Last Modified December 15, 2020
IntroductionHourglass Education Technology Solutions, LLC (“Company” or “We“) respects your privacy and is committed to protecting it through our compliance with this policy.
This policy describes the types of information we may collect from you or that you may provide when you visit the website www.hourglassets.com (our “Website“) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
Company provides applications and software (our “Applications”) to assist school districts, schools, and other educational partners (collectively referred to as “Educational Organizations”) access, use and analyze data with the goal of improving student learning outcomes (collectively, our “Service”). Educational Organizations collect information about students and their guardians, teachers, and other individuals which is then stored and processed by Company. In these situations, the Educational Organization rather than Company decides the reasons information will be collected and processed. Company’s privacy and data security practices regarding such information are governed by the contract entered into between Company and the Educational Organization and applicable law. During the course of offering certain Applications to Educational Organizations, we may have access to the personal information related to students (“Student Data”). Student Data includes “covered information” under California’s Student Online Personal Information Protection Act (SOPIPA), Cal. Bus. & Prof. Code § 22584(i) (2020). Student Data may include both de-identified and identified information, depending on the data collection methodology of the Educational Organizations. We consider Student Data to be highly confidential and special privacy policies apply to such data. We do not collect, maintain, use or share Student Data beyond that needed for authorized educational/school purposes, or as authorized by the parent/student. Please see Student Data for information about how we collect and use Student Data gathered during the provision of our Service to Educational Organizations.
This policy does not cover the practices of companies that Company does not own or control, or individuals who Company does not manage.
This policy applies to information we collect:
It does not apply to information collected by:
We will provide resources to support Educational Organizations, teachers, or parents/students to protect the security and privacy of Student Data while using the Service. In addition, we will incorporate privacy and security when developing or improving our educational products, tools, and services and comply with applicable laws.
Children Under the Age of 13Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information.
Notwithstanding the previous paragraph, during the course of providing our Service to Educational Organizations, Company may collect information from children but only at the direction of a school or educational institution for the purpose of providing the Company’s Service. Company relies on each school to obtain consent and provide appropriate disclosure, if necessary, for Company to collect any student information form students under 13, as permitted by the Children’s Online Privacy Protection Act (COPPA).
Please contact us at Hourglass@HourglassETS.com if you believe we have inadvertently collected personal information from a child under 13 without proper consents to that we may delete such information as soon as possible.
Information We Collect
We collect several types of information from and about users of our Website, including information:
We collect this information:
Information You Provide to Us
The information we collect on or through our Website may include:
You also may provide information to be published or displayed (hereinafter, “posted“) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
The information we collect automatically may include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
The technologies we use for this automatic data collection may include:
Do Not Track
Our web services do not alter, change, or respond upon receiving Do Not Track (DNT) requests or signals in browsers. As described in more detail above, we track user activity using web server logs, cookies, and similar technologies.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may also disclose your personal information:
Student Data We CollectDuring the course of offering certain applications to Educational Organizations, we may have access to Student Data. “Student Data” is any information that is directly related to an identifiable current or former student that is maintained by a school, school district, or related entity or organization, or by us. Student Data may include “educational records” as defined in the Family Educational Rights and Privacy Act (“FERPA”). We consider Student Data to be highly confidential.
Company has access to Student Data only as requested by the Educational Organization as needed to perform the Service. The type of Student Data we collect will depend on how the Educational Organization uses the Service and the particular applications we provide to the Educational Organization, but could include the following information about students and their guardians:
In many instances, we receive only de-identified or aggregate information about students from an Educational Organization, such that we would not be able to identify an individual student. From time to time, we may collect information from other sources, including from non-school sources or from the students themselves. If we combine or associate information from other sources with Student Data we collect through the Service, we will treat the combined information as Student Data under our policies and agreements. Please talk to your Educational Organization if you have questions about the type of personal information the Educational Organization provides to services like Company.
How Student Data Is Used
All Student Data that we have access to, if any, is owned and controlled by the Educational Organization. We use such data to provide the Service to the Educational Organization and for other limited purposes permitted by our agreements with the Educational Organizations, such as to evaluate, improve, and develop our products, applications and services. We will never use Student Data for marketing purposes or to engage in targeted advertising.
Company only shares Student Data in a few limited circumstances, as described below.
We do not rent or sell Student Data. We do not use or disclose Student Data for behavioral targeting of advertisements to students. We do not build personal profiles of students other than for supporting authorized educational purposes or as authorized by the parent or student.
We will not knowingly retain student personal information beyond the time period required to support the authorized educational purposes, or as authorized by the parent or student.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
Storage of Your InformationYour information collected through the Website may be stored and processed in the United States or any other country in which Company or its subsidiaries, affiliates or service providers maintain facilities. If you use our Website, you consent to have your data transferred to the United States or anywhere else Company maintains facilities.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.
Your California Privacy RightsCalifornia Civil Code Section 1798.83 permits residents of the State of California to request from certain businesses with whom the California resident has an established business relationship a list of all third parties to which the business, during the immediately preceding calendar years, has disclosed certain personally identifiable information for direct marketing purposes. For more information on how to submit a request, please contact us at the phone number or mailing address listed on our Website.
Accessing and Correcting Your InformationYou can review and change your personal information by logging into the Website and visiting your account profile page.
You may also send us an email at Hourglass@HourglassETS.com to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Student Data is provided and controlled by the Educational Organizations. If you have any questions about reviewing, modifying, or deleting personal information of a student, please contact your Educational Organization directly. Requests sent to Company regarding such information will be forwarded directly to the appropriate Educational Organization.
If the information was provided through the Educational Organization, we will assist the Educational Organization with such request.
Data SecurityWe have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure through the use of administrative, technological, and physical safeguards appropriate to the sensitivity of the information. The specific measures Company takes to secure your information are defined by the contract between Company and your Educational Organization.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Links to Other Websites and ServicesFrom time to time, we may provide links to third parties from our Website. We are not responsible for the practices employed by websites, applications or services linked to or from our Website. We recommend that you review the privacy policies of third-party sites or services before providing any information to them.
Hourglass Education Technology Solutions, LLC7349 N Via Paseo Del Sur, #515-114Scottsdale, AZ 85258480-999-2235Hourglass@HourglassETS.com
7349 N Via Paseo Del Sur#515-114Scottsdale, AZ 85258
Phone: (480) 999-2235
Fax: (480) 546-5051
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