Privacy Policy

FERPA COMPLIANCE: This Privacy Policy incorporates all elements of the U.S. Department of Education, Privacy Technical Assistance Center (PTAC) guidance titled Protecting Student Privacy While Using Online Educational Services: Requirements and Best Practices. Updated March 2016

https://studentprivacy.ed.gov/sites/default/files/resource_document/file/TOS_Guidance_Mar2016.pdf

There are many different ways you can use UniteGPS solutions. When you share information with us, for example by creating a UniteGPS Account, we can make those solutions even better. As you use our solutions, we want you to be clear how we’re using information and the ways we protect your privacy.

Our Privacy Policy explains:

·       What information we collect and why we collect it.

·       How we use that information.

·       The choices we offer, including how to access and update information.

Your privacy matters to UniteGPS so whether you are new to UniteGPS or a long-time user, please do take the time to get to know our practices.

Information we collect

We collect information to provide better solutions to all of our users. Information includes all Personally Identifiable Information (PII) and other non-public information. Data include, but are not limited to, student data, metadata, and user content.

We collect information in two ways:

·       Information you give us. For example, many of our solutions require you to sign up for a UniteGPS Account. When you do, we’ll ask for personal information, like your name, email address, image, address, relationships (parents and their children) and telephone number. If you want to take full advantage of the sharing features we offer, we might also ask you to create a publicly visible UniteGPS Profile, which may include your name and photo.

·       Information we get from your use of our solutions. We may collect information about how you use UniteGPS solutions. User behavior within our solutions is important to the ongoing improvement of our solutions.  Examples include:

·       Device information

·       We may collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). UniteGPS may associate your device identifiers or phone number with your UniteGPS Account.

·       Log information

·       When you use our solutions or view content provided by UniteGPS, we might automatically collect and store certain information in server logs. This may include:

·       details of how you used our service, such as your search queries.

·       telephony log information like your phone number, calling-party number, forwarding numbers, time and date of calls, duration of calls, SMS routing information and types of calls.

·       Internet Protocol Address

·       device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.

·       cookies that may uniquely identify your browser or your UniteGPS Account.

·       Location information

·       When you use a location-enabled UniteGPS service, we may collect and process information about your actual location, like GPS signals sent by a mobile device. We may also use various technologies to determine location, such as sensor data from your device that may, for example, provide information on nearby Wi-Fi access points and cell towers.

·       Unique application numbers

·       Certain solutions 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 UniteGPS when you install or uninstall that service or when that service periodically contacts our servers, such as for automatic updates.

·       Local storage

·       We may collect and store information (including personal information) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.

·       Cookies and anonymous identifiers

·       We use various technologies to collect and store information when you visit a UniteGPS service, and this may include sending one or more cookies or anonymous identifiers to your device. We also use cookies and anonymous identifiers when you interact with solutions we offer to our partners or UniteGPS features that may appear on other sites.

How we use the information we collect

We use the information we collect from all of our solutions to provide, maintain, protect and improve them, to develop new ones, and to protect UniteGPS and our users. We also use this information to offer you tailored content.

We may use deidentified Data for product development, research, or other purposes. De-identified Data will have all direct and indirect personal identifiers removed. This includes, but is not limited to, name, ID numbers, date of birth, demographic information, location information, and school ID. Furthermore, Provider agrees not to attempt to re-identify deidentified Data and not to transfer de-identified Data to any party unless that party agrees not to attempt reidentification.

We may use the name you provide for your UniteGPS Profile across all of the solutions we offer that require a UniteGPS Account. In addition, we may replace past names associated with your UniteGPS Account so that you are represented consistently across all our solutions.

When you contact UniteGPS, we may keep a record of your communication to help solve any issues you might be facing. We may use your email address to inform you about our solutions, such as letting you know about upcoming changes or improvements.

We use information collected from cookies and other technologies, like pixel tags, to improve your user experience and the overall quality of our solutions. For example, by saving your language preferences, we’ll be able to have our solutions appear in the language you prefer.

We will only collect Data necessary to fulfill its duties as outlined in this Agreement.

We may combine personal information from one service with information, including personal information, from other UniteGPS solutions – for example, to make it easier to share maps with people you know.

We will ask for your consent before using information for a purpose other than those that are set out in this Privacy Policy.

We will not use Data for any purpose other than the specific purpose(s) outlined in this Agreement.

We will not perform Data mining for any purposes other than those agreed to by the parties. Data mining or scanning of user content for the purpose of advertising or marketing to students or their parents is prohibited.

We will use Data only for the purpose of fulfilling its duties and providing services under this Agreement, and for improving services under this Agreement.

UniteGPS processes personal information on our servers in many countries around the world. We may process your personal information on a server located outside the country where you live.

Transparency

People have different privacy concerns. Our goal is to be clear about what information we collect.

You may also set your browser to block all cookies, including cookies associated with our solutions, or to indicate when a cookie is being set by us. However, it’s important to remember that many of our solutions may not function properly if your cookies are disabled. For example, we may not remember your language preferences.

Information you share

We provide personal information to our affiliates or other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. Data cannot be shared with any additional parties without prior written consent of the User except as required by law.

Accessing and updating your personal information

Whenever you use our solutions, we aim to provide you with access to your personal information. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. When updating your personal information, we may ask you to verify your identity before we can act on your request.

We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), 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. We aim to maintain our solutions in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our solutions, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems.

Any Data held by UniteGPS will be made available to our clients upon request at the cost of producing the requested data.

Information we share

We do not share personal information with companies, organizations, and individuals outside of UniteGPS unless one of the following circumstances applies:

·       With your consent

·       We will share personal information with outside organizations or individuals outside of UniteGPS when we have your consent to do so.

·       With domain administrators

·       If your UniteGPS Account is managed for you by a domain administrator (for example, for UniteGPS Apps users) then your domain administrator and resellers who provide user support to your organization will have access to your UniteGPS Account information (including your email and other data). Your domain administrator may be able to:

·       view statistics regarding your account, like statistics regarding applications you install.

·       change your account password.

·       suspend or terminate your account access.

·       access or retain information stored as part of your account.

·       receive your account information in order to satisfy applicable law, regulation, legal process or enforceable governmental request.

·       restrict your ability to delete or edit information or privacy settings.

·       Please refer to your domain administrator’s privacy policy for more information.

·       For external processing

·       We provide personal information to our affiliates or other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures.

·       For legal reasons

·       We will share personal information with companies, organizations or individuals outside of UniteGPS if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

·       meet any applicable law, regulation, legal process or enforceable governmental request.

·       enforce applicable Terms of Service, including investigation of potential violations.

·       detect, prevent, or otherwise address fraud, security or technical issues.

·       protect against harm to the rights, property or safety of UniteGPS, our users or the public as required or permitted by law.

If UniteGPS is involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of any personal information and give affected users notice before personal information is transferred or becomes subject to a different privacy policy.

Information security

We work hard to protect UniteGPS and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. In particular:

·       We encrypt many of our solutions using SSL.

·       We review our information collection, storage, and processing practices, including physical security measures, to guard against unauthorized access to systems.

·       We restrict access to personal information to UniteGPS employees, contractors, and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

·       We will ensure that all Data in its possession and in the possession of any subcontractors, or agents to which the Provider may have transferred Data, are destroyed or transferred to the [School/District] under the direction of the [School/District] when the Data are no longer needed for their specified purpose, upon request.

·       We will store and process Data in accordance with industry best practices. This includes appropriate administrative, physical, and technical safeguards to secure Data from unauthorized access, disclosure, and use. The provider will conduct periodic risk assessments and remediate any identified security vulnerabilities in a timely manner. UniteGPS has a written incident response plan that includes prompt notification to clients in the event of a security or privacy incident, as well as best practices for responding to a breach of PII.

Rights and License in and to Data

Parties agree that all rights to data shall remain the exclusive property of the client and UniteGPS has a limited, nonexclusive license solely for the purpose of performing its obligations as outlined in the Agreement. This Agreement does not give UniteGPS any rights, implied or otherwise, to Data, content, or intellectual property, except as expressly stated in the Agreement. This includes the right to sell or trade Data.

Application

Our Privacy Policy applies to all of the solutions offered by UniteGPS Inc. and its affiliates, including solutions offered on other, but excludes solutions that have separate privacy policies that do not incorporate this Privacy Policy.

Enforcement

We regularly review our compliance with our Privacy Policy. We also adhere to several self-regulatory frameworks. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly.

Changes

Our Privacy Policy may change from time to time. We will not change how Data are collected, used, or shared under the terms of this Agreement in any way without advance notice to and consent. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice.