StartSOLE Privacy Policy Highlights

We believe you should always know what data we collect from you, how we use it, and that you should have meaningful control over both. As our client, we want to empower you and the users you represent to make the best decisions about the information that they share with us. We offer a Data Privacy Addendum, an agreement we enter into with individuals, schools, districts, LEA’s, and businesses, that further describes our duties, responsibilities, and commitments with respect to user or student data that we collect or receive.

This Privacy Policy applies solely to the StartSOLE Services (defined below) and does not apply to the informational website located at https://www.StartSOLE.com (the "StartSOLE Website").

You should read this policy in full, but here are the highlights:

Personal Information We Collect: Please see this table where we detail the personal information we collect from each user type, including the sources from which the information was collected, the business purpose for which the information was collected, and the third parties with whom we share or disclose personal information for a business purpose.

How We Use the Information We Collect: We use the personal information we collect from users or students (or about students from sources such as teachers, parents, or employers) to provide and improve the Service, for educational purposes, security, and safety purposes, or as allowed by law. We will not require children to provide more personal information than is reasonably necessary to participate in the Service.

Data Retention: We will not retain student personal information for any longer than is necessary for educational purposes and legal obligations, or to provide the Service for which we receive or collect the student personal information.

Our User or Student Data Protection Policy: we may automatically delete a user or student if they're inactive for more than twelve months. Some content within a user or student account utilized in an enterprise (such as a school) or for educational purposes connected to a school or classroom ("User Account") will be kept after deletion of the account for school legal compliance reasons (e.g., maintenance of "education records" under the Family Educational Rights and Privacy Act (FERPA) or "User or Student Data" under state student privacy laws or equivalent laws in international jurisdictions) and will not be deleted until we receive direction from the authorized educational agency or employer. This can include content uploaded by a student, teacher, school leader, parent, employer, or other third party.

We store non-student user personal information, including content uploaded by Outside Accounts, for as long as it is necessary to provide products and Service to you and others. For non-student users, personal information associated with your account will be kept until your account is deleted or until we no longer need the data to provide the Service, whichever occurs first. Additionally, some data may be deleted or anonymized automatically after a set period of time. For additional information on our retention periods, please contact us.

We Never Sell Personal Information: We will never sell or rent your personal information or non-personal information. We will only disclose personal information as set forth in the Privacy Policy, such as with a limited set of third-party service providers necessary to provide or develop our Services (such as database hosting) or as required by law.

We will contractually require that these service providers process personal information in a manner consistent with this Privacy Policy. We ensure that these service providers employ reasonable and comprehensive data protection and security protocols.

We make clear commitments, consistent with our obligations under the Student Privacy Pledge, regarding how we handle student data in the event of a change to our organization (such as a merger) where personal information that we have collected from users would be one of the assets transferred or acquired. Consistent with the Student Privacy Pledge and applicable state and federal laws, in connection with such a change to our organization, this Privacy Policy will continue to apply to your information, and any acquirer would only be able to handle your personal information as per this Privacy Policy (unless you give consent to a new policy).

We never use student or children's data for behaviorally targeted or third-party advertising: Information collected from students and Outside Accounts (including personal information and information collected automatically) is never used or disclosed for third-party advertising. We also do not place any third-party advertisements in student or Outside Accounts logged-in areas of the Service. Additionally, personal information collected from students and Outside Accounts is never used for behaviorally-targeted advertising to students or Outside Accounts by us or any third-party. We may present contextually relevant educational content (not using Student or Outside Accounts personal information) for either our own products (e.g., Premium Features) or third-party products and services ourselves that we believe may be of interest to a student or an Outside Account.

You own your data: We don't own any content or information you provide or we receive - you (students, employers, Outside Accounts, parents, and/or schools) will own your content and information.

Security and Privacy by Design and Default: We use security industry best practices to protect personal information, including using encryption and other security safeguards to protect personal information. We design products with security and privacy in mind from day one.

Transparency and Choice: We will be transparent about our practices so that you can make meaningful choices about how your personal information is used. If we make a material change, we will provide prominent notice by posting a notice on our Service or this website page and/or we will notify you by email (if you have provided an email address to us).

Right to Access, Correction, and Deletion of Data: We support access to, correction, and deletion of personal information by the user (eg.student) or their parent or legal guardian, either by 1) assisting the school in meeting its requirements for access, correction, and deletion or by responding to requests we receive from schools, or 2) directly responding to requests from parents or legal guardians when the information is collected from an Outside Accounts, and StartSOLE obtains the consent directly from the user, parent, or legal guardian.

Teachers, parents, school leaders, and other users can contact us at support@StartSOLE.org from the email used to create your account or here once you are signed in to your account to access, correct, or update their personal information, or they can use the features in their account settings to do so.

Introduction

StartSOLE’s mission is to Let Learning Happen by placing the student at the center of learning.   Our tools allow students and users to document learning, track progress, and connect with opportunities around them.  This involves making seamless connections between the student and their learning ecosystem. For more information about StartSOLEs suite of products click on this link

Keeping this trust through your privacy and safety is incredibly important to us.

This Privacy Policy explains:

• What information StartSOLE collects from you (and why we collect it),
• How we use and share that information,
• The choices and rights you have, including how to access, update, delete your information, and take your information out of StartSOLE.

We will only collect, use, and share your personal information in accordance with this Privacy Policy. This policy applies whether you login to use StartSOLE through https://www.StartSOLE.com (the "StartSOLE Platform"), our applications (the "StartSOLE Apps"), or any of our other products or services that link to this Privacy Policy that StartSOLE, Inc. ("StartSOLE," "we," "us," "our," and our subsidiaries or affiliates) may provide now or in the future (collectively, the "Service(s)"). This Privacy Policy also covers StartSOLE's treatment of any personal information about our users that our partners or other services share with us, for example, using MailChimp as an automated email service.

This Privacy Policy does not apply to information collected through other websites, products, or services that StartSOLE doesn't own or control, such as third-party services you might access through links or other features (e.g., social media buttons, email campaigns, push or in-app notifications, or YouTube videos) on the Service. These other services have their own privacy policies, and we encourage you to review them before providing them with personal information.

Our Privacy Policy is designed to provide transparency into our privacy practices and principles. We hope you find this clear and friendly. If you have any questions, we're here to help. To learn more about how we protect your privacy send us an email at support@StartSOLE.org.

Acknowledgment and Consent

By using the Service, you acknowledge that you accept and agree to this Privacy Policy. By visiting the StartSOLE Platform or StartSOLE Apps, or using our Services in any manner, you acknowledge that you accept the terms, practices and policies described in this Privacy Policy (and as updated from time to time), and you hereby agree that we may collect, use, and share your information as described herein. If you do not agree with our policies and practices, you should not use our Services. Your use of our Services is at all times subject to our Terms of Use (as updated from time to time (the  "Terms" )), which incorporates this Privacy Policy. Any capitalized terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms.

StartSOLE's Privacy Certification

StartSOLE is also a signatory to the Student Privacy Pledge. We agree to a set of principles intended to safeguard student privacy, including responsible stewardship, protection, and transparent handling of student personal information. Read more about the Student Privacy Pledge here.

What is StartSOLE?

School Use

StartSOLE’s mission is to Let Learning Happen by placing the student at the center of learning. Our tools allow students and users to document learning, track progress, and connect with opportunities around them.  This involves making seamless connections between the student and their learning ecosystem. For more information about StartSOLEs suite of products click on this link.  

In order to have a Student or User Account created, we either (1) have the Student Account created at school by their teacher (only after the teacher represents to StartSOLE that they have authority to act as the agent of the parent and consent on the parent's behalf for the student to use StartSOLE for educational purposes or (2) create their own User or Student Account, such as with a username and password.

Participants in the ecosystem, such as educators and employers, also play a meaningful role in StartSOLE. Their access depends on their role in the user's use of the platform.

What information does StartSOLE collect?

We collect two types of information about you: (1) information that you voluntarily provide us by using the Service (described below under "Information You Provide to Us") and (2) information collected automatically as result of your use of the Service (described below under "Information We Collect Automatically"). We may also receive information about you from third-party sources (as described below under "Information Received from Third-Party Sources''). The types and amounts of information collected will vary depending on whether you are signed up as a user, teacher, school leader, school admin, employer, parent, student or Outside Accounts and how you use StartSOLE (e.g., if teachers join their school, we may need to collect school address information).

Information You Provide To Us

We ask for and collect the following personal information about you when you use the Service. When we act as a Controller, this information is necessary for the adequate performance of the contract between you and us, for our legitimate interest in being able to provide and improve the Service, and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.

As a teacher, school leader, school admin, potential employer, or parent, your first and last name and where applicable, a profile photo and your child's first name and last initial may be displayed to the people with whom you are messaging, including through StartSOLE. Additionally, parents may elect to turn on a Premium Feature that allows them to know if a teacher has read their messages and may similarly receive a 'read receipt' telling them the teacher has read the message.

We will collect and store messages from StartSOLE and any content sent with the messages (e.g., photos or videos), to provide the Service, and for StartSOLE Messaging, to help teachers, school admin, potential employers, and school leaders keep a log of their communications. 

In the case that a photo or video is shared through StartSOLE showing a student who does not want photos taken of him/her (or whose parent does not want photos taken of him/her), or if any user needs to otherwise report any abuse or inappropriate content sent through StartSOLE they may do so by emailing us at support@StartSOLE.org. Please note that StartSOLE may not be able to remove certain content as the content may be deemed an "education record" under FERPA or any applicable law (including in international jurisdictions). If a photo or video is considered an "education record" you will need to first contact your child's school to request removal. For more information on when photos or videos are considered an "education record" please see the Department of Education's guidance here. In addition, if a user needs to report any abuse or inappropriate content, they may do so using the reporting mechanism.

Information We Collect Automatically

When you use the Service, we (or our service providers) may use various technologies that automatically record or collect certain information, including personal information, from your browser or your device about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the Service. For example, this could include the frequency and duration of your visits to StartSOLE (similar to TV ratings that indicate how many people watched a particular show). If you use StartSOLE on different devices, we may link the information we collect from those different devices to help us provide a consistent Service across your different devices. If we combine any automatically-collected information with personal information, we will treat the combined information as personal information, and it will be protected as per this Privacy Policy.

The technologies and information we automatically collect include:

• Cookies and other similar technologies: We (or our service providers) may use cookies or similar technologies to identify your browser or device. We (or our service providers) may also use these technologies (never in Student or Outside Accounts logged in areas of our Service) in connection with advertising of our Service that may appear on other sites or in connection with advertising their products outside of our Service (e.g., if you view an embedded YouTube video player on our Service, YouTube may place cookies or similar technologies on your browser when you play the video off our site). We don't allow these third-parties to advertise directly on our Service (i.e. such as when an advertiser would bid to place an advertisement directly on a platform such as Facebook), but we may serve contextually relevant advertising for third-party products and services ourselves that we believe may be of interest to you (e.g., our co-created content with Brasstacks LLC and the StrengthenU application).
• Local storage: We may also use, collect, and store information and preferences locally on your device using mechanisms such as browser-based web storage (including HTTP cookies and HTML5) and application data caches.

Like many services, StartSOLE (or our service providers) uses both local storage and cookies and other similar technologies to analyze trends, gather demographic information about our users, understand your engagement with the Service, administer the Service, tailor the Service for you, and to help the Service work better for you -–for example, by remembering your language preferences or other information so that you will not have to re-enter it during the next time you visit the Services.

Device information: We collect device-specific information such as your device type, device brand, operating system, hardware version and settings, device settings, file and software names and types, battery and signal strength, and device identifiers (including unique device IDs). We may also collect device event information such as crashes, system activity, browser type, browser language, the date and time of your request and referral URL. This helps us measure how the Service is performing, improve StartSOLE for you on your particular device, and send you push notifications if you've opted in to receive them.

• Mobile application information: Certain mobile applications or "apps" include a unique application number. This number and information about your installation (for example, the operating system type and application version number) may be sent to StartSOLE when you install or uninstall that application, such as when you install a StartSOLE-developed App, when you open the application, or when that application periodically contacts our servers, such as for automatic updates. Additionally, we may receive application state and crash log information which will help us debug and improve a StartSOLE-developed App.
• Server log information: Like most online services, when you use our Service we automatically collect and store certain information in our server logs. Examples include things like:

• Telephone log information like your phone number and SMS routing information
• IP address
• Details of how you used our Service, such as your activity on the Service (including product event data used to track progress or user activity), and the frequency and duration of your visits to the Service (similar to TV ratings that indicate how many people watched a particular show)

• This information helps us make decisions about what we should work on next -– for example, by showing which features are most (or least!) popular and to send notifications to a device (such as push notifications if the user opted in) to encourage the user to finish an activity or start the next activity. We may use your IP address and share it with third parties to help diagnose problems with our servers, for security purposes, to manage the Service, to enhance the Services based on usage pattern data and for analytics and for advertising.
• Location information: When you use our Service, we may collect and process information about your geographic location, for example, based on your IP address. We collect both coarse (i.e., city-level) location data and precise location data. If we request precise geolocation information ("precise" meaning sufficient to identify street name and name of city or town) from you (such as when a teacher or parent is searching for a school), we ask for your explicit opt-in permission. We  never request precise geolocation data from students or Outside Accounts. From all users, if they upload photos or videos from their computer, or from their phone camera roll directly, as opposed to choosing to use StartSOLE's own application camera, we collect what the device sends us. If the device sends us Exchangeable Image File Format (EXIF data) (metadata contained within the image file -–e.g. camera model, lighting conditions, and location (if enabled)) this can contain location data (and may contain precise location data). We strip all EXIF data, including the location information, from the photo before it is viewed by other users (e.g., the person receiving a message). If a user accesses and uses our mobile camera within the application itself, the camera has been configured so as to not collect any EXIF data, therefore the EXIF information is not stored (as opposed to if you use your device's own camera roll).

We will not store or track your precise device location on an ongoing basis or without your permission. We do not share precise geolocation data with third-parties, other than our service providers as necessary to provide the Service. If you no longer wish to allow us to track your precise location information, you may opt-out at any time by turning it off at the device level.

• Cross-device collection: To provide users with a seamless online experience, we may link your identifiers on different browsers and environments you are using. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.
• Product events: As users interact with the product, we collect product events about how the product is being used (e.g., the number of points given, which reports are viewed, which features are used, which buttons are clicked, load time, etc.). These are collected to provide the Services, including for internal analysis on product usage and quality. We may also use it to track progress in the Service, and for sending push or email notifications to the parent's, teacher's, or student's device to encourage them to take certain actions in the StartSOLE Service. Our product event logs may also include unique device IDs and IP addresses. We automatically delete IP addresses tracked in product logs after six months.

Information Received from Third Party Sources

We may also obtain information, including personal information, from third-party sources to update or supplement the information you provided or we collected automatically. This may include aggregated anonymous information or certain personal information that may be provided to us (e.g. survey information or information about the name of teachers and address of schools). If we receive personal information from third-parties, we will handle it in accordance with this Privacy Policy. If we directly combine information we receive from other third-parties with personal information that we collect through the Service, we will treat the combined information as personal information and handle it in accordance with this Privacy Policy. Additionally, we may use any aggregated anonymous information received by third-parties". Local law may require you to authorize the third-party to share your information with us before we can acquire it. We do not control, supervise, or respond to how third parties providing your information process your personal information, and any information request regarding the disclosure of your personal information to us should be directed to such third-parties. Please see this chart with the detailed categories of personal information we collect from each user type, including the sources from which the information was collected, the business purpose for which the information was collected, and the third parties with whom we disclose personal information for a business purpose.

How Does StartSOLE Use The Information It Collects?

First and foremost, you should know that StartSOLE does not sell or rent any of your, or your student's personal information to any third-party for any purpose – including for advertising or marketing purposes. Third-party advertising is not permitted on areas where users are required to log in to StartSOLE and personal information collected from students and Outside Accounts is never used for behaviorally-targeted advertising to students or children (by us or third-parties). We may serve contextually relevant advertising for third-party educational products and services that we believe may be of interest to you. StartSOLE commits that its collection, use, retention and sharing of personal information shall be reasonably necessary and proportionate to achieve the purposes for which the personal information was collected or processed and for the purposes disclosed in this Privacy Policy and this chart and that the personal information will not be further processed in a manner incompatible with these purposes.

We use your personal information only when we have a valid legal basis to do so. Our use of information collected from users and Outside Accounts using the Service is set forth in our Data Privacy Addendum. More specifically, this information collected (from non-students and non-Outside Accounts) is used to:

• Power Our StartSOLE Services: This includes, operating, providing, enhancing and improving the Service, for example, by developing new products and features, and personalizing or customizing the Service for you.
• Provide Internal Analytics and Reviews for StartSOLE: This includes using for internal audits and review, for analyzing how the Services are used, providing statistics about the usage levels of the Services, and diagnosing service or technical problems.
• Process Your Transactions: To fulfill your requests and provide any information you request, such as responding to your emails, submissions, questions, comments, requests for information or customer support or for event registration, scheduling, or attendance; for any other purpose for which the information was collected (e.g., fulfilling Premium Features orders), or for which you provide your consent (if required).
• Communicate with You: To send you information about features on our Service or changes to our policies and Service or communicate with you about your use of the Service, your account, or transactions with us. We may also send you security alerts, and support and administrative messages and otherwise facilitate your use of, and our administration and operation of the Service (including notifying you of data privacy incidents). Additionally, we may provide school leaders, parents, and teachers information about events, announcements, offers, promotions, products, including third-party products, and services we think will be of interest to you and notify and contact contest and sweepstakes entrants.
• Request Your Participation in Surveys or Focus Groups: To request your participation in ratings, reviews, surveys, focus groups, or other initiatives which help us to gather information used to develop and enhance our products and Services.
• Security and Fraud Prevention: Most crucially, to protect our community by making sure the Service remains safe and secure, such as by detecting, investigating and preventing activities that may violate our policies or be illegal.
• Comply with Law: To comply with applicable law – for example, to satisfy tax or reporting obligations, or to comply with a lawful governmental request or notify you of data privacy incidents when legally required.

We use automatically collected information (described in the "Information We Collect Automatically" section above) to provide and support our Service, and for the additional uses described in this section of our Privacy Policy. To learn more about how we use your information for personalization and tracking, please see the Online Tracking Technologies Policy.

We do not use algorithms for profiling or to otherwise make any decision based solely on automated processing that would significantly affect you without the opportunity for human review ("Automated Decision Making").

When acting as a Controller, We process this information given our legitimate interest in improving and protecting the Service and our users' experience with it, taking into consideration your interests, rights, and expectations. Depending on the circumstances, we may also rely on your consent or the fact that the processing is necessary for the adequate performance of the contract with you, to protect your vital interest or those of other persons or the Service, and to comply with applicable laws.

Additionally, when acting as a Controller, we will process your personal information for the purposes listed in this section related to marketing given our legitimate interests in undertaking marketing activities to offer you products and services that may be of your interest. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications.

Please note that we may anonymize and/or de-identify information collected through the Services or via other means so that the information no longer relates to you. Subject to applicable laws, where we have anonymized and/or de-identified information so that it no longer identifies you personally, our use and disclosure of such information is not subject to this Privacy Policy.

Will StartSOLE share any information it collects?

StartSOLE  does not sell or rent personal information to any third-party for any purpose - including for advertising or marketing purposes. Third-party advertising is not permitted on areas where users are required to log in to StartSOLE and personal information collected from students and Outside Accounts is never used for behaviorally-targeted advertising to students or Outside Accounts (by us or third-parties). Furthermore, we do not disclose personal information with any third-parties except in the limited circumstances described in this Privacy Policy and as set forth below:

• Other Users You Share and Communicate with on StartSOLE: No teacher, school leader, school admin, parent, student, or Outside Accounts profiles are made available to the general public through our Service. Furthermore, students cannot share their account information with anyone on StartSOLE, outside of users, their parents, teachers (including those at other schools), school leaders, potential employer, or authorized third-parties, If you are a teacher, school leader, school admin, or a parent, you may choose to share information or content through the Service with other StartSOLE teachers, school leaders, students, or parents. Please keep in mind that information (including personal Information or children's personal information) or content that you voluntarily disclose to others - including to other StartSOLE users you interact with through the Service (such as messages you might send other users or other teachers and school leaders you collaborate with) - can be viewed, copied, stored, and used by the people you share it with. We cannot control the actions of people with whom you choose to share information and we are not responsible for the collection, use, or disclosure of such information or content by others.

• Third-Party Integrations on our Service: When, as a teacher, school leader, school admin, student, Outside Accounts, or parent, you use third-party apps, websites, or other services that use, or are integrated with, our Service, they may receive information about what you post or share.
• Service Providers: We do work with vendors, service providers, and other partners to help us provide the Service by performing tasks on our behalf. We may need to share or provide information (including personal information) to them to help them perform these business functions, for example sending emails on our behalf, database management services, database hosting, providing customer support software, and security. We may also authorize these third-party companies to collect information on our behalf. These providers have limited access to your personal information to perform these tasks on our behalf and are contractually bound to protect and use it only for the purpose for which it was disclosed. Additionally, these partners and service providers must adhere to confidentiality and security obligations in a way that is consistent with this Privacy Policy.
• Analytics Services: We use analytics services, including mobile analytics software, to help us understand and improve how the Service is being used. These services may collect, store and use information in order to help us understand things like how often you use the Service, the events that occur within the application, usage, performance data, and from where the application was downloaded.
• Aggregated Information and Non-Identifying Information: We may share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other de-identified or non-personally identifiable information (such as statistics about visitors, traffic and usage patterns) with third parties, including with users, partners or the press in order to, for example, demonstrate how the Service is used, spot industry trends, or to provide marketing materials for StartSOLE. Any aggregated information and non-personalized information shared this way will not contain any personal information.
• Legal Requirements: We may disclose information, including personal information, if we have a good faith belief that doing so is necessary to comply with the law, such as complying with a subpoena or other legal process. We may need to disclose personal information where, in good faith, we think it is necessary to protect the rights, property, or safety of StartSOLE, our employees, our community, or others, or to prevent violations of our Terms of Service or other agreements. This includes, without limitation, responding to law enforcement and government requests and defending ourselves against third-party claims and allegations. Where appropriate, we may notify users about the legal requests, unless (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law; (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon StartSOLE, its users or the Service. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.
• Fraud and Security Protection: We may share information to assist with security operations for scheduled penetration testing, auditing, and continuous improvement of our security practices, including without limitation, exchanging information with other companies and organizations for fraud protection. Authorized parties of the information would comply with our current privacy and security policies.
• Sharing with StartSOLE Companies: Over time, StartSOLE may grow and reorganize. We may share your personal information with affiliates such as a parent company, subsidiaries, joint venture partners, or other companies that we control or that are under common control with us, in which case we will require those companies to agree to use your personal information in a way that is consistent with this Privacy Policy.
• Change of control: The Student Privacy Pledge requires us (and all pledgers) to commit to how we handle data in the event of a change to our organizations such that all or a portion of StartSOLE or its assets are acquired by or merged with a third-party, or in any other situation where personal information that we have collected from users would be one of the assets transferred to or acquired by that third-party. Consistent with the Student Privacy Pledge and applicable state and federal laws, in connection with such a change to our organization, if any, this Privacy Policy will continue to apply to your information, and any acquirer would only be able to handle your personal information as per this policy (unless you give consent to a new policy). We will provide you with notice of an acquisition within thirty (30) days following the completion of such a transaction, by posting on our homepage, or by email to your email address that you provided to us. If you do not consent to the use of your personal information by such a successor company, subject to applicable law, you may request its deletion from the company. We may also make information, including personal information, available to a potential investor or purchaser (or their advisors) in advance of any such transaction completion.

In the unlikely event that StartSOLE goes out of business, or files for bankruptcy, we will protect your personal information, and will not sell it to any third-party. For more information on our practices regarding your data if we go out of business.

How Does StartSOLE Protect And Secure My Information?

The security of your personal information is important to us. The safety and security of your personal information also depends on you and you should maintain good internet security practices. Where you have password-protected access to an account or certain parts of the Services, you are responsible for keeping this password or QR code secure at all times. You should not share your password or QR code with anyone. You must prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or mobile device and browser by signing off after you have finished accessing your account. If you think that any of your accounts have been compromised you should change your account credentials with us. In particular make sure any compromised account can't access StartSOLE. We will never email you to ask for your password or other account login information. If you receive such an email, please send it to us so we can investigate.

We work hard to protect our community, and we maintain reasonable administrative, technical, and physical security procedures and practices appropriate to the nature of the personal information designed to protect personal information from unauthorized or illegal use, destruction, disclosure, or access. In particular:

• Our engineering team is dedicated to keeping your personal information secure
• We perform application security testing; penetration testing; conduct risk assessments; and monitor compliance with security policies
• We periodically review our information collection, storage, and processing practices, including physical security measures, to guard against unauthorized access to systems
• Whenever we develop new features, we do in a manner to keep your personal information safe
• When you enter any information anywhere on the Service, we encrypt the transmission of that information using secure socket layer technology (SSL/TLS) by default
• StartSOLE's databases where we store your personal information are encrypted at rest. This converts your personal information into a form that unauthorized users can't translate.
• We ensure passwords are stored and transferred securely using encryption and salted hashing
• The Service is hosted on servers at a third-party facility, with whom we have a contract providing for enhanced security measures. For example, personal information is stored on a server equipped with industry-standard firewalls. In addition, the hosting facility provides a 24x7 security system, video surveillance, intrusion detection systems, and locked cage areas.
• We restrict access to personal information to authorized StartSOLE employees, agents or independent contractors who need to know that information in order to process it for us, and who are subject to strict confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations

Although we make concerted good faith efforts to maintain the security of personal information, and we work hard to ensure the integrity and security of our systems, no practices are 100% immune, and we can't guarantee the security of information. Outages, attacks, human error, system failure, unauthorized use, or other factors may compromise the security of user information at any time. If we learn of a security breach, we will attempt to notify you electronically (subject to any applicable laws and school reporting requirements) so that you can take appropriate protective steps; for example, we may post a notice on our homepage (www.StartSOLE.com) or elsewhere on the Service, and may send email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

How Long Does StartSOLE Keep Information About Me?

We retain the data we collect for different periods of time depending on what it is, how we use it, and how you configure your settings.

We store your personal information for as long as it is necessary to provide the Service to you and others, including those described above. We determine the appropriate retention period for personal information on the basis of the amount, nature and sensitivity of the personal information being processed, the potential risk of harm from unauthorized use or disclosure of the personal information, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitations). The time periods for which we retain your personal information depend on the purposes for which we use it. Personal information associated with your account will be kept until your account is deleted, unless we no longer need the data to provide products and services, in which case we will delete prior to you deleting your account.

You can, of course, delete your account at any time. Please note that even if your account is deleted, messages sent between teachers and parents are retained to assist schools with various recordkeeping or compliance obligations. Additionally, some content uploaded by a teacher, school leader, or parent, including photos, videos, are retained at the direction of the school (e.g., for legal compliance reasons such as maintenance of "education records" under FERPA or "Student Data" under various state student privacy laws or equivalent laws in international jurisdictions) and will not be deleted until we receive direction from the school. Please note that we may also have to retain some information after your account is deleted or closed, to comply with legal obligations, to protect the safety and security of our community or our Service, or to prevent abuse of our Terms.

Additional examples of when we may need to retain personal information after your account is deleted:

• Our contractual or business relationship with you.
• Financial recordkeeping – when you make a payment to us (e.g. for Premium Features) we are often required to retain this information for a longer period of time for purposes of account, dispute investigation and resolution, and compliance with tax, anti-money laundering, and other financial regulations.
• Direct communication with us – if you have directly communicated with us, through a customer support channel, feedback form, or bug report, we may retain reasonable records of those communications.

StartSOLE’s Commitments To Providing Transparency And Your Rights

We try to be transparent about what information we collect so that you can make meaningful choices about how it is used. You control the personal information you share with us. You may have certain rights relating to your personal information, subject to local data protection laws. Please review local data protection laws for more information. Depending on the applicable local laws these rights may include the rights set forth in this Section. You also have the right not to be discriminated against for exercising any of your rights set forth in this Section.

• Access or correct your personal information
• Control who you share information with
• Delete your Personal Information or account from StartSOLE
• Object or restrict processing
• Withdraw Consent
• Take information out of StartSOLE
• Additional information or assistance and Article 27 GDPR local representative

If you are a California resident, you may have additional rights as set forth under the California Consumer Privacy Act, as amended by the California Privacy Rights Act and its implementing regulations (collectively the "CCPA"). Please see the  "California Privacy Disclosures" for more information if you are a California resident. Additionally, if you are a resident of certain other states within the United States, you may have additional rights as set forth in the U.S. State Law Requirements Section below.

How to Exercise Your Rights

You may exercise any of these rights described in this section by making a request here once you are signed in to your StartSOLE account. Please note that we may ask you to verify your identity before taking further action on your request, for example by requiring you to provide acceptable forms of personal identification as set forth here. Your personal information may be processed in responding to these rights. We try to respond to all legitimate requests within one month unless otherwise allowed or required by law, and will contact you if we need additional information from you in order to honor your request or verify your identity. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive. If you are an employee of a StartSOLE customer, we recommend you contact your employer's system administrator for assistance in correcting or updating your information.

We may reject requests for access, change, or deletion that are unreasonably repetitive (more than two times per year for access rights), risk the privacy of others, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), or would be extremely impractical (for instance, requests concerning information residing on backup systems). Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort or if more than two times a year for access rights.

Access or Correct Your Personal Information

StartSOLE aims to provide you with easy access to any personal information we have collected about you and give you easy ways to update it or delete it, unless we have to keep that information for legitimate business purposes (e.g., we need at least an email address for your account if you maintain an account with us) or legal purposes. You have the right to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your StartSOLE account).

• Managing Your Information: If you have registered for an account on StartSOLE, you may update, correct, or delete some of your profile information or your preferences at any time by logging into your account on StartSOLE and accessing your account settings page. You may have to verify your identity before you can do that. You may also, at any time, update, correct, or delete certain personal information that you have provided to us as set forth above.
• Accessing Your Information: Upon request, StartSOLE will provide you with information about whether we hold any of your personal information, and, If you are a user of StartSOLE, you may request access to all your personal information we have on file by contacting us as set forth above. In some cases, we won't be able to guarantee complete access due to legal restrictions - for example, you will not be allowed to access files that contain information about other users or information that is confidential to us.

How Can I Delete My Personal Information or Account?

We hope you love using StartSOLE now and always. However, if for some reason you ever want to delete your account (or your child's account, if you are his or her parent), you can do that at any time by contacting us as set forth above. If you are a parent, teacher, or school leader using the Service, you may also delete your account by logging into your account and accessing your account settings page.

When you delete your account, we delete your profile information and any other content you provide in your profile (such as your username, password, email address, and profile photos) and depending on the category of user you are (i.e., teacher, school leader, parent, child, or student), the additional content or personal information uploaded for use will be deleted. Information that you have shared with others, others have shared about you, or content other users may have copied and stored, is not part of your account and may not be deleted when you delete your account. Additionally, please note that even if your account is deleted, messages or content shared between teachers and parents are retained to assist schools with various recordkeeping or compliance obligations.

We aim to maintain our Services in a manner that protects personal information from accidental or malicious destruction. Because of this, even after you update or delete personal information you have provided us from our Service, your personal information may be retained in our backup files and archives for a reasonable period of time as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a StartSOLE account for fraud or safety reasons, we may retain certain information from that account to prevent that user from opening a new account in the future. Also, we may retain and use your personal information to the extent necessary to comply with our legal obligations.

If you are a California resident, we may also retain personal information as set forth under the CCPA

Object, Restrict, or Withdraw Consent

Where you have provided your consent to the processing of your personal information by StartSOLE you may withdraw your consent at any time by changing your account settings or by sending a communication to StartSOLE specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. StartSOLE provides school leaders, parents and teachers with the opportunity to withdraw consent or 'opt-out' of receiving any future marketing communications from StartSOLE and its partners at any time. Additionally, you can always decline to share personal information with us, or even block all cookies. However, it's important to remember that many of StartSOLE's features may not be accessible, or may not function properly - for example, we may not be able to remember your language preferences for you.

In some jurisdictions, applicable law may entitle you to require StartSOLE not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing StartSOLE will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing as set forth below and pending the verification whether the legitimate grounds of StartSOLE override your own.

Access or correct your personal information

StartSOLE aims to provide you with easy access to any personal information we have collected about you and give you easy ways to update it or delete it, unless we have to keep that information for legitimate business purposes (e.g., we need at least an email address for your account if you maintain an account with us) or legal purposes. You have the right to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your StartSOLE account).

Managing Your Information: If you have registered for an account on StartSOLE, you may update, correct, or delete some of your profile information or your preferences at any time by logging into your account on StartSOLE and accessing your account settings page. You may have to verify your identity before you can do that. You may also, at any time, update, correct, or delete certain personal information that you have provided to us by contacting us at privacy@StartSOLE.com from the email used to create your StartSOLE account or by following the instructions here. We will respond to your request within a reasonable timeframe.

Accessing Your Information: Upon request, StartSOLE will provide you with information about whether we hold any of your personal information, and, If you are a user of StartSOLE, you may request access to all your personal information we have on file by contacting us as set forth above. In some cases, we won’t be able to guarantee complete access due to legal restrictions - for example, you will not be allowed to access files that contain information about other users or information that is confidential to us.

We may reject requests for access, change, or deletion that are unreasonably repetitive (more than two times per year for access rights), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems).

Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort or if more than two times a year for access rights.

How can I delete my account?

We hope you love using StartSOLE now and always. However, if for some reason you ever want to delete your account (or your child’s account, if you are his or her parent), you can do that at any time by contacting us as set forth above If you are a parent, teacher, or school leader using the Service, you may also delete your account by logging into your account and accessing your account settings page.

When you delete your account, we delete your profile information and any other content you provide in your profile (such as your name, username, password, email address, and profile photos) and depending on the category of user you are (i.e., teacher, school leader, parent, or student), the additional content or personal information uploaded for use will be deleted. Information that you have shared with others, others have shared about you, or content other users may have copied and stored, is not part of your account and may not be deleted when you delete your account. Additionally, please note that even if your account is deleted, messages or content shared between teachers and parents (or Portfolio Comments and content shared between teachers and students) are retained to assist schools with various recordkeeping or compliance obligations. Additionally, some content within a User Account, such as Student Activity and other content uploaded by the student and/or teacher, will be kept after the User Account is deleted for school legal compliance reasons (e.g., maintenance of “education records” under FERPA or “student records” under various state student privacy laws). If you would like this content deleted, please first put in a request to your (or your child’s) school. If the school determines that the request should be implemented, the school may submit the request to StartSOLE by emailing support@startsole.com.

We aim to maintain our services in a manner that protects information from accidental or malicious destruction. Because of this, even after you update or delete personal information you have provided us from our Service, your personal information may be retained in our backup files and archives for a reasonable period of time as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a StartSOLE account for fraud or safety reasons, we may retain certain information from that account to prevent that user from opening a new account in the future. Also, we may retain and use your personal information to the extent necessary to comply with our legal obligations.

If you are a California resident, we may also retain personal information as set forth under the California Consumer Privacy Act as amended and its implementing regulations (“CCPA”).

Object, Restrict, or Withdraw Consent

Where you have provided your consent to the processing of your personal information by StartSOLE you may withdraw your consent at any time by changing your account settings or by sending a communication to StartSOLE specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. StartSOLE provides parents and teachers with the opportunity to withdraw consent or ‘opt-out’ of receiving any future marketing communications from StartSOLE and its partners at any time.

In some jurisdictions, applicable law may entitle you to require StartSOLE not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing StartSOLE will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing as set forth below and pending the verification whether the legitimate grounds of StartSOLE override your own.

What Communications Will I Receive From StartSOLE?

If you registered on StartSOLE, provided an email or phone number to us, or otherwise opted-in to receive communications from us, you consent to us sending you messages and updates regarding your account and the Services, including privacy and security notices, updates regarding the Service, and information regarding products, features or services from StartSOLE or third-parties we believe you may be interested in. We do not send communications about third-party products, features or services to students or Outside Accounts. These communications may include, but are not limited to, social media updates, SMS/MMS messages, push and in-app notifications, email, and postal mail. If you have an account with us, we'll also use your email address to contact you for customer service purposes, or for any legal matters that arise in the course of business. We may receive a confirmation when you open an email from us if your device supports it. We use this confirmation to help us understand which emails are most interesting and helpful.

If you invite another person to join you on StartSOLE, by providing their email address, StartSOLE may send an invitation on your behalf to the individual via the email you provided. Prior to providing StartSOLE with email addresses or phone numbers of another person, you must ensure you have obtained consent from the person. The invitation (and any invitation reminders) may be sent via email or SMS/MMS text message. If they would prefer not to receive our communications, they may opt-out using the "Unsubscribe" or "STOP" instructions contained in those communications. You are consenting to StartSOLE (on your behalf) sending these informational text messages.

If, as a parent/legal guardian of a student, you provided an email address or phone number to your child's school, StartSOLE, at the direction of the school, may send an invitation to join StartSOLE via the email or phone number your student's teacher provided StartSOLE. The invitation (and any invitation reminders) may be sent via email or SMS/MMS text message. If, as a parent/legal guardian, you provide your telephone number to your child's school, you are consenting to StartSOLE (on behalf of and at the direction of your child's school) sending informational text messages closely related to the school's mission.

You can always unsubscribe from receiving any of our 1) marketing emails or other marketing communications whenever you'd like by clicking the "Unsubscribe" link at the bottom of the email; 2) marketing SMS texts by replying or texting 'STOP'; or 3) marketing push notifications by turning off push notifications on your device.

Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as communications about your subscriptions or event registrations, service announcements or security information.

If you reside in Canada or other jurisdictions that require opt-in consent, you may have also opted in to receive future promotional electronic communications from us. If you opt-in to receive such communications, we may use the information to: communicate with you regarding our products, services and promotions; provide you with other information that you request; and/or improve our product and service offerings. You will always have the opportunity to "unsubscribe" from us at any time by clicking the "unsubscribe" link at the bottom of the email. We provide an ongoing opportunity to unsubscribe or opt-out of contact by us as set out on our website or by contacting us by email at support@StartSOLE.org, or as otherwise described in our messages to you.

If you decide to unsubscribe, we will only contact you thereafter: (i) for the purposes allowed under applicable law; and (ii) to receive service related messages. For example, if you unsubscribe from marketing communications, it will not limit our ability to send transactional communications to you regarding products or services you have requested

Third-party Authentication Services

If you decide to register for a StartSOLE account through an authentication service, such as Google Login ("Authentication Service"), StartSOLE may collect personal information that is already associated with your account connected to the Authentication Service. If you choose to provide such information during registration, you are giving StartSOLE the permission to store and use such information already associated with your Authentication Service in a manner consistent with this Privacy Policy.

Please note, that when using an Authentication Service for registering a student (or if a student is directly using their own Authentication Service), StartSOLE will not request more information from the Authentication Service than name and email address unless specifically requested or chosen to be passed by the teacher or school to StartSOLEwhen used in connection with the Services in school. We will only use the email collected from student users for the purposes of login and account management. The Authentication Service may collect certain other information from you in your use of that particular service (such as G-Suite for Education). You may revoke StartSOLE's access to your account on any Authentication Service at any time by updating the appropriate settings in the account preferences of the respective Authentication Service. You should check your privacy settings on each Authentication Service to understand and change the information sent to us through each Authentication Service. Please review each Authentication Service's terms of use and privacy policies carefully before using their services and connecting to our Service. Your use of Authentication Service is subject to the applicable third-party terms and privacy policies.

Please note, that when using an Authentication Service for registering a student (or if a student is directly using their own authentication service), StartSOLE will not request more information from the Authentication Service than name and email address unless specifically requested or chosen to be passed by the teacher or school to StartSOLE.

Third-Party Services

The Service may contain links to websites, applications, services, or other content provided by third-parties (e.g., video players). In addition, teachers or school leaders may choose to place third-party links to outside resources for Student Users ("School Third Party Links") within their use of the Service (e.g. in a Student User's Portfolio). StartSOLE does not control or monitor any such School Third Party Links and does not encourage students to click on School Third Party Links through the product. Your use of these features may result in the collection, processing and sharing of information about you, depending on the features. Any information, including personal information, you choose to provide or that is collected by these third-parties is subject to that third-party's policies governing privacy and security and is not covered by our Privacy Policy.

These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you, including if you view a video through an embedded video player which is played off our Service, but may appear to still be playing on our Service. The fact that we link to a website or other third-party content is not an endorsement, authorization or representation that we are affiliated with that third-party, nor is it an endorsement of their privacy or information security policies or practices. We are not responsible for the content, features, privacy and security practices and policies of any third-parties. We encourage you to learn about third-parties' privacy and security policies before providing them with personal information.

Is StartSOLE a Controller?

StartSOLE processes personal information both as a Processor and as a Controller, as defined in the GDPR and/or used under the CCPA or other applicable privacy laws.

When the StartSOLE Services are used in connection with school use, StartSOLE acts as a Processor (or service provider as defined under CCPA or other applicable privacy laws) and we will process personal information, including User of student Data, only at the direction and control of the Client (for example, a school or business). Additionally, StartSOLE will only delete personal information and User or Student Data or education records per the school's specific instructions. As a student or teacher (or parent making a request about a student's personal information), you should direct any requests for access, correction or deletion of personal information through the school as further detailed here

StartSOLE will generally be the Controller when:

• Teachers, school leaders, and parents enter personal information directly into our Service when registering for an account
• Parents or Outside Accounts use our Service (including certain Premium Features) not in connection with school use

What if I’m not in the U.S.?

StartSOLE is hosted and operated in the United States. If you use the Service from the European Union or the United Kingdom, or any other region with laws governing data collection, protection and use that may differ from United States law, please note that you will be transferring your personal information outside of those jurisdictions to the United States. The personal information we or our service providers collect may be stored and processed in servers within or outside of the United States and wherever we and our service providers have facilities around the globe, and certain information may be accessible by persons or companies outside of the United States who provide services for us. Prior to transferring your personal information to the United States, StartSOLE will take appropriate steps to ensure that the personal information will be safeguarded and used only for authorized purposes set out in this Privacy Policy or in accordance with applicable laws.

If you are outside the US and require data protection provisions for your region, please contact us at suppport@startsole.org

By using the Service, you consent to the transfer of your personal information outside your home jurisdiction, including to the United States, and to the storage of your personal information in the United States, for the purpose of hosting, using and processing the personal information in accordance with this Privacy Policy. You further acknowledge that these countries may not have the same data protection laws as the country from which you provided your personal information, and that StartSOLE may be subject to access requests and be compelled to disclose your personal information to government authorities, courts and law enforcement officials outside of your home country (including the United States). If you have questions regarding our policies and practices with respect to the transfer of your personal information outside of your home country, please contact us at suppport@startsole.org.

How Can I Contact StartSOLE With Questions?

If you have any questions or concerns about this Privacy Policy, our privacy practices, or how we protect our community, please contact us at suppport@startsole.org - we'd love to help.