Trust Center
Introduction
iorad, Inc. and its affiliates (collectively, “iorad,” “we,” “our” or “us”) recognizes the importance of privacy. This policy covers our use of “Student Information.” This Student Privacy Policy (“Student Policy”) is designed to comply with the Family Education Rights and Privacy Act (“FERPA”), the Children’s Online Privacy Protection Act (“COPPA”) and other relevant student privacy laws and regulations.
For the purposes of this Student Policy, a “student” or “students” refers to anyone who attends a covered school, as well as any child under 13 years old whose personal information is collected by iorad, and “Student Information” means data that reasonably can be used to identify a student or that reasonably relates to a student. Information that cannot be reasonably related to the identity of a specific student or child is not Student Information.
Unless otherwise specified, for the purposes of this Student Policy, “you” and “your” refers to the school, district, or educational institution (“school”) contracting with iorad for the provision of our services (the “Services”), or to you as the parent or legal guardian (each a “parent”) of a student.
This Student Policy contains important information about how we collect, use, and disclose Student Information. In some cases, as part of providing Services, we may incidentally collect personal information related to parents or school employees, staff, or contractors (all “User Information”). Where noted this policy applies to that information as well.
With regard to Student Information (and, only where noted, User Information), this Student Policy is separate from and supersedes our Privacy Policy to the extent of any conflict or inconsistency.
FERPA and COPPA Compliance Statement for Schools
We are committed to responsible data privacy protections, and our systems are designed in accordance with the Federal Educational Rights and Privacy Act (“FERPA”) at 20 U.S.C. 1232g (34 CFR Part 99), the Children's Online Privacy Protection Act (“COPPA”), 15 U.S.C. 6501-6506, and the Protection of Pupil Rights Amendment (“PPRA”) 20 U.S.C. 1232h, in all applicable respects with regard to the collection, use, disclosure, and retention of Student Information.
You, the school, have engaged iorad, for the use and benefit of the students and the school in the educational context as authorized by you. Under FERPA, a school functions as an “educational agency or institution,” and iorad functions as a “school official.” iorad maintains full compliance with FERPA via our secured cloud infrastructure.
Consent
iorad is covered as an operator under COPPA when our Services are directed to children under 13. Under COPPA, we are required to obtain parental consent to the collection of personal information online from children under 13. When schools use our Services, we require the school (including a teacher, school district, or an administrator or other designated employee of the school or district) to consent to our collection and use of Student Information, on behalf of parents. When parents use the Services independent of a school, we require parental consent to the collection and use of personal information from children under 13 as part of the Services.
All Student Information transmitted to iorad by its customers is and will continue to be the property of and under the control of the customer. By transmitting Student Information to iorad, schools and parents (1) authorize iorad to use the Student Information as described in this Student Policy and (2) acknowledge that it is the responsibility of the transmitting party to provide appropriate notification and consent mechanisms where required by regulation or statute.
You may withdraw your consent to our processing of the personal information of your student at any time. However, withdrawing consent may result in a student's inability to continue using some or all of the Services.
Incorporation into Terms of Use
Use of the Services, and any dispute over privacy of Student Information or User Information, is subject to this Student Policy and our Terms of Use including its applicable limitations on damages and resolution of disputes. This Student Policy is incorporated by reference into the Terms of Use.
Student Information
Student Information and User Information may be collected directly from you or from students, from third parties, and automatically through use of the Services. Such information may include, but is not limited to, personal information, online activity, and electronic communications.
Information We Collect Directly
In order to provide our Services and to understand a student's activity while using our Services, we may automatically collect the following information about a student or user through cookies, web beacons, and other technologies: information regarding a student's personal computing device, browser type, browser language, operating system, Internet Protocol (“IP”) address, and the actions a student or user takes while using the Services including while online (such as the web pages viewed or blocked, the length of time a student visited a website, links clicked, and messages sent or posted).
When the Services are used on a personal computing device owned by schools, we may use geolocation information to determine the location of the device. Such information is specific to the device only and is not specific to any student or child. We may also use elements of usage and analytics information (such as IP address) to determine generalized location.
How We Use Student Information
We use Student Information to provide our Services.
We do not use Student Information in the following ways:
- We do not collect Student Information for the purpose of sale of such information in any way or for building profiles for commercial purposes not related to the provision of the Services.
- We do not use Student Information for advertising.
We may use aggregate or de-identified Student Information for the following purposes:
- To monitor and analyze the Services and for technical administration;
- To better understand how students access and use our Services;
- To improve our Services; and
- For other research and analytical purposes related to the Services.
How We Share Student Information
Service Providers. We may disclose Student Information to third-party vendors, service providers, contractors, or agents (collectively “Service Providers”) who perform contractually defined functions on our behalf. We may engage Service Providers to perform Services (e.g., hosting) that may involve their access, use or storage of Student Information on our behalf. Service Providers have limited access to Student Information solely for the purpose of helping us provide the Services, and we have put in place contractual and other organizational safeguards requiring them to take steps to ensure a proper level of protection for Student Information. These third parties are contractually bound to treat Student Information in accordance with our privacy and security policies and commitments. Except as explained above, we do not disclose or transfer Student Information to third parties except for authorized educational or school purposes or as directed by the schools that have engaged us to provide Services. We prohibit Service Providers from using Student Information for any purpose other than providing the contracted service. iorad also pledges never to collect, use, or share such information for any purposes beyond the purposes set forth in this Student Policy.
Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer Student Information we have collected to the other company, provided the successor entity is subject to equivalent privacy and security commitments as iorad with regard to the Student Information, and the Student Information continues to be used only to provide services at the direction of schools or parents.
In Response to Legal Process. We also may disclose Student Information to comply with the law, a judicial proceeding, court order, subpoena, or other legal process.
To Protect Us and Others. We also may disclose Student Information 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 Student Policy, or as evidence in litigation in which iorad is involved.
With Schools and Parents. Schools and parents can view Student Information about only their students or children.
Aggregate and De-Identified Information. We may also use and share aggregate or de-identified information that cannot reasonably be linked to the identity of specific students or children with third parties for research and analytical purposes.
Information Students Share with Third Parties
Students may voluntarily share personal information with third parties, including Social Networking Sites, while using the Services. The privacy policies of these third parties are not under our control and may differ from ours. The use of any information that students provide to third parties is governed by the privacy policy of such third party or by your independent agreement with such third party, as the case may be. Please consult their respective privacy policies. We have no control over how any third-party site uses or controls the information that it collects from students.
Security
The security of Student Information is important to us. We have implemented a security program that is reasonably designed to help protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. More information is available regarding our security protocols on our Trust Center.
Your Rights to Review, Delete, and Control Our Use of Student Information
We will make reasonable efforts to keep Student Information accurate and up-to-date, and we will provide you with mechanisms to review, update, and correct your students' personal information as appropriate and/or desired. You have a right to control the Student Information we have collected from your students or children, to review it, to delete it, and to tell us to no longer use it.
Notwithstanding the foregoing, Student Information will be deleted in all cases, including personal information held by our Service Providers, when it is no longer needed for the purpose for which it was collected. All retained Student Information will remain subject to this Student Policy. If you would like your student's personal information to be deleted, or if you would like to obtain a copy of your student's personal information, please contact us using the contact information below.
Students or parents may also have the ability to opt out of using our Services entirely or request to have specific user account data deleted based on the policies of the student's school or district. Please contact the school or district with any requests regarding this provision. If we learn we have collected personal information about a student without proper consent, we will delete that information as quickly as possible.
Changes to this Student Privacy Policy
We may update this Student Privacy Policy from time to time based on changes to applicable laws and regulations or other requirements applicable to us, changes in technology, or changes to our business. Any changes we make to the Student Privacy Policy in the future will be posted on this page, so you should review it periodically.
If we make any changes to this Student Policy that materially affect our practices with regard to Student Information we have previously collected, we will endeavor to notify all affected users. Continued use of the Services following such notifications will constitute your acceptance of any such changes.
How to Contact Us
If you have any questions, comments, concerns, or suggestions with regard to the Services, the use of Student Information, User Information, or this Student Policy, please contact us at privacy@iorad.com
iorad, inc.
1 Canal Street, Unit 1119
Boston, MA 02214
