Maintaining your privacy, and the confidentiality of the data you provide us is among our top concerns. To ensure the highest levels of privacy we actively maintain and enforce the following policies and procedures.
1. General. Because we are committed to protecting your privacy and the confidentiality of information that you provide to us through the Services, we actively enforce the following policies and procedures:
We comply with the U.S.-European Union Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data (“Personal Data”) from Users residing within the European Union; unless noted otherwise, we also voluntarily comply with the principles of the Safe Harbor Framework for the data of Users originating from locations outside of the European Union (“EU”). For purposes of this Policy, “Personal Data” is defined as data about an identified or identifiable individual that are within the scope of the EU’s Directive on Data Protection which became effective on October 25, 2008, received by a U.S. organization from the European Union, and recorded in any form. See Directive on Data Protection. Directory Information (“Directory Information”) is defined as information that is not generally considered to be harmful or an invasion of privacy if disclosed, would not be considered sensitive data, and can be used to contact an individual; examples of Directory Information include an individual’s name, phone number, and email address. User data (“User Data”) includes but is not limited to data regarding an individual such as a citizen, parent, student, staff, or other User that is not publicly available, is generally considered to be harmful or an invasion of privacy if disclosed, and is received from a country that does not belong to the EU; examples of User Data include (i) demographic information, (ii) grades, (iii) status of homework assignments, (iv) confidential communications between the individual and a school or government entity, (v) library account status, and (vi) cafeteria account status for an individual residing in the United States. For individuals residing outside of the EU, Parlant will respond to requests from individuals who inquire whether Parlant has shared their Directory Information with any government entity, school, or school district individuals. For individuals residing in the EU, Parlant does not share their Directory Information with any individual or entity unless the individual has given prior consent. Personal Data, User Data, and Directory Information are collectively referred herein as “Data.”
Parlant Technology, Inc. is not the authoritative source of confidential data, including but not limited to student, teacher, attendance, and grades information. Changes made to these data only affect the confidential data stored on Parlant servers and will have no effect on the actual source of information. Passwords and other sensitive data are stored on Parlant servers using a secure, one-way encryption algorithm. Once entered, this data cannot be retrieved by Parlant employees or anyone other than the owner of the password. All Data is stored on a Parlant system that is password-protected and can only be accessed by Parlant support staff who are bound by contractual agreement to keep the data confidential.
Parlant may aggregate Data to determine statistics; however, the aggregated Data does not identify specific Users. Additionally, certain non-personal information regarding Users are recorded by the standard operation of the Internet servers hosting the Services. This information is primarily used to enhance the online experience of Users. Parlant may disclose aggregated User statistics to describe the Services to third parties or for other lawful purposes.
3. Choice. For Personal Data and User Data, we give individuals the opportunity to choose whether their Personal Data or User Data will be disclosed to a third party or used for a purpose incompatible with the purpose for which it was originally collected or the purpose authorized subsequently by the individual.
4. Relevance. We will collect only as much Data as we need for specific, identified purposes, and we will not use Personal Data or User Data for other purposes without obtaining prior consent.
5. Retention. We will keep Data only as long as we need, for the purposes for which we collected it or as permitted by law. Parlant destroys or makes unavailable to any Users all Data that has become obsolete by replacement, updated data.
6. Accuracy. We will take appropriate steps to make sure the Data in our records is accurate.
7. Access. We will provide ways for you to access your Data, as required by law, so you can correct inaccuracies.
8. Security. We will take appropriate physical, technical, and organizational measures to protect your Data from loss, misuse, unauthorized access or disclosure, alteration, and destruction.
For Data that traverses the Internet to or from Parlant servers, Parlant uses the most current SSL (Secure Socket Layer) technology with 128-bit encryption for Data transferred over the public Internet. SSL provides a mechanism that encrypts all of the Data transferred between Parlant and an Internet web user. Data transferred to Parlant (such as student lists, etc.) can also be transferred in an encrypted format using FTP with SSL or SCP (secure copy).
Any Data accessed by the Services are stored in Application Service Provider (“ASP data”) centers located in the United States of America. Our data centers provide power-conditioned, climate-controlled server space. Three-tier physical security restricts physical access only to authorized Parlant personnel. Only those who have signed Parlant’s confidentiality agreement have access to the equipment and/or the network to which the equipment is connected. Employee and/or video surveillance is provided 24×7. The data center is connected to redundant OC-192 backbone via an OC-48 IP market uplink. The Utah data center is centrally located within 20 miles of the residences of all Parlant support personnel and escalated-support personnel, allowing rapid response to after-hours escalations that require physical access to the equipment.
All attempts to access Parlant Services, both from the public Internet and from Parlant, are logged. The Parlant servers are connected to the Internet behind a pair of dual, redundant, stateful firewall systems. These firewalls are monitored and maintained with the latest security updates. The Parlant server also has its own integrated firewall to act as a second layer of protection from outside access. The Parlant server cluster, including the Parlant database server(s), resides on a private network in an IP address space that is not routable on the public Internet. This private network is independent of Parlant’s internal network and is only accessible via logged, secure-access protocols. Parlant incorporates several intrusion-detection mechanisms so that if a security breach were to occur, Parlant’s support staff would immediately be notified.
System Redundancy and Monitoring
The Parlant server cluster (including network connectivity, firewalls, hubs and switches) is configured with redundant, fault-tolerant hardware and software. Telephone connections are divided among multiple, redundant servers to eliminate single points of failure. Manual and automated 24×7 system monitoring immediately alerts the Parlant support staff of any system outages and even potential system problems. Additional hardware, similarly configured, is located in separate locations within the United States to preclude any location-based failures. Secure, off-site backups are made daily.
10. International Transfer. If we transfer your personal information to another country, we will take appropriate measures to protect your privacy and the personal information we transfer.
11. Enforcement. We will regularly review how we are meeting these privacy promises, and we will provide an independent way to resolve complaints about our privacy practices.
To access your information, ask questions about our privacy practices, or issue a complaint, contact us at:
Parlant Technology, Inc.
180 N. University Avenue, Suite 500
Provo, Utah 84601
Phone: (801) 373-9669 extension 104
Parlant has further committed to refer unresolved privacy complaints under the Safe Harbor Principles to an independent dispute resolution mechanism, the EU Data Protection Authorities, which is administered by the U.S. Council for International Business. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Parlant, please visit http://ec.europa.eu/justice/
12. Summary of Safe Harbor Compliance. Schools and entities located in the European Union (EU) must indicate consent for the transfer and storage of personal information to sites that are located outside of the EU. Parlant complies with the Safe Harbor policies of collection, use, and distribution of data from the EU. Parlant complies with the U.S.-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Parlant has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view our certification page, please visit http://www.export.gov/safeharbor/.
13. Family Educational Rights and Privacy Act (FERPA). Parlant asserts its compliance with the Family Educational Rights and Privacy Act (FERPA) as set forth by the U.S. Department of Commerce with respect to data collection, retention, and use of student data for students residing in the United States. Parlant complies with FERPA by strict adherence to its policy of not sharing student education records with any third party except during emergency situations authorized under FERPA. Parlant has designed and continues to update its Services and software as needed so that Parlant complies with FERPA standards.
14. Children’s Online Privacy Protection Act (COPPA). Parlant complies with the Children’s Online Privacy Protection Act (COPPA), as set forth by the U.S. Federal Trade Commission, with respect to any personal information received from children under the age of 13 residing in the United States. Some of the apps for mobile devices provided by Parlant have a tipline feature which allows users to submits tips, photographs, their name, their email address, and their phone, and their geolocation. Parlant presumes that schools and other organizations which service children under the age of 13 will obtain the consent of parents of children under the age of 13 before children under the age of 13 use Parlant’s apps to provide personal information. If a child under the age of 13 submits personal information, the information will not be used for commercial purposes and will only be provided to the organization whom the child requests that information be sent to. Parlant may also collect persistent identifiers for the performance of the system; the persistent identifiers may contain information such as an internal account ID, an internal ID of school, a country ID, a parent organization ID, a login ID, the first name and last name of person using the service, the role of the user (ex: student, teacher); the time zone, the last time the user’s grades were updated, and the last time the user logged in.
Parlant complies with the Children Online Privacy Protection Act. The license to use the ParentLink service excludes minors under the age of 13.
Your sole remedy for dissatisfaction with Parlant services, content, or other information is to report any issues to Parlant or stop using the Services. The most current version of the Agreement can be found on our website and supersedes all previous versions of the Agreement. You, the User, acknowledge and agree that it is your responsibility to review the Agreement periodically and be aware of any modifications.
2. User Conduct. Parlant only allows authorized users to utilize the Services. Authorized users are defined by joint agreement between Parlant and its customers. The Services allow Users to send communications for educational-related purposes, as defined by Parlant and its customers. Generally, this does not include messages which may be defined as business-oriented, threatening, malicious, pornographic/obscene, overtly intrusive, abusive, promoting illegal activity, or otherwise unseemly. Unacceptable use may result in termination of the User’s access to the Services.
You agree that you will not use the Services for any illegal purpose. In addition, you agree that:
(i) you will not harvest, collect, or otherwise use contact information made available on any Parlant product for the purpose of sending unsolicited improper communications, including without limitation, unsolicited bulk email (collectively, “spam”) and that you will not use any Parlant communications facility to deliver or attempt to deliver spam;
(ii) you will not attempt to gain unauthorized access to the Services or the servers and network associated with the Services;
(iii) you will not circumvent or attempt to circumvent any security or access control technology implemented on the Services, or the servers and network associated with the Services;
(iv) you will not use the Services in any manner designed to degrade the performance or functioning of the Services, including, without limitation, launching Denial-of-Service (“DoS”) attacks against the Services.
3. Copyright. Parlant claims a copyright in its works presented at this Web site and through its Services. Parlant authorizes you to view, copy, download and print Parlant documents on this Web site and presented through its Services, subject to the following conditions:
The documents may be used solely for personal, noncommercial and informational purposes. The documents may be posted to a private intranet that is accessible to authorized Users so long as the documents are still used solely for personal, noncommercial and informational purposes.
Commercial Use of Parlant Product Materials and Screen Shots. Reproduction, copying or redistribution of materials on the Parlant web site or presented through the Services for commercial purposes is prohibited without the express written permission of Parlant. To obtain permission to copy portions of this site, please send an email to our Legal Department at email@example.com and provide the following information in the body of the email:
(i) the Parlant content you wish to use
(ii) where and how it will be used (for example, a trade publication)
(iii) where and how copies will be distributed and to what audience
(iv) how many copies will be produced and distributed
(v) when you intend to publish
(vi) what other non-Parlant materials will be associated with the Parlant content
(vii) your name, title, company, address, email address and phone number
We will evaluate your request and advise you as soon as possible. Parlant reserves the right to refuse permission to copy, distribute, broadcast or publish any of its copyrighted material, including text and images on our Web site.
4. No Warranties and Limitation of Liability. Information provided on and through the Services is provided “as is” without warranty of any kind, either express or implied, including without limitation, warranties of (i) merchantability, (ii) fitness for a particular purpose, or (iii) non-infringement. Parlant periodically adds changes, improves or updates the information and documents for the Services without notice. Parlant assumes no liability or responsibility for any errors or omissions in the content of the Services. Your use of the Services is at your own risk. Under no circumstances and under no legal theory shall Parlant or any other party involved in creating, producing or delivering the contents of the Services be liable to you or any other person for any indirect, special, incidental or consequential damages of any character arising from your access to, or use of, the Services. Information that is presented through the Services to Users is the property of the respective organization associated with the URL through which the information is accessed. Parlant is not liable for the accuracy of this information, for the content of messages originating from or contained within the Services, or for direct or indirect damages arising out of the use of the Services.
5. Links to Third Party Sites. If you choose to use any links on any Services to websites not maintained by Parlant, you will leave Parlant website. The linked sites are not under the control of Parlant, and Parlant is not responsible for the contents of any linked site or any link contained on a linked site. Parlant provides these links to you only as a convenience and the inclusion of any link does not imply recommendation, approval or endorsement by Parlant of the site.
6. Permitted Use of Parlant Trademarks. Parlant trademarks identify Parlant products and services and let the public know the source of those products and services. You may make fair use of our trademarks in advertising and promotional materials, and in referencing our products and services (for example, in a magazine article) without our permission, provided you follow standard trademark usage practices and provide proper attribution. Other uses require our written permission. If you are in doubt as to whether you need our permission for a specific type of use, please ask us.
You may not use Parlant logos or “design” trademarks or trademarks (as opposed to our trademarks consisting solely of words) under any circumstances without our prior written authorization.
In addition, you may not use Parlant trademarks, whether design or word marks, in the following ways:
(i) in a non-Parlant name or publication title;
(ii) in, as, or as part of, your own service or trademarks;
(iii) to identify products or services that do not belong to Parlant;
(iv) in a manner likely to cause confusion;
(v) in a manner that implies inaccurately that we sponsor or endorse, or are otherwise connected with, your own activities, products and services;
(vi) as hidden or embedded text in web pages in an effort to cause a search of Parlant marks to result in a hit on a page not maintained by Parlant in a manner disparaging of Parlant.
7. Jurisdiction & Choice of Law. This Agreement and your use of the Services shall be governed by the laws of Utah, without regard to its conflict of laws provisions.
8. Severability. If any provision of this Agreement is found to be void or unenforceable, such provision shall be severed and all other provisions shall remain in force.
9. E-Mail Opt-Out. It is our intention to only send e-mails that will be useful to you and that you want to receive. Every time you receive an e-mail you will be provided the choice to opt-out of future e-mails by following the instructions provided in the e-mail, or by contacting the sender. Parlant does NOT sell e-mail addresses to third parties and only shares your email addresses and contact information with governmental entities, schools, or schools districts for the narrow purpose of contacting you during an emergency if you are a non-EU User and reside or work within the boundaries of an affiliated governmental entity or affiliated school district.
10. Trademarks. ParentLink®, Parlant™, Attendance Discovery™, Teacher Reach™ and the logo (“circle with three arrows logo”) are trademarks of Parlant Technology, Inc.
11. Pending Patents. Technology contained within the Teach Reach solution and the Attendance Discovery solution are the subjects of one or more pending patent applications. Technology contained within the Teach Reach solution and the Attendance Discovery solution are the subjects of one or more pending patent applications including, but not limited to, Patent US 8832301 B2.
© 2013 Parlant Technology, Inc.