Effective Date: August 31st, 2018
Welcome to Sangha!
Sangha of Edlio LLC (“Sangha”) is provided in Canada by Scholantis Learning Systems Inc. also of Edlio LLC (“Scholantis”). Scholantis is Incorporated in British Columbia.
- Our Policy Towards Children.
The Service is intended by Sangha, for use by parents, and to only be made available to individuals who are at least 13 years old. Students, 13 years of age or older, may only use Sangha with the permission of their teacher.
Teachers may wish to interact with students on the Sangha platform. Teachers agree that all students are 13 years of age or older and you have obtained all necessary consents, including parental consent, prior to providing permission and access to the student.
If you do not qualify for eligibility, then you are prohibited from downloading, accessing, using and registering for the Service. Sangha will not collect Personal Data from any person who is actually known to us to be under the age of 13. If we become aware that a person under 13 has provided Personal Data, Sangha will take steps to remove such information and terminate that individual’s account, access and use of the Service.
If you believe that a person under 13 may have provided us personal information in violation of this paragraph, please contact us at firstname.lastname@example.org.
“We” is defined as “Sangha Inc.”.
An application programming interface or “API” is a particular set of rules and specifications that allows one software program to access and make use of another software program. It helps facilitate the interaction between applications, similar to the way the user interface facilitates interaction between humans and computers. Sangha uses APIs to enable programming or other similar third-party technologies, products, or activities available through the Application.
2.3 Cookies and other Tracking Technologies.
Cookies are small text files that web servers typically send to users’ computer when they visit a website. Cookies can be used on mobile applications as well. Cookies can be read or edited when the user loads a website or advertisement from the domain that wrote the cookie in the first place. Cookies are used by companies to collect and send information about a user’s visit – for example, number of visits to the application, average time spent, pages viewed, navigation history through the website, and other statistics. This information can be used to improve a user’s online experience by saving passwords, or allowing companies to track and improve website loading times, for instance. Cookies can also be used to track a user’s browsing or online purchasing habits and to target advertisements to specific users. Cookies cannot be used to access any other data on a user’s mobile device, to personally identify them, or to act like malware or a virus. Users who prefer not to accept cookies on the web can set their Internet browser to notify them when they receive a cookie or to prevent cookies from being placed on their hard drive. You can read more about cookies at http://www.allaboutcookies.org/cookies/. We may also use “pixel tags,” “web beacons,” “clear GIFs” or similar means (individually or collectively “Pixel Tags”) in connection with our Application to collect usage, demographic and geographical location data. A Pixel Tag is an electronic image, often a single pixel that is ordinarily not visible to users and may be associated with cookies on a user’s hard drive. Pixel Tags allow us to count users who have visited certain screens of the Application, to deliver branded Application and to help determine the effectiveness of promotional or advertising campaigns.
2.4 Personally Identifiable Information.
We define personally identifiable information (or “PII”) as “information that can be used to uniquely identify, contact, or locate a single person or can be used with other sources to uniquely identify a single individual.” e. g. name, address, social security number, e-mail address etc. This is the common industry definition used by most Internet companies. Information they call “non-PII.”
Certain Non-Personally Identifiable Information would be considered a part of your Personally Identifiable Information if it were combined with other identifiers (for example, combining your postal code with your street address) in a way that enables you to be identified. However, the same pieces of information are considered Non-Personally Identifiable Information when they are taken alone or combined only with other Non-Personally Identifiable Information (for example, your viewing preferences).
- Information Collection and Use.
Our primary goals in collecting information are to deliver the Service to you, administer your account, and to enable users to enjoy and easily navigate the Application.
3.1 What We Collect.
a. Personally Identifiable Information
i. In the course of using the Application, we will ask you to provide us with certain Personally Identifiable Information that can be used to contact or identify you and administer your account. Personally Identifiable Information includes, but is not limited to, your name, mobile number, e-mail address, school affiliate and/or student affiliation, if applicable.
b. Required Account information.
i. Please be aware that when you register with Sangha and set up an account (each “User”), you will at minimum have to download the Application onto your mobile device.
ii. We may track your mobile device using an identifier (“User ID”) assigned by Sangha. This is a number different from your unique mobile device identification (such as “UDID”) or phone number. This identifier is used to deliver notifications within the Service.
iii. No other information is required to participate; however you may choose to provide additional information such as personal or corporate email addresses, photographs, and other contact information.
c. Information regarding your use of the Application
i. Our Application also automatically collects log data about your use of the Application, for example, how you communicate with teachers, guardians, administrators, which features you use most, when you are active on the Application, when you have read communications sent through the Application, and what device you are using.
3.2 Why We Collect Your Information and How We Use It.
a. Primary Use.
We use your Personally Identifiable Information (in some cases, in conjunction with your Non-Personally Identifiable Information) mainly as follows:
i. to administer your requests;
ii. as part of our efforts to keep the Application and integrations safe and secure;
iii. to protect Sangha’s or User content rights or property;
iv. for internal operations, including troubleshooting, data analysis, testing, research and Application improvement.
b. Combined Data.
We may combine your Personally Identifiable Information with Non-Personally Identifiable Information and aggregate it with information collected from other Users to attempt to provide you with a better experience, to improve the quality of the Application and to analyze and understand how our Application is used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions.
We also use your Personally Identifiable Information to contact you with additional information about the Application that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications. We will endeavor to comply with your request as soon as reasonably practicable. Please note that if you opt-out as described above, we will be able to remove your Personally Identifiable Information from our databases or those of our third party service providers to which we have already provided your Personally Identifiable Information as of the date that we implement your opt-out request. Sangha does not share, sell, rent or trade your Personally Identifiable Information with third parties for such third party’s direct marketing purposes.
3.3 What We Share.
a. Your Contacts on the Application.
By using the Application, users that you have connected with through the Application such as Teachers, District or School Administrators, or other Guardians of your child/children will have access to the following information about you:
i. Knowledge that you use the Application when they join.
ii. You and your child/children’s names, profile picture/s and contact info.
iii. Whether you’ve volunteered for an event, signed up for material donations, information entered in the form and / or signed / declined a form, paid or not paid a payment, reserved or not reserved a parent teacher meeting slot/s or responded to auto notices.
iv. Whether you have received and viewed an event or announcement.
v. Your one on one messaging with teachers or admins.
b. Permissible Use.
While you are allowing us to use the information we receive about you, you always own all of your information. Your trust is important to us, which is why we don’t share information we receive about you with others unless we have:
i. received your permission;
ii. given you notice, such as by telling you about it in this policy; or
iii. removed your name or any other personally identifying information from it.
c. Third Party Services That You Access.
We may make your personally identifiable information available to other companies, applications or people. For example we may share:
i. Information you choose to provide in the course of your use of the Application by communicating it to other users of the Application, by being associated with an event, a child’s class or activity group communications.
ii. Information you allow us to share when you register with us, or through a subsequent affirmative election. or
iii. Information used when and if we hire or partner with third parties to provide specialized services on our behalf, such as credit card processing, data processing, customer/support services and other products or services that we choose to make available to our Users.
iv. We may share your information with a third party when we jointly offer a service or a feature with that third party, such as connectivity with other websites or applications, to provide personalization to the Application.
v. We may share your information in order to (i) protect or defend the legal rights or property of Sangha our business partners, employees, agents and contractors (including enforcement of our agreements); (ii) protect the safety and security of Sangha users or members of the public including acting in urgent circumstances; (iii) protect against fraud or risk management purposes; or (iv) comply with the law or legal process.
e. Opting-out of Sharing
You may review, have deleted and/or refuse to permit further collection or use of your information, including any student data you may have entered, by signing on to the Service and deleting the information or contacting Sangha at email@example.com. Refusing to permit further information collection or use of your information may limit or prevent your use of the Service.
- Notifications and Other Messages.
We may send you notifications and other messages using the contact information we have for you, like your operating system.
- Change of Control.
In the unlikely event that Sangha goes out of business, or files for bankruptcy, we will protect your personal information, and will not sell it to any third party.
- Aggregate Information and Non-Personally Identifiable Information.
We may share aggregated information that does not include Personally Identifiable Information and we may otherwise disclose Non-Personally Identifiable Information and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Personally Identifiable Information.
- Service Providers.
- Compliance with Laws and Law Enforcement.
Sangha cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Sangha or a third party, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate the foregoing.
- Deleting and Deactivating your Account.
All Users may delete their account. If you choose to delete your account, Sangha may retain an archive copy of your account information for up to one (1) week after which the content will be fully purged. Sangha will only retain archive copy for longer than one (1) week if required by law or by school/district or for legitimate business purposes. Users may delete their accounts by requesting their school or district to remove their contact info from Sangha. Sangha may retain an archived copy of your records as required by law or for legitimate business purposes.
Sangha is very concerned with safeguarding your information. To prevent unauthorized access, to maintain data accuracy and to ensure the appropriate use of Account Information, Sangha uses appropriate, commercially reasonable physical, technical and administrative procedures to safeguard the information we collect. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while Sangha strives to use commercially acceptable means to protect your Personally Identifiable Information, Sangha cannot guarantee its absolute security. Do not provide your Personally Identifiable Information if you are concerned with its disclosure. We do our best to keep your information secure. We try to keep the Application available, bug-free and safe, but do not make guarantees about any part of our Application.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable provincial regulations on security breach notification) to you via e-mail or conspicuous posting via the Application in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
We store data for as long as it is necessary to provide the Application to you and others, including those described above. Typically, information associated with your account will be kept until your account is deleted. For certain categories of data, we may also tell you about specific data retention practices.
- International Transfer.
Please refer to Section 13 – Your Canadian Privacy, for more information about the Canadian version of Sangha.
Identity theft and the practice currently known as “phishing” are of great concern to Sangha. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information or national identification numbers in a non-secure or unsolicited e-mail or telephone communication.
13. Your Canadian Privacy
The Canadian Sangha data centre is maintained by and for Scholantis Learning Systems Inc. a Canadian corporation incorporated in BC. Scholantis is a fully owned subsidiary of Edlio LLC.
All information provided to Sangha by you or your School District is stored in Canada.
When using Sangha to access information about a student attending a school in Canada, you will automatically be directed to use the Canadian version of Sangha. When using Sangha in Canada you will be accessing our system which is hosted in a Canada data centre. All Personally Identifiable Information stored in the system will remain in Canada.
On occasion we may need to use a third party system to relay information sent to you by your school or district via the app, email, SMS or Voice Call. While we endeavor to use third party systems also located in Canada it may be necessary to relay your Personally Identifiable Information through a third party located in another country. When this becomes necessary we will ensure that no Personally Identifiable Information is stored outside of Canada, all information will be encrypted during transport and that any logging or other information is redacted from any non-Canadian databases.
In order to identify your account as Canadian, during your first login we send your username, email or phone number to our US data centre, if it is not matched you are identified as a Canadian user and we route you to the Canadian version of our service. No personal information is stored or logged in the US Data Centre during this process, and all information is encrypted during transport.
For more information about using Sangha in Canada please contact firstname.lastname@example.org
- Contacting Sangha.
Attn: Privacy Director:
Scholantis Learning Systems Inc.
1790 Alberni Street
Vancouver, BC , CA V6G1B2