Last Updated: June 8, 2018
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1. Information Flipgrid Collects
Flipgrid may collect personal information from Users as described below.
1.1 Grid Owner Personal Information (Collected from the Grid Owner)
When a Grid Owner creates an account on the Service, we collect the Grid Owner’s first name, last name, email address, password, instruction type, and country. If you are a teacher or a School, we will also collect your School email address and School name to set up an account.
When a Grid Owner posts content (text, images, photographs, videos, messages, comments, or any other kind of content) on the Service, the information contained in the posting, including first name, last name, email address, any audio and image included within any video, will be stored in our Service for purposes of providing the Service.
When a Grid Owner logs into an existing account through their Microsoft or Google account, we may collect his/her first and last name, email address and other information specific to that third party account to authenticate the Grid Owner.
When a Grid Owner provides feedback to a Student, such as replying to a video book report, assessing foreign language skills, encouraging group discussion, or prompting the scientific method, we store the feedback in the Service for purposes of providing the Service.
When a Grid Owner subscribes for paid services on the Service using a credit or debit card, our third-party payment provider will collect payment and billing information in order to complete the transaction. Flipgrid does not store or otherwise use this information.
If a Grid Owner provides us feedback or contacts us via email, we will collect the Grid Owner's name and email address, as well as any other content included in the email for purposes of replying to the Grid Owner and improving the Service.
1.2 Student Personal Information
If a Student provides us with feedback or contacts us via email, we will collect the Student's name and email address, as well as any other content included in the email, for purposes of replying to the Student and improving the Service.
1.3 Automatically Collected Information
When a User uses the Service, some information is automatically collected to help us understand how the Service is being used and how to improve the Service. For example, device type, the device identifier (UDID), the Open Device Identification Number (ODIN), date/time stamps for each visit, browser type, operating system, Internet Protocol (IP) address, Internet service provider (ISP), referring/exit pages, clickstream data, and domain name are all collected for purposes of administering, tracking usage of, and improving the Service. We may store this information in log files.
Cookies and Similar Technologies
In addition to the cookies we set, third parties can also set cookies when you visit our sites. For example:
Each User has a variety of tools to control cookies, web beacons, and similar technologies, including browser controls to block and delete cookies and controls from some third-party analytics service providers to opt out of data collection through web beacons and similar technologies. User browser settings and other choices may impact the functionality of the Service.
2. Use of Personal Information
We store and process User personal information in the United States, and we use this information as follows:
3. Information We Share
We do not sell Student Users’ personal information. We share personal information we collect on Users (including Students and Grid Owners) when Users create accounts, request support, record videos, share their experiences with us, or otherwise use the Service. We may also share User personal information with vendors, consultants, and other third party service providers who need access to such information to carry out work on our behalf and at our direction. For example, we rely on data center operators, payment processors, and communications vendors to operate our Service, process orders, or send you notifications.
We may also share User personal information for legal, protection, and safety purposes. For example,
Flipgrid reserves the right to share Users’ personal information to respond to duly authorized information requests of governmental authorities or where required by law. Flipgrid reserves the right to use or disclose personal information provided to Flipgrid in response to a lawful request by public authorities, including to meet national security or law enforcement requirements, or if Flipgrid reasonably believes that use or disclosure is necessary to protect Flipgrid’s rights and/or to comply with a judicial proceeding, court order, or legal process. In exceptionally rare circumstances where national, state, or company security is at issue, Flipgrid reserves the right to share our entire database of visitors and clients with appropriate government authorities. If we are going to share User personal information, we strive to provide the User with advance notice by e-mail unless prohibited by law from doing so.
4. Information Users Share
Each Grid and the content submitted to a Grid, such as topics and videos, will be displayed in the Grid and will be visible to anyone who joins the Grid as administered and permitted by the Grid Owner, subject to the Grid Owner’s ability to deactivate or moderate submissions. The Grid Owner, and not Flipgrid, sets the Grid's privacy settings.
We may publish comments or feedback from a User about Flipgrid only if we obtain that User’s consent.
5. Information Choices and Changes
Users may opt out of providing personal information to the Service at any time by uninstalling the application. Users may also opt out of providing personal information by emailing firstname.lastname@example.org to have their account removed or by asking their Grid Owner to remove their content. Flipgrid will stop collecting the User’s personal information in these cases, but may still retain the User’s personal information as outlined in the “Data Retention” (Section 8) of this Policy (below).
Our marketing emails explain how to opt out of receiving such emails. If a User opts out, we may still send them operational emails that pertain to the User's account and notifications regarding our services. Flipgrid does not market to Students under 13.
Users may send requests about their personal information to our contact information in Section 14 below, including to change contact choices, opt out of our sharing with others, and review, update, correct, or delete personal information. Once the User has been authenticated, we will use commercially reasonable efforts to honor these requests. We may retain an archived copy of User records as required by law. Such opt outs may result in disruption or cancellation of the Service or impairment of certain Service functionality.
Users may remove a posted video by using the link emailed to them by the Service for deleting the video. Users may also contact the Grid Owner and request that the video be removed. If the Grid Owner is not able to remove the video, Users can contact us at email@example.com and request that such videos be removed. However, we will only be able to remove the video if (a) the User provided their email address when posting the video and (b) the User sends the email request to us using that same email address. Otherwise, we may not be able to remove a posted video. Deletion of a video removes it from the Grid.
Grid Owners have certain options with respect to the privacy settings of their Grids. For example, teacher or School Grid Owners must password-protect the Grid and can also moderate their Grid. Parents and Students should send all requests regarding these privacy settings directly to the Grid Owner.
6. COPPA AND STUDENTS
6.1 Notice to Parents and Schools
Under the United States Children’s Online Privacy Protection Act ("COPPA"), verifiable parental consent is needed to collect, use, or disclose personal information (e.g., full name and email address) from each User under 13 years old. In accordance with COPPA, a teacher or School Grid Owner may act as the agent of the parent or legal guardian of a Student and provide consent on behalf of the parent for Flipgrid’s collection, use, and disclosure of the Student’s personal information. By enrolling a Student under 13 to use the Service, the School provides such consent to us and agrees that the Students’ activities while on the Service are subject to our Terms. Please see Flipgrid’s Teacher Toolkit (https://static.flipgrid.com/docs/Flipgrid_dos_donts.pdf) and Parent Consent Form (http://static.flipgrid.com/docs/Flipgrid_consent_form.pdf) for guidelines on how teachers and Schools should provide consent on behalf of parents.
As required under COPPA, parents can make certain choices regarding how their child’s information is used. (For more information, see “Parent’s Choices Regarding Information on Students Under 13,” in Section 6.2 below). Parents should submit these requests to the teacher or School Grid Owners, and the teacher or School Grid Owners, as the parent’s agent, must pass those requests to us by emailing firstname.lastname@example.org.
6.2 Parent’s Choices Regarding Information on Students Under 13
Parents of Students under 13 have certain rights with respect to our collection, use, retention, and disclosure of their Student’s information. This includes the right to review, update, or delete Student information, as well as prohibit our sharing Student information with third parties. Parents can exercise these rights by contacting the Student’s Grid Owner, and the Grid Owner should submit these requests, on the parent’s behalf, to Flipgrid by emailing email@example.com. Notwithstanding any such requests, we may continue to share the Student information for non-Service purposes as described in Section 3, “Information We Share.”
A Student’s account must be deleted entirely to prohibit any future collection, use, or disclosure of the Student information. A parent should request deletion of the Student’s account through the Grid Owner. Upon receiving such requests, the Grid Owner can request deletion of the Student’s account by emailing firstname.lastname@example.org. This will delete the Student information from our live databases. We will not have any liability whatsoever for any termination of the account or related deletion of the Student information. When we delete personal information, it will be deleted from our active databases but may remain in our archives for up to 30 days.
Schools and Grid Owners should always obtain parental consent for a Student under 13 to use the Service. Please see Flipgrid’s Teacher Toolkit (https://static.flipgrid.com/docs/Flipgrid_dos_donts.pdf) and Parent Consent Form (http://static.flipgrid.com/docs/Flipgrid_consent_form.pdf) for tips on how to obtain proper consent from parents.
7. INFORMATION SECURITY
We use security technologies and procedures, including designating and training individuals responsible for security, to help protect your personal information from loss, misuse, and unauthorized access, use, disclosure, alteration, and destruction. Our security procedures and practices are consistent with industry standards applicable to our collection and use of personal information. In the event of an unauthorized release, disclosure, or acquisition of User information, Flipgrid will notify affected individuals (either directly or through Grid Owners), as required by applicable law. While we use reasonable efforts to protect your personal information, we cannot guarantee its absolute security.
8. Data Retention
We store the information we collect for as long as you have an Account, or for up to 30 days in our archives when you ask for data to be deleted (as set forth in Section 6, above). Additionally, we retain User information to resolve disputes, enforce our policies, and to comply with the law.
9. How to View, Correct, or Update Personal Information
Grid Owners and Users (who are not Students) can update their information by logging into their accounts and visiting the Account Settings tab on the User profile. Parents and Students can correct, edit, or update Student information by submitting a request to the Grid Owner. If that is not effective, the Student can contact us directly at email@example.com.
Residents of the European Economic Area may have additional rights as set forth in Section 11, below.
10. How to Delete YOUR Account or User Content
You may delete your own, or if you are a Grid Owner, your Students’ accounts and any content submitted to Flipgrid, by emailing your requests to firstname.lastname@example.org. Deleted account or account content may be retained by us for up to 30 days to provide customer support and prevent accidental deletion.
11. Personal Information Transferred from the European Economic Area or Switzerland to the United States
The Service is hosted and operated in the United States and is subject to United States law. User personal information is hosted on United States servers. Flipgrid is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
When we transfer your personal data from the European Union or Switzerland to the United States, we comply with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union and Switzerland to the United States, respectively. Flipgrid has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. To learn more about the Privacy Shield program, and to view our certification, please visit privacyshield.gov (https://www.privacyshield.gov).
Flipgrid has further committed to refer unresolved Privacy Shield complaints to the BBB EU Privacy Shield, an alternative dispute resolution provider located in the United States and operated by the Better Business Bureau. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit the BBB EU Privacy Shield website at bbb.org/EU-privacy-shield/for-eu-consumers (https://www.bbb.org/EU-privacy-shield/for-eu-consumers) for more information or to file a complaint. The services of the BBB EU are provided at no cost to you.
If your complaint is not resolved through these channels, in certain limited circumstances, a binding arbitration option may be available before the Privacy Shield Panel.
12. RIGHTS OF CALIFORNIA RESIDENTS
12.1 Third Party Disclosures and Other Rights
Flipgrid complies with California's "Shine the Light" law, as applicable. Flipgrid does not share Students’ personal information with third party marketers. If you are a California resident you can request a list of personal information about you we've disclosed to third parties in the preceding calendar year, as well as the names and addresses of those third parties. You may make such a request only once per year, and you don't have to pay for it. To make a request, send an email to email@example.com or send a written request to Flipgrid, 251 First Avenue North, Suite 500, Minneapolis, MN 55401.
Flipgrid also complies with California's Digital Protection of Minors Act, as applicable.
12.2 How We Respond to Do Not Track Signals
We do not currently respond to "do not track" signals or other mechanisms that might enable consumers to opt out of tracking on our website.
13. Changes to this Policy
14. Contact Information
251 First Avenue North
Minneapolis, MN 55401