Privacy Policy
Last updated: October 18th, 2021.
At Closegap, we are dedicated to protecting the privacy of our students and their families. Closegap, a website available at www.closegap.org (“the Site”), along with a web-based and mobile application (“Applications”) make up a suite of services (collectively, “the Services”) owned and operated by Closegap Inc. (“the Company,” “we,” “us” or “our”). Closegap is a 501(c)(3) not-for-profit organization that focuses on improving the mental health and emotional wellbeing of K-12 students. Closegap Services are utilized by teachers, administrators, school counselors, social workers, and other school staff (collectively, “Educators”), and parents or legal guardians (collectively, “Parents”) to support the emotional wellbeing of their students or children (collectively “Children” or “Students”) throughout the school day. We’ve created this Privacy Policy to communicate how we protect, disclose, and use the information we collect when Closegap Services are used. Closegap has developed privacy practices to align with applicable laws, including the Family Educational Rights and Privacy Act (“FERPA") and Children's Online Privacy Protection Act ("COPPA"), in addition to federal and state-level student data privacy laws, including, but not limited to, the Protection of Pupil Rights Amendment (“PPRA”); California state student privacy laws, including, but not limited to AB 1584 and the Student Online Personal Information Protection Act (“SOPIPA"), and the New York Consolidated Law, Education Laws - Section 2-d. Closegap complies with the California Consumer Privacy Act (“CCPA”) and will not Sell your Personal Information. For purposes of Article 14(2) of the EU General Data Protection Regulation (“GDPR”), Closegap relies on the following lawful basis for processing Personal Data: consent, compliance with law and legitimate interest. Closegap does not differentiate how we treat our users whether they exercise their rights under the CCPA.
We may also share your personally identifiable information with law enforcement officials, or other third parties, when we are compelled to do so by a subpoena, court order, or similar legal procedure. In addition, we may share personally identifiable information if we believe in good faith that the disclosure of such information is necessary to protect the safety of the public or any person, to report suspected illegal activity, to investigate violations of our User Agreement.
INFORMATION WE COLLECT
Educators and Parents
When creating an account, educators and parents are asked for the following personal information: first and last name, school, phone number, email address, password, and role. After creating an account, educators and parents register accounts for their students within their Educator or Parent account.
Children
At this time, students are not permitted to create accounts on their own. When registered through a Parent or Educator account, we require the following personal information for each student or child: first and last name, birthdate, school, email address, gender, grade, homeroom teacher, and password.
In addition, we automatically collect the duration of time you spend on the site or app, including IP address, the type of device you’re using, a device identifier, the version of the Closegap application, device event information like crashes, hardware settings, date and time information, and actions performed by you while visiting our website or application.
HOW WE USE THE INFORMATION
We’re committed to protecting the personal information of our users. We do not sell or rent user information to anyone. Our primary goal in collecting information is to provide and improve our Services for your use. The personal information we collect from parents and educators is used to provide and improve Closegap services, contact you about services or products that may be of interest to you, and notify you of any changes in our services. You grant Closegap the right to aggregate and anonymize such data, in accordance with applicable law, and use such resulting de-identified data set for its purposes. The personal information we collect from students is used to improve the ease of use and access of the Services by the Educator. We collect student name so educators can easily distinguish between students; student email address for the use of a secure username. Please note: we do not send email communications to students other than to (1) set their password or (2) reset their password. We collect student birthdate to ensure we’re delivering age-appropriate content and to ensure minors don’t get past our age-gate protection measure during the registration process. We collect grade level and gender to provide educators with an easy way to search, filter, and organize students. We collect homeroom teacher to communicate to other educators where the daily check-in will occur. The aggregated and anonymized social and emotional data we collect from students is used by educators and parents to better understand and support their emotional wellbeing.
DATA ACCESSIBILITY
Student personal information may be accessed by educators and parents for review and correction at all times by logging into their account. Students may access, review and correct information through an educator or parent account. Parents or Educators can request the deletion of student data by contacting info@closegap.org.
DATA RETENTION
Closegap does not retain student personal information for longer than is necessary. If a student profile is inactive for more than 12 months, student data will be deleted immediately from all servers and technologies used by Closegap.
DISCLOSURE OF YOUR INFORMATION
Closegap partners with third-party contractors to deliver, improve and expand on the Services. In some cases, we may share personal information for the sole purpose of providing and improving our services for your use. We will not share personal information for any other purpose. The third-party contractors we partner with follow the same privacy guidelines and regulations we follow, which include, administrative, technical, and physical safeguards that equal industry best practices, including, but not limited to, disk encryption, file encryption, firewalls, and password protection.
Closegap shall ensure that a contract is in place between it and any third-party entity or agent that participates in an onward transfer of personal data.
SUCCESSOR ENTITIES
If Closegap is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and a prominent notice on our website, of any change in ownership, with options regarding your personal information, including removing it from Closegap systems entirely, will be visible. Any company acquiring all or a part of Closegap’s assets will be required to agree to the terms of the Privacy Policy.
CHILDREN’S PRIVACY
We are proud to be in compliance with the Family Educational Rights and Privacy Act (“FERPA") at 20 U.S.C. 1232g (34 CFR Part 99), Children's Online Privacy Protection Act ("COPPA"), 15 U.S.C. 6501-6506; in addition to federal and state-level student data privacy laws, including, but not limited to, the Protection of Pupil Rights Amendment (“PPRA”) 20 U.S.C. 1232h; California state student privacy laws, including AB 1584, found at California Education Code Section 49073.1 and the Student Online Personal Information Protection Act (“SOPIPA") found at California Business and Professions Code section 22584, and the New York Consolidated Law, Education Laws - Section 2-d. We store student information in electronic format on secure servers located within the United States.
PROTECTION OF YOUR INFORMATION
Closegap maintains a comprehensive security program that is reasonably designed to protect the security, privacy, confidentiality, and integrity of student personal information against risks - such as unauthorized access or use, or unintended or inappropriate disclosure - through the use of administrative, technological, and physical safeguards appropriate to the sensitivity of the information. We understand, however, that no system is perfect, and we cannot ensure or warrant the security of any or all of the information you transmit through our services. Closegap has a breach response plan in place and in the event of unauthorized disclosure of personal information of students, Educators, or Parents, this plan will be enacted immediately.
NOTICE OF CHANGES TO PRIVACY POLICY
We reserve the right to make changes to this Privacy Policy at any time. When you use the Site, please check the Privacy Policy to ensure you are aware of any changes to our privacy practices. Our Privacy Policy will indicate the date it was last updated. When we make material changes to our Privacy Policy we will notify you via email at the last email address you have provided to us. You will have a choice as to whether or not you accept the new terms of the Privacy Policy.
You can reach us directly at info@closegap.org or 2219 Main St, Suite #442, Santa Monica, CA 90405 regarding Closegap’s privacy practices or specific concerns about your personal information.