Effective Date: 22 November 2022
At Edrolo (“Edrolo”, “we”, “us”, “our”) we provide learning resources that improve secondary education. We partner with schools to drive improved outcomes for students, teachers, school leaders, and the entire school community, by providing the Service (defined below) to Schools (as defined below) as their service provider. At Edrolo, we take our responsibilities with respect to privacy and the protection of the Personal Information we collect seriously. We are committed to protecting and securing the confidentiality of, lawfully handling, and effectively managing the Personal Information we collect.
I. STUDENT CONSENT REQUIREMENT
Under the Children's Online Privacy Protection Act ("COPPA"), we are required to obtain prior consent for the online collection, use, and sharing of Personal Information from Students under 13 years of age. Our School and School District customers ("Schools") do contractually consent on behalf of the parents or guardians of Students to our practices regarding Student Personal Information that is collected on our Service.
II. INFORMATION WE COLLECT.
A. Student Personal Information provided to us.
Edrolo and third-party vendors which provide services to us ("Processors"), may collect Personal Information regarding Students from Students, or the Students' Schools to register Students for, and to provide them access to, the Services. Information Edrolo and its Processors collect may include: Student name, username, school name, email address, and in some cases, date of birth or student identification number, and curriculum progress. Once enrolled, Schools or Students will create a password , which they will use, together with one of the identifiers provided by the School to permit Students to log into the Service. Student accounts may also be associated with a class or grade level. The School will be able to see information regarding the Student's use of the Services in connection with a class, and make changes to the Student's username and other information. In some circumstances, Teachers and other authorized personnel may create accounts for Students.
B. Teacher Personal Information provided to us.
Edrolo and our Processors may collect Personal Information regarding Teachers from Teachers, or Schools to register Teachers for, and to provide them access to, the Services. Information Edrolo and its Processors collect may include: name, username, school name, and email address. Once enrolled, Teachers will create a password, which they will use together with one of the identifiers to log into the Service. The School will be able to see information regarding the Teacher's use of the Services, and make changes to the Teacher's username and other information.
C. Information collected automatically.
Edrolo and its Processors may also automatically collect certain information about Students and Teachers when they access or use the Services ("Usage Information"). Usage Information may include IP address, device identifier, browser type, operating system, information regarding use of the Services, and data regarding network connected hardware (e.g., computer or mobile device). The methods that may be used on the Services to collect Usage Information include:
1. Log information: Log information is data about use of the Services, such as IP address, browser type, Internet service provider, referring / exit pages, operating system, date / time stamps, and related data, and may be stored in log files.
2. Information collected by cookies and other tracking technologies : Cookies, web beacons (also known as "tracking pixels"), embedded scripts, location-identifying technologies, fingerprinting, device recognition technologies, and other tracking technologies now and hereafter developed ("Tracking Technologies") may be used to collect information about interactions with the Services or e-mails.
III. HOW WE USE THE INFORMATION WE OBTAIN.
A. To perform services for Schools.
We may use information collected on the Services to perform services for the applicable School, including without limitation:
1. To process account registration and manage accounts.
2. To facilitate, manage, and personalize the Services.
3. To prevent and address fraud, breach of policies or terms, and threats of harm.
Schools are the controller with respect to Personal Information and their privacy policies, and not ours, govern their data practices.
B. Aggregate and deidentified data.
We may create and use aggregate and deidentified data derived from Personal Information for our own purposes, such as the improvement of the Services.
We may also analyze Personal Information in aggregate form to operate, maintain, manage, and improve our Services. This aggregate data does not identify Students or Teachers personally. We may share this aggregate data with our affiliates and Processors. We may also disclose aggregated user statistics in order to describe our Services to Schools and to other third parties for additional lawful purposes.
IV. HOW AND WHY WE DISCLOSE PERSONAL INFORMATION.
A. Disclosures to third parties.
Like many businesses, we hire other companies to perform certain business-related services (our "Processors"). 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: data storage and hosting services, disaster recovery services, learning management systems (for example, ClassLink, Clever, or Google Classroom), analytics companies, and network and security monitoring companies. All such third parties function as our agents, performing services at our instruction and on our behalf, or as agents to Schools providing services on behalf of the Schools.
B. Disclosures to affiliate or parent organizations.
We may also disclose Personal Information to our affiliates or parent company in order to support delivery of our Services.
C. Business disclosures.
Subject to our obligations to Schools, and consistent with applicable law, Edrolo may share Personal Information, in connection with or during negotiations of any proposed or actual financing of our business, or merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of Edrolo's assets, or transfer of all or a portion of Edrolo's business to another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
D. Disclosures to public authorities.
We may share Personal Information to comply with the law, law enforcement, or other legal process, and, where permitted, in response to a government request. We may also disclose Personal Information to other third parties when compelled to do so by government authorities or as required by law or regulation including, but not limited to, in response to court orders and subpoenas.
V. ANALYTICS SERVICES.
VI. STUDENT OR PARENTAL RIGHTS.
Applicable law may grant parents or Students the right to access, review, request correction of, refuse further collection of, or delete the Personal Information collected from the Student online. Because Edrolo is not the controller of the Student Personal Information, we are not able to respond to such requests directly. To exercise these rights, please contact your School with your request.
VII. INFORMATION SECURITY.
We take the security and privacy of Personal Information very seriously. Accordingly, we will implement reasonable and appropriate security measures to protect Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in processing and the nature of the data, and compliance with applicable laws and regulations.
B. How to contact us.
E-mail us at [email protected]
Or write to us at:
321 Exhibition St, Melbourne VIC 3000