Software
Privacy
Policy

Effective Date: October 17, 2023

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Our Commitment to Your Privacy

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Pupil Inc., operating under the name Ethiqly, understands the importance of safeguarding personal information and respects the privacy of the educational institutions, students, teachers, and administrators that we serve, as well as the visitors to our websites. This Privacy Policy outlines how we collect, use, share, and retain your information through various digital channels. By using our services, websites, and tools, you agree to the terms of this Privacy Policy. We may update this policy periodically, and your continued use constitutes acceptance of any changes. This Privacy Policy is an integral part of our Terms of Use.

Geographic Scope of Our Services

As of October 17, 2023, our services are not available to customers in Europe due to compliance with the General Data Protection Regulation (GDPR) requirements. European users who have installed our services are advised to discontinue their use. We remain committed to data-handling practices in accordance with North American laws and FERPA standards.

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Information We Collect

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We collect information to provide our innovative tools and services and to operate our business. This includes Personal User Data, Tool or Service Specific Data, and Anonymous User Data:

• Personal User Data: Information that identifies you as a user, including but not limited to your name, email address, telephone number, and location.

• Tool or Service Specific Data: Information provided as part of tool functionality or service provision, such as account details, usernames, passwords, and student information.

• Anonymous User Data: Data that is anonymous, aggregated, or de-identified and does not reveal your identity, such as IP addresses, browser information, website traffic, and usage statistics.

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How We Collect and Use Your Information

Services

For our services, schools may provide us with information required to provide the services, which may include Personal User Data, Tool or Service Specific Data, and access to systems containing such data. We use this information solely for providing services in accordance with this Privacy Policy, and we do not use student Personal User Data for targeted advertising.

We may also collect Anonymous User Data from our services to enhance the services and provide information to our customers.

Tools

When using our tools, you will be required to provide your email address. We do not collect additional Personal User Data through tool usage, except when specifically prompted for participation. Any data collected is used exclusively to provide access to paid features.

Tools with Access to Google Services

Our tools may require authorization from users or domain administrators for access to Google Services. Any information shared with our tools through this authorization is subject to Google's terms of use and data privacy policies.

Websites 

From visitors to our websites, we may collect Personal User Data via web forms, including contact information and geographic location. We also gather Anonymous User Data from website usage, such as browser type and page interaction. Cookies may be used for aggregated traffic data but do not transmit Personal User Data.

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How We Share Your Information

We only share Personal User Data or Tool and Service Specific Data in specific circumstances, such as with your consent or when necessary for transaction completion, service provision, or as described in this Privacy Policy. Some scenarios where data may be shared include:

• Student Data: Student Personal User Data is shared only as authorized and directed by the respective school. The practices of third-party tools or applications authorized by schools are governed by their own privacy policies.

• Services and Tools: Personal User Data may be shared with third-party partners whose products complement our services, but only to enable us to provide the services.

• Advertising: We do not share Personal User Data for advertising purposes.

• Service Providers: Personal User Data may be shared with service providers strictly for the purpose of performing their work for us.

• As Required by Law or to Protect Rights: We may disclose data if required by law or to protect our rights, property, or the rights and property of others.

• Business Transfers: In the event of a merger or business transfer, your data may be transferred along with our other assets, subject to the commitments in this Privacy Policy.

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How We Protect Your Information

We are committed to protecting the security and privacy of Personal User Data and Tool and Service Specific Data. We employ various safeguards, including administrative, technical, and physical measures, to secure data against unauthorized access, theft, and loss. Data transmission between your device and our servers is encrypted using industry-standard Secure Socket Layer (SSL) technology. User credentials and two-factor authentication are also utilized.

Please note that data sharing features in our tools are the responsibility of the user, and it's important to handle sensitive information appropriately.

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Managing Your Privacy Settings and Access to Information
 

• Student Personal User Data: Student data is controlled by the respective school. Upon request, we can grant access to Personal User Data about a student for review or modification.

• Opting Out: You may opt out of sharing Personal User Data and Tool and Service Specific Data with third-party partners when prompted.

• Access Tokens for Google Services: If you've enabled access tokens for Google Services, you can revoke these at any time from your Google Account settings.

• Deleting or Disabling Cookies: You may disable cookies in your browser settings, but this may affect the functionality of our websites.

• Managing Geolocation Services: Most mobile devices offer controls to disable location services.

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Data Retention

We retain Personal User Data for the time required to provide services or tools. In some cases, data may be retained for backup, archival, legal compliance, or to enforce our Terms of Use. Anonymous User Data may be retained indefinitely. Student Personal User Data is retained as per the terms of use and the school's instructions.

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Children's Privacy

(a) Services and Tools: Schools are responsible for ensuring compliance with COPPA and FERPA, including obtaining parental consent for students under the age of 13 to use our tools.

(b) Websites: We do not knowingly collect Personal User Data from children under the age of 13 through our websites.

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Links to Third-Party Websites, Applications, and Services

This Privacy Policy does not apply to third-party websites, applications, or services linked on our platforms. We recommend reviewing the privacy policies and terms of use of any third-party site or service.

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International Users

By using our services, you consent to the transfer, processing, and storage of your data in the United States, where our servers are located. This Privacy Policy governs your data usage in accordance with U.S. laws.

How to Contact Us

For questions or more information about this Privacy Policy, please contact us at support@ethiqly.ai.

Changes to Our Privacy Policy

We may update this Privacy Policy, and customers will be notified at least 30 days prior to any material changes taking effect. If you disagree with the changes, you can request the deletion of your data.