GEO LISTENING MONITORING SERVICE PRIVACY POLICY

Last Updated October 10, 2013

The Geo Listening Monitoring Service Privacy Policy (“Privacy Policy”) is a legal notice about how Geo Listening (“Geo Listening”; “we”; “our”) will use information collected by our social media Monitoring Service (“Monitoring Service”). The Privacy Policy outlines what information our Monitoring Service collects; how that information is used, disclosed and protected; and your choices about the collection and use of your information. You can find more information about Geo Listening’s other privacy policies, including the privacy policy for our mobile application, by clicking 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 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 district is responsible for its own use of the Geo Location 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

Geo Listening Monitoring Service is a social media monitoring system that enables participating school districts to locate and process publicly available information for the purposes of combating 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, our Monitoring Service aggregates and saves a record of publicly available social media information, and then filters this information to provide participating school districts with an accurate and timely report of posts that can help the districts uphold their policies relating to student conduct and safety. Geo Listening only provides the information it collects to participating school districts.

 WHAT INFORMATION IS COLLECTED

Geo Listening Monitoring Service allows participating school districts to locate and process publicly available social media content. Public content is collected and provided to participating school districts from the following websites:

·         Twitter;

·         Facebook;

·         Instagram;

·         Picasa;

·         Vine;

·         Flickr;

·         Ask.fm;

·         YouTube; and

·         Google+.

 

Information collected by our Monitoring Service from these sites can include a username, a date and timestamp, geolocation data and the full content of the public post.

 Geo Listening Monitoring Service does not monitor privatized pages, SMS, MMS, email, phone calls, voicemails or other private content.

Geo Listening Monitoring Service collects, processes, analyzes and reports only publicly available data that aligns with school district procedures and board policies related to student conduct and safety. Our Monitoring Service takes into account frequency and severity of a student’s posts that include indicators relating to the school conduct and safety categories, including bullying, cyberbullying, hate and shaming activities, depression, harm and self harm, self hate and suicide, crime, vandalism, substance abuse and truancy.

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

 HOW INFORMATION IS USED

Information collected by Geo Listening Monitoring Service that falls into one of the school conduct and safety categories is aggregated into daily reports, which our Monitoring Service provides to administrators of participating school districts. The collected information is used solely for the purpose of generating these reports. Access to these reports is restricted to school administrators, who are granted unique login credentials to access and view the prepared reports. Geo Listening does not use the collected information for any purposes other than providing our Monitoring Service to school districts.

 HOW INFORMATION IS SHARED AND DISCLOSED

To School Districts for Student Conduct and Safety Purposes

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

Acquisition or Other Transfer

If Geo Listening is acquired, all of its assets, including participating 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 our Monitoring Service 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 or disclose the information that our Monitoring Service collects to any other third parties.

 WHAT AND HOW LONG INFORMATION IS RETAINED

Geo Listening retains the information our Monitoring Service collects 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 collected information for any purpose other than providing the Monitoring Service to school districts. The collected information is destroyed when it no longer furthers the purposes stated in this Privacy Policy.

 YOUR PERSONAL CHOICES

Access To and Amending Records

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

 Geo Listening

ATTN: Data Privacy Supervisor

703 Pier Avenue, Suite B704

Hermosa Beach, CA 90254

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 collects 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 collect your posts.

SECURITY

Network Security

Geo Listening has implemented a variety of commercially standard encryption and security technologies and procedures to protect information stored in our computer system 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 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 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 collects information are not directed at children under the age of 13. Geo Listening’s indexing 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

703 Pier Avenue, Suite B704

Hermosa Beach, CA 90254

privacy@geolistening.com