Privacy Policy

This Privacy Policy applies to information you provide to ExQ, LLC (“we” or “us”) via our Web site located at myexq.com (the “Site”) and through the “ExQ: for School” service available from the Site (“ExQ Service”). Otherwise this Privacy Policy does not govern other Web sites or any other data collection, disclosure or usage practices, off-line or otherwise.

Effective date: August 28, 2018

A note to parents and schools

The ExQ Service is intended as a school-based service. The Children’s Online Privacy Protection Act of 1998 (COPPA) allows schools and school administrators to act in the place of parents to provide consent to the collection of personal information from children. Schools should always notify parents about these activities. Schools and school districts must comply with the Family Educational Rights and Privacy Act (FERPA) when providing student information to us from students’ records. FERPA gives parents certain rights with respect to a school’s use and disclosure of their children’s education records. We work with schools in order to provide services in a manner that is consistent with FERPA. For more information on parental rights with respect to a child’s educational record under FERPA, please visit the FERPA site. In all circumstances, children should always check with their parents or guardians before entering information on any website, and we encourage families to discuss their household guidelines regarding the online sharing of personal information.

Children under the age of 13 should not register for their own account with the ExQ Service. Setup of accounts for the ExQ Service for children under the age of 13 is coordinated with a child’s teachers and parent. If you are a parent, please coordinate with your child’s teacher to set up an account for your child.

If you would like to review the information we have collected from your child, or if you would like to ask us to make no further use of or delete the information we have collected from your child, contact us as described in the “Contact Us” section below. In your request, please include your name and email and your child’s name, and specify the question or concern or the action you would like us to take. For your child’s protection, we may need to verify your identity before implementing your request. If you ask us to remove your child’s information, your child will not be able to use the ExQ Service any longer.

Information we collect

We describe below the type of information we receive through our ExQ Service, including information which may be automatically collected via the Site or the ExQ Service.

Contact Information of parents

We receive from the schools the contact information from parents of student participants.

Participant information

We receive the following information regarding students and teachers who participate in the ExQ service:

  • Name
  • School Email
  • DOB
  • Age
  • Gender
  • Grade
  • Username
  • Password
  • Parent Name
  • Parent Email

This information may be provided by your school to us, or you may provide it to us when you sign up with the ExQ Service (myexq.com/sign_up) or if you subscribe to our newsletter or other communications.

Participant Content

We collect content voluntarily provided by students, faculty and administrator users via ExQ Service. Such content includes:

  • users’ videos, information, answers and submissions provided in connection with the use of the ExQ Service
  • responses to assessments, exercises, prompts and questions

This content is shared with administrator and faculty users of the school.

If we would like to use your content (for example, a video) as part of our marketing, we will contact you separately and obtain your express consent. In the case of children, we will contact the parents either directly or through the school for such permission.

Passive and automatically collected information

Tools employed on our Site and through our ExQ Service may gather your IP address or similar computer or device information regarding when you access the Site or use the ExQ Service.

A cookie is a small file placed on your computer that stores information. Overall, cookies help us provide you with a better experience. Cookies help us verify your browser and maintain your login session and we may also use cookies of third party partners, such as Google.  You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the Site or ExQ Service. If you opt out of using cookies, we may employ a cookie only to help us remember this preference. 

If you would like further information on the cookies we employ on our Site or in the ExQ Service, please contact us as provided in the “Contact us” section below. The following are some online resources that provide some helpful information on how to change your cookie preferences:

http://www.aboutads.info/choices/ (if you are based in the US)
http://www.allaboutcookies.org

Google Analytics is a web analytics service provided by Google. Google Analytics may use cookies or other means to help us analyze how users use the ExQ Service and Site. The information generated by the cookies about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. You can use a browser plugin to opt out of all Google Analytics tracking software. More information on our use of Google is located below. Find more information about Google’s privacy practices here: https://policies.google.com/privacy.

By using the ExQ Service and Site, you acknowledge and agree to our receiving the passive and automatically collected information and using these tracking activities, subject to the terms of this Privacy Policy.

How we use the information we collect

In general, we use the personal information collected from participants and other users of the ExQ Service only to support the educational purposes authorized by the schools we perform services for, and for no other commercial purpose. We do not use (or permit others to use) personal information to engage in targeted advertising, nor do we use (or permit others to use) personal information to create a profile about students other than in connection with providing the ExQ Service and for authorized educational purposes.

Contact information of parents

The contact information we receive from parents is used to communicate with parents regarding the ExQ Service, including the progress and performance of their students. We do not sell this contact information to third parties.  

Participant information

The personal information of users that we collect is used

  • to create and maintain user accounts and to enable users to use the ExQ Service and Site
  • to understand, track and evaluate the participant’s performance and progress both internally and with the appropriate school faculty and staff
  • to respond to participants, including to create Evaluation Data (see below)
  • to interact with participants regarding the ExQ Service and Site, including requests for services and information
  • to develop, analyze, improve, support and manage activities and operations of the ExQ Service and Site
  • to prevent issues which may be harmful to users or the ExQ Service or Site
  • for any other purposes disclosed at the time we collect user information or pursuant to specific user consent
  • for the “Other uses” described below

In addition, if you have provided contact information as part of subscribing to our newsletter or other communications on our Site, then we will use your contact information to provide those communications to you. You may elect to stop receiving these newsletters or other communications at any time by unsubscribing via the methods available in those communications.

Participant content

We use the information as part of the ExQ Service to understand, track and evaluate the participant’s performance and progress both internally and with the appropriate school faculty and staff and to respond to participant regarding those including through the Evaluation Data. The content provided by teachers and students will be assessed and analyzed for research purposes using factors such as age, gender, and grade.

Evaluation data

The scores and reports that result from the questionnaires, evaluations and games a user engages with as part of the ExQ Service (“Evaluation Data”) are able to be viewed and accessed by the student participants and their teachers and staff and by teacher participants and their administrators. Users should not access the Evaluation Data of others without proper permission.  ExQ may use the Evaluation Data for any purpose, including to improve the ExQ Service and prepare statistical analyses, reports, and benchmarking statistics for ExQ’s own use and for marketing purposes; however, the information will be deidentified and anonymized prior to any disclosure. We will not use any Evaluation Data for behaviorally targeted advertising or to create profiles of users for non-educational purposes.

Passive and automatically collected information

We do not use persistent unique identifiers to amass a profile about a student except in furtherance of school purposes. We do use IP addresses and tracking and other information we collect from cookies and other means in the following ways:

  • to provide the ExQ Service
  • to authenticate users and protect the security and integrity of the ExQ Service and Site
  • to help tailor our services and content
  • to personalize user experience (for example, to recognize users by name when using the ExQ Services) and setting
  • to track communications to and from the ExQ Service
  • to understand, analyze, improve, maintain and administer the ExQ Service and Site
  • for the “Other uses” described below

Google uses Google Analytics data to provide the Google Analytics measurement service to us. Identifiers such as cookies and app instance IDs are used to measure user interactions with a customer’s sites and/or apps, while IP addresses are used to provide and protect the security of the service, and to determine where in the world users come from.  We use Google Analytics to track number of visitors and page hits, visitor location and ISP details. We utilize Google Analytics’s IP anonymization option.

Deidentified data

We may aggregate and de-identify personal information and metadata regarding participant content for our own purposes, including to improve and analyze the ExQ Service and Site, to provide information to others regarding the effectiveness of the ExQ service and Site and in order for us to develop new products and services.  However, we will not use any de-identified data for behaviorally targeted advertising or to create profiles of users for non-educational purposes.

Other uses

In addition to the uses described above in this Privacy Policy, we may use any information, including your personal information, content, passive and automatically collected information, and Evaluation Data, to the extent reasonably necessary for any one or more of the following purposes:

  • maintaining or analyzing the functioning of the ExQ Service and Site,
  • performing network communications,
  • authenticating users of the site or personalizing content,
  • protecting the security or integrity of the users or the ExQ Service and Site,
  • responding to judicial process, law enforcement or for legal or regulatory compliance

How we may disclose your information

Below we describe how we may disclose the information we collect from our users.

Disclosures for school purposes

We disclose personal information, content, Evaluation Data of student participants to their teachers and school administrators as part of the services we provide to schools. We disclose personal information, content, Evaluation Data of teacher participants to school administrators as part of the services we provide to schools.

Disclosures to third parties

We do not sell personally identifiable information collected via the Site or ExQ Service to third party marketers.

Third parties may operate or host the Site or the computers that operate the Site and ExQ Service, store or process data for us, and provide services part of or related to the ExQ Service. We have agreements with these third parties that contain protections regarding use of your information.

Our use of Google Analytics is described above. We currently use Amazon Web Services to host our Site and the ExQ Service. We also use a third party online application, CameraTag, to record and process the videos you make as part of the ExQ Service.  CameraTag is provided by Danzig Media, LLC. CameraTag stores a participant’s video files temporarily. We delete the participant’s video from CameraTag once it is moved to our Amazon Web Services server; CameraTag regains a backup copy of the video for 30 days after we have requested it be deleted. CameraTag’s privacy policy can be found here: https://cameratag.com/privacy.

Other disclosures

We may also disclose your information for the following reasons:

  • to ensure legal or regulatory compliance or protect against liability;
  • to respond to or participate in judicial process;
  • to protect the security or integrity of the Site or ExQ Service;
  • to protect the safety of users or others or security of the Site or ExQ Service; and
  • in the case of students, for an educational, public health, or employment purpose requested by the student's parent or guardian, provided that the information is not used or further disclosed for any purpose.

Choice

Our intent is only to use personal information in compliance with applicable law, and that includes giving you choice on how and if your personal information is used. Some uses of your information are necessary for the ExQ Service we provide through the Site or for the reason you provided us with the information, and if you don’t want your information used in certain ways, it may prevent you from using the ExQ Service.

Security

We strive to ensure the security of your personal information. We maintain, or use third parties to maintain, physical, electronic and managerial procedures designed to safeguard the information we collect through the ExQ Service and Site. Some of the measures we take include the following: using industry standard encryption and authentication tools; following industry standard security guidelines regarding detecting and remediating vulnerabilities; using methods to encrypt or obscure passwords while in storage; and employing SSL, antivirus, secure routers and firewalls. You should be aware that no information can be absolutely secure, and we can’t guarantee the security of any information that is the subject of this Privacy Policy or any information that we store or process.

Updating and removing your information

We need complete and updated information in order to properly provide the ExQ Service. We will let you update the personal information that you have provided to us through the methods available on through the ExQ Service. You may also contact us to update or remove your information via the email address in the “Contact Us” section below. We will also take steps to make sure that any updates or removal requests that you provide are processed in a timely and complete manner. If you request that we remove your personal information, that may impact your ability to access or receive our services. We will take reasonable steps to verify a user’s (or the user’s parent’s) identity before granting access, changes or deletion of that user’s personal information.

Location

The ExQ Service and Site is currently designed for and targeted to persons in the United States and is governed by and operated in accordance with the laws of the United States. If users outside the United States access the ExQ Service and Site, we can’t guarantee that they are operated in accordance with the laws of other nations. Information that we collect from you may be transferred to, and stored at, a destination outside the United States, European Economic Area (“EEA”) or the country in which you are located. The personnel who use your information as part of the practices described in this Privacy Policy may also be located outside the United States, EEA or the country in which you are located.  By submitting your personal information, you agree to this transfer, storing or processing.

Retention

We keep your personal information only as long as we need it for the purposes described in this Privacy Policy. In general, if we have no other legitimate reason to continue using your personal information, we will delete it.

Once your subscription to the ExQ Service is over, you will have had a chance to download the reports containing your Evaluation Data. During your subscription to the ExQ Service, you may also request the videos you make as part of the ExQ Service. However, after your subscription we may delete any or all of the data we have regarding your use of the ExQ Service. For example, the videos and recordings you may have made as part of the ExQ Service will usually be deleted by us 45 days after the end of your use of the ExQ Service.

Third party websites and services

With respect to any websites or services that may be linked to in the ExQ Service or Site, these or other websites are governed by their own privacy policies or information collection practices, and we aren’t responsible for those policies or practices. We encourage you to review the privacy policies and information collection practices of those websites.

Updates

As noted above, we may periodically update this Privacy Policy. For example, we may update this policy in order to describe how new Web features may affect our use of your information and to let you know of new controls and features that we may provide you. We will not apply changes to this policy retroactively to information we have previously collected unless it offers you greater protection or choice. If changes to this Privacy Policy do lessen the protections we provide or allow us broader use of your personal information we will notify you using the contact information we have and the change will not take effect until at least 30 days after we notify you.

Contact us

All inquiries regarding this Privacy Policy, your rights under it, or use, removal or updating your information, should be directed to info@myexq.com.