Last Updated: March 31, 2020
Edficiency strives to take all measures to protect your privacy. We are compliant with the United States Department of Education’s Privacy Technical Assistance Center (PTAC) and a signatory of the Future of Privacy Forum's Student Privacy Pledge.
1) Definition of “Data”
Data include all Personally Identifiable Information (PII) and other non-public information. Data include, but are not limited to, student data, metadata, and user Content.
2) Data De-Identification
Edficiency may use de-identified Data for product development, research, or other purposes. De-identified Data will have all direct and indirect personal identifiers removed. This includes, but is not limited to, name, ID numbers, date of birth, demographic information, location information, and school ID. Furthermore, Edficiency agrees not to attempt to re-identify de-identified Data and not to transfer de-identified Data to any party unless that party agrees not to attempt re-identification.
3) Marketing and Advertising
Edficiency will not use any Data to advertise or market to students or their parents. Advertising or marketing may be directed to the School/District only if student information is properly de-identified.
Edficiency will not change how Data are collected, used, or shared under the terms of this Agreement in any way without advance notice to and consent from the School/District.
5) Data Collection
Edficiency will only collect Data necessary to provide its services to its customers. All personally identifiable information and data collected will only be used for internal purposes to provide services to customers. Any data shared externally will not include any such personal information and will instead be only expressed in aggregate terms (e.g. serve X number of students).
6) Data Use
Edficiency will use Data only for the purpose of fulfilling its duties and providing services under this Agreement, and for improving services under this Agreement.
7) Data Mining
Edficiency is prohibited from mining Data for any purposes other than those necessary to provide its services to its customers and those agreed to by both parties. Data mining or scanning of user content for the purpose of advertising or marketing to students or their parents is prohibited.
8) Data Sharing
Data cannot be shared with any additional parties without the prior written consent of the User except as required by law. We are committed to ensuring any third parties with whom we work uphold practices consistent with our policies.
9) Data Transfer or Destruction
Edficiency will ensure that all Data in its possession and in the possession of any subcontractors, or agents to which the Edficiency may have transferred Data, are destroyed or transferred to the School/District under the direction of the School/District when the Data are no longer needed for their specified purpose, at the request of the School/District, or 30 days after the expiration of our contract.
10) Rights and License in and to Data
Parties agree that all rights, including all intellectual property rights, shall remain the exclusive property of the School/District, and Edficiency has a limited, nonexclusive license solely for the purpose of performing its obligations as outlined in the Agreement. This Agreement does not give Edficiency any rights, implied or otherwise, to Data, content, or intellectual property, except as expressly stated in the Agreement. This includes the right to sell or trade Data.
Any Data held by Edficiency will be made available to the School/District upon request by the School/District. Students can access their data via their profile in the system interface. Students (or parents of students) may also request access to data pertaining to them/their child from their school if they so choose, and Edficiency will support the school staff in obtaining requested data if available and necessary.
12) Security Controls
Edficiency will store and process Data in accordance with industry best practices. This includes appropriate administrative, physical, and technical safeguards to secure Data from unauthorized access, disclosure, and use. Edficiency will conduct periodic risk assessments and remediate any identified security vulnerabilities in a timely manner. Edficiency will also have a written incident response plan, to include prompt notification of the School/District in the event of a security or privacy incident, as well as best practices for responding to a breach of PII. Edficiency agrees to share its incident response plan upon request.
13) Successor Entities