Privacy Policy

This Privacy Policy describes the use and treatment of personal information when the services subject to this policy are used. This Policy was updated as of February 1, 2024 and will be modified as needed by PACanimal and reviewed on an annual basis to reflect changes and clarifications in relevant privacy laws and best practices. For the purposes of the EU General Data Protection Regulation (GDPR), PACanimal serves as a Data Processor.

Privacy Overview

PACanimal is committed to the following principles with respect to your personal information:

Compliance with Privacy Laws

Introduction

PACanimal (“PACanimal,” “we,” “our,” “us”) recognizes the importance of your right to privacy and wants you to be familiar with how we collect, use, and disclose any personal information that individually identifies you (e.g., name, phone number, e-mail address). It also describes your choices regarding use, access, and correction of your personal information.

This Privacy Policy explains how we collect, use, disclose and protect your personal information when you use our website (the “Site”), our mobile application (the “App”) and our services, including but not limited to our student portfolio, assessment, and reporting features, or any, electronic publications, newsletters and/or announcements (collectively, the “Services”). This Privacy Policy is incorporated into and forms part of our Terms of Use, which outline the terms and conditions you agree to when using our Site, App and Services. We will only collect, use, and disclose your personal information in accordance with this Privacy Policy.

By using our Site, App or Services, you represent that you, or your parent or guardian, has provided all necessary consents to use the Site, App and Services as required under any applicable privacy laws and that you, or your parent or guardian, consents to the collection, use and disclosure of your personal information as outlined in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use our Site, App or Services, or supply your personal information to us.

By using our Site, App, or Services you and your users agree not to use the services in a way to store, initiate or transmit data that is infringing, libellous, defamatory, abusive, harmful to minors, designed to cause annoyance, inconvenience or distress to any person, constitutes harassment, or cyberbullying, or is in violation of copyright laws. Users who commit such acts may have their access restricted, suspended or terminated, at the discretion of PACanimal and in consultation with the Educational Institution. In cases of allegations of copyright, PACanimal has the right to remove the allegedly offending material until the dispute is resolved. PACanimal will notify the contracting party of any action taken against the offending user. A User may contest any deletion of content or suspension of use with User's Educational Institution and PACanimal will coordinate any decision with the protections and duties afforded by this Privacy Policy.

Any user who is subject to the negative activities listed below can report them to their Educational Institution or to PACanimal. Any appeal by the user for reinstatement will be addressed by the contracting Educational Institution. Any request for reinstatement by the Educational Institution will be considered by PACanimal and its decision shall be supported by substantial evidence.

Educators have the ability to remove specific content which they believe to be harmful.

Parent/Guardian Consent Requirement

PACanimal is designed and meant to be used in a classroom setting. PACanimal requires parent or guardian consent as a condition of use of our Site, App or Services for certain users when required by applicable law if the student is under the age of consent, save as outlined below. Most Educational Institutions (including schools and school districts) have policies that govern the use of third-party educational services and products like PACanimal, and that address compliance with parental consent and annual notice requirements under laws such as the Children’s Online Privacy Protection Act (“COPPA”) and the Family Educational Rights and Privacy Act (“FERPA”). As such, Educational Institutions, administrators, and teachers are in the best position to provide required annual notices and obtain parental consent required as a condition of using our Site, App or Services in compliance with applicable law and other policies of the Educational Institution. When parent or guardian consent is required under applicable law, PACanimal requires that Educational Institutions or teachers obtain written consent from the parents or guardians of students when they set up accounts on behalf of their students, invite students to use our Site, App or Services, and allow students to access their accounts in the classroom. To help facilitate this process, we have provided a model consent form that Educational Institutions and teachers may use to obtain parent/guardian consent to our Privacy Policy and Terms of Use in our Knowledge Base. Consent can be withdrawn by a parent or guardian and in such an event, the data collected by PACanimal will be deleted. Parents or guardians’ requests to modify or delete certain data are addressed below.

If you are a Educational Institution administrator or teacher, by inviting students to use our Site, App or Services, or setting up accounts on behalf of students in your Educational Institution or classroom, you represent that you or the Educational Institution by which you are employed have obtained necessary consent from the parents or guardians of students in your classroom to whom you have invited, or will invite, to use our Site, App or Services. You further represent that each student’s parent or guardian consents: (1) to the collection, use, and disclosure of personal information as outlined in this Privacy Policy, and (2) the terms specified in our Terms of Use on behalf of his or her child.

An Educational Institution may elect to proceed under the School Official exception to the consent rule, under section 99.31 of the Family Educational Rights and Privacy Act ("FERPA") or similar legislation.

We provide Educational Institutions, school administrators and teachers with notices required under applicable law. Additionally, upon request from an Educational Institution, school administrator or teacher that has established an account with PACanimal for use in the classroom, we provide the Educational Institution with a description of the types of personal information that we collect, an opportunity to review the personal information of students, and/or have the information deleted, and the opportunity to prevent further use or online collection of a student’s personal information as required by applicable law.

In some instances, PACanimal's duties regarding the collection of Student Personal Data will be set forth in a Data Privacy Agreement ("DPA") In those cases PACanimal will ensure that the data protections set forth in the DPA will be no less than stated here in this Policy. Where applicable, PACanimal collects data only as necessary to the proper administration of lawfully authorized educational activity and serves as a contracted School Official. PACanimal does not disclose Directory Information.

What Personal Information do we collect?

Personal information means any information about an identified or identifiable individual. The types of personal information that we may collect when using our Site, App or Services include, but is not limited to:

We do not collect Geolocation or Biometric data, nor do we collect Sensitive Data, as that term is defined in the GDPR. When you use our Services, we will also know what Educational Institution you attend and the city and state or province in which your Educational Institution is located, and we may combine that information with information we have from your account. However, we do not collect data that indicates whether you are participating or are eligible to participate in any free or reduced lunch programs.

The data we collect from you will be the data generated in your use of the Service. We do not collect your data through "cookies" or "beacons", except as stated below. The data you create when using the system remains your property, or that of your Educational Institution as it pertains to PACanimal, as applicable law designates.

PACanimal also creates Anonymous Data from the data you provide. Anonymous Data means data that has been modified so that it is not associated with, or linked to any individual personal information, or will not easily permit the identification of the individual. This includes data about how users interact with the Services. PACanimal does not consider personal information to include Anonymous Data.

Why Do We Collect Your Personal Information?

We collect, use, and disclose your personal information only in order to provide you with our Services. We may disclose your personal information to comply with legal and regulatory requirements and as otherwise may be permitted or required by applicable laws. We will only use the personal information that we collect for the purposes for which it was collected. We collect your personal information for the following purposes and in accordance with applicable laws:

We do not collect, maintain, use, or share your personal information beyond that needed to provide you with our Services, for authorized educational purposes, or for the purposes listed above as authorized by you or your parent or guardian.

When Do We Collect Personal Information?

We may collect your personal information when you voluntarily provide it to us by using our Services. As described elsewhere in this Policy we do not begin to collect or release your data to other parties your data until consent from you or your parent has been obtained or through the application, or where appropriate, of the School Official exception under FERPA. Consent and the process of consent will be determined by your Educational Institution. For example, we may ask you to provide personal information if you:

Any personal information posted, used, or disclosed on a Facebook page, YouTube page or other social networking page or site is subject to that website’s privacy policy, and is not subject to this Privacy Policy. We do not collect data using cookies or beacons, except as stated below. Information is not shared with any social networking sites or third parties beyond what is prescribed herein Educational Institutions, can through the use of the PACanimal settings, block or restrict access to third-party sites.

How Do We Safely Store Your Personal Information?

We securely store your personal information in the United States if you reside in the United States. We securely store your personal information in Canada if you reside in Canada or outside of the United States. We maintain technical, physical, and administrative security safeguards to protect your personal information against loss, theft, and unauthorized access. Any personal information that you provide to us is exchanged on a secure server. We store data in a highly secure Digital Ocean datacenter. Digital Ocean provides industry-leading compliance and privacy certifications to keep student data in PACanimal safe.

Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us.

We take reasonable steps to verify your identity before granting you access to your account on our Site. This may include verifying your identity with personal information or multi-factor authentication as the Educational Institution elects. The manner in which you access PACanimal is controlled by your Educational Institution through the use of settings. For example, the Educational Institution may allow you to access PACanimal with your Google account and password. To assist us in maintaining product you asked to maintain the secrecy of your username, password, and any other account information. We train our employees to be aware of the importance of maintaining the confidentiality of personal information and that unauthorized persons do not gain access to personal information that we have disposed of or destroyed.

We provide further protections for your stored data, which is discussed further in the section, “Data Security", below.

Limiting Collection of Personal Information

We limit the collection of personal information to that which is necessary to fulfil the purposes identified in this Privacy Policy and we collect, use, and disclose your personal information in accordance with this Privacy Policy.

Use, Disclosure and Retention of Personal Information

Your personal information will not be used without your consent for purposes other than those for which it was collected or in accordance with applicable laws. From time to time, we may wish to use personal information for new or additional purposes, in which case we will amend the Privacy Policy to include these new or additional purposes.

We may generate Anonymous Data from personal information collected through the Site, App and Services by removing information that makes the data personally identifiable to an individual. This includes information about how users interact with certain areas of the Services. We anonymize personal information collected through the Site, App or Services by de-identifying records or aggregating data such that individual records cannot be linked back to an original student record system or to other individual records from the PACanimal database. We use Anonymous Data within the system to improve our Products. We may also use it to demonstrate the effectiveness of our Products and for the development and improvement of our Products.

When we contract with an Educational Institution (such as a school or school district) to provide access to our Site, App, or Services to you, we will work with the Educational Institution to determine whether we are a “School Official” under FERPA. In cases where we are designated as a “School Official”, we will be under the direct control of the Educational Institution with respect to the use and disclosure of your personal information. We do not disclose Directory Information to the Public or any organization or individual, except in a manner consistent with this Privacy Policy.

Retention Of Records

We retain your personal information only for as long as we need it to fulfil the purposes for which it was collected, to ensure your compliance with our Terms of Service, and to comply with our legal obligations. Our retention policies will vary slightly, depending on whether or not you are an Individual Free User or whether your Educational Institution has a contract with PACanimal.

  1. Individual Free Users - Dormant Account: Prior to the start of each academic year, we review user account activity to confirm that each user has accessed their account in the preceding 24 months. If a user has not accessed their account during this period, subject to legal or contractual requirements, we will delete the personally identifying information associated with that account.
  2. Individual Free Users - Deletion Request: An individual user may request that their personally identifying information be deleted. In such a case, and subject to any applicable legal or contractual requirements, the data will be deleted in a commercially reasonable time, and in no event, exceeding 90 days.
  3. Educational Institution Contract - Deletion Request: Educational institutions in a contract with PACanimal (or once a contract expires) may request us to delete the personally identifying information of its users. Unless otherwise specified under the contract, and subject to applicable legal authority, the data will be deleted in a commercially reasonable time, and in no event, exceeding 90 days.
  4. Educational Institution Contract - No Deletion Request: In the event that an Educational Institution contract expires without renewal, and there is no Deletion Request, we will delete the personally identifying information of its users following the policy outlined under the point “Individual Free Users - Dormant Account”.

Students that leave or graduate from an Educational Institution will continue to have free access to their account during the retention period.

We do not knowingly retain your personal information beyond the time period required to support the provision of our Services to you, and/or to support authorized educational purposes, or purposes authorized by you or your parent or guardian.

Third-Party Access

Third parties do not have direct access to your data. We may also use and disclose your personal information to service providers, data processors and other third parties (“Third Parties”) under the following limited circumstances:

Access To Data

If you are a student, your parent or guardian, as well as your teacher and an administrator from your Educational Institution, may view and access all your personal information, content and activity associated with your account. In certain cases, access may be granted to a decedent's fiduciary or personal representative. PACanimal strives to create an environment where data stored is accurate and accessible. If you are a teacher, you will be able to access and edit all information, including personal information, about the students in your classroom. Students or guardians of students who wish to confirm the accuracy of data modify or delete data should direct their requests to their Educational Institution. PACanimal will delete or modify data found to be inaccurate by the Educational Institution.

A student's data may be transmitted to a student's personal account or to a third party, in accordance with the terms of this Privacy Policy. Transfers of such data will be administered by their Educational Institution. As stated in our Terms and Conditions, as it pertains to PACanimal you own all proprietary right and title and interest in your own user content, including any copyright.

Commitment to Data Security

We will use administrative, physical, and technical safeguards designed to protect student data from unauthorized access, disclosure, acquisition, destruction, use or modification. These efforts will include:

Data Breach Process

If we experience an unauthorized access to your data, we will provide notification to you by email and to any relevant legal authorities without unreasonable delay in accordance with applicable law. Our notification will provide details about the unauthorized access. We will also take reasonable steps to conduct a threat assessment and remedy the impact of any data breach on you, and take other steps as required by law.

Links to Other Sites and Privacy Policies of Other Sites

Our Site may contain links to other sites that are independently owned and operated by third parties. Your teacher will have the power to regulate or moderate your access to outside sites to protect you from harmful or inappropriate material or social interactions. Your teacher will additionally have the ability and tools to moderate your interactions within the classroom and outside of the classroom to prevent cyberbullying. These other sites may have their own privacy policies and are not governed by this Privacy Policy. We are not responsible for the privacy practices, or the content of any sites owned and operated by any third parties. Other sites may collect and treat information collected differently, so we encourage you to carefully read and review the privacy policy of each site you visit.

Cookies, Web Beacons, and Other Similar Technology

As you interact with this Site, we may use automatic data collection technology and services that record and collect information that identifies your computer, tracks your use of this Site, and collects certain other information about you and your surfing habits. This data collection technology may include cookies, web beacons and other similar technologies on this Site to enhance functionality and navigation for our visitors. These cookies and beacons will be used only for the purpose of supporting and enhancing the Services we provide, as more detailed below.

What Are Cookies and Web Beacons?

A cookie is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store settings in the browser. Web beacons are an invisible image file used for tracking purposes. Web beacon type functions allow us to count the number of users who have visited a particular web page or to access certain cookies.

How Do We Use Cookies and Web Beacons?

We may use web beacons on this Site to:

You can modify your privacy controls so that you are notified when cookies are stored, you can decide in each individual case whether you want to accept cookies, or you can refuse to accept any cookies. However, if you do not accept cookies, you may be restricted in how you are able to use our Site. You can delete cookies which are already stored on your browser at any time. You will find more details on how to do this in the operating guide for your Internet browser program.

Web Analytics

Our Site also uses third party analytics services to track such technical issues as telemetry concerned with load, performance and usage metrics, exception reports, and other diagnostic data. Some of the analytics services we use may place cookies in the browser of the visitor of the web pages which allows for an analysis of your use of the site. The only user data visible in the diagnostic reports are URLs; and as a best practice our Service does not put any personal data in plain text in a URL. Analytics services we use may also use “cookies” to analyze how you use our Site. We may also use cookies to carry out frequency assessments, page usage assessments, and marketing assessments. For these assessments, we utilize cookie information without a link to your personal information, so the assessment is completely anonymous.

You or your Educational Institution can set your internet browser to prohibit the installation of cookies that are utilized by the analytics services that we use. However, if you do not accept cookies, you may be restricted in how you are able to use our Site.

Personal Information and Data Protection Rights

Your personal information is subject to international data transfer or jurisdiction laws. Compliance with International data transfer laws will be handled by a Data Protection Officer (“DPO”) or other contact.

We would like to make sure you are fully aware of all your data protection rights. These rights may be coordinated, with and subject to the processes of your Educational Institution. Every user is entitled to the following:

The right to access – You may request access to or copies of your personal information which we may hold by contacting us at the contact information set forth below, and we will respond within the time periods provided for under applicable laws. We will need to verify your identity before providing you with the personal information we hold about you. There is no cost for these access requests unless you require copies of records. We may not be able to provide you with access to your personal information if the information cannot be separated from the personal information of others, cannot be disclosed for reasons of security or commercial confidentiality, or is protected by legal privilege. If we cannot provide you with access to your personal information, we will advise you of the reasons access is being denied, unless we are prohibited by law from doing so.

The right to rectification – You may request to update, change, or correct your personal information at the contact information set forth below. You have the right to request that we correct or complete any personal information which you advise us is inaccurate or incomplete. Where appropriate, the amended information shall be transmitted to third parties having access to such information. If you have any concerns about your information that was provided by your Educational Institution and/or teacher, please contact these parties directly.

The right to erasure – You have the right to request that we erase your personal information, under certain conditions.

The right to restrict processing – You have the right to request that we restrict the processing of your personal information, under certain conditions.

The right to object to processing – You have the right to object to our processing of your personal information, under certain conditions.

The right to data portability – You have the right to request that we transfer the information we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights or have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us at __________.

Electronic Communications

We comply with the United States CAN-SPAM Act and Canada's Anti-Spam Legislation (CASL), laws that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients of such messages the right to opt-out. We will not send you electronic communications in contravention of this law. As part of signing up to receive the Services, you may have also opted in to receive email communications from us. If you opted-in to receive such communications, we may use the information to communicate with you regarding our products, Services, and promotions; provide you with other information that you request; and/or improve our product and service offerings.

You will always have the opportunity to “unsubscribe” from receiving any of our e-mail or other communications at any time and we will ensure that our e-mails include instructions on how to unsubscribe if you no longer wish to receive future e-mails from us. We provide an on-going opportunity to unsubscribe or opt-out of contact by us by accessing our Site or by e-mail to __________or by calling us at_________.

If you decide to unsubscribe, we will only contact you (i) for the purposes allowed under applicable law; (ii) to send you notices of changes to our Privacy Policy; or (iii) to receive Service-related messages.

Personal Information of Children

We are committed to protecting the privacy of children. Our Site, App and Services are primarily intended to be used only by school administrators, teachers, parents, other adults, and students for K-12 school and educational purposes. As set forth in the “Parent/Guardian Consent Requirements” section of this Privacy Policy, we require Educational Institutions and/or teachers that establish accounts through our Site, App or Services and invite students to use our Site, App or Services to obtain parent or guardian consent when required under applicable law. We also provide required notices in accordance with applicable privacy laws. Please do not send us more information than is required to use the Site, App or Services.

Changes to this Privacy Policy

We reserve the right to change or replace this Privacy Policy at our sole discretion at any time to comply with changes in applicable law or to reflect evolving best practices. Please check back from time to time to ensure that you are aware of any updates or changes in this Privacy Policy. If we propose to make any material changes, we will notify Educational Institutions by email or notify you by means of a prominent notice on this page at least thirty (30) calendar days prior to the change becoming effective and will allow you choices before your personal information is used in any manner inconsistent with the terms that you were initially provided. We will not make any material changes to other policies or practices governing the use of your personal information that are inconsistent with contractual requirements. We will post the most current version of our Privacy Policy on our Site and we will indicate at the top of this page the date this Privacy Policy was last revised. Your continued access or use of this Site, App or Services after any such changes constitutes your acceptance of the Privacy Policy as revised.

This privacy policy was last updated on February 1, 2024. You may access an archive of our previous Privacy Policies by contacting us at ______________.

Your Consent to the Terms of this Privacy Policy

By using our Services and providing us with your personal information, you agree that PACanimal may collect your personal information and you voluntarily consent to the collection, use, disclosure, and transfer of your personal information in accordance with this Privacy Policy. If you do not agree with any terms of this Privacy Policy, please do not use our Site, App or our Services or provide us with any personal information. If you do not understand the nature, purpose, and consequences of us collecting, using, and disclosing your personal information, please do not use our Site, App or our Services or provide us with any personal information, and contact us at the contact information set forth below so that we can address your questions or concerns.

Subject to legal and contractual requirements, you may refuse or withdraw your consent for certain purposes identified in this Privacy Policy at any time by contacting us at the contact information below. If you refuse or withdraw your consent, you acknowledge that we may not be able to provide you or continue to provide you with certain services or information, which may be of value to you.

Any dispute arising between you and PACanimal with respect to privacy is subject to the terms and conditions of use and this Privacy Policy, including limitations on damages, arbitration and application of the laws of the Province of Ontario (or, in some cases, where the Product was purchased by an Educational Institution).

How to Contact Us

We welcome your feedback. If you have questions, comments, or concerns about this Privacy Policy, or would like to do any of the following:

Contact PACanimal at support@camproadsoftware.com