Last Updated: October 30, 2019
Our Services enable educational institutions (“Schools” or “Customers”) to make better use of their chosen Cloud platform — Google’s G Suite 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
We collect information for several purposes, including to provide services our Customers and to communicate with and market to prospective customers. The specific information and the purposes for collection are discussed below.
In the course of performing our Services, we collect several categories of information (collectively, “Service Information”). Our Customers authorize the collection, processing and transfer of Service Information, and have the responsibility for providing notification to parents and guardians of students and for obtaining all consents as required under applicable laws and regulations. Service Information is retained only as long as it’s necessary to provide the Services and support the particular Customer.
School Information: Educational institutions who are Customers provide the following information about their schools: billing and IT contacts, timezone, class rosters – this includes class codes and titles, and teacher school email addresses. We track and collect the total number of student accounts processed for billing purposes.
Student Information: Schools provide student school email addresses for students using Hapara Services. For Customers that elect to have our Services handle the creation of student accounts, we also collect additional student information required by the Cloud Platform to create accounts, such as first and last name and school email address. Customers who use Hapara Analytics may also elect to provide additional student information to support Hapara Analytics equity reporting such as grade, ELL status, FRL status, gender, and other metrics.
Student Information is used to provide our Services and support our customers. As part of support and troubleshooting activities, select Hapara employees may directly access Student Information, including information which resides on the School’s Cloud platform.
Student Information is retained by Hapara only for the period of time required to process the information and to provide the Services to our Customers.
We do not solicit or collect information directly from students or their parents or guardians – student information can only be provided by their educational institution which is our Customer, and which retains the legal responsibility for collecting and sharing this information with service providers and Hapara.
Student Generated Information: Students create significant amounts of content in their school’s Cloud platform – such as emails, documents, sites, or blog posts. This information is controlled by their institutional policies through controls provided by Cloud platforms, and independently of Hapara. Student Generated Content and content metadata (for example document titles, creation dates) held in the School’s Cloud platform are 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 Customers allow their students to create content that resides in Hapara systems. Content creation requires a validated login with the School’s Cloud platform (SSO), 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, and the student identifiers. We do not make such content publicly accessible except as directed by the Customer, 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.
Support Information: In the course of providing Services to our Customers, the diagnostic and troubleshooting processes may require additional information to be collected (troubleshooting a student account rename for example might require access to the student’s previous name). This information is limited in scope to what is required to resolve the support request, and is not stored in or shared with other Hapara systems.
Sales & Marketing Information
We collect information through our Website and Sales and Marketing Services from visitors who wish to learn more, purchase or participate in our Services or seek support. For example, we collect information when you request marketing information, register for a Webinar, apply to a Hapara Certified Champion Program, apply for a job, interact with us via social media, take a survey, or otherwise communicate with us. The types of information we collect may include your name, e-mail address, location, phone number, school/district affiliation, role, experience, certifications and relevant professional development, and any other information you choose to provide.
Contact information is used by our sales, support, marketing and product teams to contact visitors for the purpose of providing the requested information or services support.
Information We Collect from Other Sources: If you interact with us through a social media site, we may have access to publicly available information from that site, such as follows and likes, in accordance with the policies determined by the social media site. If you attend an event or a conference we sponsor or support, your contact details may be directly or indirectly shared with us.
Web Analytics: Like most organizations, we rely on automatic data collection technologies 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.
Operational Information: We also collect Website and Service health diagnostics, and technical logging data used for troubleshooting and performance management.
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.
How We Disclose Information
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.
We do not sell student information in any form.
Your Choices and Rights
Opt-Out for Direct Marketing. We do not undertake any form of marketing to students or children.
If you are a teacher or school administrator and have provided us with your information, we may send you product marketing communications. You may opt out of these communications at any time 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. 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. Upon request to email@example.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.
Retention of Customer Personal Information
If you have requested us not to contact you, we will retain your contact details on the do-not-contact list.
How We Protect Your Information
Links to External Websites
Important Notice to All Non-U.S. Residents
Our servers are located in the U.S. If you are located outside of the U.S., please be aware that any information provided to us, including personal information, will be transferred from your country of origin to the U.S. Except in the case of data transfers under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, your decision to provide such data to us, or allow us to collect such data through our Website or the Services, constitutes your consent to this data transfer.
U.S.-EU Privacy Shield and Swiss-U.S. Privacy Shield
Hapara complies with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks 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) and Switzerland, respectively. 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”). 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.
Residents of the European Economic Area
If you are a resident of the European Economic Area (“EEA”), you have certain rights and protections under the law regarding the processing of your personal data. In circumstances where Hapara acts as a data processor, you must contact your data controller (your educational institution) to avail yourself of these rights and protections.
Legal Basis for Processing: If you are a resident of the EEA, if and when we process your personal data as a data controller, we will only do so in the following situations:
- We need to use your personal data to perform our responsibilities under our agreement with you or our customer with whom you have a relationship (e.g., for processing payments for or for providing the Hapara services you or our Customers have requested).
- We have a legitimate interest in processing your personal data. For example, we may process your personal data to communicate with you about changes to our Services or to provide, secure, and improve our Services.
- We have your consent to do so. For example, we may seek your consent to send you marketing communications.
Data Subject Requests: If you are a resident of the EEA, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may email us at firstname.lastname@example.org. Alternatively, you may contact us as indicated below.
Questions or Complaints: If you are a resident of the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
How to Learn More