EFFECTIVE DATE: NOVEMBER 1, 2021
- PURPOSE OF POLICY
Thank you for joining Sora Schools’ growing community! We are committed to protecting your privacy as you visit and use our website and any other related services provided by us (collectively, the “Service”). We understand how important privacy is to you, and we are committed to creating a safe and secure environment for all of our users.
This Policy also describes our practices related to information of individuals with whom we communicate for marketing or promotional purposes but who may not otherwise be users of the Service (the “Marketing Recipients”). By clicking the applicable button or checkbox to indicate your acceptance to this Policy and our Terms, or otherwise by using the Service, or by agreeing to this Policy as a Marketing Recipient, you consent to the privacy practices described in this Policy and agree that you are at least 13 years old.
2. PRIVACY OF CHILDREN UNDER 13 YEARS OF AGE
Our Service is currently designed for use by students. We understand that Student users who are under 13 years of age (“Students Under 13”) require special privacy protection and safeguards under the Children’s Online Privacy Protection Act (“COPPA”).
Before we have obtained required consents under COPPA, we do not allow Students Under 13 to provide any personal information, such as first and last name, address, email address, or telephone number information. Such personal information must be provided by the Parent and will be available only to Sora staff, and we will use the information only for purposes of providing the Service. We will never otherwise share or use such information without prior consent from the Parent.
Prior to Student Enrollment with Sora.
Upon Student Enrollment with Sora.
Upon a Student’s enrollment with Sora, the Parent must provide a signed enrollment agreement (“Enrollment Agreement”). The Enrollment Agreement includes a COPPA Parental Consent Form that the Parent must fill out, sign, and return along with the Enrollment Agreement for enrollment of a Student Under 13.
3. INFORMATION WE COLLECT AND HOW WE USE IT
Information You Voluntarily Provide Us.
You will not be required to provide any personally identifiable information to browse our website. However, if you would like to contact our admissions team via our website, register for and/or attend a virtual open house, submit an application for Student enrollment in the programs offered by Sora, confirm a Student’s enrollment with Sora or otherwise use the Service, after providing any applicable consents as described above, you will be required to provide us with various information that, on its own or in combination with other information, can be used to identify you as an individual (“Personal Data”). We will collect information you provide to us voluntarily as part of the application and enrollment process or that you subsequently provide through your use of the Service. Such information includes, without limitation:
- First and last name (for Student and Parent);
- Physical and/or mailing address (for Student and Parent);
- Email address (for Student and Parent);
- Phone number (for Student and Parent);
- Age and school grade level (for Student);
- Social security number (for Student);
- Financial information, including, but not limited to, credit or debit card numbers or bank account information (for Parent);
- Health and medical information (for Student); and
- Educational transcripts (for Student).
We also may collect and store communications that occur through the Service or outside of the Service between you and Sora.
Further, now or in the future, we may allow you to provide us with access to additional information and data through integrations with third-party goods and services.
The various categories of information in this subsection is, or may be, considered personally identifiable information, and is used for the purpose of providing you with the Service’s functionality. While all of the information described here may not be required to use the Service, some aspects of the Service may not be available if you choose not to provide us with such information.
Personal Data We Collect from Marketing Recipients
In addition to the Personal Data we collect from users of the Service, we collect Personal Data from Marketing Recipients who are interested in learning more about our products and services. This Personal Data consists of basic contact information such as the Marketing Recipient’s email address. This Personal Data is collected by us when Marketing Recipients sign up for commercial emails from us via online sign-up forms, and through other means, including the Facebook platform. For Marketing Recipients who are not otherwise users of the Service, we only use your Personal Data to send communications, including updates on promotions and events, relating to products and services offered by us and by third parties we work with that are related to the Service. If you no longer wish to receive marketing-related emails from us, you may opt out at any time via the unsubscribe link included in such emails. We will comply with your request as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages that are required to provide you with the Service, if applicable.
Information Collected Automatically As You Use The Service.
In addition to the information that you provide to us voluntarily, we collect information automatically through the Service, such as how you use and interact with the Service, data on activities that you pursue through the Service, and other similar activities.
We may also automatically collect your IP address and geo-location while you are using the Service through your device. You may be able to limit any such collection in the settings on your device. As with the voluntarily provided information described above, some aspects of the Service may not be available if you choose not to provide us with such information and Personal Data as applicable.
Additionally, if you participate in a virtual open house, we may use videoconferencing software. As such, your name, image and/or voice may be accessible to other participants at such time.
The information described above is used to provide you with the Service, to better understand our users and how they use the Service, and to improve the Service.
Sora uses first-party cookies that are only used to track your activity on the Service, and not on third-party sites or services.
In addition, Sora uses the following cookies:
- Google Analytics Cookies – Google Analytics is used by Sora for aggregate data to understand trends and usage patterns so as to improve the Service. These cookies do not collect personally identifiable information on our behalf, although Google may know who you are for their own purposes. Google Analytics uses only first-party cookies for data analysis. Information pertaining to privacy through the use of Google Analytics can be found at http://www.google.com/policies/privacy/partners/.
Other Anonymous Data We Collect.
Do Not Track Signals.
We do not track you or collect your information across third-party websites or online services. Thus, we do not receive Do-Not-Track signals or other similar signals. To the extent that we do receive any such signals, we will not comply with them as it is not an aspect of the functionality of our Service.
School records School sessions via audio- and video-conferencing software from time to time. The purpose of such recordings is to facilitate marketing and periodic program reviews by accreditors and School administration.
Student consent is obtained each time a session is recorded, and Students who prefer to participate via audio only will be allowed to disable their video camera so that only audio is captured. Students should discuss this option with their teachers. If a Student does not consent to being recording for a particular session, Student will be given the opportunity at the beginning of the session to remove Student’s name from the recording software’s visibility for such session, and any participatory activity attributed to Student for such session will be removed from the recording prior to use.
4. HOW WE SHARE YOUR INFORMATION
We do not sell or share your personally identifiable information with advertisers. We also do not share your personally identifiable information with other third parties except to the extent that it is in furtherance of the Service, or when you choose to do so (as described below).
To facilitate School communications and community-building, we place Student family information, including name(s), home address(es), email address(es), and telephone numbers of Parent, Student and other students in attendance at the School, in a directory (the “Directory”) made available to School families.
We do not share the Directory or information contained therein with commercial third parties or any person other than other School families. While we require all Sora enrollees to agree to the same and strive to ensure and enforce compliance, we do not retain control over actions taken by School families. If you wish to opt out of inclusion in the Directory, please contact email@example.com.
Our Personnel And Vendors.
To be able to effectively provide you with the Service, and to improve the functionality of the Service, we may disclose your information to our employees, contractors, agents, vendors, and other similar persons or entities, to the extent that such persons or entities have a need to know such information in furtherance of the Service. Our third-party vendors (“Third-Party Vendors”) provide us with various types of services, including without limitation, hosting services and marketing software services. We may share your Personal Data with our Third-Party Vendors.
Third-Party Payment Services.
Sale of Company or Assets.
In the event that we sell all or substantially all of our company or its assets, including the user information collected through our Service, we may transfer your information, upon reasonable notice to you, to the acquiring company.
Other Third Parties.
In addition to our practices described above, we may share your information if we have a good-faith belief that such action is necessary to (1) comply with the law (see the section below on “Government Requests”), (2) protect and defend the rights or property of Sora, or (3) prevent an emergency involving danger of death or serious physical injury to any person.
5. STORING YOUR INFORMATION
Storage and Retention Of Your Information.
We use commercially reasonable managerial and technical safeguards to preserve the integrity and security of your personal information.
We cannot, however, ensure or warrant the security of any information you transmit to Sora or guarantee that your information on the Service may not be accessed, disclosed, altered, or destroyed by breach of any of our managerial and technical safeguards. As such, we will not be liable for any loss or damage you incur as a result of a breach of our security systems. In the event that personal information is compromised as a result of a breach of our security systems, we will promptly notify those persons whose personal information has been compromised as required by applicable law.
We use reasonable efforts to secure your information and to attempt to prevent the loss, misuse, and alteration of the information that we obtain from you. For example, we require our personnel to sign confidentiality agreements that extend to your personal information, we have in place incident response measures, we have personnel to monitor privacy-related correspondence, and we review the privacy practices of new products and services that we integrate into our Service. In addition, we use reasonable technical safeguards, such as encryption, to secure your Personal Data, and we rely on the technical safeguards provided by the third-party vendors we use to host, store, and process your information. However, you acknowledge and agree that loss, misuse, and alteration may occur despite our efforts to protect your information. We are not responsible to our users or to any third party due to any such loss, misuse, or alteration.
6. GOVERNMENT REQUESTS
From time to time, we may receive requests from government agencies to obtain information about our users. In handling such government requests, we greatly value the privacy of your information. While we may be required to turn over user information at times, we will strive to require a search warrant or subpoena, to the extent that we can reasonably demand such warrant or subpoena, before we turn over information about you and we will also strive to notify users when we receive government requests about their data.
7. THIRD-PARTY SERVICES AND PRACTICES ARE BEYOND OUR CONTROL
Our Service utilizes third-party services as part of the functionality of the Service, such as hosting services, analytics providers, and other vendors, and we may share your information with third parties to the extent explained in this Policy. Additionally, we use third-party payment processing services. We have no control over such third parties. Thus, we make no guarantees about, and assume no responsibility for the information, services, or data/privacy practices of third parties, which may differ significantly from our practices described in this Policy. We encourage you to review the privacy practices of such third parties.
8. CHANGES TO THIS POLICY
Sora reserves the right to change this Policy from time to time, with or without notice to you. If you continue to use the Service, you consent to the new Policy. Sora will always have the latest Policy posted here on Sora’s website, available at https://soraschools.com/privacy-policy.
9. CALIFORNIA PRIVACY STATEMENT
If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email at firstname.lastname@example.org or write to us at 3343 Peachtree Rd. NE, Ste. 145-606, Atlanta, GA 30326. Indicate in your letter that you are a California resident making a “Shine the Light” inquiry.
We will retain your information as long as needed to provide you with our Service. We may also retain and use your information in order to comply with our legal obligations, resolve disputes, prevent abuse, enforce our agreements, or as otherwise described in this Policy.
10. PLEASE REACH OUT TO US WITH ANY QUESTIONS OR FEEDBACK
If you have any questions about this Policy or our Service, please feel free to contact us by email at email@example.com