GEO LISTENING MOBILE APPLICATION PRIVACY POLICY
Last Updated October 10, 2013
This Geo Listening Mobile Application Privacy Policy (“Mobile Privacy Policy”) is a legal notice about how Geo Listening (“Geo Listening”; “we”; “our”) will use information collected by our Geo Listening mobile application (“Geo Listening App” or “App”). The Mobile Privacy Policy describes why and what information the App collects; how information is collected, used, disclosed and protected; and choices about the collection and use of student information. Geo Listening also collects and uses publicly available information through the Geo Listening Monitoring Service. You can learn more about our Monitoring Service Privacy Policy here.
DATA PRIVACY BEST PRACTICES
While there is no comprehensive framework in the United States regulating data privacy practices on the Internet, Geo Listening has modeled its privacy policy on the data privacy best practices promulgated by the Federal Trade Commission’s Fair Information Practices Principles, currently available here, the Generally Accepted Privacy Principles (GAPP), available here, and the Organization for Economic Co-operation and Development’s (OECD) Guidelines on the Protection of Data Privacy, available here.
Additionally, Geo Listening proactively encourages each participating school district to engage in data privacy best practices. Geo Listening does its best to ensure that everyone that is part of the Geo Listening ecosystem is aware of these practices and has received concrete guidance concerning implementation of such practices. Of course, each participating school district is responsible for its own use of the Geo Listening platform, and Geo Listening cannot guarantee that each school district will abide by the data privacy best practices. Please review a school district’s individual terms of service and privacy policy for information on its privacy practices.
PURPOSE OF INFORMATION COLLECTION
The Geo Listening App is a mobile application used by students (“student users”) that enables student users to report instances of bullying, cyberbullying, hate and shaming activities, depression, harm and self harm, self hate and suicide, crime, vandalism, substance abuse and truancy.
To accomplish this goal, the Geo Listening App collects and shares with participating school districts information voluntarily provided by student users. Geo Listening uses this information to assemble accurate and timely reports for participating school districts that can help the school districts uphold their policies relating to student conduct and safety.
WHAT INFORMATION IS COLLECTED
The Geo Listening App only collects information that student users voluntarily provide. Specifically, the Geo Listening App collects information voluntarily provided by students when they register as student users (“Registration Information”). The Geo Listening App also collects information voluntarily provided by student users when they report incidents using the App (“Report Information”). Both Registration Information and Report Information may include Personally Identifiable Information including, without limitation:
· Name;
· Email address;
· Parent’s email address;
· Date of birth;
· Grade level;
· IP address;
· Geolocation data; and
· Photos or videos submitted by the student user.
Student users may submit incident reports via the Geo Listening App without providing identifying information. Reports submitted without a name, email address or other identifying information will be provided to participating school districts anonymously. Anonymous Report Information will not be associated with non-anonymized Registration Information.
HOW INFORMATION IS USED
During the App registration process, student users select the participating school district to which their voluntarily provided information pertains. Geo Listening provides all Report Information, and some Registration Information, collected by the Geo Listening App to the administration of the participating school district selected by the student user. Geo Listening uses Registration Information internally to manage user accounts and to perform basic business services associated with providing accurate incident reports to school districts. Geo Listening does not use any information collected by the Geo Listening App for purposes other than providing timely and accurate incident reports to participating school districts.
HOW INFORMATION IS SHARED AND DISCLOSED
To School Districts for Student Conduct and Safety Purposes
Geo Listening shares Report Information, and some Registration Information, with participating school districts solely to assist those school districts in ensuring student conduct and safety. Information submitted by a student user is only shared with the participating school district selected by the student user at the time the student registers on the App.
As Required by Law
Geo Listening discloses information where required by law and when Geo Listening believes disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order or legal process served on Geo Listening..
Acquisition or Other Transfer
If Geo Listening is acquired, all of its assets, including school district and student information, may be transferred to the acquiring company. At that time, all collected information may become subject to the acquiring company’s privacy policy. In addition, in the event that Geo Listening must liquidate its assets due to bankruptcy or other event, Geo Listening will consider the information the Geo Listening App has collected, including personally identifiable information, as a unique asset subject to sale or other transfer.
Other than as described above, Geo Listening does not share information collected by the App with any other third parties.
WHAT AND HOW LONG INFORMATION IS RETAINED
Geo Listening retains the information collected by the Geo Listening App only for as long as necessary to accomplish the purposes of the App as described above, or as long as permitted by law. Geo Listening does not retain the collected information for any purposes other than providing timely and accurate reports to school districts. The collected information is destroyed when it no longer furthers the purposes stated in this Mobile Privacy Policy.
SECURITY
Account Protection
Geo Listening cares about the security of student user information and uses commercially reasonable safeguards to preserve the integrity and security of all information collected through the Geo Listening App. To protect privacy and security, Geo Listening takes reasonable steps to authenticate a student’s identity before granting that student access to his or her own personal accounts. Geo Listening also uses authentication procedures to ensure only approved school district administrators have access to relevant student information consistent with this Mobile Privacy Policy.
Student users and school administrators are responsible for maintaining the secrecy of their unique passwords and account information, and for controlling access to their communications on the App at all times.
Network Security
Geo Listening implemented a variety of commercially standard encryption and security technologies and procedures to protect information stored in our computer systems from unauthorized access. Please be aware that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Geo Listening strives to use commercially acceptable means to protect all collected information, but we cannot guarantee its absolute security.
Management Procedures
Geo Listening also maintains standard physical and electronic procedural safeguards that limit access to collected information to our employees (or people working on our behalf and under confidentiality agreements) who, through the course of standard business activities related to the Geo Listening App, need to access the information.
Compromise of Information
In the event that any information under Geo Listening’s control is compromised as a result of a breach of security, Geo Listening will take reasonable steps to investigate the situation and where appropriate, notify participating school districts and those individuals whose information may have been compromised and take further steps, in accordance with any applicable laws and regulations.
STUDENTS’ PERSONAL CHOICES
Control Over Account Information
A student user may update the student’s account information and email communication preferences at any time by logging into the student’s account and changing the profile settings. A student user may not opt out of service-related communications (e.g., account verification, reminders, changes/updates to features of the Service, technical and security notices). If a student user has any questions about reviewing or modifying the student’s account information, the student user can contact Geo Listening directly at the contact information provided below.
Access To and Amending Records
A student has the right to access and amend any information that the Geo Listening App may have collected on that student. The student may access these records by contacting the Geo Listening Data Privacy Supervisor listed below.
How to Opt Out
The Geo Listening App only collects information that a student user voluntarily provides to the App. Therefore, if a student user wishes not to have any of his or her information collected, the student user may terminate his or her account, either directly through the App or by contacting our Data Privacy Supervisor at the address listed below. Additionally, a student user may contact our Data Privacy Supervisor to prevent the collection and/or use of certain information by Geo Listening.
CHILDREN’S PRIVACY
Geo Listening is committed to respecting the privacy of children online and ensuring that the Geo Listening App is fully compliant with the Children’s Online Privacy Protection Act (COPPA). As an organization dedicated to student safety, we are sensitive to the vulnerabilities and risks that children face online.
Accordingly, Geo Listening employs age-restriction safeguards to obtain parental consent prior to collection of information on children under 13. When a student registers, he or she is required to enter his or her parent or guardian’s email address. Geo Listening will send the parent or guardian a notification outlining the nature of the App, the type of data the App collects and the parent or guardian’s right to access, amend and delete data collected by the App.
In the event that we discover the Geo Listening App collected personal information from a child under age 13 without parental or guardian consent, Geo Listening will promptly delete any personal information associated with that child as quickly as possible. As is the case with all students, the Geo Listening App does not require a child under the age of 13 to provide more personal information, as a condition of participation, than is reasonably necessary to participate in the App and Geo Listening services.
If you believe that we might have unauthorized information from or about your child who is under the age of 13, please contact our Data Privacy Supervisor at the address listed below.
AMENDMENTS TO THIS MOBILE PRIVACY POLICY
This Mobile Privacy Policy is effective as of the date identified above. Geo Listening reserves the right to amend this Mobile Privacy Policy at any time, consistent with applicable laws. Geo Listening will provide notification of changes to this Mobile Privacy Policy through the Geo Listening App.
CONTACT US
If you have questions about Geo Listening’s privacy practices or this Mobile Privacy Policy, or to access your information or issue a complaint, you may contact our Data Privacy Supervisor:
Geo Listening Data Privacy Supervisor:
Geo Listening
ATTN: Data Privacy Supervisor
703 Pier Avenue, Suite B704
Hermosa Beach, CA 90254