Last Updated Date: December 17, 2019
Note About Our General Audience Website: Our general audience Website is not geared towards children, nor meant to be used or accessed by children. If we become aware that we have collected "personal information" (as defined by the United States Children's Online Privacy Protection Act ("COPPA")) from a child in the United States under the age of thirteen (13) without legally-valid parental or school consent or that we have collected data through our Website from an European Union resident under the age of sixteen (16) without parental consent, we will take reasonable steps to delete it or obtain valid consent as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.
THE INFORMATION WE COLLECT AND THE WAYS WE USE IT
Information Provided Directly
We collect the following information directly from you as a visitor of our Website or from your School, if it lists you as a representative:
- Support Requests: If you submit a support request or question about our Website through our Support Center (e.g., Support Center and Help Center), we receive your request/question and your associated identifying contact information.
- Online Forums: If you use our Website to sign up as a member of our online community, blog, or similar options on our Website, we receive your contact information and your associated messages.
- Partner Submissions: When a partner of a School and/or GoGuardian (e.g., a reseller partner helping a School obtain equipment and software from GoGuardian) first signs up as a partner of GoGuardian or submits a request through our reseller portal on our Website, we collect both that partner organization's and partner representative's contact information as well as both the School and School Official's contact information. If you are a School Official or partner representative, then we collect this information about you.
We use contact information, requests for information, support messages, online forums information, and partner submissions for our business purposes, including to:
- provide customer service, provide you support and respond to your requests;
- notify you via email of new features and Products that may be of interest to you through update and marketing communications;
- notify you of company updates and notable events update and marketing communications;
- help secure our Website, prevent fraud and enforce our legal terms; and
- administer and troubleshoot our Website.
Information We Collect Automatically
As you visit or use our Website, we may automatically collect network activity and device usage information including:
- Analytics Information: Our Website automatically collects data via Google Analytics and other similar services, including your IP address, Internet service provider (ISP), date and time of your visit, browser language, browser type, referring and exit pages and URLs, amount of time spent on particular pages, which parts of our Website you visit, which links you click, search terms, operating system, traffic and related statistics, keywords, and/or other general browsing or usage data.
- GoGuardian Advertisements on Other Websites: We display advertisement for our Products on other websites and services. When you click on a GoGuardian advertisement on these other websites and services, we receive information about the website or service that served the advertisement, and which advertisement you clicked. If you then interact with our Website, we may combine the information about your activity with our advertisement with the information we subsequently collect and/or you subsequently submit on our Website.
- GoGuardian Advertisements: We display advertisements about GoGuardian on other websites after you visit our Website or use certain services on our Website such as our blog.
We use the information that we collect through our Website for our business purposes, including to:
- provide you with our Website;
- respond to your requests and provide you with support;
- notify you via email of new features and Products that may be of interest to you;
- notify you of company updates and notable events;
- analyze and improve our Website;
- audit and understand the effectiveness of our placement of GoGuardian advertisements on third party websites;
- remind you of GoGuardian through advertisements after you have used our Website;
- secure our Website and help prevent fraud and enforce our legal terms; and
- administer and troubleshoot our Website.
How We Share Information Collected Through Our Website
We may share or disclose any of the information collected from our Website in the following ways:
- Third Parties Supporting Our Website: We share the information with service providers that assist us in performing business-related functions that support or improve our Website. For example, we use hosting services and customer service tools to support our Website. When we employ another company to perform a function of this nature, we provide them with the information that they need to perform their specific function.
- Legal Requirements: We may share or disclose the information if we believe in good faith that doing so is necessary or appropriate to comply with any law enforcement, legal, or regulatory process, such as to respond to a warrant, subpoena, court order, or other applicable laws and regulations.
- With Your Consent / At Your Direction: We also may share or disclose the information collected through our Website with your consent or at your direction.
- Business Transfer: We may share or disclose the information, in connection with or during negotiations of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. If such transfer is subject to additional mandatory restrictions under applicable laws, GoGuardian will comply with such restrictions. The successor entity will be subject to all applicable federal and state laws, including privacy laws.
Data Controller vs. Processor; Our Legal Bases for Using Your Information
Under applicable law, GoGuardian is considered the "data controller" of information from or about our Website visitors. In other words, GoGuardian is responsible for deciding how to collect, use, share, and disclose this information.
The laws of some jurisdictions such as the laws of the European Union ("EU") require companies to tell you about about the legal ground that they rely on for using, sharing, or disclosing your information. To the extent those laws apply, our legal grounds are as follows:
- Contractual Commitments: We may use, share, or disclose information to honor our contractual commitments to you. For example, to comply with our Website Terms, which you accept by browsing our otherwise using our Website.
- With Your Consent: Where required by law, and in some other cases, we use, share, or disclose information on the basis of your consent.
- Legitimate Interests: In many cases, we use, share, or disclose information on the ground that it furthers our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as customer service, certain promotional activities, analyzing and improving our business, providing security for our Website, preventing fraud, and managing legal issues.
- Legal Compliance: We need to use, share, and disclose information in certain ways to comply with our legal obligations.
How Long We Keep Information
We generally retain information for so long as it may be relevant to the purposes above. To dispose of any personal information, we may anonymize it, delete it or take other appropriate steps. Information may persist in copies made for backup and business continuity purposes for an additional time period of time.
How We Protect Your Information
GoGuardian takes the security and privacy of your data very seriously. For these reasons, GoGuardian has implemented various technical, administrative, and physical safeguards to protect your information. These safeguards vary depending on the sensitivity of the information at issue.
GoGuardian is committed to preventing unauthorized access to our systems and data, and will investigate any possible occurrence. In the event of a breach of personal data, GoGuardian will comply with all relevant breach laws.
In addition to the rights and choices identified below with respect to specific jurisdictions, you have certain rights and choices with respect to your information such as:
- Marketing Communications: You can decline promotional communications at the point information is requested for such purpose on our Website (e.g., by checking or un-ticking (as directed) the relevant box) or, by following the unsubscribe instructions on communications sent to you. You can also contact us as described in the "How to Contact Us" section below.
- Cookies & Analytics. You can opt out of certain cookie-related and analytics processing by following the instructions in our Cookie Notice below.
- Do Not Track: Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. At this time, we do not recognize or respond to browser-initiated DNT signals.
We will consider all of your requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include needing to continue processing your information for our legitimate interests or to comply with a legal obligation. We may request that you provide us with information necessary to confirm your identity before responding to your request.
To exercise any of these rights, please contact us as described in the "How to Contact Us" section below. In addition to those rights, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.
Privacy Information for California Residents
If you are a California resident, California law requires us to provide you with some additional information.
- CCPA Rights: Specifically, if you are a California resident and consistent with California law, you (or your authorized agent acting on behalf of you) may annually request that we:
- provide access to certain information we hold about you;
- delete certain information we have about you; and/or
- provide you with information about the financial incentives that we offer to you, if any.
- Exercising CCPA Rights: Please note that certain information may be exempt from such requests under California law such as business contact information. Further, you must first verify your identity before we take any further action on your requests. If you would like additional information regarding your legal rights under California law or would like to exercise any of them, please contact us at email@example.com
- No Sale of Personal Information: The CCPA sets forth certain obligations for businesses that “sell” personal information. We do not engage in “sell[ing]” personal information (as defined by the CCPA) and have not engaged in such activity in the past twelve months, including for minors under 16 years of age.
- Shine the Light Disclosure: The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.
Privacy Information for Nevada Residents
Under Nevada law, certain Nevada consumers may opt out of the sale of “covered information”. We do not sell covered information. If you reside in Nevada, you may submit a request pursuant to Nevada law (NRS 603A) to our designated address or firstname.lastname@example.org.
Notice to EU and Other Non-U.S. Residents
Our Website is operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to and/or accessed within the United States. The recipients of information described in the relevant "How We Share Information" sections above may be located in the United States. This information may be subject to United States law, including laws that may require disclosure of personal information to government authorities.
- European Union-United States and Swiss-United States Privacy Shield: GoGuardian has certified with the European Union-United States and Swiss-United States Privacy Shield as set forth by the United States ("U.S.") Department of Commerce regarding the collection, use, and retention of "personal data" (as defined under the Privacy Shield principles) from applicable European countries. We have certified that we adhere to the Privacy Shield Principles of notice, choice, purpose limitation, onward transfer, security, data integrity, access, recourse, liability, and enforcement for such personal data. To learn more about the Privacy Shield Framework, visit the Department of Commerce's Privacy Shield list by clicking here.
- As required under the principles, when GoGuardian receives personal data under the Privacy Shield and then transfers it to a third-party service provider acting as an agent on our behalf, we have certain liability under the Privacy Shield if both (i) the agent processes the information in a manner inconsistent with the Privacy Shield; and (ii) GoGuardian is responsible for the event giving rise to the damage.
- Other Legal Rights: Some international users (including those whose information we collect under the Privacy Shield) of our Website have certain legal rights to access certain information we hold about them and to request its deletion. For example, some international laws may permit you to:
- request that we provide access to and/or a copy of certain information we hold about you; prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling);
- update information which is out of date or incorrect; delete certain information that we are holding about you; restrict the way that we process and disclose certain of your information; transfer your information to a third party provider of services; and
- revoke your consent for the processing of your information.
Please see the "Choices about Information Collected through Our Website" Section above for more information.
- Dispute Resolution for EU and Swiss Residents: If you are a resident of the EU or Switzerland and are dissatisfied with the manner in which we have addressed your concerns, you may seek further assistance, at no cost to you, from our designated Privacy Shield independent recourse mechanism, the JAMS Privacy Shield Program, which you can learn more about by visiting https://www.jamsadr.com/eu-us-privacy-shield. Residents of the EU or Switzerland may, in certain circumstances, elect to arbitrate unresolved complaints by invoking binding arbitration pursuant to the Privacy Shield’s Recourse, Enforcement and Liability Principle and Annex I of the Privacy Shield but prior to initiating such arbitration, you must: (1) afford us the opportunity to resolve the issue; (2) seek assistance via GoGuardian's recourse mechanism above; and (3) contact the U.S. Department of Commerce (either directly or through a European Data Protection Authority) and afford the Department of Commerce time to attempt to resolve the issue. Each party shall be responsible for its own attorney's fees. Please be advised that, pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the individual. GoGuardian is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
What are cookies?
Cookies are small text files stored on your computer that allow us to understand usage of our Website. Cookies include cookies, Internet server logs, tags, Software Development Kit/SDKs, tracking pixels, and other similar tracking technologies. A number of Cookies that we use last only for the duration of your session, expiring when your session ends (the so-called "session cookies"). Other Cookies are used to help our systems recognize you if you return to our Website and will thus retained longer (the so-called "persistent cookies"). Some of the cookies used on our Website are set by us, and some are set by third parties that are delivering services on our behalf.
What types of Cookies does GoGuardian use and what data do they collect?
- understand how many unique visitors frequent our Website;
- analyze usage of our Website, including to improve our Website;
- authenticate your account for our Website services;
- remember your settings and account information for our Website services;
- understand the effectiveness of GoGuardian advertisements placed on third party websites; and
- show you advertisements about GoGuardian after you visit our Website such as our blog.
We do not use any advertising Cookies in our Products and we do not place advertisements in our Products.
What are your choices about Cookies?
You can learn more about how Cookies work and how to turn them off in your particular browsers. Please remember that if you replace, change or upgrade your browser, or delete your Cookies, you may need to use these opt-out tools again.
For information about Cookies used by the developers of these browsers, please visit:
For controls specific to advertising and analytics services offered by Google, click here and here from each of your browsers.
For more information about advertising and how you can turn off certain advertisements in general, please visit youronlinechoices.com and www.youronlinechoices.com.au and www.youradchoices.com.
How to Contact Us
If you have questions or concerns, the best way to reach us is by emailing email@example.com. You can also reach us by calling 888-310-0410 or by writing to Liminex, Inc. dba GoGuardian, Attn: Chief Privacy Officer, 2030 East Maple Avenue, El Segundo, California 90245.
Additionally, please feel free to consult additional resources such as the ones listed below.
Student Privacy Resource List: