document: title: schoolwires privacy policy (updated)
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This Privacy Policy applies both to personal information collected on web sites provided and hosted by Schoolwires for your school, school district or other organization (the “school”), and also to personal information which may be collected when individuals visit the Schoolwires corporate web site. Many of the provisions of this Policy apply equally to the personal information collected on Schoolwires-hosted sites as well as on the corporate web site, while other provisions are more specific to our practices regarding the collection, use and sharing of personal information when Schoolwires is serving in a particular role.

When hosting a web site for the school, Schoolwires, Inc. is proud to power your Internet site. We are dedicated to providing easy-to-use, powerful and affordable Internet sites. When visiting our corporate web site, we are proud of the leading role we play in providing community-based website solutions to the k-12 education market and encourage you to learn more about the valuable solutions that we offer.

At Schoolwires, we are equally committed to protecting your privacy. This Policy was developed to give you a full understanding of terms and conditions relating to information collected by Schoolwires as the provider of the school's web site and in connection with your visit to our corporate web site.

For web sites powered and hosted by Schoolwires, this Privacy Policy pertains only to the personal information that Schoolwires collects from you or that is provided to us by the school. Personal information, also referred to at times as personally identifiable information, is information that identifies a particular individual, such as a person’s first and last name, postal address, e-mail address and phone number.

In connection with the school’s Schoolwires-hosted site, this Privacy Policy applies only to Schoolwires’ own practices regarding personal information which is collected on the ASP-Delivered site hosted by Schoolwires and NOT to sites hosted by the school or a Third-Party Hosting Facility. Schoolwires has been retained by the school to provide and host the website and community management platform on which the school has added customized content to build its website. The school administers and oversees the website and, accordingly, has control over who can register for use of various features of the site and who can access the personal information posted or maintained on the site. The school can also add content and information directly onto the site. The school may have its own policies addressing collection, use and sharing of personal information. For information about whether this Privacy Statement applies to you and about the school's own policy, please contact the school’s webmaster.

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In connection with our policies and practices when collecting personal information in the course of hosting a school’s website, Schoolwires, Inc. has been awarded TRUSTe’s Children's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirements including transparency, accountability and choice regarding the collection and use of your personal information. The TRUSTe program does not cover information that may be collected through downloadable software. TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trust mark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at privacy@schoolwires.com. If you are not satisfied with our response you can contact TRUSTe here.

With respect to Schoolwires’ policies and practices, this Web site complies with the TRUSTe Children's Privacy Seal, which has been approved by the Federal Trade Commission as an authorized safe harbor under the Children's Online Privacy Protection Rule. When you and your child visit a Web site displaying the TRUSTe trust mark, you can expect to be notified of:

    1. What Personal Information the Web site seeks to collect from your child;
    2. The organization(s) collecting the information;
    3. How the information is used;
    4. With whom the information may be shared;

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Schoolwires is dedicated to the privacy of children under 13 years of age. We do not collect or entice (by use of contests, games, prizes, or other enticements) from children more information than is needed to access services. Before Schoolwires collects personal information from children under 13, the school must first obtain a signed parental consent form. We will not share any personal information about children with any third parties other than as specified in this Policy.

As a parent or legal guardian for children under 13, you may review your child's personal information. After your child's parental consent form is submitted, an individual at the school will supply you with your child's Sign-In and Password so that you may access and review the types of personal information collected from your child. If you would like to refuse to allow any further collection or use of your child's information, please contact the school’s webmaster. You may also raise questions or concerns with Schoolwires via the Contact Information provided below.

Schoolwires is also dedicated to maintain the privacy of all students, whether under 13 or older, in accordance with applicable laws. In this regard, Schoolwires will maintain any and all personally identifiable information in education records which come into the possession of Schoolwires in accordance with the requirements of the Family Educational Rights and Privacy Act (“FERPA”), and will not disclose such information to third parties except with the consent of a parent, the school or an eligible student (as applicable), unless otherwise permitted under FERPA and its associated regulations. One instance in which personally identifiable information in education records may be disclosed to third parties under FERPA is if the information is classified as “directory information” by your educational institution. Please check with the school’s webmaster if you have any questions as to which information they have classified in this manner.

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Modifications to Personal Information

There are three ways your personal information can be potentially modified, depending on your role:

1\. For users of a site hosted by Schoolwires for your school, as well as users of our corporate website, if your personally identifiable information changes (such as ZIP code, phone, email or postal address), or if you no longer desire full access to Schoolwires services, you may update or delete your personally identifiable information. This can be done by Signing In and clicking on the Access My Info button at the top of the school's page.

2\. For Schoolwires-hosted websites for schools, Site and Subsite Directors have access and the ability to update personal information. These Editors only have access to their school's user information. For children under 13 years of age, the school is responsible for first validating receipt of the parental consent form.

3\. For Schoolwires-hosted websites for schools, Schoolwires may gather information from Site Directors in the school which would allow Schoolwires to conduct a mass user import to update user information. For children under 13 years of age, the school is responsible for first validating receipt of the parental consent form. 

Links

The school's site, and/or our corporate website, may contain links to other sites. Schoolwires is not responsible for the privacy practices of other such sites. Schoolwires privacy statement applies solely to information collected by Schoolwires.

Surveys and Feedback Forms

From time to time, our site may request information from you through surveys or feedback forms. Participation in these surveys or feedback forms is voluntary. If personal information is requested, Schoolwires will fully disclose this to you prior to submission. Information collected is used for the purposes of improving our product and services and understanding our audience and no personal information collected in this manner will be used or disclosed except in compliance with this Policy.

Security

Schoolwires takes security seriously and employs reasonable security measures and procedures designed to protect your information from unauthorized access and improper use. Only employees, trusted contractors supporting the operation of the website and other third party partners and contractors expressly identified in this Policy, who are all bound to protect the information appropriately have access to personally identifiable information.

For Schoolwires-hosted sites, as well as our corporate web site, the servers that store personally identifiable information are maintained in a physical environment that utilizes industry-standard security measures. Personal information is stored in password-controlled servers with limited access. Please be aware though that, despite our diligent efforts and implementation of reasonable security measures, no security measures are perfect or impenetrable and no data transmissions over the Internet can be guaranteed to be 100% secure. If you have any questions about the security of the school's web site, please send a message to security@schoolwires.com.

If the school hosts your site or chose to host with a Third-Party Hosting Facility, the school or the Third-Party Hosting Facility is responsible for ensuring security. In addition, as noted above, the school has the ability to control the collection, use and dissemination of personal information maintained or processed through the website. Contact the school’s webmaster for information regarding its security provisions. 

Schoolwires Privacy Policy Statement Changes

If we change our privacy policy, we will post the revised policy to www.schoolwires.com/policies and other places we deem reasonable and appropriate to keep you informed. When we believe material changes affecting users under 13 years of age are made to this privacy policy in connection with websites we host for schools, Schoolwires will notify the school and request that the school obtain verifiable parental consent to the extent required, and in accordance, with applicable law. With respect to visitors to our corporate website, in the event that we make any material changes in the way we collect, use or share your personal information, we will provide notice of any such material changes by posting a change notification announcement on our corporate website. In all cases in which changes are made to this policy, we will revise the “Effective” date on our privacy policy and encourage you to periodically review this policy (either by visiting our corporate website or, in connection with our hosting of websites for schools, by clicking on the link to our policy which is generally included on your school’s website) to stay informed about how we are collecting, using and sharing personal information. No notice, other than a change to the “Effective” date of this policy, will be provided for any non-material changes to this policy. Material changes will be effective thirty (30) days from when we provide notice to schools or post a notice on our website, as applicable.

Usage Implies Consent

By using sites powered by Schoolwires, Inc., including the Schoolwires corporate website, you consent to this Privacy Statement. If you do not agree to this Privacy Statement, please do not use Schoolwires services. Similarly, with respect to personal information which you provide voluntarily (such as name, address and telephone number in order to register with us), please do not submit such information if you do not want us to collect and maintain it.

Non-Personal Information

In the event that any information we collect is, or later becomes, public information that is not required at the time to be maintained as confidential under applicable laws, or to the extent that any information we collect is neither personal in nature nor otherwise required to be maintained as confidential under applicable laws, then Schoolwires shall have no responsibility hereunder in connection therewith. As an example, Schoolwires may aggregate certain information we maintain with information about other individuals in a manner that does not disclose personal information specific to any individual. As an additional example, Schoolwires may remove characteristics that make the individual personally identifiable, thereby de-personalizing the information. In either of these examples, Schoolwires shall be free to utilize the information in any way and, unless otherwise required by law, shall not be bound the terms of this Policy. As always, Schoolwires will comply with all applicable laws and governing regulations in the collection, use and disclosure of information.

Additional Limitations

Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable. In this regard, we are not responsible for events or conditions beyond our reasonable control to the extent that they relate to or impact the obligations assumed, or commitments made, hereunder. However, in the event of any data breach or other violation of this policy caused by factors outside of our reasonable control, we will comply with all applicable laws in this regard, including those requiring notification in the event of certain defined data breaches.

International Users

As Schoolwires is a U.S.-based company, your personal information will likely be collected and maintained in the United States. If you are visiting from the European Union or other regions with laws governing data collection and use that may be different from U.S. law, then by using this site, you consent to your personal information being collected, used and transferred as set forth in this Privacy Policy.

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You may visit the school's site as a guest without registering. Registration, however, will give you access to certain features as well as the ability to personalize certain features. Schoolwires collects personal information via registration. Registration occurs in two ways:

1\. Self-Registration

If you choose to become a registered guest, on behalf of the school, we will ask for personal information from you through the school's site powered by Schoolwires. After we collect this information from you, it may be verified by an official at the school. So that the registration process is compliant with federal law under the Children's Online Privacy Protection Act (COPPA), you are first asked for your birth date. Birth date information is collected only to validate your age and is not store.

Children under 13 years of age are not allowed to register themselves with the school's Schoolwires site. Before a child under 13 may access features that require registration, the school must first obtain a signed parental consent form. After consent is received by the school, the school is responsible for providing parent access to the child's profile so the parent may, at any time, review, modify, or delete the child's personal information. A parent also has the right to refuse to further collection of the child's information. If you have questions regarding your profile, please contact the school’s webmaster.

If you are over 13 years of age, you are required to supply your First and Last Name, Email Address, Sign-In Name and Password. These fields are labeled to indicate that they are required. The following fields are labeled as optional: Title, Address, City, State, ZIP Code, Phone and Fax. After registration, the Site Director for the school may decide to assign to you a role or roles (viewing privileges). Based upon your designated role(s), you may have access to additional information or services. If you have questions concerning your role(s), please contact the school’s webmaster. 

2\. Pre-Registration

You may be pre-registered by the school in one of two ways. Either way, the school may not share personal information for children under 13 years of age with Schoolwires without first receiving parental consent.

2.1. Your registration information may be shared with Schoolwires via a school-provided list. Schoolwires would use this list to conduct a batch import of information.

2.2. A school-designated individual may input registration information for you. 

Information collected for self-registration or pre-registration may also be used to (1) provide you with important information about the school's site, such as updates or notices, (2) improve our product and services, (3) improve customer service, (4) create a profile for you, and/or (5) in aggregate, guide our internal marketing efforts. No personally identifiable information will be shared with third parties except to the extent expressly described in this Privacy Policy and otherwise in accordance with applicable law.

Additional Information Which You Provide to Us

Additional information may be requested of you in other situations, for example, if you submit a customer support request or a content submission request. In such instances, the goal of collecting additional information is to serve you more effectively and efficiently.

In addition, students, members of the school, and other users of the website may choose to post or download/upload various pieces of content and/or information on or through the use of the site, and may use certain “social media”, collaboration, interaction and other capabilities of the site to exchange various categories of data, materials and information. While we cannot know in advance all types of such information, one example is that teachers or administrators may post blogs, announcements and other information and content directly onto the site. Another example is that students may chat with each other, or send instant messages or e-mail, via technology which may now or in the future be made available over the site and may share information, photographs, images or recordings with each other or with the community. Information such as an individual’s name and e-mail address can also be exchanged or made available in messages, chats and other social media and collaborative communications facilitated over the website. Schoolwires has no practical ability to restrict the information, conduct, communications, or content which might be posted on or exchanged through the use of its technology, nor can Schoolwires ensure prompt removal of any such communications, information or content after transmission or posting. If you or your child provide personal information when using any social interaction, collaboration or messaging capabilities or features of the site (such as chat rooms, blogs, message boards, profile pages, etc.), that personal information may be copied, publicly posted and otherwise disclosed without limitation as to its use by third parties. If you are concerned about any information or content that may be posted, transmitted or accessed on the site, please contact the school’s webmaster.

In connection with the use of “PassKey Manager™” or similar solution, you or the school may provide us with your (or your child’s) login credentials for certain software applications and web services in order to facilitate single sign-on access to these applications and services. These login credentials may include the username, password and any other required information which you selected or were supplied in order to access certain applications and web services.

On behalf of the school, we may also (now or in the future) maintain and/or present academic and other similar information regarding students via technology or software provided by Schoolwires or by third parties who have authorized Schoolwires to distribute and/or present this information.

As noted below, we may also ask you to provide us with survey information to help us improve our products and services.

Information from the school

It is important to understand that the school administers and oversees the website. Generally speaking, sites powered by Schoolwires are used to present and archive information supplied by content contributors designated by the school. Schoolwires does not supply the school-specific content appearing on the school's website. Once posted to the Internet, content supplied by content contributors at the school is public information available via the Internet.

In addition to supplying the content for its site, the school can control which individuals can be registered to use certain of the site’s features and which individuals or groups are granted privileges to access, view or use personal information collected, exchanged or maintained on the site. The school can also access your personal information, and grant rights of access to others, as it deems appropriate. The school may also provide us with the registration information and login credentials described above, as well as with other information about you which it deems appropriate. Please check with the school’s webmaster regarding its policies and/or practices in this regard.

Information Collected through Technology

As noted below, we also collect cookies and web beacons in the course of your use of our technology.

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Profile

We do not associate information that we collect through log files or third parties with your personal profile. The information is provided voluntarily by you when you register for the site. A profile is stored information that gives you access to certain features as well as the ability to personalize certain features. Your profile can be used only by you, Schoolwires and the school.

Cookies and Web Beacons

A cookie is a piece of data stored on your computer tied to information about you. The only personal information a cookie can contain is information you supply. Schoolwires uses session or dynamic cookies to let us know when a user is signed in. Once you close your browser, the cookie simply terminates. We use web beacons (single-pixel gifs) to count visitors.

When a user is signed in and depending on the user's assigned role(s), additional services become available through our menu system. Again, depending on your assigned role(s), cookies may offer the following benefits after Sign-In:

1.A personalized salutation greeting

2.Content tailored to your role(s)

3.Use of services that require Sign-In

4.Session time-out, a security feature

You can disable cookies in your browser's preferences. If you disable cookies in your browser, you may still use the school's site. Services, however, that require Sign-In will not work if cookies are disabled.

Communications from the Site

Service Announcements

From time to time, it may be necessary to send out a strictly service-related announcement. For instance, if our service is temporarily suspended for maintenance, we might send you a notification email. Users cannot opt-out of these communications though they can deactivate their account. (For more information, see the Modifications to Personal Information section.) However, these communications are not promotional in nature.

Data Retention

Once you have deleted your account, your information is permanently removed from our servers. We do not retain your data except as necessary to comply with our legal obligations, resolve disputes and enforce our agreements, all in compliance with applicable laws.

E-Alerts and Subscriptions

E-Alerts and Subscriptions is an optional feature that allows registered users to subscribe to content on a site. If the school purchased the E-Alerts software option, you can use two different kinds of E-Alerts:

1\. Broadcast E-Alerts: These are accessed by Site and Subsite Directors to send an email message to a specific group or multiple groups of users (i.e., users assigned the same viewing permissions [roles]).

2\. Content E-Alerts: These provide for automatic email notification to users whenever significant changes are made to one or more homepages or sections to which they subscribe. Please note that the content editors decide whether to send an E-Alert to subscribers. The email message that users receive contains a link to the actual homepage or section, allowing them immediate and direct access.

Users can remove Content E-Alerts through options in their Account Settings. 

Customer Service

As necessary, Schoolwires may communicate with you via email, phone or online to provide requested services and in regards to account-related issues.

Sharing of Information Collected When Hosting a School’s Website

When Required by Law

Though we make every effort to preserve your privacy, we may need to disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on the school's site.

District and School Editors

Users who have been assigned by the school to editorial positions of Site or Subsite Directors have access to all registered user information strictly and solely on their school's site. Contact the school's webmaster for more information regarding who has been assigned these positions and how this position-assigning process works for the school.

Business Transitions

In the event Schoolwires goes through a business transition, such as a merger, being acquired by another company, or selling a portion of its assets, your personal information will, in most instances, be part of the assets transferred. You will be notified by a prominent notice on our corporate website prior to a change of ownership or control of your personal information. For more information, see the Schoolwires Privacy Policy Statement Changes section.

Service Providers

From time to time, we may retain trusted businesses and contractors to provide certain services which support our provision and hosting of the website or otherwise support the operation of the associated online services. We may also contract with trusted third parties to provide complimentary products or services which may be integrated with, linked to (either via a website link or otherwise) or accessible from (such as through single sign on functionality), the website. These business and contractors who have access to personally identifiable information are required to protect this information in a manner that is consistent with this privacy policy, for example, by not using the information for any purpose other than to carry out the services they are performing for us or to facilitate access to an integrated service offering. We will not disclose your personal information to any third party to the extent prohibited by law.

Compliance with Laws

Schoolwires will, of course, comply with the requirements of COPPA and FERPA to the extent that these laws apply to the information collected and maintained by Schoolwires. Accordingly, notwithstanding anything to the contrary in this Policy, Schoolwires will not collect, use or disclose personal information covered by COPPA and FERPA except in compliance with the respective requirements of each of these statutes and their associated regulations. Please see the discussion above for more details regarding compliance with these laws. Schoolwires will also comply with all other applicable laws which govern the information which it maintains.

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Information We Collect on our Corporate Website

When visiting the Schoolwires corporate site at www.schoolwires.com, personally identifiable information is collected in several ways. In the event that your use of the site requires registration (such as, for example, if we require you to register in order to post certain content or comments), you will be required to provide your first and last name, e-mail address, sign-in name and password and may, at your option, provide your title, address, city, state, zip code, phone and fax. In addition, we may ask for contact information when you correspond with us, request a demonstration, register for a seminar, inquire about special offers or programs, submit other types of requests or suggestions, or participate in various social media features. Depending on the nature of your submission, a Schoolwires representative may contact you to gather or share additional information (such as through the use of a survey).

In addition, users of our website may choose to post or download/upload various pieces of content and/or information on or through the use of the site, and may use certain social media, collaboration, interaction, and other capabilities of the site to exchange various categories of data, materials and information. Please see the applicable (non-school-specific) terms of Paragraph 3 (“Additional Information Which You Provide to Us”) under the section titled “Information We Collect When Hosting the School’s Website” above for additional descriptions of the wide variety of information that may be collected when a user utilizes or is exposed to these sorts of features, including Schoolwires’ inability to know in advance all types of such information or to restrict the postings and the potential that third parties may copy and publicly disclose your information. At a minimum, please recognize that your first and last name and/or your screen name, as well as other information you post or upload/download, may display in association with a comment or user-generated comment.

We also collect cookies and web beacons in the course of your use of our technology.

Our corporate website and its features are not intended for, directed to, or designed for use by anyone under 13 years of age and, in this regard, we do not knowingly request or collect personal information from anyone under the age of 13.

How We Use Information Collected on our Corporate Website

Cookies and web beacons are used in the same manner as described above under the section titled “How We Use Information Obtained When Hosting a School’s Website”.

Based on personal information we collect from you, we may also send you service announcements from the site if, for example, access to the site is temporarily suspended for maintenance or for other reasons related to your use of the site or our programs or services. Users cannot opt out of these communications though the can deactivate their account. We may also use the information we collect from you to respond to your inquiries regarding our offerings, to offer you products, programs or services that we believe may be of interest to you, for marketing purposes, for other internal purposes, to enforce the legal terms that govern your use of our site, to update legal terms or policies, to contact you about your account, to provide requested information or services, and/or for the purposes for which you provided the information.

The information we collect in connection with online forums and communities, and other social collaboration features, is used to provide an interactive experience. We also use this information to facilitate participation in these online communities and, from time to time, to offer you products, programs or services.

If you choose to submit content for publication (such as a posting to a blog or a discussion board, or a video), we may publish your screen name and other information you have provided to us.

Sharing of Information Collected on our Corporate Website

We may disclose your personal information as set forth in the subsections titled “When Required by Law” and “Business Transitions” under the Section titled “Sharing of Information Collected When Hosting a School’s Website” above.

From time to time, we may retain trusted businesses and contractors to provide certain services which support our provision and hosting of the website or otherwise support the operation of the associated online services or the marketing and promotion of our products and services. These business and contractors who have access to personally identifiable information are required to protect this information in a manner that is consistent with this privacy policy, for example, by not using the information for any purpose other than to carry out the services they are performing for us.

We may also disclose your information in order to comply with our legal obligations, resolve disputes and enforce our agreements.

We will, of course, comply with all applicable laws regarding the personal information we collect, use and maintain. By way of example, we will provide you with the opportunity to opt out of electronic promotional communications as and when required under the law.

No personally identifiable information will be shared with third parties except as specifically set forth in this Privacy Policy. Notwithstanding anything to the contrary in this Policy, we will not disclose your personal information to any third party to the extent prohibited by applicable law.

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http://www.schoolwires.com/policiesAt Schoolwires, we take privacy issues very seriously. If you have any questions, suggestions or concerns regarding our privacy policy or the collection of any of your personal information, please contact us. For children's privacy issues, please contact Peggi Munkittrick at 814.272.7229.

Schoolwires, Inc.

ATTN: Privacy Officer

330 Innovation Blvd.  Suite 301

State College, PA 16803

Phone: 814.689.1046

Fax: 814.689.3962

If you have questions or concerns regarding this statement, you should first contact Schoolwires. If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you should then contact the TRUSTe Watchdog Dispute Resolution Program at http://www.truste.org/consumers/watchdog_complaint.php. TRUSTe will then serve as a liaison with the Web site to resolve your concerns.

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