Last Updated: July 10th, 2024
Introduction
ThinkSync (“we,” “us,” “our”), a division of MetaNu. LLC, is dedicated to safeguarding the privacy of our users while offering a personalized and beneficial educational experience. This Privacy Notice outlines our commitments and practices regarding the collection, use, and protection of personal information, including Student Data.
We will only collect, use, and share your personal information in accordance with this Privacy Notice. This policy applies when you use our Platform or our Services, or any of our other products or services that link to this Privacy Notice that ThinkSync may provide now or in the future. This Privacy Notice also covers our treatment of any personal information about our users that our partners or third-party servicers share with us.
This Privacy Notice does not apply to the informational website located at https://thinksyncedu.com/.
This Privacy Notice also does not apply to information collected through other websites, products, or services that ThinkSync does not own or control, such as third-party services you might access through links or other features on the Service. These other services have their own privacy policies that govern how they collect, use, and share personal information.
Capitalized terms used in this Notice, unless otherwise defined, have the same meaning as found in our Terms of Use.
Acknowledgment
By using our Services or accessing our Platform through https://app.thinksyncedu.com/login, you acknowledge that you accept the terms, practices and policies described in this Privacy Notice (and as updated from time to time), and you hereby agree that we may collect, use, and share your information as described herein. If you do not agree, you should not use our Services. Your use of our Services is at all times subject to our Terms of Use (as updated from time to time (the “Terms”)), which incorporates this Privacy Notice.
Student Data Privacy
ThinkSync is committed to protecting Student Data, which is why we participate in the iKeepSafe Safe Harbor program. In furtherance of our participation, iKeepSafe has granted ThinkSync the COPPA Safe Harbor seal, meaning that our Platform and our Services have been reviewed and approved with respect to how we collect, use, store, and disclose personal information pertaining to children. Below, we outline our specific commitments under the Children’s Online Privacy Protection Act (COPPA) and the Family Educational Rights and Privacy Act (FERPA). ThinkSync EDU participates in the iKeepSafe Safe Harbor program. If you have any questions or need to file a complaint related to our privacy policy and practices, please do not hesitate to contact the iKeepSafe Safe Harbor program at COPPAprivacy@ikeepsafe.org
COPPA
We do not knowingly collect personal information from children under the age of 13 without obtaining verifiable parental consent. However, we rely on schools or school districts to provide consent on behalf of their students for the collection of Student Data necessary for accessing the Platform or Services.
Any Student Data collected from students under 13 is used solely for the purpose of providing access to the Platform and its features, as well as for improving the Platform’s functionality and content related to our Services. We do not use children’s personal information for targeted advertising or for marketing purposes. We do not ask for more personal information than is necessary for a child to participate in the Services.
Parents have the right to review the personal information collected from their children, request its deletion, and refuse further collection or use of their child’s information. Parents can exercise these rights through their school or school district.
In the event of any material changes to our COPPA practices, including changes to how we collect, use, or disclose children’s personal information, we will provide notice to schools or school districts and obtain parental consent if necessary.
FERPA
We understand that access to certain Student Data is governed by FERPA and we take appropriate measures to ensure that only authorized individuals, such as school administrators, teachers, and counselors, have access to student data necessary for using the Platform.
Student Data collected and maintained within the Platform is used solely for educational purposes, including fostering mental health awareness and well-being among students. We do not disclose Student Data for non-educational purposes without consent, except as permitted by law.
Under FERPA, eligible students and their parents have certain rights regarding the privacy of student education records, including the right to inspect and review records, and limit the disclosure of personally identifiable information. We support and facilitate the exercise of these rights by educational institutions and their students and parents.
Information We Collect
ThinkSync collects personal information necessary for providing our Services. We collect information, including personal information, in three ways:
(1) information that you voluntarily provide us by using the Services, or Student Data that is provided to us on a student’s behalf by a school or parent/guardian, including your first and last name, email address, age, date of birth, anticipated date of graduation, ethnicity and gender.
(2) information collected automatically as result of your use of the Services, including how users, including student users, access and use the Services and information about the device used to access the Services. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, file information and similar technology. The information we collect includes your browser, access time, the time you spend in the Platform or using our Services, the pages that you view, and the referring URLs. All of the information collected automatically through these tools allows us to improve your user experience, monitor and improve the Services and improve the effectiveness of our Services.
(3) information about our users from third-party sources, including aggregated anonymous information or certain personal information that may be provided to us, (e.g., through surveys). If we receive personal information from third-parties, or if we combine information from a third-party with personal information we collect, we will handle it in accordance with this Privacy Notice.
How We Use Your Information
We use personal information only when we have a valid legal basis to do so. More specifically, we use your personal information, including Student Data, to:
Deliver our Services, including any necessary technical support,
Verify your or your child’s age,
Communicate with You,
Understand and maintain our Services,
Protect our intellectual property,
Provide and maintain the functionality of our website, including identifying and fixing errors or problems,
Prevent misuse of our Services and our Platform
Comply with legal obligations, including establishing or exercising our legal rights, and to defend against a legal claim, and
Support our core business functions.
To the extent that we anonymize and/or de-identify personal information collected through the Services so that it no longer identifies you personally, our use and disclosure of such information is not subject to this Privacy Notice. We will not attempt to re-identify de-anonymize personal information.
How We Share Your Information
We share personal information with third parties only when it is necessary for the provision of our Services, or when required by law. All third-party service providers are bound by confidentiality agreements and are prohibited from using the data for any other purpose. A list of third-parties that we use is available here.
We do not rent or sell information for marketing purposes and we will never share or sell Student Data with third parties for marketing purposes.
We share information within the Services as needed to perform the Services and/or at the direction of a School. For example, Student Data may be shared between and among authorized School users, including teachers and School administrators.
We share information with our third-party service providers who perform technology services on our behalf (e.g., web hosting, chat providers, analytics services), but strictly for the purpose of carrying out their work for us.
When required, we share information with law enforcement or other third parties when compelled to do so by court order or other legal process, to comply with statutes or regulations, to enforce our Terms of Use, or if we believe in good faith that the disclosure is necessary to protect the rights, property or personal safety of our users.
We may share information in an aggregated and/or anonymous form that does not reasonably identify an individual or School.
If we sell all or part of our business, or otherwise transfer ownership of our business, we will not transfer personal information of our users unless the new owner intends to maintain and provide the Services, and provided that the new owner has agreed to data privacy standards no less stringent than our own.
We will only share Student Data as authorized and as permitted by the School.
How Long We Keep Your Information
ThinkSync does not retain personal information for longer than is necessary to fulfill a contractual agreement, save for any legal requirements that require a longer retention period. If a student profile is inactive for more than 24 months, that profile and all associated Student Data will be deleted from our Platform and our Services.
Upon request or at the termination of services, we will dispose of or return Student Data in accordance with the instructions provided by the educational institution.
How We Protect Your Information
We use commercially reasonable measures to protect your personal information. However, information transmitted over the Internet is never completely secure. You can help protect your personal information and other information by keeping your password to the Platform and our Services confidential. We will never ask you to share your password.
Any information collected through the Services is stored in the United States. We maintain a number of administrative, technical, and physical procedures to protect that information that we collect.
If we learn of a security breach, we will attempt to notify you so that you can take appropriate protective steps; for example, we may post a notice on our homepage or elsewhere on our website, and we may send email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
Your Rights
We recognize that depending on your location, you may be afforded certain rights regarding your personal information under applicable data protection laws. These rights may include the right to access, correct, delete, or transfer your personal information, as well as the right to opt-out of certain uses of your information.
If you believe you are entitled to any of these rights under applicable law, or if you have any questions about your rights and how we process your personal information, please contact us at support@thinksyncedu.com
Updates to This Policy
ThinkSync reserves the right to update this Privacy Notice at any time. We will notify users of any changes by posting the new policy on our website and updating the effective date at the top of this policy. If the changes are material and, where required by applicable law, we will obtain your consent. Notice may be by email to you at the last email address you provided us, by posting notice of such changes on our sites and applications, or by other means, consistent with applicable law.
Contact Information
For any questions or concerns regarding this Privacy Notice or our data practices, please contact us at:
ThinkSync (DBA MetaNu. LLC)
P.O. Box 296, Beaver Falls, PA 15010
Email: support@thinksyncedu.com