Privacy Policy

Last updated: May 19, 2025

Securly, Inc. and our affiliates, including Securly Ltd. (collectively “Securly,” “we,” “our” or “us”), recognize the importance of privacy. This Privacy Policy describes how we collect, store, use, disclose, or otherwise process (collectively “process”) personal information, in connection with (i) our cloud-based software products and services (collectively the “Services”), we offer to schools, districts, or other educational institutions (collectively “Schools”) and (ii) the websites that we operate (collectively, the “Sites”). A complete list of Securly Services, including descriptions of those services, is available on our Sites using the “Products” tab.

This Privacy Policy contains four sections.

• Section 1 describes the personal information that Securly processes from and about a school’s students (“Students”) when Schools install and use Securly Services.
• Section 2 describes the personal information we collect from and about a Student’s parents or guardians (“Parents”), as well as teachers, officials, and other School employees (collectively “Educators”) in connection with their use of Securly Services, including through the password-restricted areas of our Sites.
• Section 3 describes the personal information we collect from and about adults visiting the non-password restricted areas of our Sites (a “Site Visitor”).
• Section 4 contains general information about the effective date of this policy and how to contact us if you have questions, comments, or concerns.

Section 1: Personal Information Processed about Students Using Securly Services

This section of the Privacy Policy covers personal information about Students collected from Students and Educators as they interact with the Services, and from Schools using the Services (“Student Information”). Student Information is information about a Student that is linked or linkable to that Student’s identity. De-identified or aggregated Student data, as those terms are defined in applicable law, is not Student Information.

Securly processes Student Information as a processor or service provider on behalf and at the direction of Schools for the exclusive purpose of providing those Services. Schools are the controllers of any Student Information. Securly processes Student Information in accordance with applicable law, our contractual obligations to Schools, this section of this Privacy Policy, and our This link opens in a new tab.Terms of Service.

Securly processes Student Information from Students to provide our Services for the sole use and benefit of the Students and the School in the educational context as authorized by Schools, and for no other commercial purpose.

a. Applicable Law

Securly processes Student Information in compliance with applicable law. In addition to applicable State law, we comply with the Federal Educational Rights and Privacy Act (“FERPA”), 20 U.S.C. § 1232g (34 C.F.R. Part 99) and the Children's Online Privacy Protection Act (“COPPA”), 15 U.S.C. §§ 6501-6506 (16 C.F.R. Part 312), in all applicable respects with regard to the collection, use, disclosure, and retention of Student Information.

FERPA

Under FERPA, when Schools contract for Securly Services, Securly functions as a school official, with a legitimate educational interest in Students’ education records. In accordance with FERPA, Securly (i) performs an institutional service or function for which the School would otherwise use employees; (ii) meets the criteria set forth in the School’s annual notification of FERPA rights for being a school official with a legitimate educational interest in education records; (iii) remains under the direct control of the School regarding the use and maintenance of education records; and (iv) agrees to use Student Information from education records only for the purposes for which the disclosure was made, e.g., to promote School safety and the physical security and wellbeing of Students, and will not disclose Student Information from education records for any other purpose without the School’s authorization.

COPPA

COPPA obligates Securly to secure the School’s consent to collect, use, or disclose personal information collected online from children under 13. When Schools sign up to use our Services, the School consents, as agent for Parents, to the collection, use, and disclosure of personal information from and about Students. This consent allows us to process Student Information for the use and benefit of the School, and for no other commercial purpose. As required by COPPA, Securly provides Schools with a direct notice of our processing of Student Information.

b. Consent

By contracting for the Services, Schools provide consent for Securly to process personal information, de-identified information, and aggregate information about Students on behalf of the School. Schools are responsible for confirming that they are authorized to consent to the processing of this information and for obtaining any necessary consents from the Parent or Student.

In order to use Securly Services, Schools must consent to the processing of Student Information. Use of the Services, and any dispute over privacy will be governed by our contract with the relevant School, this Privacy Policy, and our Terms of Service including its applicable limitations on damages and resolution of disputes. This Privacy Policy is incorporated by reference into the This link opens in a new tab.Terms of Service.

Securly does not use Student Information for any purpose unrelated to the provision of the Services without consent. Securly may, however, use aggregated or de-identified data for the improvement of its Services.

Schools, Parents, and/or Students who are 18 or older may withdraw consent for the processing of Student Information at any time. Securly will honor all such requests, but note that withdrawing consent may result in Students’ inability to continue using some or all of the Services and/or features of those Services. To withdraw consent, contact your school, which will transmit the withdrawal to Securly.

c. Types of Information Collected by the Services

The Services may collect Student Information from Schools, Students, Parents, Educators, and automatically through the use of our Services. While Securly Services do not enable Students to make personal information publicly available, Students may access third-party sites or services while using the Services that allow them to do so. Such access is subject to the third-party sites and services’ terms of use and privacy policies.

Information Collected Directly from Students

Students interact directly with some Securly Services. When Students do, we may collect identifiers such as user name or school email and other information related to the purpose of the Services (such hall pass or flex time requests, search queries, and information about how a Student is feeling).

Information Automatically Collected by the Services

Depending on the Service, Securly may automatically collect some or all of the following information about a Student, in all cases based on policies set by the School:

• Device information. We may collect information about Students’ school-issued or personal devices, including the device hostname, device name and model, operating system type and version, browser type and language, and Internet Protocol (“IP”) address.
• Application usage information. We may collect information about how Students interact with Securly while using the Services, such as which applications are used and for how long.
• Online activities. In accordance with School policies, we may collect information about a Student’s online activities. This may include: web browsing activity (for example, websites and videos viewed or blocked, time spent on a website, links clicked, web searches, AI chat questions); social media usage, including social media posts and messaging activity; the contents of emails, blog posts, and messages; and online interactions with teachers including student/teacher chats, virtual raised hands, and teachers’ response to distracted behavior such as closing a tab on a Student’s device. Based on a Student’s online activities, Securly may identify potential signs of anxiety, depression, cyberbullying, self-harm, and potential violence.
• Geolocation information. We may collect geolocation information (including geo-related elements of device information such as IP address) to determine a rough estimate of the device’s location. Securly also offers Services that allow Schools to enable the collection of precise geolocation information, but only when school-issued devices are reported lost or stolen.
• Audio or video files. Some Services allow Educators and Students to conduct audio and video calls for educational purposes. Securly processes the audio and visual data from these calls solely for the purpose of providing this service. Calls are not monitored, recorded, or stored by Securly.

Information Collected from Schools and/or Educators

We collect information about Students from the Schools that they are enrolled in. Depending on the specific Service, this information may include the Student’s name, address, telephone number, email address, parental contact information, date of birth, grade level, year of graduation, enrollment, attendance, school schedule including extracurricular activities, and teachers’ names. In some Services, Securly will collect teacher work data including screenshots and student/teacher chats. For wellness applications only, Schools or Educators may provide information about a student’s gender, ethnicity, ESL status, receipt of special education services, and health, safety, and wellness.

Information Collected from Parents

In order to provide our Home Service, Securly may collect Parent contact information (e.g., name, address, email, or phone) and online restriction policies.

Information Collected from Google APIs

Securly Classroom imports data using Google APIs to make the data available to Students and Educators through the Securly Classroom application. Chrome operating system (“OS”) and organizational unit (“OU”) data is imported to allow Students and Educators to view and manage Chrome devices. For example, Schools use this information to move devices between classrooms, teachers, or schools, and to activate Lost Mode in Securly Classroom. User profile data, including photos, is imported to provide class roster information to enable teachers to recognize Students. Classroom APIs are accessed exclusively to provide roster information and to allow teachers to access Classwork for use in managing classes. Google domain data is used only to provide Securly Classroom Services, and no API data is shared with any outside organization for any reason.

The sole purpose for accessing data from the Google domain is to provide the Securly Services to the School. No data is shared with any outside organization for any reason. The data is used exclusively to provide Schools the management services of the Securly products to which they subscribe.

Securly Classroom does not transfer information received from Google APIs to any application outside of the Securly Services. The use of all information received through the APIs will adhere to the Google API Services user Data Policy, including the Limited Use requirements.

d. How the Services Use Student Information

We use Student Information in the following ways:

• To provide Services to Schools, including by logging Students’ online activities and the information a Student distributes, displays, or shares. We analyze this to provide Schools, Educators, and Parents with alerts, reports, and logs regarding that activity. Securly reports may relate to a specific Student or may reflect class or School-wide Student activity to allow Schools and Educators to conduct comparative analyses of Students.
• To respond to customer service and technical support issues and requests. For example, if a Student runs into technical errors while using the Services, we may request School permission to obtain a crash report along with certain logging information from the device used by the Student documenting the error. This may include information regarding the device's Operating System version, hardware, and browser version (and .NET version information in case of Windows systems).
• To comply with the law or legal proceedings, such as subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements; to protect the Sites, the Services, and our business operations; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Service or this Privacy Policy.

We do not use Student Information for any commercial purposes not related to the provision of the Services. Specifically, Securly does not:

• Sell Student Information;
• Build Student profiles for commercial purposes; or
• Use Student Information for advertising, including marketing communications and targeted advertising.

We may use data that has been aggregated or de-identified in compliance with federal and state standards 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 and analyze our Services, such as by refining the types of activities that trigger (or do not trigger) an alert; and
• For other research and analytical purposes related to the Services.

e. How the Services Share Student Information

We may share Student Information as described below. We may also use and share aggregate or de-identified Student data with third parties for research and analytical purposes.

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 databases of Student Information solely for the purpose of helping us provide the contracted 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 contractual commitments. Except as explained above, we do not disclose or transfer Student Information to third parties except for authorized educational/School purposes at the direction of 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.

Schools and Parents. In compliance with COPPA and FERPA, Schools, Educators, and Parents are able to log in to view information about their Students’ use of certain Services.

Actual Purchasers of Our Company, Business, or Assets. We may disclose Student Information to a third party that acquires or merges with Securly or that acquires substantially all of our assets (including as part of a bankruptcy proceeding), provided the third party is subject to equivalent privacy and security commitments as Securly and the information disclosed continues to be used exclusively for educational/school purposes in compliance with applicable laws.

Government Entities, Law Enforcement, and Others. We may disclose Student Information to third parties (including law enforcement or other government agencies) to comply with applicable law or regulations, a judicial proceeding, court order, subpoena, or other legal process. In particular, many states have laws that require specific categories of persons, or in some cases any person, to report certain matters pertaining to child safety to relevant state or local authorities. These matters may include any reasonable suspicion of child abuse or neglect or the presence of child sexual abuse material. We may therefore be required by law to report information from certain alerts to relevant state or local authorities in these states. In addition, we may disclose Student Information to third parties 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 Service, or as evidence in litigation in which Securly is involved.

f. Information Students Share with Third Parties

Subject to a School’s policies, Students may be permitted to voluntarily share information with third parties, including Social Media activity, while using the Services. The privacy policies of these third parties are not under our control and likely differ from ours. The third party’s privacy policy, or its independent agreement with the School—not Securly’s Privacy Policy—will govern the use of any information that Students may provide to them. You should always review the privacy practices of online sites and services as Securly has no control over how any third-party site uses or controls the information that it collects directly from Students.

g. Security of Student Information

The security of Student Information is important to us. We have implemented a written information security program that is reasonably designed to protect the Student Information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We have implemented technical, contractual, administrative, and physical security steps and other organizational safeguards designed to protect personal information. This includes the use of authentication technologies, encryption where appropriate, and a securely configured network.

Securly adheres to the information security principles of “least privilege” and “need to know.” That means that access to Student Information is limited to Service Providers and Securly employees who require such access to carry out their specific role, who are obligated in writing to maintain the security and confidentiality of such information and prohibited from using that data for any other purposes.

Please be aware that despite our best efforts, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We cannot guarantee that our Services will always be perfectly secure, and we are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

If we learn of a security breach that undermines the integrity and confidentiality of Student Information, we will notify affected Schools in accordance with applicable law, contractual obligations, and industry practices. With a School’s permission, we may also post a notice on the Sites or elsewhere on the Service. Depending on the jurisdiction, affected Students may be entitled by law to receive a written notice of a security breach.

h. Your Rights Regarding Our Use of Student Information

We will make reasonable efforts to keep Student Information accurate and up-to-date. Schools have the right to review their Students’ Student Information, to refuse to allow our further use or future collection of Student Information about their Students, and to direct us to delete their Students’ Student Information. Schools can make a request to exercise these rights by contacting us at support@securly.com or calling 1 (855) 732-8759 (ext. 101). We will review these requests and respond accordingly. Upon receipt of a School request, we will also enable Students 18 and over, Parents, and individual Educators to review, update, and correct Student Information as appropriate and/or desired.

If we learn we have collected personal information about a Student without proper consent, we will promptly delete that information.

i. How Long We Retain Student Information

As explained in section 1.d above, we collect Student Information in order to provide the Services. Retention of Student Information for some period is necessary to provide the Services, which are designed to enable Schools, Educators, and Parents to analyze Students’ online activities, manage Student internet traffic and devices, and provide Students with wellness and educational tools.

Securly will honor a School’s request to delete Student Information at any time during the contract period. Securly also permits Schools to set a specific data retention periods for each Service. If the School does not ask us to delete Student Information or fails to specify a specific retention period, Student Data will be deleted in accordance with Securly’s data retention policy, which requires us to delete Student Information when it is no longer needed for the purpose for which it was collected and in any case, within thirty (30) days after the School’s agreement with us ends.

Securly will certify that Student Information has been deleted at the request of the School. We may retain de-identified and aggregate Student data for the purposes described in section 1.d above.

Section 2: For Parents and Educators Using Securly Services

This section of the Privacy Policy covers personal information collected from Parents and Educators as they interact with the Services (“Parent and Educator Information”), including through password-restricted areas of the Sites. Nothing in this Section of the Privacy Policy describes the processing of personal information about Students or children.

Parent and Educator Information is information about a Parent or Educator that is linked or linkable to that Parent or Educator’s identity. De-identified or aggregated Parent and Educator data is not Parent and Educator Information.

Securly processes Parent and Educator Information is processed as a processor or service provider on behalf of Schools. Schools are the controllers of any Parent and Educator Information. Securly processes Parent and Educator Information in accordance with applicable law, our contractual obligations to Schools, this section of this Privacy Policy, and our Terms of Use.

a. Types of Information Collected by the Services

We collect the following information from Parents and Educators:

• Account Information. When you sign up for an account with us, we collect your name and email address. We may also ask or allow you to submit additional information, such as phone number, student name (if you are a parent/guardian), student school, and school location. We use this information in order to communicate with you about your account, facilitate your use of our Services, and, subject to our contracts with Schools, provide news, special offers, promotions, and other information we think may interest you. Parents or Educators may opt out of receiving emails about news and special offers, but may still receive transactional e-mails, such as about your account or any Services you have requested or received from us.
• Customer Support. When you contact our customer support services via email, phone, or chat, we collect a record of that communication in our customer files.

Parent and Educator Information is often combined with Student Information.

b. How the Services Share Parent and Educator Information

We may share Parent and Educator Information in the same ways that we share Student Information, described above in Section 1.e. We may also use and share aggregate or de-identified Parent or Educator data with third parties for research and analytical purposes.

c. Your Rights Regarding Our Use of Parent and Education Information

Securly will honor requests from Schools to access, correct, or delete personal information about Students, Parents, and Educators. If you would like to exercise any of your rights regarding our use of your information, please contact your School.

d. Parents and Educators Are Adults

The Sites, including the password-restricted areas, are not directed to children under the age of 18, and we do not knowingly collect personal information from children under the age of 18 on the Sites. If we discover that we inadvertently collected information from a child under the age of 18 through the Sites, we will promptly delete it.

Section 3: For Adults Visiting the Securly Sites

PLEASE NOTE: THIS APPLIES TO INFORMATION COLLECTED FROM/ABOUT VISITORS ON THE NON-RESTRICTED AREAS OF SECURLY SITES. FOR INFORMATION ABOUT HOW SECURLY PROCESSES STUDENT INFORMATION, SEE SECTION 1 ABOVE.

This Section of the Privacy Policy describes how Securly collects and processes personal information (as defined by applicable privacy law) about Site Visitors. Nothing in this Section of the Privacy Policy describes the collection and processing of personal information about Students or children.

This Privacy Policy serves as notice to you about how Securly will handle your personal information. Your use of the Sites, and any dispute over privacy, is subject to this Privacy Policy and our Website Terms including any applicable limitations on damages and resolution of disputes. The Website Terms are incorporated by reference into this Privacy Policy.

Securly is the controller of Site Visitors’ personal information.

a. Types of Personal Information Collected from Site Visitors

We collect personal information about Site Visitors directly from Site Visitors when you voluntarily provide it, for example, by subscribing to our blog or interacting with our Chat Bots. We also collect personal information about Site Visitors from third parties and certain pseudonymous personal information is automatically through Site Visitors’ use of the Sites. We may combine information we collect from these various sources. We may also infer information about your interests and preferences based on the information we collect.

Site Visitors are not under a statutory or contractual obligation to provide us with personal information.

Information We Collect Directly from Site Visitors

We collect the following information directly from Site Visitors:

• Contact Information. For example, when you communicate with us, we may collect your name, email address, or phone number. When you sign up to receive emails and offers from us, we may collect your name, email address, and zip code or area code. For information on how to opt-out of receiving newsletters and updates via email please see below.
• Communications with Us. When you communicate with us, you may choose to provide us with additional personal information.

Information We Collect from Third-Party Sources

We may also collect personal information about Site Visitors from third parties. This link opens in a new tab.Click here for a list of third parties from which we obtain information.

We, our service providers, ad networks, and AdTech service providers may use cookies, clear GIFs, and other tracking mechanisms to automatically collect Site Visitors’ personal information. For more information about these technologies, please see the “Cookie and Other Tracking Mechanisms” section below.

We, our service providers, ad networks, and AdTech service providers may use these technologies to automatically collect the following personal information:

• Device and Usage Information. We collect information about the device you use to access our Sites, your use of the Sites, and your interactions with our communications, such as your IP address, mobile device ID, device name and model, your browser type, your operating system, the emails from us you viewed or forwarded, and the pages you visit, the content you search for, and the videos you watch on our Sites.
• Geolocation Information. We may collect geolocation information (including elements of device information such as IP address) to get a rough estimate of your current location.

Please This link opens in a new tab.click here to review a detailed chart explaining the categories of personal information collected and the categories of sources of that information.

b. How We Use Site Visitors’ Personal Information

We use Site Visitors’ personal information for the following purposes:

• Providing and Improving the Sites and Our Services. To maintain and improve the Sites and our Services; to develop new features, products, or services; to perform technical operations, such as updating software; and for other customer service purposes.
• Personalizing Content and Ads. We may use the information we collect about Site Visitors to personalize the information and content we display to Site Visitors, including tailoring the content and information that we may send or display to Site Visitors, and to otherwise personalize Site Visitors’ experiences, including providing more relevant ads on the Securly Sites and on other websites.
• Marketing and Communications. We may use information about Site Visitors to send product or service updates; to respond to inquiries; to provide news, special offers, promotions, and other information we think may interest Site Visitors; to track email response rates, identify when our emails are viewed, and track whether our emails are forwarded; and for other informational, marketing, or promotional purposes. Our communications with Site Visitors may include communications via email. Site Visitors may opt out of such communications at all times by following the opt-out instructions contained in the e-mail. Please note that it may take up to 10 business days for us to process opt-out requests. If Site Visitors opt out of receiving emails about recommendations or other information, but subscribe to our services, we may still send Site Visitors transactional e-mails, such as about any account or services the Site Visitor has requested or received from us.
• Research and Analytics. We may use information about Site Visitors collect data about how Site Visitors interact with the Sites over time; to analyze how Site Visitors interact with our Sites; to monitor and analyze usage and activity trends; to evaluate the success of our advertising campaigns; and for other research, analytical, and statistical purposes.
• Protecting Legal Rights and Preventing Misuse. We may use information about Site Visitors to protect the Sites, the Services, and our business operations; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Website Terms or this Privacy Policy.
• Complying with Legal Obligations. We may use information about Site Visitors to comply with the law or legal proceedings. For example, we may disclose information in response to subpoenas, court order, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.
• General Business Operations. We may use information about Site Visitors to consider and implement mergers, acquisitions, reorganizations, and other business transactions, and, where necessary, to administer our general business, accounting, recordkeeping, and legal functions.
• Aggregate, De-identified or Anonymous Data. We may also use information about Site Visitors to create and use aggregate and/or de-identified data (as those terms are defined in applicable law) to assess, improve and develop our business, products, and services, and for similar research and analytics purposes. This information is not subject to the restrictions in this Privacy Policy, provided it does not identify and could not be used to identify a particular individual.
• Other Purposes. We may use Site Visitors’ personal information for other purposes that are disclosed at the time of collection or for which we obtain Site Visitors’ consent.

Please This link opens in a new tab.click here to review a detailed chart explaining why Securly uses each category of personal information collected.

c. How We Disclose Site Visitors’ Personal Information

We may disclose Site Visitors’ personal information for the purposes listed above for which we collect it to:

• Affiliates. We may share Site Visitors’ personal information with our affiliates, whose handling of personal information is subject to this Privacy Policy.
• Service Providers. We may disclose Site Visitors’ personal information to our third-party vendors, service providers, marketing partners, third parties, contractors or agents who perform functions on our behalf.
• Prospective or Actual Purchasers of Our Company, Business, or Assets. We may disclose Site Visitors’ personal information to another entity in connection with an acquisition or merger, sale or transfer of our assets, bankruptcy proceeding or as part of any other similar business transfer, including during negotiations related to such transactions.
• Government Entities, Law Enforcement, and Others. We may disclose Site Visitors’ personal information to government entities, law enforcement, and other parties are required or permitted by applicable law.

In addition, we may share Site Visitors’ personal information with:

• Ad Networks and AdTech Service Providers. We may sell or share Site Visitors’ personal information to ad networks and AdTech service providers to assist us in targeted advertising (i.e., displaying advertisements on third-party websites) and to evaluate the success of our advertising campaigns.

We may share aggregate or otherwise de-identified information about Site Visitors with third parties for marketing, advertising, research, or similar purposes.

Please This link opens in a new tab.click here to review a detailed chart listing (1) the categories of entities to whom Securly discloses personal information for a business purpose, and (2) the categories of entities with whom Securly sells or shares personal information for commercial purposes. Click here for a list of third parties to whom we sell Site Visitors’ personal information.

d. Cookies and Other Tracking Mechanisms

Cookies, Clear GIFs, and Other Technologies. Cookies are alphanumeric identifiers that we transfer to a Site Visitor’s computer’s hard drive through the web browser. Clear GIFs (a.k.a. web beacons, web bugs or pixel tags) are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on a Site Visitor's computer’s hard drive, clear GIFs are embedded invisibly on web pages. We, our service providers, or ad networks may also use other tracking mechanisms with similar purposes.

How We Use Cookies, Clear GIFs, and Other Technologies. We, our service providers, and ad networks may use these tracking mechanisms to make it easier for Site Visitors to navigate our Sites, track Site Visitors' activities on our Sites, help us manage Site content, compile statistics about Site usage, track e-mail response rates, identify when our e-mails are viewed, track whether our e-mails are forwarded, assist us in displaying advertisements on third-party websites, evaluate the success of our advertising campaigns, and help us improve our Sites, performance, and Site Visitors’ experience.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, Site Visitors can edit browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Site Visitors who disable cookies will be able to browse certain areas of the Sites, but some features may not function. Please keep in mind that without cookies Site Visitors may not have access to certain features on the Sites, including certain personalized content.

e. Targeted Advertising for Site Visitors

We may work with third parties such as network advertisers to assist us in displaying advertisements on third-party websites and to evaluate the success of our advertising campaigns. We may use information about Site Visitors for these purposes.

Site Visitors may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information regarding this practice by NAI members and DAA members, and choices regarding information used by these companies, including how to opt out of ad networks operated by NAI and DAA members, please visit their respective websites:

Canada: This link opens in a new tab.http://youradchoices.ca
EU: This link opens in a new tab.http://youronlinechoices.eu
US: This link opens in a new tab.http://aboutads.info; This link opens in a new tab.https://optout.networkadvertising.org/

If you opt out of targeted advertising, you will still be shown ads as you navigate the World Wide Web, but they will not be targeted based on your online activities. Site Visitors may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs. Please note that opt-out mechanisms are cookie based; so, if Site Visitors delete cookies, configure browsers to block or reject cookies, or use another device, the opt-out will no longer be effective.

Depending on where you reside, you may have the right to opt out of targeted advertising. See the "Your Rights Regarding Our Use of Site Visitors’ Personal Information” section below for more details.

f. Purposes and Legal Bases for Processing Site Visitor Information

We process Site Visitors’ personal information on the following legal bases:

Our Legitimate Business Interests. We process Site Visitors' personal information in furtherance of our legitimate business interests, which are not overridden by Site Visitors' interests and fundamental rights, including:

• Performance of contracts with customers and other parties;
• Implementation and operation of support services for our business operations;
• Improving our Sites and Services, developing reports, and similar purposes;
• Subject to rights you may have under applicable law, customer relationship management and improving our Sites and Services, including other forms of marketing and analytics;
• Fraud detection and prevention, including misuse of our Sites or Services;
• Physical, IT, and network perimeter security;
• Internal investigations; and
• Mergers, acquisitions, reorganization, and other business transactions, including related negotiations.

Compliance with Laws. We process Site Visitors’ personal information to comply with our legal obligations, including those in the area of labor and employment law, social security, and data protection, tax, and other corporate compliance laws, and/or to defend against legal claims.

With Your Consent. We process Site Visitors’ personal information where we have Site Visitors’ consent to do so for a specific purpose.

g. Security of Site Visitor Personal Information

The security of Site Visitors’ personal information is important to us. We have implemented a security program designed to protect the information we collect through our Sites from loss, misuse, unauthorized access, disclosure, alteration, and destruction. However, given the nature of information security, there is no guarantee that our Sites will be 100% secure.

We encourage Site Visitors to help protect the security of personal information. For instance, Site Visitors should never give out personal credentials when using the Sites. Furthermore, Site Visitor are responsible for maintaining the security of any personal computing device using the Sites. We are not responsible for any lost, stolen, or compromised passwords or for any activity on Site Visitor accounts via unauthorized password activity.

h. International Transfers

Securly, Inc. is headquartered in the United States of America and has operations and service providers in the United States and other jurisdictions. As such, we and our service providers may transfer your personal information to, or access it in, jurisdictions that may not provide levels of data protection equivalent to your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it in accordance with applicable laws, including through appropriate written data processing terms and/or data transfer agreements.

If you are in the European Economic Area (“EEA”) or the United Kingdom (“UK”), and we process your personal information in a jurisdiction that the relevant regulator has deemed to not provide an adequate level of data protection (a “third country”), we rely upon legal measures to adequately protect your personal information. These measures include standard contractual clauses approved by the relevant authorities (i.e., the European Commission or the UK Information Commissioner’s Office) or another method approved by those authorities as providing adequate safeguards for the protection of personal information when transferred to a third country. You have a right to obtain details of the mechanism under which your personal information is transferred outside of the UK or the EEA; you may request such details by contacting us as set forth above. We may redact data transfer agreements to protect commercial terms.

i. No Automated Decision-Making

Securly does not process Site Visitors’ personal information for automated decision making.

j. Your Rights Regarding Our Use of Site Visitors’ Personal Information

Depending on the circumstances and where you reside, you may have certain data subject rights. These rights may include the following:

• Right of Access. You may have the right to ask us to confirm whether we are processing your personal information, to provide specific information on what information we have processed, the purpose of that processing, and to whom we have disclosed that information. You also may have the right to request a copy of that information. Depending on where you reside, you may ask us for certain further information about the processing of your personal information.
• Right to Rectify and Complete Personal Information. You may have the right to ask us to rectify inaccurate information. We may seek to verify the accuracy of the data before rectifying it.
• Right of Erasure. You may have the right to ask us to erase your personal information, subject to certain exceptions such as for compliance with a legal obligation or for the establishment, exercise or defense of legal claims. Depending on where you reside, this right may not apply to personal information we did not collect directly from you.
• Right to Opt Out of Targeted Advertising. You may have the right to opt out of targeted advertising involving the processing of your personal information.
• Right to Opt Out of the Sale of Personal Information. You may have the right to opt out of the sale of your personal information.
• Right of Restriction. You can ask us to restrict (i.e., keep but not use) your personal information, but only where: its accuracy is contested, to allow us to verify its accuracy; the processing is unlawful, but you do not want it erased; it is no longer needed for the purposes for which it was collected, but you still need it to establish, exercise or defend legal claims; you have exercised the right to object, and verification of overriding grounds is pending. We can continue to use your personal information following a request for restriction where: we have your consent; to establish, exercise or defend legal claims; or to protect the rights of another natural or legal person.
• Right to Object to Our Use or Sharing of Your Personal Information for Direct Marketing Purposes. You can ask us at any time not to process your personal information for direct marketing purposes, including transferring your personal information to unaffiliated third parties for the purposes of direct marketing/targeted advertising.
• Right to Object for Other Purposes. You can object at any time to any processing of your personal information which has our legitimate interests as its legal basis. We may continue to process your personal information if we have compelling legitimate interests which override your rights and freedoms.
• Right to Data Portability. You can ask us to provide your personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it ported directly to another data controller. Depending on where you reside, this right may not apply to personal information we did not collect directly from you.
• Right to Withdraw Consent. You can withdraw your consent for any processing of personal information that is based on consent you previously provided.
• Right to Lodge a Complaint with Your Local Supervisory Authority. You can lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information. If you are a UK resident, this is the Information Commissioner’s Office (ICO), the UK regulator for data protection issues. Contact details for ICO are available here. We ask that you please attempt to resolve any issue with us first, although you have a right to contact your supervisory authority at any time.

You can make a request to exercise these rights by contacting us at support@securly.com or calling 1 (855) 732-8759 (ext. 101). We will review your request and respond accordingly. The rights described herein are not absolute.

You will not have to pay a fee to exercise any these rights, except that we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. We will not provide access to your personal information more than twice in any 12-month period.

Individuals who submit requests for access, rectification, or erasure of personal information will be required to verify their identity by answering certain questions. We will not disclose or delete any information until such individual’s identity is verified.

You may designate an authorized agent to submit a request on your behalf by providing that agent with your written permission. If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us before we can honor the request.

Agents who make requests on behalf of individuals will be required to verify the request by submitting written authorization from the individual. We will not honor any requests from agents until authorization is verified.

You may appeal our decision regarding your request to exercise these rights by contacting us at support@securly.com or calling 1 (855) 732-8759 (ext. 101). Your email must provide your name, your state of residence, and a brief description of the appeal subject matter. Upon receipt, we will inform you in writing of our response to the appeal, including an explanation of the reasons for our decision, within 45 days. Where required by law, we will also provide you a method through which you can submit a complaint to your state attorney general.

We will not discriminate against you in any manner prohibited by applicable law on the basis that you have exercised any of these rights.

k. How Long We Retain Site Visitors’ Personal Information

We will generally keep Site Visitors’ personal information only for as long as it remains necessary for the identified purposes for which it was collected or as authorized or required by law. We may retain certain personal information as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated data, account recovery, or if required by law.

All retained personal information will remain subject to the terms of this Privacy Policy.

l. Links

When you visit our Sites and leave to go to another linked site, we are not responsible for the content or availability of the linked site. Please be advised that if you enter into a transaction on the third-party site, we do not represent either the third party or you. Further, the privacy and security policies of the linked site may differ from ours.

m. Site Visitors Are Adults

The Sites, including the password-restricted areas, are not directed to children under the age of 18, and we do not knowingly collect personal information from children under the age of 18 on the Sites. If we discover that we inadvertently collected information from a child under the age of 18 through the Sites, we will promptly delete it.

Section 4: General Information

a. Effective Date

This Privacy Policy is effective as of the date set forth above. We may change this Privacy Policy from time to time, so please be sure to check back periodically.

• If we make any changes to this Policy that materially affect our practices with respect to personal information about Site Visitors, we will provide advance notice by posting a notice on our Sites.
• If we make changes that materially affect our processing of personal information about Students and/or Educators, we will notify Schools directly in advance, e.g., via email or as otherwise specified in our contracts.
• If we make changes that materially affect our processing of personal information about Parents, we will notify those Parents directly in advance, e.g., via email or a notice posted in the password protected areas of our Sites.

b. Contact Us

If you have any questions, comments, or concerns about the privacy aspects of our Sites or Services or would like to make a complaint, please email us at support@securly.com, call us at 1 (855) 732-8759 (ext. 101), or write to us at: