Privacy Policy

INTRODUCTION

The ReflEQ early-access program is enabled for the period April – June 2019, after which the service will be opened to the general public. ReflEQ’s vision mission is to provide schools and institutions with an online, formative teaching and learning space using reflection.

To accomplish this goal, it is essential that ReflEQ is a safe place for students to document their learning, and that they and their teachers are in complete control over how their information is shared.

Protecting your privacy is fundamental to our mission. The following summarize our promises to you, and these promises will continue to hold true once ReflEQ is launched to the public.

  • We do not, and will never sell your data or student data.
  • We will never advertise.
  • Students solely own the content they add to ReflEQ.
  • Student work is private to the student and their teacher by default.
  • We use the latest security industry best practices to protect you.
  • We are transparent about our practices.
  • We are compliant with FERPA, COPPA, and GDPR.

This Privacy Policy governs the use of the ReflEQ (“ReflEQ” or “the Service”). This includes any personally identifiable information that we collect when you create a account (the “Account Information”) at your school or site, and subsequent content added to student reflections (“Reflection Content”). Any data collected by ReflEQ that can be linked back to an individual student is considered “Student Data”.

By using ReflEQ, you agree to this Privacy Policy. If you don’t agree, please don’t use ReflEQ. You can contact us anytime with questions about this policy at support@refleq.com.

 

REFLEQ AND PARENTAL CONSENT

COPPA regulations state that teachers or schools have parental consent to use ReflEQ with children who are under the age of 13. You should check your local laws to determine the relevant age in your country. If you are aware ReflEQ is collecting information from a student under the age of 13 without parental consent, please contact us immediately and we will delete the data.

 

REFLEQ AND FERPA

Data collected by ReflEQ may include personally identifiable information from education records that are subject to the Family Educational Rights and Privacy Act, “FERPA”, (“FERPA Records”). To the extent that Student Data includes FERPA Records, you designate ReflEQ as a “School Official” (as that term is used in FERPA and its implementing regulations) under the direct control of the school with regard to the use and maintenance of the FERPA Records and ReflEQ agrees to comply with FERPA.

 

REFLEQ AND GDPR

ReflEQ is not currently open to schools and students in the European Union. However, it does comply with the European Union General Data Protection Regulation (the “GDPR”).

 

WHO DOES REFLEQ COLLECT INFORMATION FROM?

School administrators may create both teacher and student accounts on ReflEQ by manual entry or CSV import (or provide such information directly to ReflEQ for assistance with CSV import). Teachers may only create student accounts, by manual entry only.

 

INFORMATION DOES REFLEQ COLLECT?

Account Information: When teachers or school administrators create an account on ReflEQ we collect your name, email address, password, and you may upload a profile picture if you so choose.

Students cannot create an account by themselves, but must be invited to a ReflEQ class by a teacher or school administrator. Where students have this permission to use ReflEQ, ReflEQ collects a small amount of personally identifiable information about them including their names and email addresses. The student names and email addresses are entered by a teacher or school administrator. At the student’s choice, they may also upload a profile picture on an optional basis only. The student email address is used for login. It is also used if the teacher issuing a reflection question chooses that the student should receive email notifications to remind them of a due date.

Reflection Content: ReflEQ stores content that the student writes into a student ReflEQ journal. The purpose of such journal entry is to document student learning and is in written form only. Reflection content may occasionally include an associated PDF if the student is requested by the teacher to upload such attachment. Reflection Content that is uploaded by a student may be considered a student education record as defined by FERPA.

Third-Party Sign-in Services and Integrations: At this time, ReflEQ has no third-party sign-in services nor integrations.

 

REFLEQ ALLOW ADVERTISING OR SHARE DATA FOR ADVERTISING?

Absolutely not. We will never display ads, allow third-party ads, share data for the purpose of displaying ads, or allow data collection by third-party advertisers or data brokers.

 

IN WHAT LIMITED CIRCUMSTANCES MAY REFLEQ NEED TO SHARE MY INFORMATION?

We do not sell or share any data you provide with third parties. The only instance that we may share any information is if obligated to do so by law.

 

DO YOU WORK WITH THIRD-PARTY ANALYTICS SERVICES?

As part of its early-access program, ReflEQ uses one third-party service to monitor how it is being used. The service employed is FullStory, which tracks for example what buttons you click on or what pages you visit. FullStory does allow us to receive log data such as your IP address, browser type, operating system and device information. This information is used generically by ReflEQ to inform decisions related to iterative product development as the platform prepares for broader launch and adoption. There are absolutely no other uses of this information.

 

HOW DO YOU USE COOKIES?

Cookies are small text files that we transfer to your web browser that allow us to identify your web browser and store information about your account. We use these cookies to keep you logged in to ReflEQ. If the ‘Remember Me’ checkbox is checked on login, it sets a cookie that will expire two days after login. This cookie will persist across browser restarts. If that box is not checked, it uses a ‘session cookie’ that will expire when the browser is closed. You can choose to remove or disable cookies via your browser settings. Please be aware that ReflEQ will not work properly if you disable or decline cookies.

 

HOW CAN USERS SHARE STUDENT REFLECTION INFORMATION?

ReflEQ is designed for safe sharing. A student is the sole owner of his or her Reflection Content. It is visible only to the 1-2 teachers who have created that ReflEQ project for use with a class of students. A student’s Reflection Content is not visible to other students in the class, nor anyone else at the school or site. Students can only choose to share specific Reflection Content beyond the 1-2 authorized teachers by exporting their Reflection Content to a PDF format, and/or by creating a shareable weblink.

HOW TO VIEW, CORRECT, EDIT, PORT, OR UPDATE YOUR PERSONAL INFORMATION

You have the right to access, correct, download for transport to a similar service, or delete any of your personal information collected by ReflEQ. If you are a teacher, you can update the information associated with your ReflEQ account directly by contacting ReflEQ directly. If you are a parent and want to correct, edit, download, or update information about your student, please work directly with your teacher or school, or you can contact us at support@refleq.com.

 

HOW TO DELETE YOUR REFLEQ ACCOUNT

If you would like to delete your ReflEQ account or any content submitted to ReflEQ, please send an email to support@refleq.com. If you request that your account or any content submitted to ReflEQ be deleted, ReflEQ may still retain information for up to 60 days to provide support and prevent accidental deletion.

If you are a teacher or school administrator within the US, please be aware that FERPA requires us to retain student education records once a valid request to inspect those records has been made.

 

HOW DOES REFLEQ KEEP YOUR DATA SAFE?

ReflEQ takes protecting your security and privacy seriously and we’ve put a number of measures in place to protect the integrity of your information, including use of highly secure software programs. There is no software development activities occurring outside the U.S. In the event of a security breach, we will notify affected account holders within the amount of time required by law so that you can take steps to keep your data safe.

 

CHANGES TO OUR PRIVACY POLICY

This Privacy Policy applies only to the limited application of the ReflEQ early-access program, being carried out during April – June 2019 in an invite-only setting. If we make changes to this Privacy Policy that we believe will materially affect your rights, we will notify your school by email about these changes. If you continue to use our service after you receive notice of changes to this Privacy Policy, you will accept these changes.

 

CONTACT INFORMATION

If you have any questions about this Privacy Policy or feedback, please contact rigele@refleq.com.

 

You can reach ReflEQ by mail at:

ReflEQ LLC
380 Hamilton Ave, Suite 172
Palo Alto, CA 94301

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