Revision Date: August 8, 2019
NameCoach may use certain De-Identified Data obtained from you as a part of its product development process. De-Identified Data is content that removes all direct and indirect personal identifiers of Authorized End Users, including, but not limited to, name, location information, and school ID. NameCoach agrees not to attempt to re-identify De-Identified Data.
Note: NameCoach takes privacy extremely seriously, and strictly adheres to the Family Education Rights Protection Act of 1974 (“FERPA”). NameCoach works with Institution(s) to ensure compliance with FERPA and applicable privacy laws, and one of the most important ways in which it ensures compliance with FERPA is by never storing any student personally identifiable information or student academic records in unencrypted form. Refer to the FERPA Policy for more information. [Insert Link]
III. Information Collection and Use.
You can generally visit our Site without revealing personal information including, but not limited to, your name (including audio pronunciation), email address, phone number, physical address or zip code, gender pronoun, age, birthdate, and institution (“Personally Identifiable Information”). To use the Services, however, we may be required to collect Personally Identifiable Information. For example, we use Personally Identifiable Information to assist members of an Institution in learning how to pronounce a student’s (or other individual’s) name, how to correctly address a student, and learn other relevant information the student chooses to share. We do not share any of your contact information with this Institution without your consent. All student records obtained by NameCoach from an Institution are the property of and are under the control of that Institution.
Additionally, we may invite you to participate in surveys, questionnaires, contests, or to contact us with questions, comments, or to provide us with feedback, which due to the nature of some of these activities, may include the collection of Personally Identifiable Information. By accessing or using the Services, we might collect additional data as set forth below in the “Aggregate Information” paragraph.
We may use your Personally Identifiable Information to contact you to deliver certain services, news, or information related to the Services, verify your authority to use our Services, and improve the content and general administration of the Services. If you do not wish for your Personally Identifiable Information to be used as described in this Section, do not use the Services. You may also opt out of receiving promotional notifications by following the opt-out instructions in the emails that are sent to you.
Note: Under no circumstances will Personally Identifiable Information be disseminated to third parties for any use, and NameCoach will never use this information for targeted advertising.
You may have the opportunity to create a profile (e.g. a NameBadge), which consists of information about you, which may include Personally Identifiable Information, photographs, and other information regarding your use of the Services (“Profile”). Some or all of this information may be visible to third parties, depending on your account settings and the Services you are using. If you do not want your Profile to visible to Third Parties, you may contact us at email@example.com to opt-out of this feature.
IV. Children's Privacy.
The Children's Online Privacy Protection Act (“COPPA”) requires that all online service providers, including NameCoach, obtain parental consent before knowingly collecting personally identifiable information from children under the age of 13. Our Services are directed towards adults who are of the legal age to access them in their respective jurisdictions and by accessing and using our Services, you represent and warrant that you are of the legal age to form a binding contract with us in your respective jurisdiction and that you meet the foregoing eligibility requirements. NameCoach does not knowingly collect or solicit any personally identifiable information from children under the age of 13. Children under the age of 13 are prohibited from using the Services or creating an Account unless they are doing so with parental consent or with the consent of a teacher, school, or district who is providing such consent in compliance with COPPA. If we learn that we have collected personal information from a person under the age of 13 that does not comply with COPPA, we will delete that information in a reasonably prudent amount of time. If you believe that a child under the age of 13 has provided personally identifiable information to us, please contact us at firstname.lastname@example.org.
V. Cookies and other Usage Information.
Like many websites, we use “cookie” technology to collect additional website usage data and to improve our Services, but we do not require cookies to use the Site. A cookie is a small data file that is transferred to your computer's hard disk. NameCoach may use both session cookies and persistent cookies to better understand how you interact with our Services, to monitor aggregate usage by our users and web traffic routing on our Services, and to improve our Services. Most Internet browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.
We, as well as our affiliate program partners and other third parties, may also employ a software technology called clear gifs, or web beacons to help us better manage content on our Services, and improve the quality and experience of our Services. The same is applicable to any embedded script we may use in addition to flash and HTML5. Various browsers may offer tools for removing certain usage information trackers such as HTML5 LSOs.
We may also work with analytics service providers and other vendors to provide us with information regarding traffic on the Services.
VI. Aggregate Information.
We may track the total number of visitors to our Site, the number of visitors to each page of our Site, browser type, and IP addresses. We may also analyze this data for trends and statistics in the aggregate, but such information will be maintained, used and disclosed in aggregate form only and will not contain Personally Identifiable Information. We may use such aggregate information to analyze trends, administer the Site, track users' movement, and gather broad demographic information for aggregate use.
VII. Third Party Services.
NameCoach uses a variety of services hosted by third parties to help provide our Services, including Amazon Web Services. These services may collect information sent by your browser as part of a web page request, such as cookies or your IP request. We do not control third parties' tracking technologies. If you have any questions about these third-party technologies, you should contact the responsible provider directly.
VIII. Data Deletion and Destruction.
NameCoach will store and maintain data for up to 30 days after the termination of an applicable agreement, unless otherwise specified or unless required to retain such data to comply with a legal obligation, resolve disputes, maintain security, prevent fraud and abuse, enforce our terms of service, or fulfill your request to “unsubscribe” from further messages from us. We may retain certain information that is considered “Directory Information” under FERPA, and/or De-Identified information to enable us to refine and hone our Services after you have discontinued your use of the Services. Questions regarding data storage, recovery, and deletion should be directed to:
Attn: Customer Success Manager
2627 Hanover St.
Palo Alto, CA 94107
Phone: (650) 394-6263
We do not disclose your Personally Identifiable Information except in the following limited circumstances: (i) if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect NameCoach's rights or property; (ii) if we are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction; or (iii) to fulfill the purpose for which you provide it and to enforce or apply your MSA and other agreements with us.
X. Links to Third Party Sites.
We employ procedural and technological security measures that are reasonably designed to help protect your Personally Identifiable Information from loss, unauthorized access, disclosure, alteration or destruction, which includes encryption and other security measures to help prevent unauthorized access to your Personally Identifiable Information.
XII. Correcting or Deleting Information.
Parents, legal guardians, or eligible students have the following options regarding their Personally Identifiable Information:
Delete Data: You may request that we delete your personal data; however, in some cases we cannot delete your personal information except by also deleting your user account.
Change or Correct Data: You can also ask us to change, update, or fix your data in certain cases, particularly if it’s inaccurate. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Object to, or Limit or Restrict, Use of Data: You may request that we do not use your personal data, but keep in mind that this will terminate our ability to provide any Service(s) to you.
Right to Access and/or Take Your Data: You can ask us for a copy of your personal data.
You may send us an email at email@example.com to request access to, obtain copies of, correct, or delete any personal information that you have provided to us.
XIII. Users from Outside of the United States
Legal Basis for processing your information. If you are a user located in the EEA or Switzerland, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. We will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate business interests. In some cases, we may also have a legal obligation to collect personal information from you. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to Contact Us” heading below.
XIV. Data Breach Notification.
NameCoach maintains an information security plan to protect the security, confidentiality, and integrity of Personally Identifiable Information of users and Institutions. As part of its information security plan, NameCoach will promptly notify affected individuals and the Institution of a data security breach. Written notification will be sent by first-class mail to the address on record for the individual or Institution. Written notification will contain:
A brief description of what occurred with respect to the breach, including, to the extent known, the date of the breach and the date on which the breach was discovered;
A description of the types of Personally Identifiable Information that were involved in the breach;
A description of the steps the affected individual or Institution should take to protect against potential harm from the breach;
A description of what NameCoach is doing to investigate and mitigate the breach and to prevent future breaches; and
Contact procedures for individuals to ask questions or learn additional information, which will include a toll-free telephone number, an email address, website or postal address.
If NameCoach determines individuals or an Institution should be notified urgently of a breach because of possible imminent misuse of unsecured Personally Identifiable Information, NameCoach may, in addition to providing notice as outlined above, contact the individual or Institution by telephone or other means, as appropriate.
XV. California Privacy Rights.
California Civil Code Section § 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of Personally Identifiable Information to third parties for their direct marketing purposes. To make such a request, please email firstname.lastname@example.org.