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Text Content

 * Products
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      schools to trouble
   
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      in any environment
   
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      with Apple devices
   
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      made easy

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PRIVACY POLICY

For privacy notices regarding Securly Classroom, please refer to the Securly
Classroom Privacy Policy.

--------------------------------------------------------------------------------

Last updated: October 2021

Securly, Inc. (“we,” “our” or “us”) recognizes the importance of privacy. This
Privacy Policy describes how we collect, store, use and disclose, or otherwise
process (collectively “process”) information, including personal information,
that we obtain about visitors and users of our website www.securly.com (the
“Site”) as well as users of our software and related services including the
Securly Parent Portal and mobile applications (collectively, the “Services”).

This Privacy Policy does not apply to (and for purposes of this Policy
“Services” does not include) the personal information that we process on behalf
of school and other institutional customers that use our services. For school
and other institutional customers, we process personal information as a data
processor or service provider under applicable laws, only on behalf of the
schools that we serve. Any personal information we collect about students who
are children under 13 years old or that is processed on behalf of our school
institutional customers will be treated in accordance with our Student and COPPA
Privacy Policy as well as our Terms of Use and is also subject to the policies
and practices of the institution on whose behalf we are processing the
information.

For the purposes of this Privacy Policy (“Policy”), “you” and “your” refers only
to you as the visitor to our Site or user of our Services. By using our
Services, you acknowledge that you have been given this notice about how your
information, including personal information, will be handled as described in
this Policy. Your use of the Services, and any dispute over privacy, is subject
to this Policy and our Terms of Use including any applicable limitations on
damages and resolution of disputes. The Terms of Use are incorporated by
reference into this Policy.

We process your personal information as set forth in this Policy or otherwise
with your consent or as permitted or required by law. In case we base our
Processing of your personal information on your consent, you may withdraw your
consent at any time. However, withdrawing consent may result in our inability to
continue providing you with some or all of the Services.

With respect to the personal information that is subject to this Privacy Policy,
Securly, Inc and Securly Ltd. are the controllers of your personal information.


1. INFORMATION WE COLLECT ABOUT YOU

We may collect information, including personal information (as defined by
applicable privacy law), directly from you, from third parties such as your
child’s school, or automatically though your use of the Services. We may combine
certain information we collect from these various sources

Information We Collect Directly from You.

We collect information (including personal information) from you directly as set
out below.

Account and Registration Information. We collect personal information from you
when you sign up for an account with us, including your name and email address.
We may also ask or allow you to submit additional account information, such as
your phone number, student name, student school, location of school. You may
browse parts of our Site without creating an account, however, if you would like
to use Securly’s Services, we ask you to create an account.

Customer Support. We collect personal information you provide, when you submit a
request through our Site, such as your email address, or if you otherwise
contact our customer support services via email, phone, or chat, related to your
enquiry or complaint. We keep a copy of such records in our customer files.

Newsletters and Updates. You can also sign up to receive emails and offers from
us by submitting your name, email address, and zip code or area code. For
information on how to opt-out of receiving newsletters and updates via email
please see below.

Other Information We Collect Regarding Your Usage of Our Services. We collect
personal information about your use of our Services, such as your purchase
history, online related activity such as sites visited, online searches and
videos watched, email content, email address, and geolocation information.

Information We Collect from Third-Party Sources We may also collect information
about you from third parties, which we append to the information we have
collected.

Information We Collect Automatically.We automatically collect information about
you through your use of our Services, including log files, IP address, app
identifier, advertising ID, location info, browser type, device type, domain
name, the website that led you to our Services, the website to which you go
after leaving our Services, the dates and times you access our Services, and the
links you click and your other activities within the Services (“Usage Data”). If
you authorize us to collect your geolocation information, we will collect it
while our App is running on your device. You can disable our access to your
location services by changing your device’s location settings. For more
information please see the Cookie and Other Tracking Mechanisms Section further
below.


2. PURPOSES AND LEGAL BASES OF USE

Certain laws, including the EU General Data Protection Regulation (“GDPR”),
require that we inform you of the legal bases for our processing of your
personal information. Pursuant to the GDPR (and other similar laws), we process
personal information for the following legal bases:

Performance of Contract: as necessary to enter into or carry out the performance
of a contract with you, for example creating your customer account and
processing your payments, or with a school or other institutional customer.

Our Legitimate Business Interests: in furtherance of our legitimate business
interests, which are not overridden by your interests and fundamental rights,
including:

 * Performance of contracts with customers and other parties
 * Implementation and operation of support services for our business operations
 * Improving our Site and Services, developing reports, and similar purposes
 * Customer relationship management and improving our Site and Services,
   including other forms of marketing and analytics
 * Fraud detection and prevention, including misuse of Services
 * Physical, IT, and network perimeter security
 * Internal investigations
 * Mergers, acquisitions, and reorganization, and other business transactions,
   including related negotiations

Compliance with Laws: for compliance with legal obligations and/or defense
against legal claims, including those in the area of labor and employment law,
social security, and data protection, tax, and other corporate compliance laws.

With your consent: where we have your consent - for example for some forms of
direct marketing, or for the setting of certain cookies - (the GDPR (where it
applies)) and other applicable laws give you the right to withdraw your consent,
which you can do at any time by contacting us using the details set out at the
end of this Policy.

Vital Interest: In addition, in rare cases we may process your personal
information where necessary to protect the vital interests of any individual.


3. HOW WE USE YOUR INFORMATION

Providing and Improving Services. To provide you with, maintain, and improve our
Services; to develop new features, products, or services; to perform technical
operations, such as updating software; to authenticate you as a valid user; to
help train our Services to avoid false positives and bias; to prevent fraudulent
activity on our platform; and for other customer service purposes. (Legal bases:
performance of our contract with you; and/or our legitimate interests).

Responding to requests. To respond to your enquiries, fulfill your orders and
requests. (Legal basis: performance of our contract with you).

Personalizing Content and Ads. We may use the information we collect about you
to personalize the information and content we display to you, including to
tailor the content and information that we may send or display to you, and to
otherwise personalize your experiences while using Services, including providing
you with more relevant ads. (Legal basis: our legitimate interests).

Marketing and Communications. We do not use information about students for any
marketing purpose. We may use information about teachers and other school
personnel as well as parents and other adults to communicate with you about your
account and use of our Services; to send you product or service, updates; to
respond to your inquiries; to provide you with news, special offers, promotions,
and other information we think may interest you; and for other informational,
marketing, or promotional purposes. Our communications with you may include
communications via email. Please see our section regarding Your Choices for more
information about how to change your communications preferences. If you are
located in a jurisdiction that requires opt-in consent to receive electronic
marketing messages, we will only send you such messages if you opt-in to receive
them. We do not use personal information to market to students or children.
(Legal bases: our legitimate interests; and/or with your consent).

Research and Analytics. To analyze how you interact with our Services; to
monitor and analyze usage and activity trends; and for other research,
analytical, and statistical purposes. (Legal basis: our legitimate interests).

Protecting Our Legal Rights And Preventing Misuse. To protect the Site and our
business operations; to prevent and detect fraud, unauthorized activities and
access, and other misuse; where we believe necessary to investigate, prevent or
take action regarding illegal activities, suspected fraud, situations involving
potential threats to the safety or legal rights of any person or third party, or
violations of our Terms of Use or this Policy. (Legal bases: our legitimate
interests; and/or compliance with laws)

Complying with legal obligations. To comply with the law or legal proceedings.
For example, we may disclose information in response to subpoenas, court order,
and other lawful requests by regulators and law enforcement, including
responding to national security or law enforcement disclosure requirements.
(Legal bases: our legitimate interests; and/or compliance with laws)

Related to our general business operations: to consider and implement mergers,
acquisitions, reorganizations, and other business transactions, and where
necessary to the administration of our general business, accounting,
recordkeeping and legal functions. (Legal bases: our legitimate interests;
and/or compliance with laws)

Aggregate, De-identified or Anonymous Data. We also create and use aggregate,
anonymous and de-identified data to assess, improve and develop our business,
products and services, and for similar research and analytics purposes. This
information is not generally subject to the restrictions in this Policy,
provided it does not identify and could not be used to identify a particular
individual.


4. HOW WE DISCLOSE YOUR INFORMATION

In general, we disclose the personal information we collect as follows:

 * Affiliates. We may share your personal information with our affiliates, whose
   handling of personal information is subject to this Policy.
 * Service Providers. We may disclose the information we collect from you to our
   third-party vendors, service providers, marketing partners, third parties,
   contractors or agents who perform functions on our behalf so we can provide
   you with the Services. These may include companies who send emails to our
   customers and prospective customers; help us to track email response rates,
   views and forwards; to serve visitor advertisements and to provide
   advertisements about products of interest to them; and to collect data about
   how customers and prospective customers interact with our products over time.
 * Business Transfers. We may disclose information to another entity in
   connection with, including during negotiations of, an acquisition or merger,
   sale or transfer of our assets, a, bankruptcy proceeding or as part of any
   other similar business transfer, including during negotiations related to
   such transactions.
 * In Response to Legal Process. We also may disclose the information we collect
   from you in order to comply with the law, a judicial proceeding, court order,
   or other legal process, such as in response to a court order or a subpoena.
 * To Protect Us and Others. We also may disclose the information we collect
   from you where we believe it is necessary to investigate, prevent, or take
   action regarding illegal activities, suspected fraud, situations involving
   potential threats to the safety of any person, violations of our Terms of Use
   or this Policy, or as evidence in litigation in which we are involved.
 * Aggregate and De-Identified Information. We may share aggregate or otherwise
   de-identified information about users with third parties for marketing,
   advertising, research or similar purposes.


5. USE OF COOKIES AND OTHER TRACKING MECHANISMS

We and our third-party service providers may use cookies, log files, Web beacons
and other tracking mechanisms to track information about your use of our
Services. We and our third-party service providers use cookies and other
tracking mechanisms to track information about your use of our Services. We may
combine this information with other personal information we collect from you
(and our third party service providers may do so on our behalf).

Cookies. Cookies are alphanumeric identifiers that we transfer to your
computer’s hard drive through your web browser for record-keeping purposes. Some
cookies allow us to make it easier for you to navigate our Site and Services,
while others are used to enable a faster login process or to allow us to track
your activities at our Site and Service. There are two types of cookies: session
and persistent cookies.

Disabling Cookies. Most web browsers automatically accept cookies, but if you
prefer, you can edit your browser options to block them in the future. The Help
portion of the toolbar on most browsers will tell you how to prevent your
computer from accepting new cookies, how to have the browser notify you when you
receive a new cookie, or how to disable cookies altogether. Visitors to our Site
who disable cookies will be able to browse certain areas of the Site, but some
features may not function. Please keep in mind that without cookies you may not
have access to certain features of our products and services on this site,
including access to your account or profile and certain personalized content.

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with
a unique identifier, similar in function to cookies. In contrast to cookies,
which are stored on your computer’s hard drive, clear GIFs are embedded
invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or
pixel tags), in connection with our Services to, among other things, track the
activities of Site visitors, help us manage content, and compile statistics
about Site usage. We and our third party service providers may also use clear
GIFs in HTML e-mails to you, to help us track e-mail response rates, identify
when our e-mails are viewed, and track whether our e-mails are forwarded.

Third Party Analytics. We use automated devices and applications, such as Google
Analytics, to evaluate usage of our Site and our Services. We also may use other
analytic means to evaluate our Services. We use these tools to help us improve
our Services, performance and user experiences. These entities may use cookies
and other tracking technologies to perform their services.

Geolocation Information. We may use geolocation information for the purpose of
administering our Services to you.

Do-Not-Track Signals. Our Site does not currently respond to do-not-track
signals. For more information about do-not-track signals, please click here. You
may, however, disable certain tracking as discussed in the Cookies and Other
Tracking Mechanisms section above (e.g., by disabling cookies).


6. `INTEREST-BASED ADVERTISING

We may work with third parties such as network advertisers to assist us in
displaying advertisements on third-party websites, and to evaluate the success
of our advertising campaigns. We may use information about your visit to our
Site for these purposes; however, we do not use personal information collected
from the Services for these purposes.

You may opt-out of many third-party ad networks, including those operated by
members of the Network Advertising Initiative (“NAI”) and the Digital
Advertising Alliance (“DAA”). For more information regarding this practice by
NAI members and DAA members, and your choices regarding having this information
used by these companies, including how to opt out of ad networks operated by NAI
and DAA members, please visit their respective websites:

Canada: http://youradchoices.ca
EU: http://youronlinechoices.eu
US: http://aboutads.info; https://optout.networkadvertising.org/

Opting-out of participating ad networks does not opt you out of being served
advertising. You may continue to receive generic or “contextual” ads on our
Services for example, based on the particular website that you are viewing
(i.e., contextual advertising). You may also continue to receive targeted ads on
other websites, from companies that do not participate in the above programs.
Please note, that opt-out mechanisms are cookie based; so, if you delete
cookies, configure your browser to block, or reject cookies or use another
device, your opt-out will no longer be effective.


7. INTERNATIONAL TRANSFERS

Securly, Inc. is headquartered in the United States of America and has
operations and service providers in the United States and other jurisdictions.
As such, we and our service providers may transfer your personal information to,
or access it in, jurisdictions (including the United States, India, and Mexico)
that may not provide levels of data protection equivalent to your home
jurisdiction. We will take steps to ensure that your personal information
receives an adequate level of protection in the jurisdictions in which we
process it in accordance with applicable laws, including through appropriate
written data processing terms and/or data transfer agreements.

If you are in the European Economic Area (“EEA”), and we process your personal
information in a jurisdiction that the European Commission has deemed to not
provide an adequate level of data protection (a “third country”), we rely upon
legal measures to adequately protect your personal information, such as putting
in place standard contractual clauses approved by the European Commission or
another measure that has been approved by the EU Commission as adducing adequate
safeguards for the protection of personal information when transferred to a
third country. You have a right to obtain details of the mechanism under which
your personal information is transferred outside of the EEA; you may request
such details by contacting us as set forth in the “Contact us” section below.


8. SECURITY OF YOUR PERSONAL INFORMATION

The security of your personal information is important to us. We have
implemented a security program designed to protect the information we collect
from loss, misuse, unauthorized access, disclosure, alternation, and
destruction. However, no transmission over the Internet is 100% secure, and we
cannot guarantee that our services will always be secure,.

We encourage you to help protect the security of your personal information. For
instance, never give out your personal credentials when you are using the
Services, so that other people will not have access to your personal
information. Furthermore, you are responsible for maintaining the security of
any personal computing device on which you utilize the Services. We are not
responsible for any lost, stolen, or compromised passwords or for any activity
on your account via unauthorized password activity.


9. NO AUTOMATED DECISION-MAKING

Securly itself does not take any actions that affect the legal rights of
persons; Securly is a tool that helps parents, schools, and others make better
informed decisions about how to protect and guide the children in their care.
Our services do not make automated decisions that have legal impacts on anyone
without the intervention of humans. Although our Services may block a particular
person from a particular site at a particular moment, the information from the
services and decision to continue to block any particular sites are always
subject to review by humans.


10. YOUR CHOICES

Correcting or Deleting Personal Information. You may modify or delete certain of
your personal information that you have submitted by logging into your account
and updating your profile information, including your user name and password.
Please note that we may retain certain information about you as required by law
or as permitted by law for legitimate business purposes (e.g., in accordance
with our record retention policies or to enforce our Terms of Service).

If you wish to make an access or correction request regarding your personal
information, please contact the Privacy Director, as referenced below.

Opting out of Email Communications. We may send periodic promotional or
informational emails to school and parent users. You may opt-out of such
communications at all times by following the opt-out instructions contained in
the e-mail. Please note that it may take up to 10 business days for us to
process opt-out requests. If you opt-out of receiving emails about
recommendations or other information we think may interest you, we may still
send you transactional e-mails, such as about your account or any Services you
have requested or received from us.


11. ADDITIONAL RIGHTS FOR EEA INDIVIDUALS

According to the GDPR, individuals in the EEA have the below rights with respect
to their personal information. Please note that your ability to exercise certain
rights (objection; portability) will depend on the basis on which your personal
information is processed (see section ii), and the exercise of all rights may be
subject to exemptions or restrictions under applicable law – we will advise you
if we rely on these. We may also need to ask you to provide evidence of your
identity before complying with a request.

Right of access: You can ask us to: confirm whether we are processing your
personal information; give you a copy of that information; provide you with
other information about your personal information such as what data we have,
what we use it for, who we disclose it to, whether we transfer it abroad and how
we protect it, how long we keep it for, what rights you have, how you can make a
complaint, where we got your information from and whether we have carried out
any profiling, to the extent that such information has not already been provided
to you in this Policy.

Right to rectify and complete personal information: You can ask us to rectify
inaccurate information. We may seek to verify the accuracy of the data before
rectifying it.

Right of erasure: You can ask us to erase your personal information, but only
where: it is no longer needed for the purposes for which it was collected; you
have withdrawn your consent (where the data processing was based on consent);
following a successful right to object (see ‘Objection’ below); it has been
processed unlawfully; or to comply with a legal obligation to which we are
subject. We are not required to comply with your request to erase your personal
information if the processing of your personal information is necessary: for
compliance with a legal obligation; or for the establishment, exercise or
defense of legal claims. There are certain other circumstances in which we are
not required to comply with your erasure request, although these two are the
most likely circumstances in which we would deny that request.

Right of restriction: You can ask us to restrict (i.e., keep but not use) your
personal information, but only where: its accuracy is contested, to allow us to
verify its accuracy; the processing is unlawful, but you do not want it erased;
it is no longer needed for the purposes for which it was collected, but we still
need it to establish, exercise or defend legal claims; you have exercised the
right to object, and verification of overriding grounds is pending. We can
continue to use your personal information following a request for restriction,
where: we have your consent; to establish, exercise or defend legal claims; or
to protect the rights of another natural or legal person.

Right to object to our use of your personal information for direct marketing
purposes: You can request that we change the manner in which we contact you for
marketing purposes. You can request that we not transfer your personal
information to unaffiliated third parties for the purposes of direct marketing
or any other purposes.

Right to object for other purposes: You have the right to object at any time to
any processing of your personal information which has our legitimate interests
as its legal basis. You may exercise this right without incurring any costs. If
you raise an objection, we have an opportunity to demonstrate that we have
compelling legitimate interests which override your rights and freedoms. The
right to object does not exist, in particular, if the processing of your
personal information is necessary to take steps prior to entering into a
contract or to perform a contract already concluded.

Right to (data) portability: You can ask us to provide your personal information
to you in a structured, commonly used, machine-readable format, or you can ask
to have it ‘ported’ directly to another Data Controller, but only where our
processing is based on your consent and the processing is carried out by
automated means.

Right to withdraw consent: You can withdraw your consent in respect of any
processing of personal information which is based upon a consent which you have
previously provided.

Right to obtain a copy of safeguards: you can ask to obtain a copy of, or
reference to, the safeguards under which your personal information is
transferred outside the EU/EEA. We may redact data transfer agreements to
protect commercial terms.

Right to lodge a complaint with your local supervisory authority: You have a
right to lodge a complaint with your local supervisory authority if you have
concerns about how we are processing your personal information. We ask that you
please attempt to resolve any issue with us first, although you have a right to
contact your supervisory authority at any time.

Submitting a GDPR Request: please contact us as set out in the “Contact Us”
section below to exercise one of these rights. If we receive any requests from
individuals related to the Platform Data, we will forward the request to the
relevant clients.


12. CHILDREN

Please refer to our COPPA Policy with respect to the personal information
collected from children and students under the age of 13 via the Services.
Children under the age of 16 cannot legally give their consent. Instead, consent
of their parent or legal guardian needs to be provided.


13. RETENTION

We will generally keep personal information only for as long as it remains
necessary for the identified purposes for which it was collected or as
authorized or required by law. We may retain certain data as necessary to
prevent fraud or future abuse, or for legitimate business purposes, such as
analysis of aggregated data, account recovery, or if required by law. All
retained personal information will remain subject to the terms of this Policy.


14. CHANGES TO THIS POLICY

This Policy is current as of the date set forth above. We may change this Policy
from time to time, so please be sure to check back periodically. We will post
any changes to this Policy on our Site. If we make any changes to this Policy
that materially affect our practices with regard to the personal information we
will endeavor to provide you with notice in advance of such change by
prominently highlighting the change on our Site or make other appropriate notice
to you.


15. CONTACT US

If you have any questions, comments or concerns about the privacy aspects of our
Services or would like to make a complaint, please contact:

Bharath Madhusudan
Privacy Director
Securly, Inc.
111 N. Market Street, 4th floor, Suite 400
San Jose, California 95113
United States
support@securly.com
1 (855) 732-8759 (ext. 101)

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