Privacy Policy

PRIVACY POLICY

Hapara, Inc.

Last Updated: August 29, 2016

Hapara, Inc. (“Hapara”, “we,” “us,” “our”) provides this Privacy Policy because we know that you care about how your information is collected, used, shared and retained. This privacy policy applies only to information collected when you access our website located at https://hapara.com/ (“Website,” “site”), or use our services which may be accessed via the Website, the Hapara App, Hapara Dashboard, Hapara Workspace, Hapara Highlights and Hapara Analytics (“Services”). By visiting the Website or using the Services, you consent to this Privacy Policy.

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.

This privacy policy covers:

  • 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
  • Children
  • 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
  • Changes to this Privacy Policy
  • 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”).

School Information:  We ask School officials to provide the following information about their Schools: billing and IT contacts, time zone, and system configuration information; education information such as the name of classes, class codes and subjects taught; and Student Information (see below). School Information is only used in to provide Services and support in a manner consistent with this privacy policy; to improve our Services; and to provide our Customers with additional information about our Services.

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).    


Other Information
:

Google Analytics: Like most organizations, we rely on automatic data collection technology (Google Analytics) when you visit our Website or use the Services. We may collect information such as your IP address, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Website you visit, number of links you click while on the Website, search terms, and other data. This information is collected automatically and anonymized by Google Analytics. By accessing and using the Website and/or the Services, you consent to the processing of data about you by Google Analytics in the manner and for the purposes set out in this privacy policy.

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.

Cookies: We also use cookies to compile aggregate data about our Website’s traffic so that we can improve our Website in the future https://hapara.com/cookies-policy/. Cookies are small text files that help us to personalize the content of our Website. If you prefer, you can choose to turn off all cookies via your browser settings. However, if you turn your cookies off, some features of our Website may not function properly. We do not behaviorally target advertising.


Onward Transfer to Third Parties

Like many businesses, we hire other companies to perform certain business-related services. We may disclose personal information to certain types of third party companies but only to the extent needed to enable them to provide such services. The types of companies that may receive personal information and their functions are: mail services (hard copy and email); hosting services; database management/back-up services; real-time messaging services; monitoring services; and payment processors.  If Student Information is required, we encrypt it prior to transfer whenever possible. All such third parties function as our agents, performing services at our instruction and on our behalf pursuant to contracts which require they provide at least the same level of privacy protection as is required by this privacy policy and implemented by Hapara.  You may opt out of having your personal information transferred to any or all of our categories of agents by sending an Opt Out request to Privacy@Hapara.com. Please allow us a reasonable time to process your request.


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.

Business Transfers:  In the event of a merger, dissolution or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this privacy policy.


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

Hapara acknowledges the right of individuals to access their personal information. Upon request to privacy@hapara.com, we will provide you with confirmation as to whether we are processing your personal information, and have the data communicated to you within a reasonable time. You have the right to correct, amend or delete your personal information where it is inaccurate or has been processed in violation of this privacy policy. We may require payment of a non-excessive fee to defray our expenses in this regard. If you are a parent or guardian and wish to delete your child’s records from our database, please contact the appropriate School official and ask them to carry out this action in collaboration with our team. Please allow us a reasonable time to respond to your inquiries and requests.


Retention of Personal Information

We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this privacy policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this privacy policy. After such time periods have expired, we may either delete your personal information or retain it in a form such that it does not identify you personally.


How we protect your Information

Hapara takes very seriously the security and privacy of the personal information that it collects pursuant to this privacy policy. Accordingly, we will implement reasonable and appropriate security measures to protect such personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in processing and the nature of such data, and comply with applicable laws and regulations.  Access to such personal information is limited to those of our employees who require it to perform their job functions. We also use two-factor authentication, SSL (Secure Socket Layer) encryption, physical access controls to files and buildings, and other industry-standard best practices. School Information is transferred to Hapara servers through a secure Web site, or secure file transfer protocol based on industry-standard encryption technology, permissions granted to the Hapara Marketplace app or via Customer’s Cloud platform infrastructure. We have also committed to comply with the Student Privacy Pledge (coordinated by FutureofPrivacy.org).


Children

We ask School officials to provide the Student Information. We do not knowingly collect any personal information directly from children under the age of thirteen through the Website and the Services.  If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our privacy policy by instructing their children never to provide personal information to us without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us at privacy@hapara.com, and we will endeavor to delete that information from our databases.


Links to External Websites

The Website may contain links to third party websites (“External Sites”). Hapara has no control over the privacy practices of these External Sites. As such, we are not responsible for the privacy policies of those External Sites. You should check the applicable third party privacy policy and terms of use when visiting any External Sites, and before providing any personal information to such External Sites.


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 complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from the European Union member countries (including Iceland, Liechtenstein and Norway). Hapara has certified that it adheres to the Privacy Shield principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability (the “Privacy Shield Principles”). If there is a conflict between this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. With regard to the Principle of Accountability for Onward Transfer, for example, we remain liable if our agent processes such personal information in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

Hapara is subject to the investigatory and enforcement powers of the Federal Trade Commission.

In compliance with the EU-US Privacy Shield Principles, Hapara commits to resolve complaints about your privacy and our collection or use of your personal information.  EU individuals with inquiries or complaints regarding this privacy policy should first contact Hapara at privacy@hapara.com. Hapara has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and 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 by Hapara, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. If these processes do not result in a resolution, you may also contact your local data protection authority, the US Department of Commerce, and/or the Federal Trade Commission for assistance. If your complaint still remains unresolved, then you have the right to invoke binding arbitration by the Privacy Shield Panel upon written notice to Hapara at privacy@hapara.com.


US-Swiss Safe Harbor Framework

Hapara complies with the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from Switzerland. Hapara has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement. If there is any conflict between the policies in this Privacy Policy and the Safe Harbor Privacy Principles, the Safe Harbor Privacy Principles shall govern.  To learn more about the US-Swiss Safe Harbor and to view our certification page, please visit http://www.export.gov/safeharbor/

In compliance with the US-Swiss Safe Harbor Principles, Hapara commits to resolve complaints about your privacy and our collection or use of your personal information.  Swiss citizens with inquiries or complaints regarding this Privacy Policy should first contact Hapara at privacy@hapara.com.

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.


Changes to this Privacy Policy

We may change this privacy policy from time to time. When material changes are made to this privacy policy, Customers will be notified through the contact email given to us at least two weeks prior to modification taking effect.  In that time, the primary administrative contact for a Customer may request that we delete the Service Information from our systems if it does not wish to be bound by the new policy. Please allow us a reasonable time to comply with your request.


How to Learn More

Hapara’s principal headquarters are located at 425 Broadway St. Redwood City, California. We can be reached by telephone at 650 847-1371. To learn more about our privacy policy, you can email us at privacy@hapara.com.