Last revised: August 1, 2019

You should read the ClassTag Privacy Policy in full; below are links to specific portions of this Privacy Policy.

HOW TO CONTACT US

INFORMATION WE COLLECT AND HOW WE COLLECT IT

HOW WE CAN USE INFORMATION

HOW WE CAN DISCLOSE INFORMATION

WHERE WE STORE INFORMATION

COOKIES AND OTHER TECHNOLOGIES; DO NOT TRACK

CHOICES REGARDING INFORMATION

SECURITY

CHILDREN

LINKS TO OTHER WEBSITES AND MOBILE APPLICATIONS

CHANGES TO THIS PRIVACY POLICY

For California Users (as related to California Education Code Section 49073.1):

ClassTag Inc. (“ClassTag”, “we” or “us”) owns and operates the classtag.com website and any ClassTag mobile application (collectively, the “Service”) and this Privacy Policy describes the information we collect, how we use and protect it and the choices you can make about your information. Throughout this Privacy Policy, “information” includes personal information about you (for example, teacher, parent, legal guardian or caregiver).

Please read this Privacy Policy and the Terms of Service (the “Terms”) carefully. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY OR THE TERMS, DO NOT USE OR VISIT THE SERVICE. BY USING OR VISITING THE SERVICE, YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY AND THE TERMS.

Please contact ClassTag with any inquiry regarding this Privacy Policy as follows:

We may collect the following types of information in the manner described below.

1. We collect information from and about you and any other individual when you visit or use with the Service.

Following are examples of ways in which you can visit or use the Service:
• To provide contact information for you and/or a third party (for example, first name and last name, postal address, email address and telephone number and related preferences), information for transactions with us (for example, password, information you provide from a third party social networking service account, language preference, school name, school postal address, district name, classroom role (for example, teacher, parent, legal guardian or caregiver), photographs, videos, audio files, documents or drawings) through the Service; and

• Information when you contact or otherwise interact with us (for example, messages and comments) or a third party.

• If you register for an account by logging in using your social networking service account, the information we get from such account depends on your settings and the privacy policy of the social networking service platform, so please check such policy to understand the privacy practices of such platform.

2. We can automatically collect other information about you regarding your access to and use of the Service, including from the device which is used and based on Service usage:
• An identifier that is unique to the device on which you install the Service and some device identifiers may be persistent device identifiers, as well as certain software and hardware information about your device;
• Operating system;
• Browser details;
• Mobile network information;
• The model and serial number of your mobile device;
• The referring service, including referring URLs;
• Your Internet Protocol (IP) address;
• Domain name of your Internet service provider;
• Your geographic location;
• The Service areas that you visit and the date and time of your visits (for example, time spent on the Service, clicks, click paths, access time, active/engagement time and page views); and
• Information regarding your access to and use of the Service.

3. We can receive information from or about you through other individuals or third parties, including third party service providers and/or third party social networking services, which information can be used as described in this Privacy Policy.

4. We can collect information about you from:
• Third party social networking services;
• Publicly accessible sources; and
• Our third party service providers and other partners.

5. We can link any of the information we collect from or about you and use it in the manner described in this Privacy Policy.

We can use the information that we collect for the following purposes, subject to applicable law, including:

• To identify you as a user of the Service and to call you via telephone and send you electronic communications on our behalf or on behalf of other users using your first name and last name, email address and telephone number;
• To display media files on the Service and to share media files through thumbnails in messages;
• To use browser details by our servers and by customer service;
• To help identify the device you are using the unique device identifier;
• Using referring URLs to provide you the appropriate page when you visit;
• Using IP address to provide information for the operation of our servers and for determining your geographic location;
• To determine your access time and time spent on the Service;
• Using clicks to identify activity for our advertisers and to improve the Service;
• Using click paths and active/engagement time to understand how users access our products and deliver better services;
• Using page views to identify information you have already viewed and to calculate engagement statistics;
• Using language preference to provide translations in the correct language;
• Using school name and district name to help organize classrooms;
• Using school postal address to send ClassTag Rewards;
• The purposes for which you provided it;
• To provide the Service to you, including any notifications or updates relating to the Service;
• To create, use or make changes (for example, corrections, updates, or deletions) to, and using your password validate the authenticity of ownership of, your registered account with us;
• To respond to your inquiries and comments (for example, regarding support or other requests);
• To send you information about your relationship or transactions with us;
• To notify you about changes to the Service, our policies, terms or any products or services we offer or provide though it;
• To improve the Service or to develop new products and services;
• To allow you to participate in surveys;
• To contact you with information, including marketing and advertising information about us or a third party, that we believe will be of interest to you;
• To customize our marketing and advertising;
• For testing, research, analysis, product and service development that we or a third party can perform regarding the Service (for example, user base preferences and Service usage);
• To create anonymous data or de-identified information, which we or a third party can do and which we or a third party can use for any purpose;
• To aggregate information, which we or a third party can compile, and which we or a third party can do and can use for any purpose;
• To analyze how you use the Service and to analyze the Service, which we or a third party can do;
• To allow us to personalize and enhance your experience using the Service;
• To allow you to participate in interactive features on the Service;
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
• To investigate, and deter against fraudulent, unauthorized, or illegal activity and otherwise protect our users and our business;
• To administer and troubleshoot the Service;
• From time to time, we may specifically describe a particular use of your information at which time you will have the opportunity to accept or decline such usage (e.g., enrollment in a sweepstakes); and
• As otherwise stated in this Privacy Policy and the Terms.

Information can be disclosed to third parties in accordance with this Privacy Policy, subject to applicable law. Please note that a user can choose not to share certain information. Please see Choices Regarding Information below.

1. Third Parties and Service Providers. We can use third parties or service providers to perform functions in connection with the Service. We can use third parties or service providers to perform any of the actions or activities allowed under this Privacy Policy. We can share information about you with them in accordance with our instructions, this Privacy Policy and any other appropriate confidentiality, security or other requirements that we deem appropriate. These third parties and service providers (collectively, the “Third Parties and Service Providers”) will have access to the information they need to perform functions in connection with the Service. A list of the Third Parties and Service Providers, including links to their respective privacy policies, is available [incorporate by link; list is at the end of this document]. This list may change over time, and we will make efforts to keep it up-to-date.

2. Business Changes. If we become involved in a merger, acquisition, sale of assets, divestiture, joint venture, securities offering, financing, bankruptcy, reorganization, liquidation, dissolution, or other transaction or if the ownership of all or substantially all of our business otherwise changes, we can share or transfer your information to a third party or parties in connection therewith and it can be used subsequently by such third party or parties.

3. Investigations and Law. Regardless of any choices you make regarding your information (as described below) and to the extent permitted by applicable law, we can disclose information about you to third parties to:
• Enforce or apply the Terms and other agreements;
• Comply with law, in response to subpoenas, warrants, or court orders, or in connection with any legal process or cooperate with government or law enforcement agencies or officials or private parties, including laws outside of your country of residence;
• Protect our rights, reputation, safety and property or in an emergency, or that of our users or others;
• To resolve disputes;
• Protect against legal liability;
• Establish or exercise our rights to defend against legal claims; or
• To investigate, prevent or take action regarding suspected illegal activities, suspected fraud, the rights, reputation, safety or property of us, users or others, violation of the Terms, our policies or agreements or as otherwise required by law.

4. Service Analysis. We or a third party can analyze how you use the Service and can analyze the Service.

5. Aggregated or De-Identified Information. We can share aggregated or de-identified information relating to visitors to and users of the Service with any third party for any purpose.

6.  With Your Consent. We can share your information other than as described in this Privacy Policy if we notify you and you consent to the sharing thereof.

7.  At Your Request. We can share your information with any other individual or third party or service provider at your request.

8.  For Any Other Purpose Disclosed by Us. For any other purpose we describe to you at the time you provide your information.

9.  Cookies and Other Technologies; Do Not Track. Please see Cookies and Other Technologies; Do Not Track below.

We store the information that we collect on systems that we utilize. If you are located outside of the United States, please note that the Service is hosted on our systems in the United States. Therefore, your information can be processed and stored in the United States. As a result, United States federal and state governments, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your information through laws applicable in the United States. By using the Service, you understand that your information can be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.

We, along with third parties, use cookies, Web beacons, application analytics software, persistent device identifiers and other technologies. These technologies are used for tracking, advertising, analytics and personalization and optimization of the Service.

1. Cookies. Cookies are small text files that are stored on your computer.

• Persistent cookies remain on the visitor’s or user’s computer after the browser has been closed.

• Session cookies exist only during your online session and disappear from your computer when you close the browser software. You can instruct your browser to stop accepting cookies. But if you do not accept cookies, you may not be able to use all portions or all functionality of the Service.

For example, social media cookies are used to enable you to share pages and content you find interesting on the Service through third party social networking services and other websites. In addition, we may use cookies to promote the Service to you when you visit other websites or mobile applications.

2. Web Beacons. Web beacons or tags (small images embedded into websites or emails that send information about your computer when you visit the Service, or open an email we send to you).

3. Persistent Device Identifiers. Persistent device identifiers are unique strings that are associated with the mobile device that you use to connect to the Service. Persistent device identifiers can be modified or disabled by sophisticated users.

4. Third parties may collect personally identifiable information about an individual user’s online activities over time and across different Internet services when a user uses the Service.

5. Below are links to resources for regarding different types of online tracking and advertising:

• For Google Analytics, please see https://policies.google.com/privacy, https://policies.google.com/technologies/partner-sites, https://www.google.com/analytics/terms/ and https://tools.google.com/dlpage/gaoptout.

• We also use Google conversion tracking and/or similar services to help us understand your and other users’ use of the Service; please see https://support.google.com/adwords/answer/1722022?hl=en for more information about conversion tracking provided by Google.

6. Do Not Track. At this time, we do not respond to “Do Not Track” signals sent from Web browsers or other mechanisms that provide users the ability to exercise choice regarding the collection of personally identifiable information about a user’s online activities over time and across third party Internet services.

7. Advertising. To generate revenue for the Service, ClassTag provides targeted and contextual advertising from third parties. Depending on the information from or about you that we collect (for example, school postal address or IP address) and/or your settings, the advertising may be targeted or contextual.

You may opt out from targeted advertising by going to your account settings and making sure to uncheck the “Use my personal info” checkbox. After this is done, a user will continue to see contextual ads, which are ads shown to you based on the context of the specific Service you are visiting. For example, you still may see an ad appropriate for a specific grade level based on your viewing of a classroom at such grade level. You should also know that we may still collect information from your computer or device and use it for other purposes like evaluating how the Service works, for consumer research or detecting fraud.

A teacher may opt out from all advertising, targeted and contextual, in the teacher’s classroom that such teacher has enrolled in ClassTag Rewards, by going to such teacher’s classroom settings and making sure to uncheck the “Participate in ClassTag Rewards” checkbox.

We will not use any personal information in a student’s records in the Service to engage in targeted advertising.

You have choices regarding your information on the Service.

1. Changing Your Information. You can make changes to your information, including accessing, correcting or updating your information, through your registered account or by emailing us at support@classtag.com. A school may request (or a parent, legal guardian, caregiver or teacher may request that the applicable school make a request) to review, to have corrected or updated or to cease further use or collection of content or information relating to a student by contacting us via live chat during regular business hours on the Service or via email at support@classtag.com. A parent or legal guardian can remove a student from the Service and this will result in no further collection or use of content or information from such student.

2. Deleting or De-identifying Your Information. You can delete your information through your registered account or by emailing us at support@classtag.com. A school may request (or a parent, legal guardian, caregiver or teacher may request that the applicable school make a request) to have deleted or de-identified content or information relating to a student by contacting us via live chat during regular business hours on the Service or via email at support@classtag.com. We will retain such content or information that is deleted or de-identified for as long as reasonably necessary for the purposes described in this Privacy Policy or the Terms, while we have a business need to do so in connection with your registered account or as required by law (for example, for legal, tax, accounting or other purposes), whichever is the longer.

3. Email Communications. You can make changes regarding receiving email communications from us through your registered account.

4. Push Notifications. You can at any time request opt out from further allowing us to send you push notifications by adjusting the permissions in your mobile device.

5. Text Message Communications.
By providing your mobile phone number to us, you expressly consent to receive transactional text messages from us on your mobile phone number.

Any transactional text messages delivered to your mobile phone or device may cause you to incur extra data, text messaging, or other charges from your wireless carrier. MESSAGE AND DATA RATES MAY APPLY. You are solely responsible for any carrier charges incurred as a result of phone and/or text communications from ClassTag.

You can make changes regarding receiving text message communications from us through your registered account.

6.  Withdrawing Consent. You can withdraw your consent to our processing of your personal information at any time by emailing us at support@classtag.com.

7.  Cookies and Other Technologies; Do Not Track. Please see Cookies and Other Technologies; Do Not Track above.

8.  Social Networking. If you choose to access or make use of third party social networking services, we may receive personal information about you that you have made available to those services. Some third party social networking services also will facilitate your registration or log-in for the Service or enhance or personalize your experience on the Service.Your decision to use a third party social networking service will always be voluntary. You should make sure you are comfortable with the information that a third party social networking service can make available to us by carefully reviewing the service’s privacy policy and terms and conditions and by modifying your privacy settings directly on that service.

Although we use administrative, technical and physical measures to help protect the information you submit via the Service from loss, misuse, and unauthorized access, disclosure, alternation, and destruction (including use of authentication technologies and encryption where appropriate), we cannot guarantee its absolute security.

No Internet or electronic communication transmission is ever fully secure or error free. Internet or electronic communications, including those sent through the Service, may not be secure. You should use caution whenever submitting information through the Service and take special care in deciding which information you provide us with. We encourage you to take steps to help protect the confidentiality and security of your registered account and your information, including by doing the following:

• Reviewing your registered account periodically and immediately reporting any unexpected activity or unrecognized information;

• Installing the latest security updates and anti-virus software on your computer or device to help prevent malware and viruses;

• Password protecting your computer or device;

• Using complex passwords, not using the same password on more than one website or mobile application and not sharing your password with others; and

• Signing out or logging off of website or mobile application sessions so that your session is closed, especially when using a public computer or device.

We are not responsible for any lost, stolen or compromised passwords or for any activity on your registered account via unauthorized password activity. You are responsible for maintaining the security of any computer or device on which you use the Service.

 If we learn of a security breach that poses a serious risk of harm, we will attempt to notify you (subject to any applicable laws) so that you can take appropriate protective steps; for example, we may post a notice on the Service, and may send email to you at the email address you have provided to us.

We do not knowingly collect personal information from individuals under age 18. If you are under the age of 18, please do not access, use, or submit any personal information through the Service. If you have reason to believe that we may have accidentally received personal information from an individual under age 18, please email us immediately at support@classtag.com.

This Privacy Policy applies only to the Service. The Service may contain links to other websites or mobile applications to which this Privacy Policy does not apply, including third party social networking services. The links from the Service do not imply that we endorse or have reviewed such websites or mobile applications. The policies and procedures we describe here do not apply to such websites or mobile applications. We neither can control nor are responsible for the privacy practices or content of such websites or mobile applications. We suggest reviewing the privacy policies of such websites or mobile applications.

We reserve the right to update or modify this Privacy Policy at any time and from time to time. We will notify users via the classtag.com website or the ClassTag mobile application and/or via email (as practicable) in advance of material changes to this Privacy Policy. Please review this Privacy Policy periodically, and especially before you provide any information. This Privacy Policy was made effective on the date indicated above.

Last revised: July 4, 2019

Below is a list of Third Parties and Service Providers, including links to their respective privacy policies. This list may change over time and we will make efforts to keep it up-to-date.

Airbrake for error monitoring
Info shared: Event and user data associated with errors on the Service

Amazon for network infrastructure, photo and video encoding, data storage
Info shared: Media files

EPOM for serving contextual and targeted advertising from ClassTag, depending on your settings and/or information from or about you that we collect (geographic location, for example, through school postal address and/or IP address)

Info shared: user identifier and persistent device identifier, classroom grade, classroom location, user role (parent or teacher) and approximate school zip code

Google – Google Analytics for Service analytics, Google Cloud for language translations, Google G Suite for internal data storage, Google Marketing Platform for managing javascript on the Service
Info shared: Service usage and IP address for Google Analytics and Google Marketing Platform, User-generated content for Google Cloud, Internal emails, files, documents, etc. for Google G Suite,

Heroku/Salesforce for servers, databases
Info shared: User information, aggregated information

HubSpot for sending emails on our behalf
Info shared: User information and user activity

Intercom for managing customer service contacts, emails
Info shared: User information, user activity, contact activity, marketing content

mLab/MongoDB for data storage
Info shared: User information, visit logs

OneSignal for sending push notifications on our behalf
Info shared: Hashed user identifiers, user-generated content

Papertrail for Service logging and fixing errors
Info shared: IP address, browser information

Plivo for sending text messages on our behalf
Info shared: telephone number, user-generated content

Redis Labs for data storage
Info shared: user information, events

SendGrid/Twilio for sending emails on our behalf
Info shared: Email address, user information, user-generated content