifiable information about yourself. However, in certain sections of the Site and in order to use our Services, we require you to submit your personally identifiable information to us. When you register to use our Services, you may be required to provide us with personally identifiable information such as your name,
address, email address, phone number, password and username.

Users of our Services include school administrators, teachers and parents, guardians and students. School administrators set the privacy settings that govern what other users (such as teachers, parents and students) can post and view on the Services. Teacher or School Administrative users provide access to the portal to their designated staff and students.

School administrative and teacher users of our Services may voluntarily upload personally identifiable information about personnel and students at their schools and the parents of such students. Such information may include names, contact information such as address, email and phone number, age, grade, classroom, gender, report card data, accommodation or individualized education plans, performance outcomes, teacher notes, photos, videos and work samples as well as school health education records (such as allergies, learning differences or medical action plans).

In our agreements with our school customers, the school, if required, is responsible to obtain consent from parents or guardians (or if the student is an adult, from the student) to release information from a student’s education record to Novare Education. With respect to our student users that may be under age 13, please see the Section below titled “Children.”

Provided that student users have been granted access to use our Services, students may voluntarily upload personally identifiable information about themselves such as in projects, photos, videos, word documents, links and other assignments. All student uploads will be in folders that the student’s teacher designates on the Services. Students may tag other students in their postings to the Services provided that the student’s teacher set up a folder for such group project that is accessible to specific listed students that the teacher designated.

Additionally, if you comment to a blog post on our Site or request more information, we will collect the personally identifiable information that you include in your posting and other users of the Site will be able to view such information. We will also collect any personally identifiable information that you include in any communications that you send to us.

How we use Personal Information

We may use your personally identifiable information to: deliver certain services and information you have requested, verify your authority to enter certain password protected areas of the Site and/or Services, and improve the content and general administration of the Site and the Services.

If you are a user of our Services, we will use your personally identifiable information and personally identifiable information that you have uploaded about personnel and students at their schools and the parents of such students to provide the Services to you and to provide user support to you.

Aggregate Information

The Site and Services may track the total number of visitors to our Site and/or Services, browser type, IP addresses, External Web Sites (defined below) linked to and other aggregated data collected through our Site. We may analyze this data for trends and statistics in the aggregate. Such information will be maintained and used in aggregate form only and it will not contain personally identifiable information. We also may use such aggregate information to administer
the Site and Services and track users’ movement, and gather broad demographic information for aggregate use such as to improve Novare Education’s Services and to demonstrate the success of Novare Education’s platform.

Information Sharing And Disclosure

Within the Services, school administrator users may set the privacy parameters to establish the information that other administrators, teachers and students within their own school may view, access, upload and/or change material in a record on the Services. School administrator users will also establish who (within the same school) may communicate with your child through the Services.

Subject to the school administrator’s and each teacher’s designated privacy settings within the Services: (i) parent users of our Services will be able to access information that their child’s school administrator, teacher or child has posted to their own child’s portal and (ii) student users may be able to tag other students in their postings to the Services provided that the student’s teacher set up a folder for such group project that is accessible to specific listed students that the teacher designated.

Parents will not be able to access information about students other than their own child, except that parents may be able view pictures and videos of other students that are tagged or included in a photo or video or other artifact on their child’s portal. Administrators and teachers will only have access to their own school.

Additionally, a parent and school administrator also may request that a specific child’s tutor have access to certain records of a child within the Services.

We may provide your personally identifiable information and the data generated by cookies and the aggregate information to the vendors and service agencies that we may engage to assist us in providing our services to you, such as our third party hosting providers or payment processing services. We will contractually prohibit such service providers from using any personally identifiable information other than to provide the services on our behalf, prohibit further disclosure of personally identifiable information and require such service providers to implement and
maintain reasonable security procedures.

We will disclose your personally identifiable information and aggregate data if we reasonably believe we are required to do so by law, regulation or other government authority or to assist in any investigation, to protect our or our users’ rights or to enforce our terms of use. We will not sell your personally identifiable information to any company or organization except we may transfer your personally identifiable information to a successor or parent entity upon a merger,
consolidation or other corporate reorganization in which Novare Education participates or to a purchaser of all or substantially all of Novare Education’s assets to which this Site and/or Services relates.

Additionally, Novare Education will share personally identifiable information with other platform providers whose services integrate with Novare Education’s Services and in furtherance of the education purpose of Novare Education’s Services. Such other platforms providers will be prohibited from further disclosure of personally identifiable information and must implement and maintain reasonable security procedures.

Children

Novare Education recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. This ‘Site’ is not intended for use by children under the age of 13. Novare Education does not target this Site to children under 13.

We do not knowingly collect personally identifying information from Children on this Site. If a child e-mails us via a “Contact Us ” link on our Site and we identify the sender as a child, any personally-identifying information submitted will be deleted and not used or will only be used to respond on a one-time basis to such child and will thereafter be deleted from our records.

Novare recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. We require consent from an authorized administrator of a school to allow children under the age of 13 within their school to use our ‘Services’. Such authorized administrator provides consent on behalf of the parents and legal guardians of the students under age 13 in accordance with the Children’s Online Privacy and Protection Act (“COPPA”).

Novare does not condition a child’s participation in an online activity on the child providing more personally identifiable information than is reasonably necessary for that activity.

Provided the school administrator has received prior consent from the child’s legal
guardian/parent to allow a child within their school that is under the age of 13 to use our Services, we will allow the child to use our Services. We will use the child’s information for the purposes as described in this Privacy Policy.

A school and a parent may review their own child’s personally identifiable information, direct Novare to delete it, and refuse to allow any further collection or use of the child’s information.
The parent may exercise these rights by contacting Novare at privacy@novareedu.com. Even if a school or parent agrees to the collection and use of their child’s information, the school or parent may elect to not allow disclosure to third parties (as disclosures are described in the “Information Sharing and Disclosure” Section above). In such event your child may not be able to communicate with others (such as other students within the same school) through the Services.

Cookies And Collection And Use Of Information

We receive and store certain types of information whenever you interact with this Site. For example, like many Web sites, we use “cookies,” and we obtain certain types of information when your Web browser accesses this Site. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your Web browser to enable our systems to recognize your browser and to provide customized features to you. The Help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the
browser notify you when you receive a new cookie, or how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on’s settings or visiting the Website of its manufacturer. However, cookies allow you to take full advantage of this Site’s best features, and you may not be able to use all of the features of our Site if you turn cookies off. We use both session ID cookies and persistent cookies on our Site. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time.

Novare Education may use Google Analytics and other analytics providers, as third party services, to collect aggregate visitor data on our Site. These analytics service providers do not collect any personal information such as names, ages, phone numbers, addresses or e-mail addresses from visitors to the Site. Novare Education uses these services to collect visitor information like IP addresses, browser types (such as Internet Explorer or Netscape), referring pages, pages visited and time spent on a particular site for the following purposes: (1) to provide statistical analysis of web page traffic patterns; (2) to administer our Site and servers; (3) to allow for auditing of our services by third parties; and (4) for internal marketing purposes. These analytics providers may track your use of the Site and on other websites and use “cookies”. You may be able to opt out of the collection of such information by downloading add-ons at their respective sites, which will be posted here as and when we use them.

Links To Other Sites

The Site may provide links to other web sites or resources over which Novare Education does not have control (“External Web Sites”). Such links do not constitute an endorsement by Novare Education of those External Web Sites. You acknowledge that Novare Education is providing these links to you only as a convenience, and further agree that Novare Education is not responsible for the content of such External Web Sites. Your use of External Web Sites is subject to the terms of use and privacy policies located on the linked to External Web Sites.

Social Plugins on Our Site

We may use social plugins on our Site and may include icons that allow you to interact with third party social networks such as Twitter and Facebook. For example, you may “like” us on Facebook or follow us on Twitter. The third party social plugin may set a cookie when your browser creates a connection to the servers of such social networks and the plugin may transmit your data to the social networks. Your use of these social plugins is subject to the privacy policies of the third party social networks.

Security and Destruction of Data

We employ industry standard procedural and technological measures that are reasonably designed to help protect your personally identifiable information from loss, unauthorized access, disclosure, alteration or destruction. Novare Education may use, without limitation, encryption, firewalls, password protection, secure socket layer, and other security measures such as restrictions on internal data access to help prevent unauthorized access to your personally identifiable information.

Novare Education will retain your data as long as it is necessary to fulfill the purpose for which it was collected and Novare will delete your data (other than archival automatic backups) on your or the associated school’s request. Additionally, Novare Education has a policy of deleting data within the services about: (i) students, five (5) years after their graduation from high school; and
(ii) school personnel, five (5) years from their termination of employment / relationship with the school. Novare deletes data using reasonable measures to protect against unauthorized use and access.

Notice to Asian & European Users

The information you enter on the Site or Services or otherwise provide to Novare Education may be transferred outside of the Country or European Union to the United States of America, which does not offer an equivalent level of protection to that, required in the respective country. In particular, you are advised that the United States of America uses a sectoral model of privacy protection that relies on a mix of legislation, governmental regulation, and self-regulation. Article 26 of the European Union’s Data Protection Directive (Directive 95/46/EC, 1995 O.J. (L 281) 31) allows for transfer of personal data from the European Union to a third country if the individual has unambiguously given his or her consent to the transfer of personal information, regardless of the third country’s level of protection. By agreeing to this Privacy Policy, you consent to the transfer of all such information to the United States of America which may not offer an equivalent level of protection to that required in the respective countries and to the processing of that information by Novare Education on its servers located in the United States of America as described in this Privacy Policy.

Additional Information About Privacy

If you are a user of our Services, you may update personally identifiable information about yourself or the information about others in your account by accessing your account or contacting us at privacy@novareedu.com. If you have any concerns or questions about privacy on this Site, please contact us at privacy@novareedu.com.