PRIVACY POLICY, HIGH SCHOOLS

Effective June 1, 2020 –

Thank you for choosing SpringPath, (which includes our social platform “SpringPath Connect”, our data analytic services “SpringPath Analytics”, collectively, “SpringPath”).

This Privacy Policy further explains SpringPath Connect’s online information practices and the information collected. There may be other notices about our information practices and choices. Please review these disclosures and any other privacy disclosures to understand how they apply to you. Our privacy policy is designed to provide transparency into our privacy practices and principles.

INTRODUCTION

SpringPath Connect is a social network and online platform for students and professionals. Our registered users (“Users”) share their student or professional identities, engage with their network, exchange knowledge and professional insights, post and view relevant content, learn and develop skills, and find school and career opportunities. Information Users share is viewable to Users and non-users (“Guests”).

These Policies are designed to provide transparency to our privacy practices and principles specifically applicable to student information we collect from schools and school districts. Please also review our Privacy Policy and User Agreement.

 INFORMATION WE COLLECT FOR SPRINGPATH “CONNECT”

SpringPath uses Application Program Interfaces (“APIs”) to connect to the database of a school or school district. We collect personal and academic information which may include student name, grade or grade point average (“GPA”), other test scores, student date of birth, student contact information and parent contact information.

LEGAL CONSENT & STUDENT REQUEST TO SHARE INFORMATION

SpringPath use APIs to access databases containing student information to autogenerate and validate a student’s User profile. The autogenerated User profiles are placed in “Non-Active” status and remain inactive until approved by a legal guardian (if required) and activated by the User.  In “Non-Active” mode no personal information associated with the student’s user profile can be viewed or shared.

Following the guidelines of Student Data Privacy & FERPA only eligible students or legal guardians can approve the activation of a student’s profile.  Once the eligible student or legal guardian completes the approval process, student will have the ability to share their requested personal and academic information with other resources on the platform. ie. Representatives from colleges, universities, trade schools, or independent educational consultants.

 HOW WE USE THE INFORMATION

Springpath uses Information for the purposes described in this or other privacy policies or disclosed at the time of collection or with written consent.

SpringPath uses APIs to validate with the school or school district’s database the designated parent or guardian contact information provided and use that contact information to send the parent or guardian instructions via email to consent & approve the sharing of data and the activation of the student’s User profile.

SpringPath automatically updates student information via an on-going API connection to databases maintained by schools or school districts. This allows us to update student academic information such as GPA, SAT, ACT, periodically.

INFORMATION SHARING AND DISCLOSURE

Our active Users publish and share their information on our platform to connect with other Users, allow other Users to search their profile, and connect with representatives from colleges, universities, trade schools, or independent educational consultants.

Inactive user profiles are not viewable or searchable until they are claimed and activated by the User. SpringPath may contact inactive Users to encourage the activation and use of their profile. Information of inactive Users are anonymized and may be used by SpringPath for any purpose associated with general market research and data analysis.

Please refer to our Privacy Policy for all Users to fully understand our privacy practices.

SCHOOL DISTRICT CHOICES AND CONTROLS

We data, time stamp and archive each acceptance of the eligible student’s and legal guardian’s request and approval process, to active the user account.   An authorize representative of the school may request at any time to received documentation related to the legal guardian’s or eligible student’s approval to release & share their information on the SpringPath Connect Platform.

You may revoke permission to access your database(s) or terminate SpringPath’s services at any time by written notice to [email protected].

Upon revocation of permission or termination of services, SpringPath will disable APIs connection to your databases and your student’s profile information will be designated as a self-reporting. Unless you instruct us otherwise, SpringPath will retain information acquired before the date of revocation or termination for lawful purposes, including but not limited to data reporting, analytics and research.

HOW SCHOOLS CAN ACCESS OR CORRECT INFORMATION

You have the right to ask us for a copy of your student’s information, to correct, delete or restrict (stop any active) processing of the information; and to obtain the information you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share this information to another controller.

These rights may be limited, for example if fulfilling your request would reveal information about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.

To exercise any of these rights, you can get in touch with us or our Privacy Policy Coordinator using the details set out below.

Privacy Coordinator:

INFORMATION SECURITY

We have put in place reasonable controls designed to help safeguard the information being collected and shared by Users. However, no security measures are perfect, and we cannot assure you that information being collected from or shared by Users will never be accessed or used in in an unauthorized way.

INFORMATION & REPORTING FOR SPRINGPATH “ANALYTICS”

SpringPath Analytics is an add-on module which is a separate application service available to each school. The analytics reports are securely hosted on a separate application server and are restricted to that school’s authorized User(s) only. These reports are generated specifically to provide teachers and faculty with real-time analytics on their school’s student activity which they may use or share at their discretion in accordance with applicable rules and laws. SpringPath will not share information specific to these reports with other entities, schools, recruiters or non-faculty personnel.