Date of Last Revision: February 24, 2020
Protecting your privacy is really important to us. Accordingly, we’re providing this Privacy Policy to explain our practices regarding the collection, use, and disclosure of information that we receive when you use the Services (as defined in our Terms of Service and Acceptable Use Policy). This Privacy Policy applies only to those websites, services, and applications included within the “Services” and doesn’t apply to any other third-party websites, services, or applications, even if they are accessible through our Services. Also, please note that, unless we define a term in this Privacy Policy, all capitalized words used in this Privacy Policy have the same meanings as in our Terms of Service.
“Plain-language” summaries (“This means that…” sections) are provided for your convenience and are not legally binding. Make sure you read this Privacy Policy for the complete details of how Populi handles your information.
This Privacy Policy applies to all users of the Services, including our “Customers” and our Customer’s “Authorized Users”.
This means that…
We collect certain information from Customers when they set up a Customer Account. We only use this information to provide the Services to you. If you cancel your Customer Account, we may retain some of your information for internal uses—but we will not sell it or otherwise use it.
This section of the Privacy Policy applies to information that Populi collects from our Customers.
Our goals in collecting information are to provide and improve the Services, to administer your use of the Services (including your Populi customer account (“Customer Account”)), and to enable you to enjoy and easily navigate the Services.
When you create a Customer Account we’ll collect certain information that can be used to identify and contact you, such as your name, email address, mailing address, and phone number. As indicated in Section 2 below, similar information will be collected from the individual employees designated as Customer “account administrators”, “billing contacts”, or other Authorized Users.
We use this information to provide the Services to our Customers and their Authorized Users.
If you are using the Services in your capacity as a Customer, you can access and modify certain information associated with your Customer Account via your Customer Account. If you want to delete any such information, you should contact us at support@populi.co with your request. We’ll take steps to delete the applicable information as soon as is practicable, but some information may remain in archived/backup copies for our records or as otherwise required by law.
This means that…
We collect certain personally-identifying information from our Customer's Authorized Users. We only use this information to provide the Services to our Customers and their users and also to learn how you use Populi. Most of the information is collected by our Customers so they can run their school. If you want to remove your information from the Customer's Populi site, you’ll need to contact the Customer. Even if it’s removed, we may retain some of your information for internal uses—but we will not sell it or otherwise use it.
This section of the Privacy Policy applies to information that Populi may receive about Authorized Users.
Our goals in using information about Authorized Users are to provide and improve the Services, to administer your use of the Services (including your Populi user account (“Account”)), and to enable you to enjoy and easily navigate the Services.
In connection with your user account, you provide certain information that can be used to identify you, such as your name, email address, mailing address, phone number, vaccination records, and education records (including course enrollment and performance data), and in some cases your social security number (“Personally Identifiable Information” or “PII”). You may also be asked to provide certain information that is not PII because it cannot be used by itself to identify you, such as your gender, date of birth, ethnicity, marital status, and zip code.
Most PII we receive with respect to Authorized Users is collected by and held on behalf of our Customers. If you are an Authorized User, you acknowledge and agree that any PII or other information that you provide to the Customer via the Services is received, used, and processed by us and our third party service providers on behalf of the applicable Customer in accordance with this Privacy Policy.
This information is generally collected via your Account when you use the Services, pursuant to the applicable Customer’s information collection practices, which are typically outlined in a privacy policy like this one and made available on the Customer’s website. We encourage all Authorized Users to read the privacy policies or statements of the applicable Customer and other online services they access or use.
We analyze and use this information to provide the Services to our Customers and their Authorized Users.
If you are an Authorized User, you can access certain of the PII associated with your Account via your Account. In order to access and modify the PII associated with your Account however, you must contact the Customer directly. If instructed by our Customer, we’ll take steps to delete the applicable information as soon as is practicable, but some information may remain in archived/backup copies for our records or as otherwise required by law.
The Services may include certain communications to Account-holders from Populi, such as administrative messages; these communications are considered part of Populi and you will not be able to opt out of receiving them.
You may also at any time via your Account provide your mobile phone number and opt-in to receive text messages, including emergency notifications and campus alerts, from the Customer where you are employed, engaged or enrolled. You can opt-out of this service at any time via your Account.
This means that…
We collect certain personally-identifying information from our Customer's Authorized Users. We only use this information to provide the Services to our Customers and their users and also to learn how you use Populi. Most of the information is collected by our Customers so they can run their school. If you want to remove your information from the Customer's Populi site, you’ll need to contact the Customer. Even if it’s removed, we may retain some of your information for internal uses—but we will not sell it or otherwise use it.
The remainder of this Privacy Policy applies to information that Populi may receive about any users of the Services, including both Account holders (including Customers & Authorized Users) and non-Account holders (each a “User”).
We may collect PII through our Site when you provide it to us in order to schedule a demo or request to receive our newsletter.
We collect certain information through the use of “cookies,” which are small text files that are saved by your browser when you access the Services. We may use both session cookies and persistent cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with the Services. We may also use cookies to monitor aggregate usage and web traffic routing on the Services and to customize and improve the Services. Unlike persistent cookies, session cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept cookies, you can change your browser options to stop automatically accepting cookies or to prompt you before accepting cookies. Please note, however, that if you don’t accept cookies, you may not be able to access all portions or features of the Services. Some third-party services providers that we engage may also place their own cookies on your browser, some of which may connect to third-party advertisers (we do not knowingly connect to any third-party advertisers). Note that this Privacy Policy covers only our use of cookies and does not include use of cookies by such third parties.
Our servers automatically record certain information about how a person uses the Services (we refer to this information as “Log Data”). Log Data may include information such as a User’s Internet Protocol (IP) address, browser type, operating system, the web page that a User was visiting before accessing the Services, the pages or features of the Services to which a User browsed and the time spent on those pages or features, search terms, the links on the Services that a User clicked on and other statistics. If you are an Account holder, Log Data about you is connected to and used in conjunction with your Account. We use this information to administer the Services and we analyze (and may engage third parties to analyze) this information to improve and enhance the Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences. We may use a person’s IP address to fight spam, malware and identity theft. We also use the IP Address to generate aggregate, non-identifying information about how the Services are used.
We may use your PII to contact you with Populi newsletters, marketing or promotional materials and other information that you have specifically requested from us. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications.
This means that…
Your personally-identifying information is sometimes administered via our third-party service providers. Their access to your information is limited to what they need to perform services on our behalf. Sometimes we’ll share information in aggregate form (i.e. "We serve 20,000 students!"). If necessary, we might have to disclose information to comply with the law or to protect people or property.
We will not share any PII that we have collected from you except as described below:
We may engage third party service providers to work with us to administer and provide the Services, including service providers who process payments. These third-party services providers have access to your PII only for the purpose of performing services on our behalf.
We may share aggregated information and non-identifying information with third parties for industry analysis, demographic profiling and other similar purposes.
Information that we collect from our users, including PII, is considered to be a business asset. As a result, if we go out of business or enter bankruptcy or if we are acquired as a result of a transaction such as a merger, acquisition or asset sale, your PII may be disclosed or transferred to the third-party acquirer in connection with the transaction, including to enable such third-party acquirer to continue to provide the Services to our Customers and their Authorized Users.
It is our policy to protect you from having your privacy violated through abuse of the legal systems, whether by individuals, entities, or governments, and to contest claims that we believe to be invalid under applicable law. However, it is also our policy to cooperate with government and law enforcement officials and private parties. Accordingly, we reserve the right to disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary:
When handling student education records as defined by the Family Educational Rights and Privacy Act (FERPA), Populi will abide by the limitations and requirements imposed by 34 CFR 99.33(a). Populi will disclose student education records as directed by school officials, or in order to comply with a court order, subpoena, or other legitimate demand by government authorities.
When handling "Non-public information" records (NPI) for customers considered by the Gramm-Leach-Billey Act (GLBA) as "Financial Institutions", Populi will implement and maintain the safeguards required of "Service Providers" set forth in 16 CFR 314.4(d) of the FTC Safeguards rule.
In our legal agreements, data deletion and security policies, and Services, Populi observes best practices for complying (and helping to enable your compliance) with the European Union’s General Data Protection Regulation (GDPR). If you have any questions about Populi and compliance with GDPR, please contact us at support@populi.co.
This means that…
We do everything we reasonably can to keep your information safe and secure, but 100% security is a moving target and we can’t guarantee anything.
We take reasonable measures to protect the information that we collect from or about you (including your PII) from unauthorized access, use, or disclosure. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.
This means that…
Populi may contain links to other websites or services. This Privacy Policy does not apply to those other sites.
The Services (including the Site and our Customers’ websites) may contain links to other websites and services. Any information that you provide on or to a third-party website or service is provided directly to the owner of the website or service and is subject to that party’s privacy policy. Our Privacy Policy does not apply to such websites or services and we’re not responsible for the content, privacy, or security practices and policies of those websites or services. To protect your information we recommend that you carefully review the privacy policies of other websites and services that you access.
This means that…
Your information might be stored in a different jurisdiction with different privacy laws.
Your PII may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside the United States and choose to provide your PII to us, we may transfer your PII to the United States and process it there.
This means that…
We do not knowingly collection information from children and if we inadvertently do, we delete it. Our Customers may collect such information, and it is their responsibility to make sure they comply with applicable laws.
The Services are not directed to children under 13 and we do not knowingly collect PII from children under 13. If we learn that we have collected PII of a child under 13 on our Site, we will take steps to delete such information from our files as soon as possible.
We are not responsible for the collection of PII of children under 13 by our Customers and their Authorized Users. It is the responsibility of our Customers and their Authorized Users to utilize the Services in a manner that complies with FERPA and any similar regulations in force in the jurisdiction(s) within which our Customers operate.
This means that…
Sometimes we’ll need to update this Privacy Policy, and we’ll let you know when we do.
Any information that we collect is subject to the Privacy Policy in effect at the time such information is collected. We may, however, modify and revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll notify you of such changes by posting them on the Services or by sending you an email or other notification, and we’ll indicate when such changes will become effective.
If you have any questions about this Privacy Policy, please contact Populi at:
info@populi.co
877-476-7854
P.O. Box 9481
Moscow, ID 83843
