Guardian App Privacy Policy
Version 1.2 Effective Date: April 2022
Alef Education Consultancy LLC (“we” or “ Alef Education”) is a company registered in Abu Dhabi with commercial license CN-2209313. Alef Education provides this privacy policy (“Privacy Policy”) to help you understand how Alef Education collects and uses data when you download and use the Alef Education mobile application (the “App”) in conjunction with the services we provide to client schools, school districts, and educational organizations. “You” means an individual who downloads or uses the App.
If you have any questions about the Privacy Policy or how we protect personal data, please contact privacy@alefeducation.com.
This Privacy Policy covers our treatment of Personal Information, as that term is defined in Section 13 below, that we gather when you are accessing viewing, completing, or using the App. It does not apply to any other Alef Education websites, products, software or services (collectively, the “Services”) which may be subject to separate privacy policies. Unless specifically stated otherwise, this Privacy Policy does not modify or alter other agreements you or your school, school district, or educational organization may have, or enter into later, with Alef Education, including Alef Education’s Privacy Promise . Where noted, the terms of this Privacy Policy are limited by the Privacy Laws, as that term is defined in Section 13 below, that govern an individual’s or user’s jurisdiction, such that requirements created by the Privacy Laws of one jurisdiction with regard to Personal Information are not incorporated herein and made to apply to the Personal Information of an individual or user of another jurisdiction if such Privacy Laws would not otherwise govern. Notwithstanding the foregoing, this policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
In addition to this Privacy Policy, for certain features of the App, Alef Education may present different or additional practices and terms concerning Personal Information specific to those programmes at the time the information is collected.
Information You Provide . For permitted users, we will provide a unique username and password so that you can download, login to and use the App. We may record information about you which you voluntarily disclose through use of the App and when you correspond with us, such as when you report problems with the App.
From time to time, we may ask you to update the Personal Information you have provided to us and to provide other categories of Personal Information. In some cases, it will not be possible for Alef Education to make a particular service available to you if you do not provide certain information. Except as otherwise noted, you do not have a legal obligation to provide any Personal Information to Alef Education, however, we may not be able to provide access to the App or to certain features unless you do so.
Information Collected Automatically . Personal Information may be collected automatically when you use the App, such as your IP address and your device’s encrypted IMEI number or SIM card ID, or from our affiliates.
Alef Education may also collect location data regarding where the App is used and information from the device you
use to access the App, such as your browser type, operating system version, device type and time period of use.
You may stop Alef Education collecting location data at any time by going to “Settings” in the App and turning off
location services, although this may affect the provision of services which make use of location data sent from
your device.
Alef Education uses ‘cookie’ technology (small computer files placed on your device’s hard drive). When you go to
particular pages within the App, the cookie identifies your browser with a unique, random number. You are always
free to decline the cookies, if your browser permits, although doing so may interfere with your use of the App.
Special Categories of Personal Information and Sensitive Personal Information . Except as otherwise stated in this Privacy Policy, we do not knowingly collect sensitive Personal Information or special categories of Personal Information through the App, including (1) Personal Information revealing racial or ethnic origin, political opinion, religious or philosophical beliefs, criminal record or trade union membership, (2) genetic data, biometric data, data concerning health, and data concerning a natural person’s sex life or sexual orientation, and (3) other identifiers (such as Social Security numbers and driver’s licenses), financial account and login information (such as credit or debit card number together with login credentials), precise geolocation, or content of nonpublic communications (mail, email and text messages). As applicable under the relevant Privacy Laws, where we collect and use such information as a processor, contractor, or service provider, we rely on the controller or business to obtain your informed consent.
Personal Information Alef Education has collected in the last 12 months . In the 12 months immediately preceding the Effective Date, Alef Education has collected all the categories of Personal Information described in Sections 1(A) and (B) in addition to Personal Information that are publicly available or that we received from client schools, school districts, and educational organizations. The business purposes of this information are described in Section 2 below. The categories of third parties we share this information with are described in Section 3.
Use of Personal Information We use your Personal Information for the following purposes:
to enable us to provide the App and associated services;
to communicate or enable the client schools, school districts, and educational organizations to communicate with you;
to investigate and resolve disputes and other issues;
to enable you to participate in interactive features of the App;
to operate, maintain, and improve the App and associated services we provide to our clients and to notify you about changes to them;
to administer the App and our services, including for troubleshooting and testing purposes;
to detect and investigate fraud and abuse of our services;
where necessary for compliance with our contractual obligations with client schools, school districts, and educational organizations to which we are subject;
where necessary for compliance with a legal obligation to which we are subject; and
where necessary for the purposes described in this Privacy Policy.
Alef Education may anonymize or aggregate Personal Information it collects. It may also use that information and other non-Personal Information it collects when you use the App to better understand our users and their behaviour and to improve the user experience of the App and the Services.
We may also share Personal Information with third parties (as described in this section and in Section 3 below).
Storage of Personal Information
We store Personal Information on servers operated by Alef Education or with hosting service providers in locations worldwide. Please see Alef Education’s Privacy Promise for more details.
We share your Personal Information with third parties as described below.
Clients
We share Personal Information with our client schools, school districts, and educational organizations as part of the services Alef Education’s provides to those entities.
Third Party Businesses We Do Not Control that Facilitate the Services We Provide
In certain situations, we will share Personal Information with third-party businesses that facilitate certain aspects of the services provided through the App.
Anonymized, Aggregate, and Non-Personal Information
We may disclose anonymized, aggregated, or other non-Personal Information we collect when you use the App to our clients, affiliates (who may be interested in learning about the characteristics of users accessing the App, such as their location), and third party analytics providers.
Business Transfers
We may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that is transferred. Also, if we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information would be one of the assets transferred to or acquired by a third party.
Legal Obligations, Our Protection, and the Protection of Others
We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of Alef Education, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and risk reduction.
Personal Information Alef Education Has Sold in the Last 12 Months
Alef Education does not sell Personal Information, however, we share Personal Information with our school, school district, and educational organization clients as part of the Services provided to those clients, as described in Section 3.G below, which may qualify as a sale of Personal Information under applicable Privacy Laws.
Personal Information Alef Education Has Disclosed to Third Parties in the Last 12 Months
Alef Education has disclosed the following categories of Personal Information to our school, school district, and educational organization clients in the 12 months immediately preceding the Effective Date: names; phone numbers; users’ relationships with students; and communications sent to schools and teachers using the App. Alef Education relies on third party vendors to support the Services, including cloud hosting platforms for all data storage. As a result, all Personal Information collected and described in Sections 1(A) and (B) has been disclosed to third party vendors in the 12 months immediately preceding the Effective Date.
Where required by applicable Privacy Laws, Alef Education collects and uses your Personal Information pursuant to your informed consent, which you have granted by (a) confirming the prompts produced by the App, and (b) continuing to use the App, consistent with this Privacy Policy and any other documentation we may provide. Please note that without your consent to collect and use the Personal Information required in any particular transaction, Alef Education may disqualify you from using the App and/or the Services. If you have any questions concerning the terms of this Privacy Policy and the conditions of your consent, please contact us using the contact information in Section 15.
To the extent that you provide Alef Education with the Personal Information of other people, you warrant and represent that each such person who is required under the Privacy Laws to give consent (e.g. the individual who owns the Personal Data), or the person who is required to give consent, if the Privacy Laws require the consent of another person (e.g. the parent of the minor who owns the Personal Data), has granted his or her consent to you sharing the Personal Information with Alef Education for the use described in this Privacy Policy.
In addition to relying on informed consent, and as necessary under the Privacy Laws, Alef Education reserves the right to process your Personal Information (1) in order to pursue our legitimate business interests, (2) in order to carry on a transaction to which you are a party and/or (3) to comply with our legal obligations. Where the processing is based on a transaction, your failure to provide the relevant Personal Information may result in Alef Education’s inability to continue the transaction. Any one or more of these bases are the legal basis for Alef Education’s collection and use of your Personal Information, depending on (x) how you use the App and Services and (y) your relationship with Alef Education.
Except upon the request of an individual, as explained in Section 6 below, and except as the law permits and requires, Alef Education determines the retention period of Personal Information based on the following considerations:
The continued presence of the App on your device;
The nature of the Personal Information;
The purpose for which the Personal Information was collected;
The existence of (i) other transactions or communications with the person who provided the Personal Information, and (ii) ongoing or expected projects with the relevant school, school district, or educational organization client; and
Our internal research and analytic needs.
To the extent required by the Privacy Laws, except where permitted or required by law (including, but not limited to, compliance with a legal obligation, to further a public interest, and establishing and/or exercising a legal claim or defense), you have the following rights regarding Alef Education’s collection and use of your Personal Information. Please note that, consistent with Section 2 of Alef Education’s Privacy Promise , we retain the right to direct you to the school, school district, or other organization that has retained Alef Education to provide the Services and that serves as the controller or business, per applicable Privacy Laws, to enforce any rights listed below.
Requests to Alef Education
You may request the following from Alef Education with respect to your Personal Information:
The correction, updating, deletion, or restriction of collection and use of your Personal Information;
The categories of Personal Information Alef Education has collected about you;
The categories of sources from which Alef Education has collected your Personal Information;
The envisaged period for which the Personal Information will be stored, or, if not possible, the criteria used to determine that period;
The business or commercial purpose(s) for collecting and disclosing your Personal Information;
An account of how Alef Education has used or is using your Personal Information;
A copy of your Personal Information, including the specific pieces of Personal Information, in a format that is easily understandable to the average consumer, and to the extent technically feasible, in a structured, commonly used, machine-readable format, which also may be transmitted to another entity at your request without hindrance;
The categories of third parties with whom Alef Education shares your Personal Information;
The categories of your Personal Information that we have shared with third parties and the categories of third parties to which we have shared each particular category of Personal Information;
The Personal Information Alef Education collects, uses, discloses, shares, and sells; and
A list of all third parties that have received your Personal Information from Alef Education.
All requests may be sent via the contact information in Section 15.
If you request that your Personal Information be erased or deleted or that Alef Education otherwise restrict its collection and use of Personal Information, Alef Education may terminate or limit your access to the App and Services. If Alef Education has not collected or used your Personal Information, or has not disclosed your Personal Information to another party, Alef Education will inform you of that in response to any of the above requests. Some information may remain in Alef Education’s backup media after erasure or deletion for a period of time. When you request that Alef Education update information, Alef Education may retain a copy of the unrevised information in Alef Education’s records. Alef Education also may use any anonymized aggregated statistical data derived from or incorporating Personal Information after it is updated, erased, or deleted, but not in a manner that would identify you.
We will confirm receipt of all such requests, provide information about how Alef Education will process the request, and substantively respond to all such requests that are consistent with the Privacy Laws. There may be a delay in processing a request while we verify that the request is valid and originates from you as opposed to an unauthorized third party. Our verification process varies based on the source and nature of the request, but may include: comparing data in the request against Personal Information we retain; contacting you using other contact information; requesting further information, although we will avoid doing so to the extent possible; and the consideration of certain factors, including the type, sensitivity, and value of your Personal Information, the risk of harm to you posed by an unauthorized request, the likelihood that fraudulent or malicious actors would seek your Personal Information, the manner in which we interact with you, the available technology, and whether the information you have provided to verify your identity is sufficiently robust to protect against fraudulent requests. To the extent permitted by the Privacy Laws, Alef Education retains the right to deny any request if we cannot verify that it originated from you or if the Privacy Laws provide that the request can be denied for any reason.
Alef Education retains records of all of the above requests and our responses as required by the Privacy Laws.
When you update information, we may maintain a copy of the unrevised information in our records. Please note that some information may remain in our private records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.
Authorized Agent
You may authorize an agent to take any of the acts permitted in this Section 6 on your behalf. To do so, you must provide written and signed authority to the agent and written and signed notice to Alef Education that Alef Education may act on such requests by that agent.
Withdrawal of Consent
To the extent that we process your Personal Information based on your consent, you may withdraw your consent at any time using the contact information in Section 15.
Please be aware that such withdrawal does not affect the lawfulness of Alef Education’s use of your Personal Information before such withdrawal. We reserve the right to terminate and/or limit your access to the App and/or Services in the event that you withdraw your consent.
“Do Not Sell My Personal Information” and Opting Out of Sharing Personal Information
You may opt out of all disclosures of your Personal Information via the contact information in Section 15. Your authorized agent may opt out of the disclosure of your Personal Information pursuant to the terms of Section 6.B above.
We will act upon any request to opt out of all disclosure and sharing of your Personal Information, including notifying all third parties to whom we have disclosed or shared your Personal Information and ceasing to disclose or share your Personal Information, consistent with the requirements of the Privacy Laws.
Object or Challenge
You may object to, or otherwise challenge, Alef Education’s collection and use of your Personal Information by contacting us via the information in Section 15 below. Alef Education will respond consistent with the requirements of the Privacy Laws.
Filing a Complaint
Regulatory authorities that oversee the Privacy Laws typically advise individuals to file an objection or challenge with the company before lodging a formal complaint with a regulatory authority. If an individual is dissatisfied with Alef Education’s response to an objection or challenge filed under Section 6.E, or wishes to file a complaint with a regulatory authority first, the individual may do so, including as follows:
PIPEDA: Office of the Privacy Commissioner of Canada ;
CCPA or CPRA: California Attorney General;
PII Laws: the relevant states’ Attorney General’s office;
NY SHIELD Act: New York Attorney General .
PDPL UAE: Data office.
Prohibit Automated Processing
At your request, Alef Education will terminate any automated decision making, including profiling, that is the sole source of decisions that produce a legal effect concerning or similarly significantly affecting you. Consistent with Section 12, Alef Education does not use any such automated decision-making or profiling at this time.
Accessibility for Users with Disabilities
If you are unable to review this Privacy Policy or any portion of this Policy, please contact us via Section 15 to request an alternative format.
Non-Discrimination
Alef Education will not discriminate against you because you have exercised any of the rights above or any other rights you retain pursuant to Privacy Laws, including, but not limited to by:
Denying goods or services to you;
Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
Providing a different level or quality of goods or services to you; and
Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Consistent with Privacy Laws, Alef Education: (i) retains the right to charge you a different price or rate, or provide a different level or quality of goods or services to you, if that difference is reasonably related to the value provided to Alef Education by your Personal Information; (ii) may offer financial incentives, including payments to you as compensation, for the collection, disclosure, or deletion of your Personal Information; (iii) may enter you into a financial incentive program only if Alef Education clearly describes the material terms of the financial incentive program, so long as you give Alef Education prior opt-in consent, which you may revoke at any time; and (iv) shall not use financial incentive practices that are unjust, unreasonable, coercive, or usurious in nature.
Alef Education does not offer any financial incentives for providing your Personal Information.
Alef Education employs reasonable and appropriate technological, physical, and administrative measures to safeguard the confidentiality, integrity, and availability of Personal Information. Individuals seeking additional information about such safeguards may contact Alef Education using the contact information in Section 15 below.
The App may contain links to other sites and third party content. Alef Education is not responsible for the security or privacy provided by such third parties. When following a link to another site you should read that site’s privacy policy.
To the extent that the App collects or solicits Personal Information from anyone under the age of 18, we rely on our school, school district, and educational organization clients to obtain verified consent from you as the parent, guardian, or custodian of the child as part of using the Services. In the event that your child or dependent provides Personal Information through the App, you hereby warrant that the child or dependent does so with your consent, which has been verified by the school, school district, or educational organization that has contracted with Alef Education. You may exercise any of the rights described in Section 6 above on behalf of your child or dependent via the contact information in Section 15.
Except as noted in this Privacy Policy or in contractual documents, Alef Education’s collection and use of Personal Information is not a contractual or statutory requirement or a requirement necessary to enter into a contract.
You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to use some of the App’s functionalities.
Alef Education does not rely on automated decision-making in respect of the App, including profiling, and will not subject you to decisions based solely on automated processing which will produce legal effects concerning you or similarly significantly affecting you.
“Personal Information” means: (1) personally identifiable information, as defined by numerous statutes in the United States, including New York (such statutes, the “PII Laws”), (2) personal information and private information, as defined by the New York Stop Hacks and Improve Electronic Data Security Act (the “SHIELD Act”); (3) information protected by the California Online Privacy Protection Act (“CalOPPA”), California Consumer Privacy Act (the “CCPA”), and California Privacy Rights Act (the “CPRA”); (4) children’s education records protected by the Federal Family Educational Rights and Privacy Act (“FERPA”); (5) personal information protected by the Federal Children’s Online Privacy Protection Act (“COPPA”); (6) personal information, as defined by Canada’s Personal Information Protection and Electronics Documents Act (“PIPEDA”); (7) personal data, defined by the European Union General Data Protection Regulation (the “GDPR”); (8) personal data, defined by the UAE Personal Data Protection Law (the “PDPL”) and (9) personal information the confidentiality, availability, or integrity of which is protected by applicable law, including those referenced in Alef Education’s Privacy Promise (the “Other Applicable Laws”).
“Privacy Laws” means the PII Laws, the Shield Act, CalOPPA, CCPA, CPRA, FERPA, COPPA, and PIPEDA, GDPR, PDPL and the Other Applicable Laws.
We may change this Privacy Policy at any time, including when required to comply with law or the directions of governmental authorities. Any changes we may make to this Privacy Policy will be notified to you by email or prominently displayed when you access the App and by continuing to use the App you will be deemed to have accepted them.
If you have any questions or concerns regarding this Privacy Policy, please contact us at privacy@alefeducation.com