Last Updated: December 2019
At Circool LLC. ("Circool," "we," "us," "our"), we understand that you care about the privacy of you and your family’s data. We take your privacy seriously.
Capitalized terms not defined in this Definitions section below shall have the meaning set forth by applicable law when a citation is present.
“Agreement” means the underlying Service Agreement and related agreements between Circool and the School.
“Services” means Circool’s school event-management solutions as provided to Schools, which include, but are not limited to, a school event-notification system, school event-invite system, mobile tickets to school events, and attendee verification mechanisms.
“School” means the local education institution, school, or school district that has purchased and is using Services pursuant to an Agreement with Circool.
“Student Data” means the personally identifiable information Circool receives regarding a student of a School.
“User” means an authenticated user of Circool’s applications, products, websites, and services.
Student Data Collected:
Circool receives Student Data from Schools and Users in order to provide Services under its Agreement with the School. Circool receives personally identifiable information such as a student’s first and last name, through information provided by the User.
Circool collects Student Data and User personally identifiable information in two ways: (1) Circool integrates with the School’s Student Information System (“SIS); and (2) Users enter Student Data and User personally identifiable information through our Website.
Student Data we collect and store from the School’s SIS includes, but is not limited to the student’s and or User’s:
First and last name
Grade level (for example: first grade, second grade, etc.)
Associated guardians as listed by the School
Guardian’s associated listed children under their care under the age of 18
Guardian’s email address
User Information Collected
Users provide us with information through the Services. This information may include, but is not limited to, personal information such as your first and last name, user logon credentials, email address, phone number, profile picture, address, school district affiliation, and any other information necessary to provide Services.
If you opt to do so, and solely with your consent, Circool may access the contact list on your mobile device to allow you to connect to your contacts and to invite them to join Circool. We use your contact list solely to send invitations or messages with your explicit consent and we will never sell, transfer or rent this information. If you provide Circool with a contact’s name and email address, and/or telephone number, Circool will send the contact an email inviting the contact to visit the Services.
Cookies and Internet Tags
We may collect and process information, such as anonymous usage statistics, by using “cookies,” server logs, and other similar technology as you use the Service in order to help us improve the Services and to compile aggregate statistics about the use of Services for internal purposes. Cookies enable you to sign in to the Service and access your stored preferences and settings. If you choose to block this function, it may impair required functionality and therefore your use of the Services.
User Support. We may collect Student Data and personally identifiable information when Users communicate with User support services. By using the Service, you are authorizing us to gather, parse, and retain data related to the provision of the Service.
Persons under the age of 18 are not intended users of Circool. Circool is an invitation-only application that is restricted to parents and guardians of students, approved adult guests and staff at the schools or school districts we have contracted with.
Internal and Service-Related Usage. We use information, including Student Data, for internal and service-related purposes and may provide it to third parties to allow us to facilitate the Service. We may use and retain data we collect to provide and improve our services.
Aggregate Data. We may anonymize and aggregate data collected pursuant to the Agreement and use it for the purposes of providing Services under the Agreement and to improve our Services.
We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of the Service. We may share information, including Student Data, with our third-party transportation providers as necessary to provide the Service. If we transfer personal information to a third party, we will take reasonable and appropriate steps to ensure that the third party collects, processes and discloses personal information only for limited and specified purposes in order to provide Services under the Agreement.
No Marketing or Ownership of Student Data and User Data. We will never: 1) rent or sell any Student Data or User personally identifiable information to third parties; 2) share Student Data or User personally identifiable information with third parties for the purpose of targeted advertising; 3) use Student Data or User personally identifiable information for marketing purposes; 4) claim ownership of Student Data or User personally identifiable information.
As Required by Law and Similar Disclosures. We may access, preserve, and disclose Student Data if we believe doing so is required or permitted by law or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena or to meet national security requirements; respond to your requests; or protect yours’, ours’ or others’ rights, property, or safety.
SECURITY OF STUDENT DATA
Circool stores and processes Student Data in accordance with industry standards and applicable law. In this regard, Circool ensures Student Data is protected from unauthorized access, use, and disclosure. In the event that Circool learns that the security of Student Data has been compromised, Circool will notify you pursuant to the terms of the Agreement and as required by applicable law. Circool will attempt to notify you as promptly as possible under the circumstances of any security breach affecting Student Data that Circool believes may pose a material risk of harm.
If Circool receives notice from a School or a parent to delete or destroy Student Data, we will take steps to make sure that the deletion of Student Data complies with FERPA standards.
To protect Student Data, Circool maintains an information security program that implements appropriate physical, administrative, and technical safeguards. Circool conducts risk assessments of its information security program and remediates potential security vulnerabilities if identified.
Our Services comply with all applicable provisions of the Children’s Online Privacy Protection Act (COPPA) (15 U.S.C. 6501 et seq.). To the extent COPPA applies to the information we collect, we process such information for educational purposes only, at the direction of the partnering School and on the basis of educational institutional consent.
Jason Routson, CEO