Privacy Policy

DATED 2019-10-11 · VERSION 20191120_rev01 · COMPARED WITH 20191016_rev01 · ARCHIVE SNAPSHOT

Full text changes — 20191016_rev01 to 20191120_rev01

COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED

 ### 3\. HOW WE STORE AND PROTECT YOUR INFORMATION
 **Storage and processing:** Any information collected through the Service is stored and processed in the United States. If you use our Service outside of the United States, you consent to have your data transferred to the United States.
 **Keeping information safe:** Clever maintains strict administrative, technical and physical procedures to protect information stored in our servers, which are located in the United States. Access to information is limited (through user/password credentials and two factor authentication) to those employees who require it to perform their job functions. We use industry-standard Secure Socket Layer (SSL) encryption technology to safeguard the account registration process and sign-up information. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to building and files.
+**Unauthorized disclosure:** If there is any disclosure or access to any personally identifiable Student Data by an unauthorized party, we will promptly notify the affected School(s) and will use reasonable efforts to cooperate with their investigation of the incident.
 ## Questions about data? Here are your options.
 ### 4\. YOUR CHOICES ABOUT YOUR INFORMATION
 **Account information and settings**: Schools may update account information and modify Services by signing into the administrator account. Schools and other website visitors can opt-out of receiving promotional email from us by clicking on the "unsubscribe" feature at the bottom of each email. Sorry, you cannot unsubscribe from Service-related messaging.
 **How long we keep User Content:** Following termination or deactivation of a School account, Clever may retain profile information and content for a commercially reasonable time for backup, archival, or audit purposes, but any and all Student Data associated with the School will be deleted promptly. We may maintain anonymized or aggregated data, including usage data, for analytics purposes. If you have any questions about data retention or deletion, please contact us by visiting our [Help Center](https://support.clever.com/).
 ## We do not collect any information from students without consent.
 ### 5\. CHILDREN'S PRIVACY
+Clever does not knowingly collect any information from children under the age of 13 unless and until the School has obtained appropriate parental consent for the student to use the Service. Because Clever collects and uses Student Data at the direction of and under the control of a School, Clever relies on each School to provide appropriate notice to parents of the School's use of third party service providers such as Clever, and for the Schools to provide consent, if necessary, and authorization for Clever to collect Student Data, as permitted by the Children's Online Privacy Protection Act (COPPA). Please contact us at urgent@clever.com if you believe we have inadvertently collected personal information of a child under 13 without proper consent so that we may delete such data as soon as possible.
+Clever does not knowingly collect any information from children under the age of 13 unless and until the School has obtained appropriate parental consent for the student to use the Service. Because Clever collects and uses Student Data at the direction of and under the control of a School, Clever relies on each School to provide appropriate notice to parents of the School's use of third party service providers such as Clever, and for the Schools to provide consent, if necessary, and authorization for Clever to collect Student Data, as permitted by the Children's Online Privacy Protection Act (COPPA). Please contact us at [urgent@clever.com](mailto:urgent@clever.com) if you believe we have inadvertently collected personal information of a child under 13 without proper consent so that we may delete such data as soon as possible.
 ### 6\. LINKS TO OTHER WEB SITES AND SERVICES
 We are not responsible for the practices employed by websites, applications or services linked to or from our Service. We recommend that the School review the privacy policies of other applications before authorizing a third party to access data through the Service.
 ### 7\. HOW TO CONTACT US
+If you have any questions about this Privacy Policy or the Service, please contact us by visiting our [Help Center](https://support.clever.com/).
+If you have any questions about this Privacy Policy or the Service, we recommend contacting us by visiting our [Help Center](https://support.clever.com/).
+Additionally, Clever can be reached:
+- By Email: [trust@clever.com](mailto:trust@clever.com)
+- By Mail: Clever Inc, ATTN: Dan Carroll, 1263 Mission St, San Francisco CA 94103
+- By Phone: 1-800-521-6516
+If you are not satisfied with our response, you can contact the iKeepSafe Safe Harbor Program's dedicated consumer complaint department at: [coppaprivacy@ikeepsafe.org](mailto:coppaprivacy@ikeepsafe.org)
 If a Student contacts Clever with a question about our Service, we will collect personal information from that Student only as necessary to respond to the Student's request and direct the Student to contact the Student's School, and we will then delete or anonymize the personal data of the Student after providing our response.
 ### 8\. CHANGES TO OUR PRIVACY POLICY
 Clever may modify or update this Privacy Policy from time to time so you should review this page periodically. [Click here](https://github.com/Clever/policies/releases) to see all changes to this Privacy Policy. If we change the policy in a material manner, for example if we seek to use personal information in a materially different way than we had previously, we will provide at least 30 days notice to the Schools so that you have sufficient time to evaluate the change in practice. Of course, you can always opt-out by deleting your account before the changes take effect.
+**This privacy policy was last modified on April 2, 2018.** Effective Date: May 2, 2018
+**This privacy policy was last modified on October 11, 2019.** Effective Date: October 11, 2019