Privacy Policy

Updated and effective 10/01/2019


UR Turn, SBC (ā€œUR Turnā€) is committed to providing insight and experience drawn from years of research that students, parents, and counselors can use to keep students on track for high school graduation and beyond. In doing so, we want to be transparent about how personally identifiable data is collected, used and disclosed by UR Turn, and your choices to protect the privacy of all users (which includes schools, counselors, parents and students).


Personally Identifiable Data Collected From Schools:

UR Turn collects and stores personally identifiable data about students, parents and counselors.

That data is collected in two ways; through the schools using UR Turnā€™s services, and from the people ā€“ students, parents, and counselors, using the UR Turn platform. Ā 


Information about Schools:

A school administrator provides UR Turn with their first and last name and email address, which we use to create and authenticate their school account. The administrator also provides UR Turn with the personally identifiable data elements about their institution (School name, grade, school year(s), course numbers, score, credit type, credit earned, GPA weight, GPA value).


Information about Students:

Schools provide UR Turn with the following information about each student: student first and last names, email address, parent email address, school name, state, GPA, suspension and enrollment information, and date of birth. This information is used to create student accounts in UR Turn. In addition, schools provide student grades and attendance data to generate the insight needed by parents, counselors, and students to keep students on track for their goals.


Upon initial log in, students are asked to create a new password. Students may also log into UR Turn through a third party, single sign-on portal authorized by their school.


Students may update their password at any time directly through their account dashboard. Students may also add a parent email address to their account.


Students Under 13. Ā 

In compliance with the Childrenā€™s Online Privacy Protection Act (ā€œCOPPAā€), UR Turn collects only minimally required information from students in order to provide the UR Turn Platform.Ā If schools and parents allow students under the age of 13 to submit personal information, as defined in COPPA, to UR Turn then schools and parents agree they have the authority to and will be responsible for obtaining verifiable parental consent prior to allowing such students to use UR Turn. UR Turn will otherwise fully manage its compliance obligations with COPPA.


Information about Parents:

Schools may provide parent first and last names, email address and the name of each student the parent is authorized to access. At their option, schools may also provide a parent phone number. We use this information to create parent accounts that permit parents to access information about their childrenā€™s UR Turn profile. Ā 


We also use the parent email address to send information to parents about how they may access their childā€™s student dashboard and to provide important updates related to their use of the platform. In the event that a phone number has been provided, we use that for the same communications sent via SMS messaging to parents who have opted in to receive such messaging.


Information about Counselors:

Schools provide first and last names and email addresses for their counselors and other employees who will be using UR Turn. We use this information to create their employee accounts and facilitate employee access to their advisees.


School employees may update their password directly through their account dashboard.


Optional data collected from use of UR Turn

In addition to the data provided by schools and students as noted above, students, their parents, and counselors may provide additional, optional personal information to help personalize the insight and experience provided by UR Turn. Personal information that may be collected by UR Turn includes: phone numbers for receiving text alerts, personalized goals for the students, personalized tasks for the students, additional grades and assessment data. Ā At their option, students and parents may also provide phone numbers.


Additional data collected during use of UR Turn

In addition, to improve our service, we automatically collect information from your web browser. Ā This information includes your IP (Internet Protocol) address, browser type, date and time of visit, time spent, pages viewed and the referring URL.


To collect this information, we use cookies.

Cookies are small data files sent from a website or application and stored on your computer or device. Cookies allow us to recognize your browser when you return to UR Turn and to keep track of your current session so that we can maintain your login from one page to the next. Cookies also allow us to authenticate you as a user, serve certain features, better understand how you interact with UR Turn, to improve your experience and to monitor and analyze aggregated usage. Ā Most browsers have settings that allow you to delete cookies, to stop accepting cookies or to prompt you before accepting a cookie. To learn more about browser cookies, including how to manage or delete them, look in the Tools, Help or similar section of your web browser, or visitĀ allaboutcookies.org. Ā 

By using UR Turn, you agree to our use of cookies.


We use Google Analytics to assist us in collecting and understanding Log Data. For more information about Google Analytics, see theĀ Google Privacy Policy. Ā To opt out, visit https://tools.google.com/dlpage/gaoptout. Ā Note that we are not responsible for the Google Analytics opt-out tools. Ā 


How is the information used?Ā 

We do not sell or rent your information. Personally identifiable data collected about and from students, parents, and counselors is used to:

  • Provide access to UR Turn Ā 
  • Customize your experience
  • Respond to your requests and provide support
  • Measure and improve UR Turn
  • Send you relevant emails and SMS messages when you have opted in to receive such communications
  • Enforce ourĀ Terms of UseĀ and investigate suspected violations of our Terms of Use, suspected fraud or other unlawful activity


Studentsā€™ personally identifiable data such as courses, grades, GPA, attendance suspensions/expulsions are also used to generate the insights and guidance provided to the students and their parents to keep students on track for high school graduation and on track of their post-secondary goals.


How is the information secured?

We take the responsibility of securing sensitive personally identifiable data seriously. Personally identifiable data collected and transmitted by UR Turn is encrypted at rest and during transmission. Access to the UR Turn application is encrypted between the browser and our servers using TLS (Transport Layer Security). Personally identifiable data stored in UR Turnā€™s databases is encrypted while at rest. Connections to UR Turn databases require SSL (Secure Socket Layer) encryption. Personally identifiable data access credentials are unique to each employee and application, and access is granted only to those employees and contractors who have need for direct access to perform their jobs.


However, the Internet is not entirely secure, and we are not responsible for security incidents not reasonably foreseeable or not reasonably within our control.


Under what circumstances do we share your information?

We share your information in the following circumstances:

  • To our third party service providers, such as data host sites, to allow us to operate UR Turn
  • In the event of a reorganization, merger, sale, bankruptcy or other business change, in which case your information will remain subject to the terms of this Privacy Policy;
  • As may be required by law or by a court order, in which case, where legally permissible, we shall attempt to notify schools, parents and students and work with you to seek to limit the scope of the required disclosure; and
  • With your consent and as permissible under applicable laws and regulations.
  • Schools and counselors may have access to all information the student or parent post on the platform, such as additional name and email of guardian(s).


Personally Identifiable Data Retention

UR Turn will maintain personally identifiable data records for up to two years for schools with an active contract, and for 3 months after expiration of the contract. Should a school choose to not renew their contract with UR Turn, the school may request a copy of the personally identifiable data within ninety (90) days of the end of the contract. After the ninety-day waiting period, all personally identifiable data for the school will be permanently deleted from UR Turnā€™s servers.


Schools may also request deletion of their student personal information by providing written notice to UR Turn. UR Turn will securely destroy student personal information within 30 days of receipt of such request. If students or parents want to have their personal information deleted from the UR Turn Platform, they will need to make a deletion request with their school (and the schoolā€™s student information system) rather than contacting UR Turn.

UR Turn may retain deidentified, aggregated data to use for legally permissible purposes including product improvement, development and improvement of new educational products and services, to demonstrate the efficacy of its products, including in the marketing of its products, and for customized and adaptive learning.


Data Access and Modification:

Schools may update their information by adding/changing graduation credit requirements, course names, adding/deleting parent/guardian contact information. Parents and students must work directly with the school to access, modify or request deletion of their information, with the exception of passwords, which they may change directly using their account dashboards.


Communications Opt-Out:

At any time, parents or counselors who have opted in to receive messaging about their and their studentsā€™ use of UR Turn may opt out by contacting UR Turn atĀ  info@urturn.org or by clicking the ā€˜unsubscribeā€™ link that appears on the bottom of each message.


Updates

We reserve the right to update this policy at any time. We will give advanced notice of any material changes by providing notice within UR Turn by contacting you at the email address of the account holder or otherwise as required by law.


Contact

If you have questions about this policy or our privacy practices, you may contact us atĀ info@urturn.org.



August 2019

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