Effective date: April 6, 2016
For the purposes of this Policy, the term “Users” refers to (a) “Leaders” -- this includes those who initially set up the Service (“Primary Leader”) and other that are granted Leadership privileges by the Primary Leader; (b) Administrators – those who operates the technical features available through the Services (“Administrators”) (Leaders and Administrators, collectively “Administrative Users”), c) Teachers – users for whom is guaranteed by an Administrative Users the powers to use the classroom features in order to manage students’ mobile devices during class time (“Teachers”), and d) Students: those who are enrolled at the School and uses a mobile device managed by the Services for educational purposes (“Students”).
1. INFORMATION WE COLLECT
We collect the following types of information:
(a) Personally identifiable information (“PII”) you give us: PII is information that personally identifies one individual from another. As a Primary Leader, you voluntarily provide us this information when you initially establish an account on the Service. As of the effective date of this Policy, to establish your account we ask you to provide all the information necessary to fill the sign-up form available on http://manager.mosyle.com/sign-up that includes school’s name, school’s website, school address and your name, email and position. Once your account is established, you (as Primary Leader) will have the power to freely register all the other Users, providing information as name, email and role. The email address is not required to register a Student; any unique information (including but not limited to an e-mail address) that allows differentiating users can be used for a Student.
Finally, when you log on to your account, we will record your geo-location, IP address and/or unique mobile device identifier and may tie it to your specific account. Under ordinary circumstances, an IP address recorded in isolation is not PII under the standard definition of the term. However, it may become PII when it is combined with other information, as in this case.
We do not anticipate receiving student contact information through the sign-up form on our Site. Nevertheless, if you are under 13, please do not leave your contact information on our Site. If you are a parent or guardian of a child under 13 years old and you learn that your child has left PII on our Site, please contact us.
We do not request personal information from Students when they are fewer than 18 except where COPPA authorize us to collect personal information without verifiable parental consent. For this reason, the login of Students is always made by a code generated by us based on the information provided by Administrative Users.
Our Service is not intended to be managed by Users under the age of 18. If we become aware that a person managing the Services and submitting information is under 18, we will delete the information as soon as possible. According to our Terms of Service, all users that manage the Service represent that they are at least 18. Please note, that if a child indicates that he/she is not under the age of 18 (or 13), your child WILL NOT be blocked from using our Services.
In addition, if a child provides us feedback or contacts us (for support, for example), we will collect the data included in the communication.
(b) Usage Information: Usage Information consists of information that is anonymous in nature and does not identify you as an individual. We get Usage Information from all Users. This includes the unique mobile device identifier, browser type, ISP or carrier name, and other persistent identifiers. This information gives us insights on how you and other users use the Services.
We additionally collect some special information necessary to provide the Services, including (i) geo-fence locations; (ii) requests of app installs; (iii) requests of app removals; (iv) frequency and duration of some features; and (v) how you use some of our features. We also collect several information about the managed mobile devices including (i) list of all apps installed on each device, including the date of installation; (ii) geo-location while Mosyle Manager App is being used and while it is in background; (iii) device info, including but not limited to device name, serial number, model, storage, version and status of operation system, battery level, and any additional and potential information that we can get through mobile device management features; (iv) time of use per app installed.
2. HOW WE USE PII
How we use PII: We use the PII we collect from and about you to enable us to interact with you on a personal level, and to enable you to better use the Services. We may also use PII for the following purposes: (a) to verify your eligibility for our Services; and (b) to otherwise perform functions associated with our Services. We use your email address to contact you regarding your account. We may also send you emails that may be of interest to you. You may stop receiving emails from us by clicking the unsubscribe link at the bottom of the email.
3. HOW WE SHARE PII
We will not sell, rent, or share PII with third parties outside of our company without your consent, except in the following ways:
(a) If requested or required by law enforcement authorities, courts, or regulators, we may disclose any information we have about our users. We also may disclose your PII to exercise or protect legal rights or defend against legal claims;
(b) We sometimes contract with other companies and individuals to perform functions or services on our behalf, such as software maintenance, data hosting, sending email messages, etc. We necessarily have to share your PII with such third parties as may be required to perform their functions;
(c) In some cases, we may choose to buy or sell assets. In these business transfers, customer information, including PII, is typically one of the business assets that are transferred. Moreover, if all or substantially all of our business assets were acquired, or in the unlikely event that we go out of business or enter into bankruptcy, customer information (including your PII), would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any assets may continue to be used according to your PII as set forth in this Policy;
(d) We may reserve and have the right to disclose any information about you or your use of our Service without your prior permission, if we in good faith believe that such action is necessary to: (i) protect and defend the rights, property or safety of our company or its affiliates and other users of the Services, or the public; or (ii) to enforce this Policy.
4. HOW WE USE AND SHARE USAGE INFORMATION
We use the Usage Information for the following purposes: (i) to monitor the effectiveness of our Service; (ii) to monitor aggregate metrics such as use and demographic patterns; and (iii) to diagnose or fix technology problems reported by our Users or our employees; (iv) to provide usage trends reports (“Trends”) to support recommendation and statistics to our Users. The Trends will never use PII or nicknames and/or mobile line numbers, and will only be based on general information such as gender, age and geo-location combined through our algorithms with Usage Information.
Also, we reserve the right to use the Usage Information to: (i) create, publish and sell any kind of public or private reports and other informational content that we believe can be interesting for our company; (ii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Services; or (iii) for any other business or marketing purposes decided by us.
5. HOW WE PROTECT YOUR INFORMATION
We take the security of your PII seriously and use appropriate technical and organizational measures to protect your personal information against unauthorized or unlawful processing and against accidental loss, destruction or damage. We also limit access to PII to employees who reasonably need access to it to provide products or services to you, or in order to do their jobs. However, because no security system can be 100% effective, we cannot completely guarantee the security of any information we may have collected from or about you. Our Site, and our Services are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to or accessed within the United States. By providing us with any information through our Site, or our Services, you consent to this transfer.
6. HOW LONG WE KEEP INFORMATION
We retain PII for as long as your account is active, or otherwise as long as necessary to fulfill a business purpose or comply with a legal request. We may also choose to anonymize certain of the information you provide to us so that it can no longer be attributed to you if we would like to retain it for longer periods of time. We retain the Usage Information for how long we believe it can be necessary or relevant for our company.
7. YOUR CHOICES ABOUT YOUR INFORMATION
You may decline to provide PII, in which case we will not be able to establish your account or provide our Services to you. You may modify your account information, update or amend your personal information, or change your password at any time by logging in to your account.
8. CHILDREN UNDER 13
Our Services are not intended to be managed by individuals under the age of 13. If we become aware that person managing our Services and submitting information is under 13, we will delete the information as soon as possible. According to our Terms of Service, all users that manage our Services represent that they are at least 18. Please note, that if your child indicates that he/she is not under the age of 13, your child WILL NOT be blocked from using our Services.