This Privacy Policy applies to the Wingspans website, or any other website or application of Wingspans linking to this Privacy Policy (“Services”), and exists in accord with our Terms of Use.
BY VISITING THE WEBSITE OR USING THE SERVICES, YOU ACKNOWLEDGE YOU HAVE READ THIS PRIVACY POLICY AND UNDERSTAND THAT YOUR PERSONAL INFORMATION SHALL BE PROCESSED AND TREATED IN ACCORDANCE WITH THIS PRIVACY POLICY.
Overview
We understand that privacy is important to you. At Wingspans, we are committed to being transparent about our practices and technologies. We agree to comply with all applicable laws concerning our collection and use of your personal information. We are committed to maintaining the confidentiality, integrity, and security of your personal information including Student Personal Information.
Specifically, we are committed to protecting your personal information, including Student Personal Information, and satisfying all applicable legal requirements, including the Children’s Online Privacy Protection Act (“COPPA”), the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and the Family Educational Rights and Privacy Act (“FERPA”), through our compliance with this Privacy Policy.
“Student Personal Information” means information that may, alone or in combination with other available information, be reasonably used to identify a current or former Student. Student Personal Information may include, but is not limited to, FERPA Records.
Educators, Students, parents or guardians of a Student, Authorized Administrators of a School account and Individual Users who use the Services are each individually a “User” and collectively “Users.” Anyone else who comes to the site is a “Visitor.”
How We Collect Information
We will only collect, use, maintain and share your information in a manner allowed by applicable law.
Information Provided by Schools and Districts and Educators
Schools and Districts that use the Services provide certain information about their students (“Students”) and their professors, teachers, counselors, and administrators (“Educators”) to create accounts. Schools and Districts may provide the following (1) Student Personal Information: Student ID, First Name, Last Name, Gender, Date of Birth, Current Year, Current School, and Next Year School; and (2) Student email address.
Schools and Districts may provide information about courses Students have taken, including course codes, course names, date of course completion, or grade level completed, final grades, credits achieved, and the term achieved. For Schools and Districts that implement e-Transcript services, Schools and Districts may provide Students transcript data for submission to colleges and universities.
Schools and Districts may provide Educators names and email addresses. For Students and Educators, when creating their own accounts, will be required to provide an email address as well as first and last name. We may collect the following information from a School or Authorized Administrator to set up and administer a School account: (1) Authorized Administrator contact information as well as information about his/her School relevant to purchasing and setting up accounts such as School’s name, address, billing address, and number of students; and (2) Support requests and any other information submitted by a School or Authorized Administrators.
Information Provided by Students
Students may provide a variety of information including certain Student Personal Information in the Services. Students may provide information such as email address, phone number, mailing address, profile picture, cover page picture, education goal, favorite clusters, interests, skills, test scores, work experiences, volunteer experiences, high school course plan, career plans, bookmarked pages, and any other information or User Content that Students choose to provide.
Information Provided by Individual Users
Individuals using the Website independently, which means outside of a School or District, and may be asked for certain information to create an account. This information includes, but it not limited to: (1) First Name, Last Name, Age Range; (2) email address; and (3) payment information, as part of the account creation process. By creating an account outside of any School or District, or by visiting or using the Website apart from any School or District, the Individual User represents and warrants that (1) they are at least 13 years old and (2) if they are under 18 years old, they are visiting our Website under the supervision of a parent or guardian.
We may collect the following information directly from individual visitors: (1) Requests for Information; and (2) Support Requests. If you submit a request for information or otherwise contact us, we collect your request and your identifying contact information (including name, email address, phone number and address). If you submit a support request or question, we receive your request/question and your associated identifying contact information.
Information Provided by Visitors
We may collect the following information directly from Visitors: (1) Requests for Information; and (2) Support Requests. If you submit a request for information or otherwise contact us, we collect your request and your identifying contact information (including name, email address, phone number and address). If you submit a support request or question, we receive your request/question and your associated identifying contact information.
Automatically Collected Information
When a User uses the Services or a Visitor comes to the Wingspans website, we collect information about how they interact with the Services (e.g., the pages viewed, the links clicked, and other actions taken on the Services) and usage of the Services over time.
Our servers automatically collect other information about Users or individual visitors that may include web request, Internet Protocol (“IP”) address, browser type, and mobile device information. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Services. We do not allow any third-party advertising networks to collect information about Users.
How We Use Information
We use the information we collect, including Student Personal Information and User Content, to help Students and Individual Users create a successful future. Specifically, we use such information to: (1) provide, improve and analyze the Services; (2) respond to questions, comments, and requests for information or provide customer support; (3) comply with applicable law or legal process; (4) detect, investigate and prevent activities that may be a violation of our Terms of Service or law; (5) Administer, troubleshoot and secure the Services; and (6) as directed by a School or District that has licensed the Services.
We use and share de-identified and aggregate information for a variety of purposes including improving the design, features, and functionality of the Services, for marketing purposes, for general business purposes, and for administrative purposes. In addition to the above, we use School or School Authorized Administrator or Individual User information to send information about features on the Services or changes to our policies and communicate about the Services, including your account, transactions with us and security alerts.
How We Do Not Use Information
We do not sell or rent personal information, including Student Personal Information or User Content provided in the Services. Nor do we disclose or provide any personal information, including Student Personal Information or User Content, to third parties for any purpose except as described in this Privacy Policy or directed by a School or Individual User. In addition, we do not use, sell, or rent personal information, including Student Personal Information or User Content, for the purpose of advertising.
How We Share Information
We may permit certain trusted third parties to track usage, as well as analyze information such as the source address that a page request is coming from, your IP address or domain name, the date and time of the page request, the referring website (if any), and other parameters in the URL. This is collected in order to better understand usage of our website and the Services and enhance the performance of and maintain and operate the Services.
We may also use trusted third parties to host portions of the Services infrastructure, operate various features of the Services, store content, send emails, and store data on our behalf. If we share student information with certain trusted third parties, we require that third-party with whom student personal information is shared to meet and commit to the same privacy standards that we employ and have set forth in our Privacy Policy.
We may also disclose personal information in certain special cases, including the following: (1) we are required to do so by law or as ordered by a court;(2) to detect, investigate and prevent activities that may be a violation of our Terms of Service or law; (3) to resolve a technical problem or secure the Services; and (4) as directed by a School or District that has licensed Wingspans.
We may also share personal information or User Content in connection with a merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company. In these circumstances, we will only share such information with a company that has agreed to data privacy standards no less stringent than our own and after providing advanced notice to you with an opportunity to opt out of our sharing of such information.
Third-Party Services
Certain third-party products or services (such as single sign on) may be available for Schools to choose to integrate within or use within the Services. A School is not required to use such additional products in the Services. Before electing to use such third-party services, Schools should review the terms, policies and practices of the third-party products and services to understand their terms and policies with respect to any personal information, including Student Personal Information, they may collect. We strive to make available third-party services that will be useful to Schools, but we are not responsible for their practices, including with respect to personal information.
How We Protect Information
We are committed to protecting personal information, including Student Personal Information and User Content submitted to the Services. We have numerous systems in place to safeguard against security breaches, denial of service attacks, and destruction of data. These measures include physical security and backups, employee restriction to data, and a comprehensive security breach policy.
All traffic transmitted to and from the Services is safely encrypted using Secure Socket Layers (SSL). We use industry-standard hashing mechanisms for sensitive data, such as passwords, and all backups are securely encrypted. Network infrastructure is monitored 24/7 by an intrusion detection system, while all servers use virus protection with full antivirus pattern updates. We maintain a detailed, and frequently tested, disaster recovery plan with multiple layers of redundancy plus a robust backup strategy.
Our employees who require access to personal information, including Student Personal Information, to perform their function must complete a criminal background check and sign a non-disclosure agreement prior to employment.
Your Choices
Information Provided by Schools and Districts
Information provided by Schools and Districts is controlled by such educational institutions. If you have any questions about reviewing, modifying, or deleting the personal information they have provided us, please contact your educational institution directly. Schools may update account information and modify the Services by contacting us at support@wingspans.com.
Information Provided by Students
The Services offer a robust set of tools and features which allow Students to edit or delete Student Personal Information and User Content that they have added. Students may also request changes or deletions to Student Personal Information and User Content provided by emailing us support@wingspans.com. We will respond to your request, when permitted by law, within 30 days. Please note, this request may be referred to the School for instruction.
Information Provided by Individual Users
The Services offer a robust set of tools and features which allow Individual Users to edit or delete Personal Information and User Content that they have added. Individual Users may also disable their account in the Account Information Page. They can also request changes or deletions to personal information and User Content provided by emailing us at support@wingspans.com. We will respond to your request, when permitted by law, within 30 days.
Data Retention
Following termination or deactivation of an Individual User’s account or School’s account, we will retain personal information and User Content for a period of 90 days. Should the Individual User or School decide to renew their subscription or contract within this 90-day period, the account and all related information will be restored. At the end of 90 days, or earlier at the request of the Individual User or School, we will delete or transfer (and direct any subcontractors to delete or transfer) to a School with rights in the information: Student Personal Information (including FERPA Records), personal information of Educators, and User Content in our or our subcontractor’s possession. Notwithstanding the foregoing, we may retain any such information as required by or to demonstrate compliance with applicable law.
At any time upon termination of an agreement or otherwise at their discretion, an Individual User or School can request we delete all Student Personal Information and User Content. We will follow these instructions within 30 days of receipt.
Children’s Privacy
Students use the Website within a School or District and are not allowed to create their own accounts in the Services. Student accounts are created under the direction of the School or Educators. Only Educators provided access by the School in the Services have access to that Student’s personal information and content. Under the Children’s Online Privacy Protection Act (“COPPA”) there must be verifiable parental consent in order to collect, use, or disclose personal information from Children under the age of 13. As provided for by COPPA, we rely upon the School to obtain parental consent for the online collection of personal information from Children who are Students of such School.
Changes to Our Privacy Policy
We may modify or update this Privacy Policy from time to time, so you should review this page periodically. If we make a material change to this Privacy Policy with respect to how we collect and use personal information, we will provide at least 30 days prior written notice School and Users by email to the email address specified in the applicable account. Schools are responsible for ensuring that we have an up-to-date, active, and deliverable email address to provide such notice to School and for periodically visiting this Privacy Policy to check for any changes. Similarly, Schools that license the Services for their Students will be notified by email of material changes to our Privacy Policy at least 30 days prior to any changes.
Contact Us
If you have any questions regarding this Privacy Policy, please email us at support@wingspans.com.
