| COPPA Compliance |
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| Guaranteach Statement of Compliance - Children's Online Privacy Protection Act (COPPA). |
| Guaranteach is committed to complying with all aspects of the Children's Online Privacy Protection Act (COPPA). In terms of COPPA we must obtain parental permission for all children under the age of 13 to be registered as students, to use any of our services, or to receive any part of our teaching content. For all children under the age of 13, a parent or legal guardian must provide verified consent wherever we gather information about the child. We will not knowingly accept any information from any children under the age of 13 beyond what is needed for our platform to perform the role of an expert tutoring system by processing their responses to academic questions. At any time a parent may revoke his/her consent for Guaranteach to use or collect their child's information, and direct us to delete the information. We reserve the right under such circumstances to terminate any feature of our service to the child if we feel that the information at issue is reasonably necessary for the child to use that part or feature of the Guaranteach service. |
| Our information practices are fully explained below as required by the Federal Trade Commission's Children's Online Privacy Protection Regulations. In addition, please read our Privacy Policy. |
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| Information Collected (16 CFR 312.4) |
| System Logging. Our webserver and e-mail systems keep log files about our network transactions. We analyze these log files to calculate statistics about which pages are visited, which content is viewed, student performance on tests, and how long visitors stay on our site. We do not track individuals with this information. We are required to retain this information for the security of our website and online service, and we need to do so for our educational records. E-mail addresses of messages sent from our system are logged as well. These logs are not viewed unless necessary for security reasons and are deleted after 30 days (16 CFR 312.5(c)(5)(i)). |
| Internet Addresses. Guaranteach may gather Internet Protocol ("IP") addresses and pages viewed as part of the logging system within our webserver. When calculating statistics on visits and pages viewed, IP addresses may be used. IP addresses are never used to identify someone personally unless a security breach requires such an investigation (16 CFR 312.5(c)(5)(i)). |
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| Registration of Children as Guaranteach Students |
| Children are enrolled as Guaranteach students by their parent(s) or legal guardian, and never directly. During registration, data is collected through direct input by the parent to enable us to send messages about Guaranteach and to perform Guaranteach-related activities. Information requested may include the parent's name and email address, but not the actual name, home address, e-mail address, telephone number or any other information about the child that would allow us to identify or contact the child directly. At the parent's discretion, the child may be identified by a nickname or screen name only. Guaranteach will not knowingly directly register any child under 13. |
| Dates of birth may be collected to help us select appropriate teaching content for children. We also collect the birthday so that we may comply with the requirements of the Children's On-line Privacy Protection Act. The date upon which a child is registered as a Guaranteach student may be collected indirectly. If your child subsequently is removed from our list of students, we may use this information to determine how long a child was registered with us. We do not disclose this information to third parties. |
| Guaranteach does not use cookies or other types of tracking mechanism to deduce or to store individually identifiable information for children under 13. While our software may use student responses to derive a model for a child's learning aptitude(s), we will not collect or store information about any child's hobbies or interests, or any other personal information that could be used to individually identify the child. |
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| Communication with Children, including Guaranteach Students Under 13 |
| Under no circumstances will Guaranteach market any product directly to children visiting our site or using our educational software. We will not hold contests in which direct communication with any child under 13 would be necessary. Neither our website nor our product will include any form of chat room or similar facility. If we need to engage in any communication with a student for any reason not directly related to the immediate teaching and testing with our regular teaching content, this communication will be done through the parent (by e-mail, letter or phone call) and never directly with the child. Guaranteach will ask parents to establish and use a verifiable means of identification in such communications (such as a passphrase, PIN or digits from a credit card). |
| If we receive an unsolicited communication from a child under 13 years of age, or who we believe may be under 13 years of age, especially a communication which gives us identifiable information about the child, we will respond as follows: |
| If the request is related directly to the course or topic of study that the child is pursuing with Guaranteach, we will respond to the point of origin of the communication;
Otherwise, we will send our response to a parent of the child if we have the parent's contact information. In this case we will offer the parent the opportunity to stop the communication before we send any response to the child.
We will discard the identifiable information relating to the child unless doing so would jeopardize the safety of the child, the security of our site, or our subsequent ability to respond to law enforcement.
In general, if we act in good faith by following these procedures, in response to a request for parental access we understand that we are protected from liability under federal and state law in cases of inadvertent disclosure of a child's information to someone who purports to be a parent. |
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| Visitor and Member Surveys (16 CFR 312.4) |
| Occasionally we collect surveys of visitors and Guaranteach students. Any personal information is supplied either optionally or anonymously. Personal information supplied is not saved, and such data is not supplied to, or shared with, any third party. |
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| How Data Collected is Used (16 CFR 312.4) |
| Visitor data is used for system logging, as explained above (16 CFR 312.5(c)(5)(i)), and for calculating statistics, also as explained above (16 CFR 312.5(c)(5)(i)). We also use visitor data to select the teaching content that we deliver to each student. |
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| Third Party Disclosure (16 CFR 312.4) |
| Guaranteach does not disclose, sell, trade, or release any visitor or student information to third parties. We will, however, fully comply with any legal information request related to a criminal investigation by the authorities. |
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| Participation (16 CFR 312.4) |
| Guaranteach will never prohibit any child from participation as a Guaranteach student on the basis of requiring more personal information than is necessary. |
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| Review or Deletion of Privacy Data (16 CFR 312.4) |
Guaranteach will make all the information that we store about a child available for review by the child's parent. This information will in fact be visible to the parent through the Parent Interface at any time. Any parent wishing to review or have deleted personally identifiable information about their child should contact Guaranteach with this concern. Each child's performance data will be accessible to the child's parent(s) through the Guaranteach parent's interface, access to which will be password protected with the parent(s) being the only holder(s) of the password.
If we make material changes to the way that we collect, use or disclose our data, or if we add features to our site in future that change the way in which identifiable information about children under 13 may be collected, stored or processed, we will send out a notice and obtain verifiable consent from parents before introducing these changes into our product(s). |
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| Links to External Sites |
| Guaranteach makes every effort to avoid any inclusion of links to external websites from our teaching content, web pages or user interfaces. Although we will carefully screen our content, we cannot be responsible for links that may appear in teaching content without our knowledge, in cases where such content has been submitted to us by an external content provider. |
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| If you have further questions about this Statement, we invite you to contact Guaranteach either by e-mail or by telephone to 1-800-604-7021. |
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