GEO LISTENING MONITORING SERVICE PRIVACY POLICY

Last Updated May 3, 2018

The Geo Listening Monitoring Service Privacy Policy (“Privacy Policy”) is a legal notice about how Geo Listening (“Geo Listening”; “we”; “our”) will use information curated by our social media Monitoring Service (“Monitoring Service”). The Privacy Policy outlines what information our Monitoring Service reviews; how that information is used, disclosed and protected; and your choices about the collection and use of your information. 

 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 Trust Services Criteria (TSC), 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 or school district to engage in data privacy best practices. Geo Listening does its best to ensure that everyone that is a 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 or school district is responsible for its own use of the curated information, and Geo Listening cannot guarantee that each school or school district will abide by the data privacy best practices. Please review a school or school district’s individual terms of service and privacy policy for information on its privacy practices.

PURPOSE OF INFORMATION COLLECTION

The Geo Listening Monitoring Service is a social media monitoring service that enables participating school or school districts to review contextually relevant publicly available posts for the purposes of better meeting the social and emotional needs of students in a more timely manner. Posts help identify issues affecting schools such as bullying, cyber-bullying, hate and shaming activities, depression, harm and self-harm, self-hate, suicide, crime, vandalism, substance abuse and truancy. The criteria for each client school is derived from state guidelines regarding school safety plans, district and school policies as well as the CDC’s Youth Risk Behavior Study, available here.

To accomplish this goal, our Monitoring Service reviews publicly available social media information, and then curates this information for context to provide participating school or school district designated staff with an accurate and timely report of posts that can help them intervene on behalf of students with regard to their specific need. Geo Listening only provides the information it curates to its participating school or school district client’s designated staff members.

 WHAT INFORMATION IS COLLECTED

Geo Listening Monitoring Service allows participating school or school districts to review publicly available social media posts that are directly relevant to school/student safety and mental wellness. Public content from social networks is reviewed and provided to participating school or school districts.

Information reviewed and curated by our Monitoring Service from sites can include a student’s name, grade level, assigned school, social network usernames, date and timestamp of post(s), geo location if available via the Social Network Provider’s user interface and the full content of the public post along with the user’s profile image if no actual name is available on their page.

Geo Listening Monitoring Service does not monitor privatized social pages, text messages (SMS or MMS), email, phone calls, voicemails, browser history or other private content.

Geo Listening Monitoring Service analyzes and reports only publicly available posts that align with school or school district criteria, procedures and board policies related to school safety plans.

Geo Listening does not circumvent any personal privacy settings on any of the platforms from which it reviews content. Our Monitoring Service is intended solely to review publicly available information.

 HOW INFORMATION IS USED

Information reviewed by Geo Listening Monitoring Service that falls into one of the school safety categories is aggregated into dynamic, daily or special reports, which our Monitoring Service provides to designated administrators of participating school or school districts. The gathered information is used solely for the purpose of generating these reports. Access to these reports is restricted to school administrators, and only accessible via their respective credentials assigned by their employer (school or district) to access and view the prepared reports. As a best practice, all clients are advised to purge the reports after they are reviewed and processed in accordance with their respective policies and state law where applicable. Geo Listening does not use the gathered information for any purposes other than providing our Monitoring Service to school or school district clients.

 HOW INFORMATION IS SHARED AND DISCLOSED

To School Districts for Student and School Safety Purposes

Geo Listening shares information it curates with participating school or school districts designated staff solely to assist school districts in ensuring student safety, as identified throughout this Privacy Policy. Only the information our Monitoring Service curates for a particular participating school or school district is shared with that particular school or school district.

As Required by Law

Geo Listening will disclose 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 our website. Geo Listening will also purge any personally identifiable information (PII) regarding curated posts in accordance with any law that requires the deletion of records. PII is relevant to serving each client’s need. Once that need is met, industry best practices and existing rules of law regarding PII will be applied to any data. No PII will be maintained once a contract obligation is met and not continued. All PII that can be identified by way of school or district notification will be purged in accordance with law.

Acquisition or Other Transfer

If Geo Listening is acquired, all of its assets, including participating school or school district information, may be transferred to the acquiring company if and only if they are continuing to meet the existing contract obligations with the same business purpose. At that time, all curated 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 purge the personally identifiable information that our Monitoring Service has curated.

Other than as described above, Geo Listening does not share or disclose the information that our Monitoring Service curates with any other third parties.

 WHAT AND HOW LONG INFORMATION IS RETAINED

Geo Listening retains the information our Monitoring Service curates only for as long as necessary to accomplish the purposes of the Monitoring Service described above, or as long as permitted by law. Geo Listening does not retain the curated information for any purpose other than providing the Monitoring Service to school or school districts. The curated information is destroyed when it no longer furthers the purposes stated in this Privacy Policy or the contract term has expired without a continuing contract.

 YOUR PERSONAL CHOICES

Access To and Amending Records

You have the right to access and amend any information Geo Listening Monitoring Service may have curated on you. You may access these records by contacting the Geo Listening Data Privacy Supervisor at:

Geo Listening

ATTN: Data Privacy Supervisor

665 San Rodolfo Drive 124 B120

Solana Beach, CA 92075

privacy@geolistening.com

 

How to Opt Out

If you would like to ensure that Geo Listening Monitoring Service does not monitor the content that you post through a social media platform or profile, you should ensure that your social media posts are non-public. Our Monitoring Service only reviews publicly available information. Therefore, if a social media platform includes settings that allow you to designate your posts as private, doing so will ensure our Monitoring Service will not review your posts.

SECURITY

Network Security

Geo Listening has implemented a variety of commercially standard encryption and security technologies and procedures to protect information stored 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 stored information, but we cannot guarantee its absolute security.

Management Procedures

Geo Listening also maintains standard physical and electronic procedural safeguards that limit access to stored 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 our Monitoring Services, 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 or school districts of individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

 CHILDREN’S PRIVACY

Geo Listening, through our Monitoring Service, does not knowingly collect or solicit any information from any individual under the age of 13 absent parental or guardian consent, nor do we direct any of our business practices or system outputs towards children under the age of 13.

Geo Listening is committed to respecting the privacy of children online and ensuring that our Monitoring Service is fully compliant with the Children’s Online Privacy Protection Act (COPPA). In the event that we learn that we have collected personal information from a child under the age of 13 without verification of parental or guardian consent, Geo Listening will promptly notify the participating school district representatives and delete any personal information associated with that child as quickly as possible. 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 contact information provided.

Social media platforms are required by COPPA to employ age-gate restrictions on the use of the platforms by children under the age of 13. The social media platforms from which our Monitoring Service reviews information are not directed at children under the age of 13. Geo Listening’s review and storage of publicly available information includes information from public websites and profiles that may have in error, or with the consent of the parents, granted accounts to children under the age of 13. While we assume age-gate verification processes of third party websites are effective, and make no warranty as to the verification practices of other websites and services, we will take reasonable steps to identify and delete any records that do not comply with COPPA.

 AMENDMENTS TO THE PRIVACY POLICY

This Privacy Policy is effective as of the date identified above. Geo Listening reserves the right to amend this Privacy Policy at any time, consistent with applicable laws. Geo Listening will provide notification of changes to this Privacy Policy through the Geo Listening website.

 CONTACT US

If you have questions about Geo Listening’s privacy practices or this Privacy Policy, or to access your information or issue a complaint, you may contact our Data Privacy Supervisor:

Data Privacy Supervisor:

Geo Listening

ATTN: Data Privacy Supervisor

665 San Rodolfo Drive 124 B120

Solana Beach, CA 92075

privacy@geolistening.com