Last Updated: July 17, 2024
At Project Leo, we take your institution's privacy seriously. Please read this Privacy Policy (this "Policy") to learn how we treat personal data. By using or accessing the Platform in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Policy.
Remember that your use of Project Leo's Platform is at all times subject
to our Customer Terms and Conditions
https://www.projectleo.com/docs/terms.html,
which incorporates this Policy. Any terms we use in this Policy without
defining them have the definitions given to them in the Terms and
Conditions.
This Privacy Policy covers how we treat Personal Data that we gather when an educational institution or another Customer organization (an "Organization") accesses the Platform. "Personal Data" means any information that identifies or relates to a particular individual and also includes information referred to as "personally identifiable information" or "personal information" under applicable data privacy laws, rules or regulations. Keep in mind that Project Leo services schools, districts, companies, and other Organizations. This Policy covers Personal Data we collect as a controller with those Organizations, which comprises of Business Contact Data. If you are a student, teacher, administrator, or other individual for whom access to the Platform has been enabled by one of our Organizations, please contact the applicable organization signed up for access to Project Leo on your behalf to learn more about Personal Data of yours that Organization collects and shares with Project Leo. Project Leo is a service provider and processor of that Personal Data only, and in accordance with all applicable laws in all applicable jurisdictions, only processes that data in order to provide the Platform in accordance with the Customer Terms and Conditions. Please refer to the Customer Data rights and ownership language outlined in our Customer Terms and Conditions, and our Data Processing Addendum https://www.projectleo.com/docs/data.html for more information on our role as a processor of Personal Data. Specifically, parents wishing to retain more information about their child's student records or other personal information processed by Project Leo should contact the educational institution-Organization which purchased Project Leo access for their student to review, update, access, and otherwise delete any Personal Information about their child. Note that students may not directly sign up for our Platform, and thus we never directly collect Personal Information from students of any age.
As we continually work to improve our Platform, we may need to change this Policy from time to time. Upon such changes, we will alert you to any such changes by placing a notice on the Project Leo website or Platform, by sending you an email and/or by some other means. Please note that if you've opted not to receive legal notice emails from us (or you haven't provided us with your email address), those legal notices will still govern your use of the Platform, and you are still responsible for reading and understanding them. If you use the Platform after any changes to the Policy have been posted, that means you and your organization agree to all of the changes.
PROJECT LEO WILL ONLY COLLECT AND PROCESS PERSONAL DATA TO PROVIDE THE PLATFORM, AND WILL NOT SHARE IDENTIFIABLE, ORGANIZATION DATA CONSTITUTING OF PERSONAL DATA TO THIRD PARTIES, EXCEPT FOR AUTHORIZED SUBPROCESSORS WHO HELP US PROVIDE THE PLATFORM AND WHO ENTER INTO AGREEMENTS WITH US TO PROTECT THAT PERSONAL DATA IN SUBSTANTIALLY THE SAME MANNER AS WE AGREE TO PROTECT IT IN OUR TERMS AND CONDITIONS.
This chart details the categories of Personal Data that we collect and have collected over the past 12 months from our Organizations:
| Category of Personal Data | Examples of Personal Data We Collect | Categories of Third Parties With Whom We Share this Personal Data: |
| Profile or Contact Data |
|
|
| Online Identifiers |
|
|
| Device/IP Data |
|
|
| Web Analytics |
|
|
| Consumer Demographic Data |
|
|
| Photos, Videos and Recordings |
|
|
| Other Identifying Information that You Voluntarily Choose to Provide |
|
|
Please note the above categories of third parties we share Personal Data with are detailed below, and constitute Project Leo's subprocessors. Personal Data is solely processed and shared with authorized subprocessors to provide and improve the Platform.
We collect Personal Data about you from the following categories of sources:
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
We disclose your Personal Data to the categories of service providers and other parties listed in this section. For more information, please refer to the state-specific sections below.
For more information about specific subprocessors of your Personal Data that may fall under each of these categories, please visit https://www.projectleo.com/docs/data.html.
Legal Obligations
We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under "Legal Obligations" in the "Our Commercial or Business Purposes for Collecting Personal Data" section above.
Business Transfers
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices. Please note that any Personal Data we collect that is subject to the Family Educational Rights and Privacy Act ("FERPA"), the Children's Online Privacy Protection Act ("COPPA") or other laws or regulations relating to the protection of students' and/or childrens' Personal Data will remain subject to such laws or regulations in the event that a third party assumes control of our business. To the extent that we are required to enter into a contract with a School under such laws or regulations, the contract will specify that any successor entity to Project Leo will be bound by the terms of such contract.
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Platform and promote our business, provided that we will not share such data in a manner that could identify you.
The Platform use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, "Cookies") to enable our servers to recognize your web browser, tell us how and when you visit and use our Platform, analyze trends, learn about our user base and operate and improve our Platform. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Platform. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Platform does not support "Do Not Track" requests sent from a browser at this time.
We use the following types of Cookies:
You can decide whether or not to accept Cookies through your internet browser's settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Platform and functionalities may not work.
To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies / if you are located in the European Union or United Kingdom.
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
We retain Personal Data about you for as long as necessary to provide you with our Platform or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
For example:
As noted in the Organization Terms and Conditions, our Organizations are solely responsible for providing School Consent under COPPA, or obtaining verifiable parental consent for students under thirteen (13) to use the Platform. In accordance with COPPA guidelines, Project Leo only collects personal information of children from an Organization (after obtaining School Consent) reasonably necessary to provide the Platform so that children may receive our educational services, and will not collect personal information of children under 13 for any extraneous purposes.
California Resident Rights
Nevada Resident Rights
Utah, Colorado, Connecticut, and Virginia Resident Rights
If you provide us Business Contact Data for individuals who are residents of the European Union ("EU"), United Kingdom ("UK"), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the "GDPR") with respect to that Personal Data, as outlined below.
For this section, we use the terms "Personal Data" and "processing" as they are defined in the GDPR, but "Personal Data" generally means information that can be used to individually identify a person, and "processing" generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Project Leo will be the controller of your Personal Data processed in connection with the Services.
If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at support@projectleo.com. Note that we may also process Personal Data of our customers' end users or employees (i.e. students and teachers) in connection with our provision of the Platform to your Organization, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.
Personal Data We Collect
The "Categories of Personal Data We Collect" section above details the Personal Data that we collect from you.
Personal Data Use and Processing Grounds
The "Our Commercial or Business Purposes for Collecting Personal Data" section above explains how we use your Personal Data.
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our "legitimate interests" or the legitimate interest of others, as further described below.
Disclosing Personal Data
The "How We Disclose Your Personal Data" section above details how we disclose your Personal Data with third parties.
EU, UK and Swiss Data Subject Rights
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at support@projectleo.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
Transfers of Personal Data
The Services are hosted and operated in the United States ("U.S.") through Project Leo and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Project Leo in the U.S. and will be hosted on U.S. servers, and you authorize Project Leo to transfer, store and process your information to and in the U.S., and possibly other countries. In some circumstances, your Personal Data may be transferred to the U.S. pursuant to a Data Privacy Framework described at https://www.dataprivacyframework.gov/Program-Overview .
Project Leo complies with the EU-U.S. Data Privacy Framework (" EU-U.S. DPF"), the UK Extension to the EU-U.S. DPF ("UK-U.S. DPF"), and the Swiss-U.S. Data Privacy Framework ("Swiss-U.S. DPF") as set forth by the U.S. Department of Commerce. Project Leo has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (" EU-U.S. DPF Principles") with regard to the processing of all personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF (the "EU-UK DPF Principles"). Project Leo has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles ("Swiss-U.S. DPF Principles") with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles, the EU-UK DPF Principles, and the Swiss-U.S. DPF Principles, the EU-U.S. DPF Principles, the EU-UK DPF Principles, and the Swiss-U.S. DPF Principles shall govern. To learn more about the EU-U.S. DPF, the UK-U.S. DPF, and the Swiss-US DPF, and to view our certification, please visit https://www.dataprivacyframework.gov/ .
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, process Personal Data of your end-users, or your choices and rights regarding such collection and use, please do not hesitate to contact us at: support@projectleo.com
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