Table of Contents
- What information we collect (and why we collect it),
- How we use and share that information,
- The choices and rights you have, including how to access, update, and delete your information.
Project Wayfinder does not place ads in its Education Services or use personal information that we collect for ad purposes, including for behaviorally-targeted advertising purposes. We do not, and will not, sell, rent or lease the personal information of students, teachers, or anyone else using our Education Services.
We hope this will help you make an informed decision about sharing personal information with us.
We’ve also added summaries below each section that provide short explanations of the legal language in plain English (it starts with ‘Basically...’) to aid in understanding. These summaries are explanatory only and are not intended to be legal binding or affect the interpretation of this Agreement.
At Project Wayfinder, we recognize that privacy is important. You should read this policy in full, but here are a few key points:
- We practice privacy by design. Everything we do, from improvements to the platform to how we train our staff, has privacy and security in mind.
- We collect limited information. Project Wayfinder collects only the minimal amount of information about students needed to sign up for the service.
- We don’t sell or rent student or user data. We never sell or rent the personal information of any student or any user.
- We use data solely for educational purposes. We only use student personal information for educational purposes.
- We don’t share any of student information with advertisers or marketers.
- We let schools, teachers, and parents control their personal information. School staff, teachers and/or students can modify and delete their information whenever they want to. They are also free to choose to discontinue use of Project Wayfinder anytime.
- We are compliant with COPPA. Project Wayfinder is fully COPPA-compliant. Schools and teachers creating accounts for children under 13 must first obtain parental consent.
- We support schools’ compliance with FERPA. Project Wayfinder's practices fully support a school's FERPA requirements.
- We will notify you if we make any material changes to our practices.
- We only work with trusted partners. We rely on service providers to help develop and support Project Wayfinder, and we require all the service providers who have access to student personal information to comply with strong privacy and security terms.
- We're committed to continuous improvement. Best practices in privacy and security evolve just as technology evolves, and we are committed to working with parents/guardians, schools, vendors, industry leaders, and partners who help us keep learning and evolving in these areas in order to help protect student personal information.
Prior to a student accessing the Education Services, the Student User’s teacher or Partner School administrator must create the Student User’s account on the Education Services. When the Partner School administrator or teacher registers its students, we rely on consent obtained from Partner Schools acting as an agent of the Student User’s Caregivers. For more information, please see the section on Children’s Privacy.
User accounts are personal to the registered user. In the event of the death of a user, the user’s account will be deactivated. Project Wayfinder cannot provide any personal information regarding the user or the account (including username and password) to any family member, next of kin or legal representative without an order from a court of competent jurisdiction compelling Project Wayfinder to do so.
4. Users of Education Services
Basically, we provide the Education Services to schools and districts. To operate our service, we need to collect and use certain personal information from users to provide them their educational services. Any personal information we collect comes with specific protections and sharing limitations.
All students who use the Program will be enrolled in a Partner School that has signed an Agreement to use Project Wayfinder’s Services, including the Education Services. Pursuant to each Agreement, each Partner School has consented to our practices regarding the collection, use, and disclosure of personal information from Student Users as permitted by law.
For Student Users, we define personal information as information that alone, or in combination with other, nonpersonal information would allow someone to identify or contact the child. This includes, but may not be limited to, all information considered to be "personal information" under the Children's Online Privacy Protection Act ("COPPA") or "personally identifiable information" under the Family Educational Rights and Privacy Act ("FERPA"). For more information, please see sections regarding FERPA and COPPA below.
Basically, we define "personal information" from students using the Education Services as any information that would allow that student to be identified or contacted by another individual. We collect this type of personal information on the Education Services so that we can provide students with educational services and use such information only for educational purposes.
5. The Information We Collect
On our Education Services, we collect two types of information about Users: 1) information voluntarily provided to us while using the Education Services (described below under “Information Provided to Us”) and (2) information collected automatically as a result of use of the site (described below under “Information Collected Automatically”). We may also receive information about Users from third-party sources as described below under “Information Received from Third Party Sources.”
Basically, Project Wayfinder asks for some information directly from teachers, school leaders, and students (such as account information), and also collects some information automatically (such as crash reports when errors occur) in order to provide with the best possible Project Wayfinder education services.
5.1. The Information Provided to Us
Licensed Users or their Partner School may choose to provide us personal information and Partner Schools may direct that personal information be provided to us by others for use in connection with our Services. Examples of such information include the following:
- Account sign up information, including name, email, and student identification number
Project Wayfinder collects the minimal amount of information from Student Users necessary to register for an account on the Service. This information is necessary to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the Service and for security and safety purposes.
Basically, we don’t require students to provide personal information beyond that which is reasonably necessary to use Project Wayfinder.
5.2. Information Collected Automatically
We may collect certain information from Users’ computers and devices as they use or engage with the Services.
To provide a personalized and high-quality experience for our users, we (or our service providers) may use various technologies that automatically record or collect certain information, including personal information, from your browser or your device about the services you use and how you use them. This information is necessary for the adequate performance of our Education Services, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the Service.
5.2.1. Device and Network Information
When you visit our Education Services, we may collect information about networks (such as language, Internet protocol (IP) addresses, internet service provider, and connection speed) and other identifiers that are automatically assigned you’re your computer or device (such as browser type and operating system).
We also collect the date and time of your use of the Services, and information about the links clicked and pages viewed within the Services.
We collect and may share this information with third parties to help diagnose problems with our servers, for security purposes, to manage the Education Services, to enhance the Education Services based on usage pattern data and, for analytics.
5.2.2. Education Services Tracking Technologies
We also use technologies such as cookies, local storage, and similar technologies to automatically collect this information to provide you with information, or to help us understand your interests. We do not use or disclose information collected through these technologies for third-party advertising purposes (including behaviorally targeting advertising to students or children) on our Education Services.
- Cookies. Cookies are small text files placed on your device consisting of a string of numbers and letters of that uniquely identifies your device. This helps us do things such as gauge engagement on content on our Education Services; or personalize content users receive in the future based on what they have previously engaged with. You may be able to have your browser block or delete cookies, but some parts of the Web Services may not work properly as a result.
Basically, we collect information about you automatically that we use to provide and improve our Education Services.
5.3. Information Received from Third-Party Sources
Additionally, we may use any aggregated anonymous information received by third parties as set forth below under the heading “Aggregated Information and Non-Identifying Information”. Local law may require you authorize the third-party to share your information with us before we can acquire it. We do not control, supervise, or respond to how third parties providing your information process your personal information, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.
Basically, we may collect some information from third-party sources, such as Google Analytics, to provide, optimize and improve our Service, communicate with you about our Service, and for security and safety reasons.
5.4. Information We Do Not Seek to Collect or Store
We do not seek to collect sensitive information about students, such as precise location or biometric data. If we become aware that such information has been provided, we will delete it within a reasonable time of such awareness.
Basically, we don't intentionally collect sensitive information through the Education Services, such as the exact location of students. If we become aware that sensitive information is on the service, we will delete it.
6. Use of Personal Information
- Provide the Education Services;
- Respond to User requests and inquiries, and manage Users’ account and provide customer service;
- Personalize the Education Services, content, and experiences for you;
- Operate, develop, analyze, evaluate, and improve Project Wayfinder’s educational sites, services, or applications;
- Perform research and analysis about your use of our Education Services or interest in Project Wayfinder Services and to develop new services;
- For safety and security reasons, such as detecting, investigating and preventing activities that may violate our policies or be illegal; and
- Perform functions as otherwise described to you at the time of collection.
Please note that we may anonymize and/or de-identify information collected through theEducation Services or via other means so that the data cannot reasonably be used to identify or contact an individual. We use de-identified information for other purposes, including research and product improvement.
Basically, we use your personal information collected from our Education Services to:
- Provide a safe, reliable, and secure Education Services experience
- Respond to requests for information
- Communicate about Education Services changes
- Offer information about Project Wayfinder services and news, and other products, services, or events we think might interest you (but you can opt-out)
To be clear, we will not:
- Include advertising in the Services including behaviorally-targeted advertising to Student Users;
- Sell, rent or lease (or authorize Service Providers to sell, rent or lease) any personal information we collect from Student Users for any purpose including for advertising and marketing purposes;
- Use the personal information we collect from Student Users for marketing purposes;
- Use (or authorize Service Providers to use) the personal information we collect from Users for the creation of commercial products or services; or Use information collected from Student Users for any purposes other than educational purposes of our Partner Schools unless we have de-identified the information such that it cannot reasonably be linked to an identifiable Student User.
Basically, we don't sell or use personal information to make money from anyone using our Services, and we require our own service providers to make the same commitment. We also don't use student personal information anything other than educational purposes. In certain cases, we may use de-identified information, (i.e., information that cannot be used to identify or contact an individual) to improve your experience on the Education Services.
7. Information Sharing
Project Wayfinder only shares personal information with other companies or individuals outside of Project Wayfinder in the following limited circumstances:
- Consent. We have your consent.
A current list of such subcontractors or third-party affiliates is available here.
- Affiliates and Partners. Over time, Project Wayfinder may grow and reorganize. We may share your information, including personal information with affiliates such as a parent company, subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
- Change of Control. If Project Wayfinder becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, your personal information may be transferred as a business asset.
- Aggregated and Non-Personal Information. We may share aggregated, non-personal information with third parties, including business advisors, for the purpose of conducting general business analysis.
Basically, we may share information collected from our Education Services in limited ways with the following parties:
- Those who need access to use the Education Services.
- Third-party authentication services that help users log-in to the Education Services.
- Third-party service providers and subcontractors that help us operate the Education Services (Note: We never sell your information and require our third party service providers, subcontractors, and third party affiliates to make the same commitment).
- Other third parties if required by law or directed by the Partner School.
- Any new owners of Project Wayfinder.
8. Deletion Requests
If you are an eligible Student User (or Caregiver of a Student User that is under the age of 18) and wish to have your (or your student’s) personal information removed from the Education Services, please contact your Partner School.
Partner Schools may request the review or deletion of their Student User information in the Services. We will delete or de-identify such information within sixty (60) days, or in compliance with applicable law, unless we otherwise have consent to retain such information or are required to retain such information to comply with our legal obligations or law enforcement requests, resolve disputes, or enforce the User Agreement, Program Agreement, (including the Data Privacy Addendum and Partner School Terms of Service), or any posted guidelines, policies or rules applicable to specific features of the Services. Such information will be deleted when it is no longer needed for the purpose for which it was retained.
Basically, schools can request that we delete student personal information on their own or parents’ behalf.
9. Data Retention
We will only retain personal information, including personal information from Users, for the time period required to support the authorized educational purposes.
If a Partner School leaves our Program or requests removal of any personal information, we will promptly direct our Staff to delete, dispose of, or de-identify the personal information. We will delete, dispose of, or de-identify the personal information within sixty (60) days following such Partner School requests unless, consistent with applicable law, there is a legitimate reason to retain such personal information.
Our normal retention period will not apply if we have consent to retain such information or if we are required to retain such information to comply with our legal obligations or law enforcement requests, resolve disputes, protect the safety and security of our Users or our Education Services, or enforce our Terms of Service, Agreement, or any posted guidelines, policies, or rules applicable to specific features of the Services.
Basically, we only keep User personal information for as long as necessary to provide the Education Services. In certain cases, we may need to keep personal information if the law requires a different duration, or as directed by the relevant Partner School.
10. Data Integrity and Security
We take appropriate security measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of, data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through our Education Services cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.
The security of your information is important to us, and we work hard to protect it from unauthorized access and use. In an effort to prevent unauthorized access, disclosure, or improper use of your information, and to maintain data accuracy, we have established physical, technical, and administrative safeguards designed to protect the personal information we collect.
We're constantly evolving our security procedures as technology changes, but our security procedures at a minimum include the following:
- Using strong authentication methods,
- Limiting who has access to personal data,
- Destroying or deleting personal information as needed,
- Using strong encryption technology,
- Using secured data backup and recovery capability,
- Maintaining industry standard software development lifecycle,
- Requiring service and analytics providers to follow similar terms.
We restrict access to personal information to Project Wayfinder employees, agents, service providers, or independent contractors who reasonably need to know that information in order to process it for us in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, potentially including termination and criminal prosecution, if they fail to meet these obligations.
If we learn of a security breach, we will attempt to notify you electronically (subject to any applicable laws) so that you can take appropriate protective steps; for example, we may post a notice on our homepage https://www.withwayfinder.com/, on the Education Services log-in page https://app.withwayfinder.com/ or elsewhere on the Education Services and may send email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
Should you discover any security bugs or vulnerabilities in our Services or have any questions regarding our data practices, please contact our team at email@example.com.
Basically, we are constantly working on ways to prevent unauthorized access and misuse of personal information through administrative, physical, and technical safeguards.
If we make any significant changes, we’ll posting a prominent notice on the Service, so you can review and make sure you know about them. Your continued use of our Education Services after we publish or send a notice about our changes to these terms means that you are consenting to the updated terms following their “effective date.” If you object to any changes, you must stop using our Education Services.
12. Communications from Project Wayfinder
As part of the functionality of the site, we require an email address from all Users. Users will receive an invitation at this email address, password reset emails, and functional emails. We may also use your email address to contact you for customer service purposes, or for any legal matters that arise in the course of business.
You can always unsubscribe from receiving any of our marketing emails or other marketing communications whenever you’d like by clicking the “Unsubscribe” link at the bottom of the email. You can also always send us an email at firstname.lastname@example.org.
Basically, we may contact you with messages and notifications about Project Wayfinder and its Services, including information about your account, privacy and security notices, and service updates.
13. Student Privacy Policies
Project Wayfinder’s Education Services, as well as applicable Terms of Service and Privacy Policies, support schools’ compliance with all applicable provisions of the Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g; 34 CFR Part 99). FERPA is a federal law that protects personally identifiable information in students’ education records from unauthorized disclosure. FERPA also affords parents the right to access their child's education records, the right to seek to have the records amended, and the right to have some control over the disclosure of personally identifiable information from the education records.
Project Wayfinder only collects and uses personally identifiable information in students’ education records for educational purposes. It shares this information only with third parties who aid in providing the Project Wayfinder Services. We do not disclose, sell, or provide any data generated by the use of our site, other than anonymous data used internally in completing technical tasks such as maintenance, security, usage and performance analysis. Additional third-party software include:
- Google Analytics: We send Google Analytics anonymized data to help us understand what features and pages are used most, including user workflows.
- MixPanel: We send MixPanel anonymized data to help analyze performance.
- Zonka: If you choose to send a response to our business surveys, that information will be stored by our vendor Zonka.
- In addition, mail is sent through our vendor SendGrid.
Caregivers or Student Users over 18 years old can make a request to access, review, correct or delete personal information in the Services by contacting the appropriate official at the Student User's Partner School. If the Partner School determines that the request should be implemented, the Partner School may either make the change themselves or ask us to make such change. We will process such Partner School requests within sixty (60) days of receiving a written request in a manner consistent with applicable law, and the terms of the Agreement.
Basically, Project Wayfinder helps schools stay fully FERPA-compliant. Caregivers and eligible students over the age of 18 may request to access, review, correct or delete personal information through the Partner School.
14. Children’s Privacy and COPPA Compliance
Our Education Services comply with all applicable provisions of the Children’s Online Privacy Protection Act (COPPA) (15 USC 6501 et seq.). COPPA is a federal law that allows parents to control what information is collected online from their children under the age of 13. COPPA generally requires companies that collect personal information online from children under age 13 to provide notice of their data collection and use practices and obtain verifiable parental consent. In the educational context, however, schools can consent on behalf of parents to the collection of student personal information, but only if such information is used for a school-authorized educational purpose and for no other commercial purpose. To the extent COPPA applies to information we collect, we process such information for educational purposes only, at the direction of the partnering school customer and on the basis of educational institution consent.
For additional information on COPPA and educational institution consent, please refer to the Federal Trade Commission’s Complying with COPPA: Frequently Asked Questions.
If we become aware that a child under 13 has provided us with personal information or that personal information has been collected from a child under 13, then we will delete this information from our files as quickly as possible. If you are the parent or legal guardian of a child under 13 who you believe has provided personal information to Project Wayfinder, please send an email to Project Wayfinder at email@example.com.
Basically, we are committed to trying to protect the personal information for students of all ages on the Education Services. As part of this commitment, we voluntarily comply with the core principles of COPPA.
15. California Residents
California residents also have specific privacy rights. For more details, see our page with Privacy Information for California Residents.
16. International Users
The Education Services is hosted and operated in the United States. If you use the Education Services from the European Union or the United Kingdom, or any other region with laws governing data collection, protection and use that may differ from United States law, please note that you may be transferring your personal information outside of those jurisdictions to the United States.
17. Contacting Project Wayfinder
You may also write to us at:
Project Wayfinder, Inc.
PO Box 2876
Berkeley, CA 94702