Our Commitment to Your Privacy

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Pupil Inc., operating under the name Ethiqly ("Ethiqly," "we," "our," or "us"), is committed to safeguarding the privacy and security of personal information. This Privacy Policy outlines how we collect, use, share, and retain your information through our websites ("Websites"), digital tools ("Tools"), and related services ("Services"). By accessing or using our Websites, Tools, and Services on any device ("Device"), you agree to the terms of this Privacy Policy. We may update this Privacy Policy, and your continued use of our offerings constitutes acceptance of any changes. This Privacy Policy is an integral part of our Terms of Use for the Websites, Tools, and Services.

 

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Information We Collect

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We collect various types of information to provide innovative Tools and Services and operate our business. These include:

 

Personal User Data

Personal User Data includes information that can directly or indirectly identify you as a user of our Tools or Websites. It may encompass your name, email address, telephone number, and location.

 

Tool or Service Specific Data

This category covers information provided by you to enable the functionality of our Tools or the provision of Services. Examples include personal details, account usernames, passwords, student information such as names, email rosters, and class codes.

 

Anonymous User Data

Anonymous User Data comprises information that is anonymous, aggregate, de-identified, or does not reveal your identity. Examples include school identifiers, IP addresses, browser and operating system details, and website usage statistics.

 

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How We Collect and Use Your Information

 

Services

For certain engagements, educational institutions or Schools may provide us with information required to offer the Services. This may include Tool or Service Specific Data, Personal User Data of students or staff, and access to account credentials, Devices, or systems. This information is supplied and managed by the School and is solely used to provide Services, as described in this Privacy Policy. We do not utilize student Personal User Data for ad targeting.
 

We may also collect Anonymous User Data from our Services to enhance our offerings and provide customers with additional information about our products and services.

 

Tools

When you use our Tools, you may be required to provide your email address. We refrain from collecting other Personal User Data through Tool usage, unless explicitly prompted within a Tool's dashboard for Tool and Service Specific Data. You will be presented with an ongoing opt-out option for additional information collection. Our Tools are intentionally designed not to collect Personal User Data from student users. The Tool and Service Specific Data gathered is exclusively used to grant access to paid Tool features.

 

We may collect Anonymous User Data such as the domain portion of your email address or other activity markers to analyze and report aggregate user behavior, improve our Tools, and communicate with potential customers.

 

Tools with Access to Google Services

In some cases, our Tools may request authorization from you or the domain administrator to act on your behalf within Google Platform services. This authorization process adheres to OAuth 2.0 protocols and provides our Tools with limited access to the Google Platform ("Google Services"). These Google Services may involve personal information, subject to Google, Inc.'s terms of use and data privacy policies. Unless explicitly initiated by you, no information from Google Services is shared with us, stored by us in your Google account for public access, or held in a data storage location outside your control via your Google account.

 

Websites

Our Websites may collect Personal User Data via web forms, including contact details, geographic location, and pre-sales inquiries. Visitors provide the information they wish to share. We collect Anonymous User Data based on website usage to serve current and potential customers better and enhance our Services, Tools, and Websites.

We also use cookies to compile aggregate traffic data for future improvements. These cookies do not transmit Personal User Data. You can disable cookies via your browser settings, but please note that certain website features may not function correctly without them. We do not engage in behavioral ad targeting.

 
 

How We Share Your Information
 

We will only disclose your Personal User Data or Tool and Service Specific Data with your consent or as described in this Privacy Policy or during data collection. We may share your information:

 

• Student Data: Student Personal User Data is not shared or disclosed except as authorized and directed by a child's School. Schools may authorize us to share student Personal User Data with third-party tools or applications. These third-party tools or applications are governed by their privacy policies.

• Services and Tools: In certain cases, Personal User Data or Anonymous User Data may be shared with third-party business partners whose products complement our Services, subject to the School's consent.

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

• Service Providers: We may share Personal User Data or Tool and Service Specific Data with service providers strictly for technology services such as web hosting, payment processing, and analytics. These service providers must uphold the same privacy commitments as we do, especially concerning student Personal User Data.

• As Required by Law or to Protect Rights: We may disclose your information if required by law, to protect our rights, property, or the rights and property of others, or for the prevention or detection of crime.

• Business Transfers: If we merge with another company or decide to sell or transfer part or all of our business, Personal User Data, Tool and Service Specific Data, and Anonymous User Data may be transferred. We will not transfer your Personal User Data unless the purchaser or successor entity adheres to the commitments outlined in this Privacy Policy.

 
 

How We Protect Your Information
 

Ethiqly is committed to protecting the security and privacy of your Personal User Data, Tool and Service Specific Data, and student data in Schools we serve. We adhere to applicable laws and regulations governing our Tools and Services, implementing various security measures, including:
 

• Strict administrative, technical, and physical safeguards

• Secure Socket Layer (SSL) encryption technology

• User/password credentials

• Two-factor authentication

• Industry-standard data encryption and firewalls

• Physical access controls

• Other industry-standard best practices

 

Responsibility for sharing sensitive information appropriately rests with the user when using our Tools.

 
 

Managing Your Privacy Settings and Access to Information

 

Student Personal User Data

Student Personal User Data is managed by your child's School. We will grant reasonable access to this data upon request, for reviewing or requesting changes. However, please be aware that removing or modifying information in our databases may not always be possible.

 

Opting-Out

You can opt out of sharing your Personal User Data and Tool and Service Specific Data with third-party business partners for complementary products and services. You may also opt out when prompted by our Tools to provide additional information or access tokens.

 

Access Tokens for Google Services

If you've enabled access tokens for Google Services, you can revoke them at any time in your Google Account settings.

 

Deleting or Disabling Cookies

You can manage your cookie settings in your browser to disable them. Disabling cookies may impact website functionality, especially on mobile devices.

 

Managing Your Geolocation Services

Most mobile Devices offer the ability to disable location services via the device's settings menu.

 

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Data Retention
 

We may retain Personal User Data as needed to provide Services or Tools. This data may be kept for backup, archival, audit, legal compliance, and enforcement of our Terms of Use. Access credentials associated with a School are promptly deleted upon termination. Anonymous User Data may be retained indefinitely.

 

Student Personal User Data will be retained in accordance with the retention policy outlined in the relevant terms of use, or as instructed by the child's School.

 
 

Children's Privacy

 

Services and Tools

Student Personal User Data is provided by Schools and is owned and controlled by them. Schools are responsible for compliance with COPPA and FERPA, including obtaining parental consent when collecting student Personal User Data used with our Tools.

 

Websites

We do not knowingly collect Personal User Data from children under 13 years old through our Websites. If you are under 13, please do not provide Personal User Data on our Websites. If you believe we have inadvertently collected a child's data without proper parental consent, please contact us to have it removed.

 
 

Links to Third-Party Websites, Applications, and Services
 

Our Websites and Tools may contain links to or from third-party websites, applications, or services. Our Privacy Policy does not apply to the practices of companies we do not own or control. We are not responsible for third-party privacy policies and practices. We recommend reviewing the privacy policies and terms of use of any third-party before using their services.

 
 

International Users

 

Our servers are based in the United States, and our digital operations are conducted there. Regardless of your location, you consent to having your data transferred, processed, and stored in the United States, in accordance with this Privacy Policy.

 

 

How to Contact Us
 

If you have questions about this Privacy Policy or need further information, please contact us at support@ethiqly.com

 

 

Changes to Our Privacy Policy
 

We may update this Privacy Policy periodically, and we will provide notice to our customers at least 30 days before changes take effect. If you disagree with the updated policy, the primary administrative contact for your organization can request data removal from our systems.