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Revision Date: June 20, 2021
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. [https://cloud.name-coach.com/studentrecords/]
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 or other individual 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 protected] to opt-out of this feature.
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 [email protected].
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.
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.
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.
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
Email: [email protected]
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.
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.
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:
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.
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. We do not provide your Personally Identifiable Information to any third parties for direct marketing purposes as defined in California Civil Code Section § 1798.83. Please contact us [email protected] for any questions regarding your Personal Information.
California Consumer Privacy Act (“CCPA”)
As set forth above, we collect the following categories of information: identifiers (such as your name, voice pronunciation, and email address), other personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (such as your name and contact information), internet or other similar network activity, geolocation data, and inferences drawn from the collected personal information. This information is collected directly from you when you provide it to us (for example when you submit a form requesting more information, or when you enter into a contract with us) or automatically as you navigate through the Site. We use this information for one or more legitimate business purposes, including to provide our Services, improve our Services, and offer information about our Services to you.
If you are a resident of California, you have other rights under the CCPA. Any personal data that we collect is based upon your consent as detailed in this Privacy Statement. You have many choices concerning the collection, use, and sharing of your data, including the following rights:
When you contact us regarding any of your rights under the CCPA, we will verify your identify before we provide any information. If you have any questions or comments about your rights under the CCPA, please contact us at [email protected].
The goal of the GDPR is to standardize data protection laws and processing across the EU, and to give individuals stronger, more consistent rights to access and control their personal information. NameCoach is committed to ensuring the security and protection of all personal information that we process, and to approach data protection in a compliant and consistent manner. We have developed and are continuously implementing and updating our data protection roles, policies, procedures, controls, and measures to ensure maximum compliance.
In most processing contexts, NameCoach acts as a processor or service provider for a controller institution or certifying entity. In those situations, where required by applicable law, NameCoach only transfers personal data to third countries or international organizations where the controller institution or certifying entity has authorized NameCoach to do so in accordance with applicable law.
When we transfer information from individuals in the EEA to countries that have not received an adequacy finding under Article 45 of the GDPR, we rely on alternative adequate safeguards, such as the contractual mechanisms set forth in Article 46 of the GDPR or derogations for specific situations set forth in Article 49 of the GDPR. In the limited situations where we act as a controller and rely on a cross-border transfer mechanism under Article 49, we only collect and transfer your information to third countries: (i) with your consent; (ii) to perform a contract with you; or (iii) to establish, exercise, or defend legal claims.
Methods of Compliance
Rights of Data Subject
Some internet browsers have incorporated “Do Not Track” features. We respond to Do Not Track signals by not tracking browser and URL information collected through a tracking pixel. However, for security purposes, we do not respond to Do Not Track signals for information collected via server logs, such as user IP address and firewall events.