STUDENT PRIVACY

FINAO EDUCATION PLATFORM PRIVACY TERMS AND ADA COMPLIANCE

PRIVACY:

FINAO Education is a place wherein user's Privacy and Security are of paramount importance.  We employ best practices when it comes to the handling of member content, data, and personally identifiable information (PII); FINAO Education handles all student information in accordance with guidelines established by the US Department of Education's Privacy Technical Assistance Center (http://ptac.ed.gov) - FINAO is compliant with the rules of; Children's Internet Protection Act (CIPA), Children’s Online Privacy Protection Act (COPPA), and The Family Educational Rights and Privacy Act (FERPA).

FINAO will not sell, share, or otherwise distribute students’ information or data. “Data” includes all Personally Identifiable Information (PII) and other non-­public information. Data includes, but is not limited to, student data, metadata, and user content.

FINAO may use De-identified 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, FINAO agrees not to attempt to re‐identify de-identified Data and not to transfer de-identified Data to any party unless that party agrees not to attempt re-identification.

FINAO will not use any Data to advertise or market to students or their parents. Advertising or marketing may be directed to the [School/District] only if student information is properly de-­identified.

Data may not be used for any purpose other than the specific purpose(s) outlined in this Agreement.

FINAO provides access to student personal information to parents and students for review and correction. This can be done via the FINAO applications or through the school.

FINAO will not change how Data is collected, used, or shared under the terms of this Agreement in any way without advance notice to and consent from the [School/District].

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

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

FINAO is prohibited from mining Data 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.

Personally Identifiable data cannot be shared with any additional parties without prior written consent of the User except as required by law.

The [School/District] understands that FINAO will rely on one or more subcontractors to perform services under this Agreement. FINAO agrees to share the names of these subcontractors with User upon request. All subcontractors and successor entities of FINAO will be subject to the terms of this Agreement.

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

Parties agree that all rights, including all intellectual property rights, shall remain the exclusive property of the [School/District], and FINAO has a limited, nonexclusive license solely for the purpose of performing its obligations as outlined in the Agreement. This Agreement does not give FINAO 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.

Any Data held by FINAO will be made available to the [School/District] upon request by the [School/District].

FINAO 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.

FINAO maintains a comprehensive security program that is reasonably designed to protect the security, privacy, confidentiality, and integrity of student personal information against risks – such as unauthorized access or use, or unintended or inappropriate disclosure – through the use of administrative, technological, and physical safeguards appropriate to the sensitivity of the information.

FINAO will conduct periodic risk assessments and remediate any identified security vulnerabilities in a timely manner. FINAO will also have a written incident response plan, to include prompt notification of the [School/District] in the event of a security or privacy incident, as well as best practices for responding to a breach of PII. FINAO agrees to share its incident response plan upon request.

ADA Compliance:

ADA compliance is very important to FINAO to ensure that all users have an experience that is pleasant and of benefit.  While the ADA requirements for native Apps is still being refined we are compliant with the guidance set forth for native apps.

a.      Colors: We’ve taken great care to ensure we do not use red and green in our App.  We also use native platform technology to augment color if needed.

b.      General Accessibility: We use the wonderful built-in accessibility features for those with special needs. Features include a voice-over screen reader and zoom function for blind and low vision users, switch control, playback of closed captioned or audio described video, guided access, text to speech, and more.

For questions, please contact us as info@finaoeducation.com