November 16, 2018

K-12 Privacy Policy

GIVING – TREE ASSOCIATES, LLC
T/A PASSPORT FOR GOOD (“PFG”)

333 Broadway – 4th Floor
Troy, New York 12180
(518) 203-6710 (T)
General E-Mail: info@passportforgood.com
Website: www.passportforgood.com

K-12 PRIVACY POLICY

A. INTRODUCTION

PFG is referred to herein as (“We/Us/Our”. The terms not defined herein, are defined in the Privacy Policy or the PFG General Terms (Terms”) appearing on the Site and the PFG App corresponding to the revision date of this K-12 Privacy Policy.

We operate the Site and the PFG App and may engage in Data Handling as described in this K-12 Privacy Policy. We believe in Our disclosure regarding Data Handling. Additionally, We do not ask for disclosure of more data, including, personally identifiable information, to Us than is reasonably necessary to use the Site or the PFG App.

We value the privacy of all students in attendance at an Educational Entity.

We especially value the privacy of students under the age of 18 (“Children”).

We particularly value the privacy of Children under the age of 13.

We are subject to certain privacy rules in respect to Children’s and other student’s data, including, personally identifiable information.

This K-12 Privacy Policy addresses specific privacy concerns under: the Family Educational Rights and Privacy Act (“FERPA”) for all Children; the Children’s Online Privacy Protection Act (“COPPA”) for Children under the age of 13; and any State and Local specific privacy requirements for Children as well as all other applicable rules, regulations and laws.

For clarity, an Educational Entity as referenced herein, is a PFG Client and if you are K-12 student and affiliated with an Educational Entity, then you are a Client User.

If you are a K-12 student and not affiliated with an Educational Entity, then you are an Individual User.

This K-12 Privacy Policy applies to Children and other students in grades K-12 to the exclusion of any conflicting provision in the Privacy Policy.

Data Handling of Children’s data, including, personally identifiable information, of Children under the age of 13, by Us will be specifically under the terms of the COPPA provisions of this K-12 Privacy Policy. The COPPA provisions of this K-12 Privacy Policy will be controlling as to any other provisions of this K-12 Privacy Policy in respect to Children under the age of 13.

Should you or your parent have any general questions, concerns or requests about this K-12 Privacy Policy and are a Client User or parent of a Client User of an Educational Entity, you should as a first level of support, contact the administrator at the Educational Entity. If general questions, concerns or requests are not addressed by the administrator at the Educational Entity, you or your parent should, as a second level of support, contact Us as follows:

PFG Chief Privacy Officer
333 Broadway
Troy, New York 12180
Phone: (518) 424-9221
E-Mail:  cpo@passportforgood.com

If you are an Individual User or parent of an Individual User and have any general questions, concerns or requests about this K-12 Privacy Policy, We can be contacted directly as follows:

PFG Chief Privacy Officer
333 Broadway
Troy, New York 12180
Phone: (518) 424-9221
E-Mail:  cpo@passportforgood.com

Any specific inquiry to Us regarding technical support or technical issues for the Site or the PFG App should be given in writing via E-Mail to support@passportforgood.com.

B. DATA HANDLING

Our Data Handling is generally described in our Privacy Policy.

Specifically, Our Data Handling, includes for Children: first and last name, physical address, telephone numbers, E-Mail addresses, passwords, student age/date of birth, personal/other student ID, name of Educational Entity that you may be associated with, activities which are of interest (teams/clubs), certain photographs, video and audio files that contain a child’s image or voice, browser type and access time, time spent on Site, page views, referring URLs and seniority or grade year.

Please see the below specifics regarding Data Handling for Children and other students.

Our Data Handling, including, collection, involves specifically:

  • first name and last name
  • phone/mobile number
  • E-Mail address
  • PFG password
  • other student ID
  • date of birth
  • school name
  • teams/clubs
  • photographs, video or audio file
  • browser type
  • access time
  • time spent on PFG App or PFG Site
  • page views
  • referring URLS
  • grade year

Data Handling for the data, including, personally identifiable information, of parents is limited to Data Handling required by Us for any verified parental consent and subsequent parental involvement

Data, including, personally identifiable information, that We encrypt as part of Our Data Handling is as follows:

  • first name and last name
  • phone/mobile number
  • E-Mail address
  • PFG password
  • other student ID
  • date of birth
  • school name
  • teams/clubs
  • photographs, video or audio file
  • grade year

Encryption, where there is Data Handling of parent data, including, personally identifiable information, is aligned with the encryption that is otherwise deployed by Us.

Data, including, personally identifiable information, that may be transferred to or shared as part of Our Data Handling, with third party service providers is as follows:

  • first name and last name
  • phone/mobile number
  • E-Mail address
  • PFG password
  • other student ID
  • date of birth
  • school name
  • photographs, video or audio file
  • browser type
  • grade year

Transferring or sharing to third party service providers, where there is Data Handling relating to a parent data, including, personally identifiable information, is aligned with the process that is otherwise deployed by Us.

As a commitment to privacy, We from time to time conduct and receive training on applicable rules, regulations and laws regarding confidentiality of Children’s and other student’s data, including, personally identifiable information.

We try to minimize Data Handling and we try to mitigate, to the extent commercially practicable, Data Handling by Us and any third party service providers utilized by Us.

We may collect data, including, personally identifiable information about Children and other students directly from them, as well as automatically through use of the Site and the PFG App. We post a copy of all of Our privacy policies, including, those pertaining to Children and other students on the Site and PFG App for review by Children and other students and their parents.

We may automatically assemble statistical information about Children’s and student’s use of the Site and the PFG App through cookies and other technologies.  Usage of a cookie is in no way linked to personally identifiable information. Children and other students may always choose not to accept cookies, but, upon doing so use of the Site and the PFG App may be partially or completely impaired.

For any purposes, other than permitted purposes, We will mask, de-identify, anonymize and/or aggregate the data, including, personally identifiable information of Children and other students before We use it for any other purposes. When We, mask, de-identify, anonymize and/or aggregate the data, including, personally identifiable information, We make certain to strip out names, E-Mails, contact information and other personal identifiers.

We only deploy unique identifiers, such as IP addresses, as necessary to operate the Site and the PFG App, including, to maintain or analyze their functioning; perform network communications; authenticate users or personalize content; and protect the security or integrity of users of the Site and PFG App. We never use unique identifiers to track users across third-party apps or websites.

We may mask, de-identify, anonymize and/or aggregate the data, including, personally identifiable information for the following purposes:

  • to better understand how user’s access and use the Site and the PFG App;
  • to improve the Site and the PFG App and respond to user desires and preferences; and
  • to conduct research or analysis, including, research and analysis by third parties.

Further general information about Our Data Handling practices is available upon request by contacting support@passportforgood.com.

C. The Children’s Online Privacy and Protection Act (“COPPA”)

COPPA protects Children’s data, including, personally identifiable information on websites and online services — including apps — that are directed to Children under the age of 13.

COPPA requires certain websites and certain service providers to notify parents directly and get their approval before they collect, process, use, share and store Children’s data, including, personally identifiable information.

Data, including, personally identifiable information under COPPA includes Children’s name, address, phone number or E-Mail address; their physical whereabouts; photos, videos and audio recordings of the Children and persistent identifiers, like IP addresses, that can be used to track Children’s activities over time and across different websites and online services.

As a parent, you have control over the data, including, personally identifiable information, We collect from Children under 13.

COPPA gives you tools to do that. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule.

If a website or service provider is covered by COPPA, it has to obtain your consent before collecting data, including, personally identifiable information from Children under the age of 13 and it has to honor your choices about how that data, including, personally identifiable information is used. We follow COPPA and seek from you the necessary consent.

A full text of COPPA is available at COPPA , COPPA FAQ’s  

How is Verifiable Parental Consent Obtained?

COPPA requires Us to obtain verifiable parental consent (with limited exceptions) prior to the collection, use and disclosure of your data, including, personally identifiable information.

Verifiable parental consent can be obtained directly from the parents before the Children can login to their account and use the Site or the PFG App.

Verifiable parental consent can also be obtained on behalf of the parent through Children’s school referred to as “school consent”.

Does COPPA affect the Site and PFG App?

The answer is yes, as We through the Site and the PFG App and Our Data Handling practices, collect Children’s data, including, personally identifiable information.

How does COPPA work with PFG?

We do not permit Children under the age of 13 to register as Individual Users at the Site or the PFG App without verifiable parental consent and meeting any other requirements of Ours for registration with Us as an Individual User.

Children that are under the age of 13 that are associated with an Educational Entity, follow the parental consent process through the policies and procedures established by the Educational Entity and parental consent is always through the Educational Entity.  Also, for such Children any subsequent parental involvement follows the process and procedures established by the Educational Entity and is always through the Educational Entity.

Please review and familiarize yourself with Our Privacy Policy as well as the entire K-12 Privacy Policy of which these COPPA provisions are a part.

What are your choices?

The first choice is whether you’re comfortable with Our privacy policies, including, this K-12 Privacy Policy. Start by reading Our Data Handling policy in the Privacy Policy and this K-12 Privacy Policy.

Then, it’s about whether you want to allow participation in the Site and PFG App which will be subject to the Privacy Policy and this K-12 Privacy Policy.

As the parent, you have the right to review or have deleted the data, including, personally identifiable information, collected about Children.

As the parent, you also have the right to retract your consent at any time, to collect any data, including, personally identifiable information, about your Children.

Specific Data Handling for Children

From Children, Our Data Handling involves specifically:

  • first name and last name
  • phone/mobile number
  • E-Mail address
  • PFG password
  • other student ID
  • date of birth
  • school name
  • teams/clubs
  • photographs, video or audio file
  • browser type
  • access time
  • time spent on PFG App or PFG Site
  • page views
  • referring URLS
  • grade year

Data Handling for the data, including, personally identifiable information, of parents of Children is limited to Data Handling required by Us for any verified parental consent and subsequent parental involvement.

What Data, Including, Personally Identifiable Information, Is Encrypted

Data, including, personally identifiable information that We encrypt is as follows:

  • first name and last name
  • phone/mobile number
  • E-Mail address
  • PFG password
  • other student ID
  • date of birth
  • school name
  • teams/clubs
  • photographs, video or audio file
  • grade year

Encryption, where there is Data Handling of a parent data, including, personally identifiable information, is aligned with the encryption that is deployed by Us for Children.

What Data, Including Personally Identifiable Information, May Be Transferred To Or Shared With, Including, Third Party Service Providers

Data, including, personally identifiable information that may be transferred to or shared with third party service providers is as follows:

  • first name and last name
  • phone/mobile number
  • E-Mail address
  • PFG password
  • other student ID
  • date of birth
  • school name
  • photographs, video or audio file
  • browser type
  • grade year

Transferring or sharing to third party service providers, where there is Data Handling relating to a parent data, including, personally identifiable information, is aligned with the process that is deployed by Us for Children.

Special Message About Data Sharing As to Children under the age of 13

We do not use or sell data, including, personally identifiable information of Children for advertising or marketing purposes.

Children or parents may not make his or her data, including, personally identifiable information public through the Site or PFG App.

We will only disclose Children’s data, including, personally identifiable information, if required to do so by applicable rules, regulations and laws, or as otherwise stated in this K-12 Privacy Policy and Privacy Policy or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Us; (b) protect and defend Our rights or property and those of others, including, among other things to enforce Our contracts; (c) act under exigent circumstances to protect the personal safety of Children or the public; (d) to correct technical problems and malfunctions in how we provide the Site and PFG App to you and to technically process Children’s data, including, personally identifiable information; (e) to take precautions against liability; (f) to respond to claims that the rights or interests of a third party have been violated; or (g) as permitted or required by law to respond to law enforcement agencies. Also, certain technical processing of Children’s data, personally identifiable information is required for: (a) providing the Site and PFG App; (b) conforming to technical requirements of connecting networks; (c) conforming to the limitations of the Site or the PFG App; or (d) other similar technical connecting requirements.

What if you have concerns? 

Should you or your parent have any questions, concerns or requests about these COPPA provisions of this K-12 Privacy Policy and are a Client User or parent of a Client User of an Educational Entity, you should as a first level of support, contact the administrator at the Educational Entity. If questions, concerns or requests are not addressed by the administrator at the Educational Entity, you or your parent should, as a second level of support, contact Us as follows:

PFG Chief Privacy Officer
333 Broadway
Troy, New York 12180
Phone: (518) 424-9221
E-Mail:  cpo@passportforgood.com

If you are an Individual User or parent of an Individual User and have any questions, concerns or requests about these COPPA provisions of this K-12 Privacy Policy, We can be contacted directly as follows:

PFG Chief Privacy Officer
333 Broadway
Troy, New York 12180
Phone: (518) 424-9221
E-Mail:  cpo@passportforgood.com

If you or your parent think We have collected data, including, personally identifiable information from Children or marketed to them in a way that violates the law, you or your parent can contact the FTC at FTC.

D. FERPA COMPLIANCE [FERPA & ITS REGULATIONS (20 U.S.C. 1232g)]

1. Summary

FERPA protects data, including, personally identifiable information in student’s “educational records” from unauthorized disclosure.  FERPA also provides parents the right to have the records amended and the right to have some control over the disclosure of data, including, personally identifiable information from student’s education records. The purpose of FERPA and its regulations is to set out the requirements for the protection of Children, parents and Eligible students.

Because We are involved in Data Handling of Children’s and Eligible student’s data, including, personally identifiable information, We are subject to FERPA and its regulations and are hereby providing this K-12 Privacy Policy to comply with applicable laws, rules and regulations, and to fully demonstrate Our commitment to privacy. Under FERPA, schools cannot share student’s data, including, personally identifiable information contained in an “educational record” without parent’s written consent. Under FERPA, schools can share data, including, personally identifiable information from educational records with third parties that provide a legitimate educational function.

A full text of the FERPA regulations is available at FERPA.

2. Protection of Data, Including, Personally Identifiable Information

As part of Data Handling of  data, including, personally identifiable information, We may mask, de-identify, anonymize and/or aggregate data, including, personally identifiable information, and in such instances all data, including, personally identifiable information, is completely anonymous and We are providing notice of such not only to comply with applicable laws, rules and regulations, but, to fully demonstrate Our commitment to privacy.

We comply with applicable laws, rules and regulations, and to fully demonstrate Our commitment to privacy, We are informing you that We use certain third party service providers to assist in masking data, de-identifying, anonymizing or aggregating data, including, person identifiable information and in such instances all data, including, personally identifiable information, is completely anonymous.

You understand and acknowledge specifically the masking, de-identification, anonymization and aggregation of data, including, personally identifiable information, notifications set forth in the above two paragraphs as to Us and the third party service providers which assist Us in providing the Site and the PFG App to you.

Under FERPA, all data, including, personally identifiable information is protected.

3.  FERPA Definitions

Personal[ly] Identifiable Information (also sometimes known as “PII”) includes, but is not limited to—

(a) The student’s name;

(b) The name of the student’s parent or other family members;

(c) The address of the student or student’s family;

(d) A personal identifier, such as the student’s social security number, student number, or biometric record;

(e) Other indirect identifiers, such as the student’s date of birth, place of birth, and mother’s maiden name;

(f) Other information that, alone or in combination, is linked or linkable to a specific student that would allow a reasonable person in the school community, who does not have personal knowledge of the relevant circumstances, to identify the student with reasonable certainty; or

(g) Information requested by a person who the educational agency or institution reasonably believes knows the identity of the student to whom the education record relates.

“Parent” means a parent of a student and includes a natural parent, a guardian, or an individual acting as a parent in the absence of a parent or a guardian.

“Eligible student” means a student who has reached 18 years of age or is attending an institution of postsecondary education.

4. Consent & Involvement

Under FERPA, verified parental consent is required for schools to share educational records containing data, including, personally identifiable information, if you are under the age of 18 years.

Where Children are associated with an Educational Entity, the required consent of the parent given to Us is obtained through the Educational Entity and all of Our subsequent involvement are through the Educational Entity. We reciprocate the policies and procedures of the Educational Entity that We are working with as to verified parental consent and parental involvement We will have a contract with the Educational Entity that We are working with, which contains terms regarding verified parental consent and parental involvement.  The Educational Entity is required to validate the identity of the parent in all instances of verified parental consent or parental involvement.

We rely on the Educational Entity to obtain the necessary verifiable parental consent for any Client User under the age of 18 years and to obtain any further verifiable parental consent under this K-12 Privacy Policy for any Client User under the age of 13 years. Once verified parental consent is obtained by Educational Entity, any subsequent involvement with a parent for any Client User under the age of 18 years, will be through the Educational Entity, except, as otherwise designated herein.

When Children become Eligible students the rights accorded to and consent required of parents under FERPA transfers from parent to the Eligible student. We work with the Eligible student in the same manner that We worked with the parent of the Eligible student when that Eligible student was under the age of 18.

Where Children or Eligible students are not associated with or disassociated with an Educational Entity, to continue to use the Site or the PFG App, they need to register as an Individual User in accordance with the Terms If you are under age of 18, you are required to follow the PFG user registration beginning at the user registration form.

5. Notification of Rights

Children’s or student’s data, including, personally identifiable information, cannot be sold or released for any commercial or marketing purposes by Us.

Children’s or student’s data, including, personally identifiable information, may only be used by Us for purposes that are deemed to be legitimate educational purposes and within the intended purposes of the Site and the PFG App.

Parents and Eligible students have the right to know all data, including, personally identifiable information, which are subject to Data Handling by Us, regarding a student.

Parents and Eligible students have the right to inspect and review all data, including, personally identifiable information, which are subject to Data Handling by Us regarding a student.

Parent and Eligible students have the right to seek amendment of all data, including, personally identifiable information, regarding a student, that is believed to be inaccurate, misleading or otherwise in violation of a student’s privacy rights.

Parent and Eligible students have the right to seek deletion of all data, including, personally identifiable information, regarding a student, provided however that if such data is deleted, such could affect the functionality you experience with the Site or the PFG App.

Should you have any need for exercising any of the above rights, including, those as to inspection and review, amendment or deletion of data, including, personally identifiable information, and are a Client User or parent of a Client User of an Educational Entity, you should as a first level of support, contact the administrator at the Educational Entity. If your concerns are not addressed by the administrator at the Educational Entity, you should, as a second level of support, contact Us as follows:

PFG Chief Privacy Officer
333 Broadway
Troy, New York 12180
Phone: (518) 424-9221
E-Mail:  cpo@passportforgood.com

If you are an Individual User or parent of an Individual User and have any need for exercising any of the above rights, including, those as to inspection and review, amendment or deletion of data, including, personally identifiable, We can be contacted directly as follows:

PFG Chief Privacy Officer
333 Broadway
Troy, New York 12180
Phone: (518) 424-9221
E-Mail: cpo@passportforgood.com

6. Safeguards

In furtherance of the section of the Privacy Policy regarding privacy and security, We have developed and implemented administrative, technical and physical safeguards associated with industry standards and best practices, including, but not limited to, encryption, firewalls and password protection when data, including, personally identifiable information, is stored or transferred or otherwise in motion.  We conduct security audits from time to time for the Site and the PFG App.

7. Third Party Service Providers Specifically

In compliance with applicable laws, rules and regulations, and to fully demonstrate Our commitment to privacy, We are informing you that We use certain third party service providers for Data Handling and other services which assist Us in providing the Site and the PFG App to you. We hold such third party service providers to the same standard that We are held to as to Data Handling. PFG does not share any data, including, personally identifiable information from “educational records” with any third party unless, they are providing services to Us and only to the extent that such must be shared to facilitate the functioning of the Site and the PFG App.

We utilize the services of third party service providers to assist Us in providing access to the Site and the PFG App to you.  A list of third party service providers is available upon request by contacting support@passportforgood.com.

The third party service providers We utilize, have established comparable privacy terms consistent with the privacy terms under the Privacy Policy and this K-12 Privacy Policy which we have established and notify them of such on an annual basis.

We inform the third party service providers annually that Our services are directed to Children and students and of Our Data privacy and security policies and practices.

8. Notification of Breach

We are required to notify the Educational Entity of any breach of privacy or security involving Children’s and student’s data, including, personally identifiable information, by Us or any third party service providers utilized by Us.

E. NEW YORK STATE RULES, REGULATIONS & LAWS

As a New York State corporation, We are subject to general requirements of privacy under New York State law as set forth in New York Gen Bus L § 899-AA.

Specifically, in respect to Children and students enrolled in an Educational Entity, Section 2-d of the Education Laws of the State of New York (“Section 2-d”) are applicable to Us directly and Our third party service providers.

Under Section 2-d, among other things, a Parent’s Bill of Rights applies, standard for data privacy and security shall be stated in clear and plain English terms and terms regarding Data Handling shall be stated.

A full text of Section 2-d is available at Section 2-d.

Our summary of the Parent’s Bill of Rights as it applies to Us has been extracted from Section 2-d and text is available at PFG Summary of Parent Bill of Rights – Data Privacy and Security.

We are committed to ensuring the privacy of Children and students in accordance with Local, State and Federal regulations and the policies of schools/school districts in New York state. To this end the following summary of Section 2-d is provided to you which parallels the requirements of FERPA:

Children’s and student’s data, including, personally identifiable information, cannot be sold or released for any commercial or marketing purposes by Us.

Children’s and student’s data, including, personally identifiable information, may only be used by Us for purposes that are deemed to be legitimate educational purposes and within the intended purposes of the Site and the PFG App.

Parents and Eligible students have the right to know all data, including, personally identifiable information, which are subject to Data Handling by Us, regarding a student.

Parents and Eligible students have the right to inspect and review all data, including, personally identifiable information, which are subject to Data Handling by Us regarding a student.

Parent and Eligible students have the right to seek amendment of all data, including, personally identifiable information, regarding a student, that is believed to be inaccurate, misleading or otherwise in violation of a student’s privacy rights.

Parent and Eligible students have the right to seek deletion of all data, including, personally identifiable information, regarding a student, provided however that if such data, including, personally identifiable information, is deleted, such could affect the functionality you experience with the Site or the PFG App.

Should you or your parent have any need for exercising any of the above rights, including, those as to inspection and review, amendment or deletion of data, including, personally identifiable information, and are a Client User or parent of a Client User of an Educational Entity, you should as a first level of support, contact the administrator at the Educational Entity. If your concerns are not addressed by the administrator at the Educational Entity, you should, as a second level of support, contact Us as follows:

PFG Chief Privacy Officer
333 Broadway
Troy, New York 12180
Phone: (518) 424-9221
E-Mail:  cpo@passportforgood.com

If you are an Individual User or parent of an Individual User and have any need for exercising any of the above rights, including, those as to inspection and review, amendment or deletion of data, including, personally identifiable information, We can be contacted directly as follows:

PFG Chief Privacy Officer
333 Broadway
Troy, New York 12180
Phone: (518) 424-9221
E-Mail:  cpo@passportforgood.com

In furtherance of the section of the Privacy Policy regarding privacy and security, We have developed and implemented administrative, technical and physical safeguards associated with industry standards and best practices, including, but not limited to, encryption, firewalls and password protection when data, including, personally identifiable information, is stored or transferred or otherwise in motion.

The third party service providers We utilize have established comparable privacy terms consistent with the privacy terms which we have established and notify them of such on an annual basis.

We notify the Educational Entity of any breach of privacy or security involving Children’s or student’s data, including, personally identifiable information, by Us or any third party service providers utilized by Us.

Please be advised that the Parent’s Bill of Rights for data, privacy and security under Section 2-d is subject to change, based upon regulations of Commissioner of Education issued from time to time, which address data, privacy and security in respect to third-party contractors, such as Us, in providing educational related products and services.

F. PRIVACY CERTIFICATIONS

Protecting Children’s and student’s privacy is especially important to Us. We participate in the iKeepSafe Safe Harbor program. We have been granted the iKeepSafe COPPA Safe Harbor seal signifying that Our Site and PFG App as well as the Software that runs the Site and the PFG App have been reviewed and approved for having policies and practices surrounding the collection, use, maintenance and disclosure of data, including, personally identifiable information  from Children consistent with the iKeepSafe COPPA Safe Harbor program guidelines.

We hold the iKeepSafe FERPA Certification signifying Our Site and the PFG App as well as the Software that runs the Site and the PFG App have been reviewed and approved for having policies and practices that are compliant with the federal mandates for FERPA.

G. DATA & ACCOUNTS

Where this K-12 Privacy Policies applies, please note that it is Our policy to delete data, including, personally identifiable information, and accounts of an Individual User, if there has been no activity for seven (7) years.

Where this K-12 Privacy Policies applies, please note that it is Our policy to delete your data, including, personally identifiable information, and accounts of a Client User associated with an Educational Entity, if there has been no activity for seven (7) years.

In addition to the other specific provisions of this K-12 Privacy Policy, data, including, personally identifiable information, generally may be deleted at any time as follows. Upon receipt by Us at support@passportforgood.com of a request by a Client User or an Individual User or parents of a Client User or an Individual User to delete the data, including, personally identifiable information in writing, We will delete the data, including, personally identifiable information as soon as reasonably possible after receipt of a such request.

In addition to the other specific provisions of this K-12 Privacy Policy, an account generally may be deleted at any time as follows. Upon receipt by Us at support@passportforgood.com  of a request by a Client User or an Individual User or parents of a Client User or an Individual User to delete the account, in writing, We will delete the account as soon as reasonably possible after receipt of a such request. Notwithstanding the above, in respect to data, including, personally identifiable information, and accounts, the following applies:

Data, including, personally identifiable information, and account details, may be retained by Us as required by applicable rules, regulations and laws. Some or all data, including, personally identifiable information, and account details, may need to be retained by Us for school legal compliance reasons. Some or all data, including, personally identifiable information, and account details, may need to be retained by the Educational Entity.

Data, including, personally identifiable information, and account details, may be retained by Us for archival purposes.

Data, including, personally identifiable information, and account details, may be cached on various storage devices of Ours or those of third party service providers from which it will not be deleted.

Data, including, personally identifiable information, and account details, may also continue to remain on Our server in a dormant status without being deleted.

As a reminder, you are solely responsible for back-up of your data, including, personally identifiable information.

As a further reminder, you are responsible at all times to ensure that your data, including, personally identifiable information, associated with the Site or the PFG App is kept secure by you and backed-up by you.

Where, We have been requested to take some action regarding your data, including, personally identifiable information, or your account, We will do so as timely as reasonably possible given the nature and scope of the requested action.

H. GENERAL

We have adopted confidential company policies connected to this K-12 Privacy Policy. A list of those confidential company policies is available upon request by contacting support@passportforgood.com

No updates, revisions or amendments of any provision of this K-12 Privacy Policy and any document referenced herein or linked hereto, shall be valid unless made in a writing (including, by electronic means) and posted on the Site and the PFG App or otherwise initiated or confirmed by Us, including, by E-Mail.

We reserve the right to update, revise or amend the Software, the Site, the PFG App and this K-12 Privacy Policy, at any time, for any reason or no reason, and any update, revision or amendment shall apply as of the designated date.  We reserve the right to update, revise or amend any document referenced herein or linked hereto, at any time, for any reason or no reason, and any update, revision or amendment shall apply as of the designated date. It is your responsibility to periodically check this Site and the PFG App and any E-Mails from Us regarding any such updates, revisions or amendments.

We will notify each Educational Entity that we work in writing at a minimum thirty (30) days in advance of any material changes to this K-12 Privacy Policy.

This K-12 Privacy Policy as well as any documents referenced herein or linked hereto represent the entire understanding between Us and you regarding its subject matter