Privacy Policy for Website Visitors

Last Updated Date: September 18, 2019

Introduction

Welcome to GoGuardian's Website! GoGuardian (formally — Liminex, Inc. doing business as GoGuardian — "GoGuardian", "we", "us", "our") is an educational technology company that provides K-12 schools and school districts with software facilitating safer access to online educational materials along with technology management. GoGuardian's Website refers to our general-audience, public-facing website with a main landing page of goguardian.com ("Website"). This Website Privacy Policy applies to visitors and users of our Website and explains how we collect, use, share, disclose, and protect information from these visitors and users of our Website ("Website Privacy Policy").

This Website Privacy Policy does not apply to:

  • the use of GoGuardian's Products by one of our school or school district customers or other organizational customers ("School(s)" or "your Organization"). For more information about how we treat information in our Products, please visit our Privacy Policy for Product Users ("Product Privacy Policy"), and, as applicable to Schools in the European Economic Area ("EEA"), our Data Processing Addendum ("DPA"); or
  • organizations or third parties that GoGuardian does not own or manage, or to individuals that GoGuardian does not employ or manage. For example, there may be links to third parties available on our Website or support center. We encourage you to review the applicable third party privacy policies and terms of use before submitting any information through those sites or services.

By using our Website, you are declaring that you have read and understand this Website Privacy Policy.

Information Provided Directly

We collect the following information directly from you as a visitor and/or of our Website:

  • Requests for Information: If you submit a request for information or otherwise contact us through our Website, we collect your request and your contact information.
  • 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 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 School Official or partner representative, then we collect this information about you.

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 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 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.

Information We Collect Automatically

As you visit or use our Website, we may automatically collect the following information:

  • 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.
  • Cookies: GoGuardian and its third party service partners use Cookies. To learn more about our use of Cookies and your choices about Cookies, please see our Cookies Notice below.

How We Use Information Collected Through Our Website

We use the information that we collect through our Website for a variety of 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;
  • 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;
  • 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 information in the following ways:

  • Third Parties Supporting Our Website: We share 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.
  • Protection of GoGuardian and Others: We may share or disclose certain information if we believe in good faith that doing so is necessary or appropriate to (i) protect or defend the rights, safety, or property of GoGuardian or third parties, including to defend or enforce our Website Privacy Policy, our Website Terms of Service, or our EULA, or any other contractual arrangement or (ii) to respond to claims that content violates the rights of third parties.
  • Legal Requirements: We may share or disclose certain 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 your information with your consent or at your direction.
  • Business Transfer: We may share or disclose certain 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.

Your Choices

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.
  • California Rights: Under California law, California residents may annually request a list of the third parties to which we disclose personal information for such third parties' marketing purposes and the types of information disclosed. However, we do not disclose personal information to third parties for such third parties' direct marketing purposes.
  • 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. We do not recognize or respond to browser-initiated DNT signals.
  • Your Legal Rights Under Local Law:
    • Your local laws (e.g., laws of the EU) 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.
  • Note About 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. Some browsers do not recognize DNT settings. At this time, we do not recognize or respond to browser-initiated DNT signals because we do not track you across websites.

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 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.

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.

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.

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. Please see the "Choices about Information Collected through Our Website" section above for more information.

How to Contact Us for Non-U.S. Residents: If you are located outside the United States and have questions or concerns regarding GoGuardian's Website Privacy Policy or practices, you may direct a complaint in writing to GoGuardian Privacy Officer, Liminex, Inc. dba GoGuardian, 2030 E Maple Ave, El Segundo, CA 90245. Tel: 1-888-310-0410 Email: privacy@goguardian.com. Within a reasonable time of receiving the written complaint, GoGuardian will review and address your complaint, as appropriate, and inform you of the results of such review and any steps taken to address your complaint.

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).

Cookies Notice

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?

We use Cookies on our Website that automatically collect information to:

  • 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.

Changes to this Privacy Policy

We may change this Website Privacy Policy to reflect changes in the law, our information practices, or components of our Website. At the top of our Website Privacy Policy, we will indicate the date of the most recent update to this Website Privacy Policy. Where required by applicable law, we will apply changes only after notifying and/or obtaining your consent before any material changes to our Website Privacy Policy apply to you.

How to Contact Us

If you have questions or concerns, the best way to reach us is by emailing privacy@goguardian.com. You can also reach us by calling 888-310-0410 or by writing to Liminex, Inc. dba GoGuardian, Attn: Chief Privacy Officer, 2030 E Maple Ave, El Segundo, CA 90245.

Because GoGuardian participates in iKeepSafe's COPPA Safe Harbor Program (after iKeepSafe has independently reviewed and determined GoGuardian's data practices in our Products comply with COPPA), if GoGuardian is unable to satisfactorily address your concerns and if you are a resident of the United States, then you may contact iKeepSafe Safe Harbor Program's dedicated consumer complaint department at: coppaprivacy@ikeepsafe.org or see ikeepsafe.org/about-us/contact-us/.

Additionally, please feel free to consult additional resources such as the ones listed below.

Student Privacy Resource List: