Privacy Policy

Effective Date: November 28, 2020

At Wavely ("Wavely," "we," "us," "our"), we recognize the importance of how your Personal Data and Student PII is used and shared, and we take your privacy seriously. Please read on to learn more about our Privacy Policy. By visiting or using our website(s) and all other products, services and applications made available by Wavely from time to time (collectively, our "Services"), you acknowledge that you accept the practices and policies outlined in this Privacy Policy and our Terms of Service. If you do not accept these terms, then you may not use our Services.

 

​​​Collected Information.

The information we collect from users of our Services include the following:

  • School information for your Wavely network (e.g., school name, mailing address, time zone, payment and billing information)

  • Profile information for each network admin user profile (e.g., first and last name, email, position/title, and password).

  • Profile information for each student and responder user profile (e.g., first and last name, email, student or employee ID, grade level (of students), position/title (of responders), and password).

 

When this information is collected, we use it in the following ways:

  • To provide and maintain our Services.

  • To notify you about changes to our Services.

  • To provide customer support.

  • To gather analysis or valuable information so that we can improve our Services.

  • To monitor the usage of our Services.

  • To detect, prevent and address technical issues.

  • To notify users about important app updates and changes via email (e.g., account verification, changes/updates to features of our Services, technical or security notices. You may not opt out of Service-related emails).

 

​We will not collect, maintain, use, sell or share this collected information or Student PII. We will also not build a personal profile of a student other than for supporting an authorized school purposes or as authorized by a parent or legal guardian. Additionally, we will not use or disclose Personal Data or Student PII collected through our Services for behavioral ad targeting.

 

The Student PII that is collected, used, shared, and retained will only be used for purposes for which we are authorized by a school, school administrator, staff member, or the parent or legal guardian of a student. We will also support access to and correction of Student PII by a student or their authorized parent or legal guardian, either by assisting the school in meeting its requirements or directly when the information is collected directly from the student with parental consent.

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Usage Data.

We may also collect information that your browser sends whenever you visit our website or when you access our Services by or through a mobile device ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When you access our Services with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

 

Tracking Cookies Data.

We use cookies and similar tracking technologies to track the activity on our Services and we hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Services.

Examples of Cookies we use:

  • Session Cookies which we use to operate our Services.

  • Preference Cookies which we use to remember preferences and various settings.

  • Security Cookies which we use for various security purposes.

Third Party Access.

If you are a user of our Services, we will not sell, rent, swap or authorize any third party to use your Personal Data or Student PII. In the future, we may sell, buy, merge or partner with other companies or businesses. In such transactions, we may allow a third party to maintain your Personal Data and Student PII provided the third party is subject to the same commitments stated in this Privacy Policy for previously collect Student PII.

​Legal Basis for Processing Personal Data Under the General Data Protection Regulation (GDPR).

If you are from the European Economic Area (EEA), Wavely legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data and Student PII we collect and the specific context in which we collect it. Wavely may process your Personal Data and Student PII because:

  • We need to perform a contract with you.

  • You have given us permission to do so.

  • The processing is in our legitimate interests and it is not overridden by your rights.

  • For payment processing purposes.

  • To comply with the law.

 

Retention of Data.

Wavely will retain your Personal Data and Student PII only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data and Student PII to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. Wavely will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer periods. When it comes to retaining Student PII, it will not be knowingly retained beyond the time period required to support the authorized school purposes, or as authorized by the parent or legal guardian of a student.

 

Transfer of Data.

Your information, including Personal Data and Student PII, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data and Student PII, to the United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Wavely will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data and Student PII will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data.

Business Transaction: If Wavely is involved in a merger, acquisition or asset sale, we will allow a successor to maintain your Personal Data and Student PII only if the successor entity agrees to act in accordance  with the Student Privacy Pledge. If they do not, users will be given the option to send their information to the future entity or have their information deleted.

Disclosure for Law Enforcement: Under certain circumstances, Wavely may be required to disclose your Personal Data and Student PII if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

 

Legal Requirements: Wavely may disclose your Personal Data and Student PII in the good faith belief that such action is necessary to:

  • To comply with a legal obligation.

  • To protect and defend the rights or property of Wavely.

  • To prevent or investigate possible wrongdoing in connection with our Services.

  • To protect the personal safety of users of our Services or the public.

  • To protect against legal liability.

 

​Data Protection and HIPAA/FERPA Compliance.

Onboarded students and staff will receive a welcome email that includes a unique authorization code and access code assigned to their student or employee ID. This information, along with a secure password, is required to activate and access their profile. All data passing through the platform, whether it is through our online or our mobile application, is encrypted. This means that all user data is converted into complex code to ensure that its contents cannot be understood, intercepted, or collected - read further for more details.

​Here is a breakdown of current security safeguards we've established to ensure data encryption in compliance with HIPAA and FERPA:

  • Our AWS EC2 Instance is encrypted. No one can use it without the MyKeyStore.pem file. All of our code is placed inside the encrypted directory. Our code is placed in a private repository on Bitbucket.org.  Only we have complete access to the code. 

  • No one can deploy the code without the AWS Sign-In Password and Username. The FTP server also cannot be connected without the MyKeyStore.pem file.

  • In our EC2 instance on AWS, we have only enabled secure communication options such as HTTPS-based or TCP/SSL-based to protect the confidential PHI data for the end-to-end communication, and all the list of PHI data is encrypted.

  • To access the RDS database the MyKeyStore.pem file is also required.

  • We are using the SHA-256 Cryptographic Hash encoding method. If we have a message “hello how are you”. Its encrypted form is “f5bf53fcd6980fedeb2495657a489cd10f5fef01b52de3e309d42dca10908948“.All the data of schools and user is encrypted. No one can decrypt the data without the key.

  • All the data which is passing through the internet gateway whether it is on our web or mobile application(s) is encrypted.

  • We use Indirection strategy. When a new object containing PHI is written to S3 via S3 Transfer Acceleration, an S3 trigger signals AWS Lambda to write the appropriate metadata to an Amazon SQS queue. A service running on Amazon EC2 polls the SQS queue, and if new data is available, pulls the PHI data from S3. A second Lambda function triggers a mobile alert, notifying that processing of data has begun. In this example only S3 and EC2 are used to store, process, and transmit all PHI data; Lambda and SQS are only used to orchestrate services or notify when jobs should begin.

 

Please also know that the security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data and Student PII, we cannot guarantee its absolute security. Additionally, we cannot control the actions of anyone with whom you or any other Wavely users may choose to share information transmitted through our Services. Therefore, we cannot and do not guarantee that content you or any user share through our Services will not be viewed by unauthorized persons. It also is your responsibility to keep your phone, computer and access to our Services secure. We therefore recommend that you do not jailbreak or root your phone, which is the process of removing software restrictions and limitations imposed by the official operating system of your device. It could make your phone or computer vulnerable to malware, viruses, malicious programs, compromise your phone’s or computer’s security features and it could mean that our Services will not work properly or at all.

 

​Lastly, keep in mind that you are responsible for any content you provide in connection with our Services. We cannot control the actions of anyone with whom you or any other Wavely users may choose to share information. Therefore, we cannot and do not guarantee that content you or any user share on our Services will not be viewed by unauthorized persons. We will occasionally provide schools with resources to help protect the security and privacy of Student PII while using our Services.

 

Enforcing Development Privacy and Security.

Wavely incorporates privacy and security procedures when developing or improving our products, tools, and services and comply with applicable laws. We do this by taking a programmatic approach to privacy and security, applying privacy and security by design principles; considering privacy and security best practices; or analyzing guidance concerning reasonable privacy and security measures and comprehensive privacy and security programs. Factors we consider include: the potential for misuse or unexpected use of Student PII; the privacy and security practices of third party vendors (if any); the potential harms that could result from product development or improvement; and whether any of these risks could be mitigated with additional training or resources for product users, educational institutions, or parents and students. We also carefully evaluate the use and development of new technologies in our products and services to consider the potential impact on the privacy and security of Student PII.

​​Our Policy on "Do Not Track" Signals under the California Online Protection Act (CalOPPA).

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights under the General Data Protection Regulation (GDPR).

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Wavely aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data and Student PII. If you wish to be informed about what Personal Data and Student PII we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data protection rights:

  • The right to access, update or delete the information we have on you: Whenever made possible, you can access, update or request deletion of your Personal Data and Student PII directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

  • The right of rectification: You have the right to have your information rectified if that information is inaccurate or incomplete.

  • The right to object: You have the right to object to our processing of your Personal Data and Student PII.

  • The right of restriction: You have the right to request that we restrict the processing of your personal information.

  • The right to data portability: You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

  • The right to withdraw consent: You also have the right to withdraw your consent at any time where Wavely relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data and Student PII. For more information, please contact your local data protection authority in the European Economic Area (EEA).

 

​Children’s Online Privacy Protection Act.

The Children's Online Privacy Protection Act ("COPPA") requires that we inform parents and legal guardians about how we collect, use, and disclose Personal Data and Student PII information from children under thirteen (13) years of age. COPPA also requires us to obtain the consent of parents and legal guardians for children under thirteen (13) years of age to use our Services. Parents and legal guardians may be referenced collectively as “Parents” herein.

 

For Children Under 13 - Please Read: Prior to using our Services, your parent or legal guardian is required to sign a technology consent form that gives you authorized permission to use the app. It is the responsibility of your school to distribute and maintain a record of these completed consent forms. You will only be onboarded to your school’s Wavely network if your school administration has a record of this signed technology consent form.

For Parents of Children Under 13 - Please Read: If your child is using Wavely without your consent, contact your school administration immediately. Prior to your child using our Services, you are required to sign a technology consent form that gives your child authorized permission to use the app. It is the responsibility of your school to distribute and maintain a record of these completed consent forms. Your child will only be onboarded to your school’s Wavely network if your school administration has a record of this signed technology consent form.

Mailing Policy.

When you send us an email or complete a contact form on our website, we use your email address to thank you for your comment and/or reply to your question,  and we will store your communication and our reply for any future correspondence. Beyond our initial reply, we will never use your email address to send any unsolicited message or information, nor will we share it with or sell it to anyone else for such use.

When you accept to receive information about our Services, promotions, newsletters, press releases, and/or new offers, we use your email address and other information you give to provide you with information or other Services, until you ask us to stop (using the “unsubscribe” instructions provided with each email communication).

When you request information or other Services from us, we use your email address and any other information you give us to provide you with the information or other Services that you requested, until you ask to stop (using the “unsubscribe” instruction provided with email, and/or on the site where you signed up, and/or as we otherwise provide), or until the information or Service is no longer available.

We will never use your email address or other information to provide you with unsolicited messages or information (unless that is part of the Service you are requesting), nor will we share it with or sell, rent or lease it to any third party for such use.

Service Providers.

We may employ third party companies and individuals to facilitate our Services ("Service Providers"), provide our Services on our behalf, perform Service-related services or assist us in analyzing how our Services are used. These third parties have access to your Personal Data and Student PII only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. The third parties who have access to this information are required by Wavely to have the same privacy policies that are consistent with those of the Student Privacy Pledge.

 

Analytics.

We may use third-party Service Providers to monitor and analyze the use of our Services.  A third-part Service Provider we use is “Google Analytics”. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Services. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Payments.

We use third-party Service Providers for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information. The payment processor we work with is “Stripe”.  Their Privacy Policy can be viewed at https://stripe.com/us/privacy

Links to Other Sites.

Our Services may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Dispute Resolution.

If you have any complaints regarding our compliance with this Privacy Policy, you should contact us. We will investigate and attempt to resolve the complaints and disputes regarding use and disclosure of Personal Data and Student PII in accordance with this Privacy Policy.

Helpful Practices.

Wavely will from time to time provide resources to support educational institutions/agencies, teachers, or parents/students to protect the security and privacy of Student PII while using our technology. The primary security tips we encourage all users to follow are as follows: use a secure password; secure your phone or computer with a password or passcode; disable lock screen notifications; stay private on wi-fi networks.

 

Changes to Privacy Policy.

We will not make material changes to our privacy policy without first providing prominent notice to the users and/or account holder(s) (i.e., the institution/agency, or the parent/student when the information is collected directly from the student with student/parent consent) and allowing them choices before data is used in any manner inconsistent with terms they were initially provided; and not make material changes to other policies or practices governing the use of Student PII that are inconsistent with contractual requirements. If a change is made to our privacy policy, users will be notified upon account login and receive the option to provide consent to continue using the service.

Contact Us.

If you have any questions or suggestions about our Privacy Policy,  please send an email to support@joinwavely.com.

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