Last Updated: August 29, 2016
Our Services enable educational institutions (“Schools”) to make better use of their chosen cloud platform — Google Apps for Education or Microsoft Office 365. Our Website serves as a channel for us to share information about our Services with current and potential Customers.
- What Information We Collect; the Purpose of Collection and Use
- Onward Transfer to Third Parties
- Disclosure to Public Authorities, Other Third Parties
- Student-Generated Content
- Opt-Out for Direct Marketing
- Access to Personal Information
- Retention of Personal Information
- How we protect your Information
- Links to External Websites
- Important Notice to All Non-US Residents
- Important Notice For Residents of the European Economic Area
- US-Swiss Safe Harbor Framework
- How to Learn More
What Information We Collect; the Purpose of Collection and Use
We collect the following categories of information. Our Customers authorize the collection, processing and transfer of such Information, and assume contractual responsibility for providing notification to parents and guardians of students and obtaining all consents as required under applicable laws and regulations.
Contact Information: We collect contact information on our Website from visitors who wish to purchase our Services or seek support. All contact information is provided voluntarily via website forms. Contact information means: first name, last name, e-mail address, job title, name of the organization, country, and state/region. Contact information is used by our sales, support and product teams to contact visitors for the purpose of providing the requested information or support.
Service Information: in the course of performing our Services for Schools (“Customers”), we collect three categories of information (collectively, “Service Information”).
Student information: We ask School officials to provide the following Student Information: a student identifier in the cloud platform(s) used by the School (most commonly the student’s School-assigned email address), the student’s roster (i.e. the list of classes the student is enrolled in, and an identifier for the School they are attending); and, for educational institutions that elect to have our Services handle the setup of student accounts, we also collect the student’s first and last name for each such account. Student Information is used to provide our Services and support. As part of support and troubleshooting activities, select Hapara employees may directly access Student Information which resides on the School’s cloud platform. We track the total number of student accounts processed for billing purposes.
Student Information is retained by Hapara only for the period of time required to load the information into the cloud platform of the educational institution, our App, and in some instances, to accommodate support / troubleshooting activities. We do not sell Student Information, and is retained only for as long as necessary to provide the Hapara Services.
Student Generated Information: Students that use our Services through our Customers create significant amounts of content such as emails, documents, sites, and blog posts that is retained in the School’s cloud platform. Student Generated Content and content metadata (for example document titles, creation dates) held in the School’s cloud platform is essential for providing the Services, and we access and process it only for that purpose. We do not collect or maintain copies of the Student Generated Content held in the School’s cloud platform.
Some of our Services allow students that use our Services through our Customers to create content outside of the School’s cloud platform. Content creation requires a validated login with the School’s cloud platform, and all interactions with such content are protected with SSL encryption. This Student Generated Content is held in Hapara systems and associated with the Customer, the class, and the student identifiers. We do not make such content publically accessible, and use it only to provide the required Services. This Student Generated Content is retained by Hapara only for as long as necessary to provide the associated Services (for example display the workspace the student created).
For more information on Google Analytics, including how to opt out from certain data collection, please visit https://www.google.com/analytics. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Website or the Services.
Operational Information: We also collect service health diagnostics, and technical logging information.
Referral Source: We may identify and record the referring source (other Internet location) that directed a visitor to our Website. We collect the referring Website address from the HTTP “referrer header” provided by your browser. We use this information to better serve our current and potential clients, measure our marketing services and to identify where we might find future Customers.
Onward Transfer to Third Parties
Opt-In to Certain Onward Transfers:
We will not transfer your personal information to a third party controller without first providing you with information regarding the identity of such controller or the nature of such controller’s business, and obtaining your opt-in consent.
We will not transfer your sensitive personal information to any third party agent or controller without first (i) providing you with information regarding the category of agents and the purpose of such transfer, or, as applicable, the identity of such controller or the nature of such controller’s business, and (ii) obtaining your opt-in consent.
In each instance, please allow us a reasonable time to process your response.
Disclosure to Public Authorities, Other Third Parties
We are required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
We also may disclose your information when we have reason to believe someone is intending to or is causing harm to other users, or anyone else that could be harmed by such activities, or our rights or property.
Opt-Out for Direct Marketing
You may opt out at any time from the use of your personal information for direct marketing purposes by sending a request at Privacy@Hapara.com. Please allow us a reasonable time to process your request.
Access to Personal Information
Retention of Personal Information
How we protect your Information
Links to External Websites
Important Notice to All Non-US Residents
Our servers are located in the US. If you are located outside of the US, please be aware that any information provided to us, including personal information, will be transferred from your country of origin to the US. Except in the case of data transfers under the EU-US Privacy Shield and the U.S.-Swiss Safe Harbor Framework, your decision to provide such data to us, or allow us to collect such data it through our Website or the Services, constitutes your consent to this data transfer.
Important Notice For Residents of the European Economic Area
Hapara is subject to the investigatory and enforcement powers of the Federal Trade Commission.
US-Swiss Safe Harbor Framework
Hapara has further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.
How to Learn More