FLIPGRID PRIVACY POLICY <p>
<b>Last Updated: August 5, 2020</b>
</p>
<p>Your privacy and that of your students is important to us: </p>
<ul>
<li>
<p>We do <b>not</b> use personal information to market or advertise to you or students, nor do we permit third parties to do so.
Our Flipgrid website and apps do not show advertising.
</p>
</li>
<li>
<p>We do <b>not</b> sell user personal information.
</p>
</li>
</ul>
<p>Flipgrid does use your personal information for certain stated purposes, such as providing and improving the service and communicating with Discussion Owners (but not Students) about new Flipgrid features and events.
Please read the Privacy Policy below, as it describes what information we collect from you, how we use that information, and the legal bases we have to process your information.
</p>
<p>This Privacy Policy governs how Flipgrid, Inc., a Microsoft subsidiary, ("Flipgrid," "we," "our," or "us") uses and shares personal information collected by our website at Flipgrid.com, the Flipgrid mobile app, and any associated services (the “Service”).
</p>
<p>"You" may be a: </p>
<ul>
<li>
<p>"Discussion Owner" (i.e., an adult over the age of 18, a teacher or other School representative that subscribes to the Service with the administrative right to create, invite, manage, moderate or delete a Flipgrid video that may be set up using the Service ).
</p>
</li>
<li>
<p>a "School" (i.e., an educational institution, organization or other educational business for which one or more Discussion Owners offers the Service to Students).
</p>
</li>
</ul>
<ul>
<li>
<p>a "Student" (i.e., an individual who was invited to use the Service at the invitation of a Discussion Owner).
or </p>
</li>
<li>
<p>a "User" (i.e., any individual user of the Service, including a Discussion Owner or a Student).
</p>
</li>
</ul>
<p>
<b>1.
Information Flipgrid Collects</b>
</p>
<p>Flipgrid may collect personal information from Users as described below.
</p>
<p>
<b>1.1Discussion Owner Personal Information (Collected from the Discussion Owner)</b>
</p>
<p>When a Discussion Owner creates an account on the Service, we ask you for certain information, such a Discussion Owner’s first name, last name, email address, password, instruction type, and country.
If you are a teacher or a School, we will also collect your School email address and School name to set up an account.
</p>
<p>When a Discussion Owner posts content (text, images, photographs, videos, messages, comments, or any other kind of content) on the Service, the information contained in the posting, including first name, last name, email address, any audio and image included within any video, will be stored in our Service for purposes of providing the Service.
</p>
<p>When a Discussion Owner logs into an existing account through their Microsoft or Google account, we may collect first and last name, email address and other information specific to that third party account to authenticate the Discussion Owner.
</p>
<p>When a Discussion Owner provides feedback to a Student, such as replying to a video book report, assessing foreign language skills, encouraging group discussion, or prompting the scientific method, we store the feedback in the Service for purposes of providing the Service.
</p>
<p>If a Discussion Owner provides us feedback or contacts us via email, we will collect the Discussion Owner's name and email address, as well as any other content included in the email for purposes of replying to the Discussion Owner and improving the Service.
</p>
<p>
<b>1.2 Student Personal Information</b>
</p>
<p>Discussion Owners provide consent for the collection of Student personal information as discussed in Section 6 of this Privacy Policy, below.
When a Student posts content (text, images, photographs, videos, messages, comments, links, or any other kind of content) using the Service, the information contained in the posting, including first name, last name, email address, and any audio and image included within any video will be stored in our Service as per the consent provided by the Discussion Owner.
Depending on the Discussion Owner’s privacy settings for the Group or Topic, other Users may view and share Student content.
</p>
<p>If a Student provides us with feedback or contacts us via email, we will collect the Student's name and email address, as well as any other content included in the email, for purposes of replying to the Student and improving the Service.
</p>
<p>
<b>1.3 Automatically Collected Information</b>
</p>
<p>When a User uses the Service, some information may be automatically collected to help us understand how the Service is being used and how to improve the Service.
For example, device type, the device identifier (UDID), the Open Device Identification Number (ODIN), date/time stamps for each visit, browser type, operating system, Internet Protocol (IP) address, Internet service provider (ISP), referring/exit pages, clickstream data, and domain name are all collected for purposes of administering, tracking usage of, and improving the Service.
We may store this information in log files.
</p>
<p>
<b>Cookies and Similar Technologies</b>
</p>
<p>Flipgrid uses cookies (small text files placed on your device) and similar technologies to provide the Service, to help collect data, and to share information about Flipgrid and its features and functionalities to Discussion Owners.
These cookies help us provide the Service.
For example, they allow you to log in to secure areas of the Service and help the content of the pages load quickly.
We use cookies to provide Users with a more personal, useful, and interactive experience with our Service.
We also use web beacons to help deliver cookies and gather usage and performance data.
The Service may include web beacons and cookies from third-party service providers.
</p>
<p>In addition to the cookies we set, third parties can also set cookies when you visit our sites.
For example: </p>
<ul>
<li>
<p>Companies we hire to provide services on our behalf, such as site analytics, may place cookies when you visit our sites.
</p>
</li>
<li>
<p>Companies that deliver content, such as videos a Discussion Owner links to or embed, place cookies on their own.
These companies use the data they process in accordance with their privacy policies, which may enable these companies to collect and combine information about your activities across websites, apps, or online services.
</p>
</li>
</ul>
<p>Each User has a variety of tools to control cookies, web beacons, and similar technologies, including browser controls to block and delete cookies and controls from some third-party analytics service providers to opt out of data collection through web beacons and similar technologies.
User browser settings and other choices may impact the functionality of the Service.
</p>
<p>
<b>2.
Use of Personal Information</b>
</p>
<p>We store and process User personal information in the United States, and we use this information as follows: </p>
<ul>
<li>
<p>To provide the Service, including updating, securing, troubleshooting, and providing support.
</p>
</li>
<li>
<p>To improve and develop the Service.
</p>
</li>
</ul>
<ul>
<li>
<p>To respond to User comments and questions and provide customer service.
</p>
</li>
<li>
<p>To communicate with Discussion Owners about upcoming Microsoft education or Flipgrid events, new Flipgrid features and other news.
</p>
</li>
<li>
<p>To send the User information including confirmations, technical notices, updates, security alerts, and support and administrative messages.
</p>
</li>
<li>
<p>To identify specific Users in our system.
</p>
</li>
<li>
<p>To facilitate the creation and management of accounts on our Service.
</p>
</li>
</ul>
<ul>
<li>
<p>To process and deliver orders.
</p>
</li>
<li>
<p>To comply with applicable laws, including website accessibility laws that may require transcription of audio or other methods to make User content available on the Service.
</p>
</li>
<li>
<p>For other purposes with your permission.
</p>
</li>
</ul>
<p>Flipgrid does <b>not</b> use your personal information to market or advertise to you (regardless of whether you are a Student or other User).
Flipgrid also does <b>not</b> use your personal information to track and target advertisements on third party websites or services.
</p>
<p>
<b>3.
Information We Share</b>
</p>
<p>Flipgrid does <b>not</b> sell User personal information.
We share personal information we collect on Users (including Students and Discussion Owners) when Users create accounts, request support, record videos, share their experiences with us, or otherwise use the Service.
We may also share User personal information with vendors, consultants, and other third party service providers who need access to such information to carry out work on our behalf and at our direction.
For example, we rely on data center operators and communications vendors to operate our Service or send you notifications.
</p>
<p>We may also share User personal information for legal, protection, and safety purposes.
For example, </p>
<ul>
<li>
<p>We may share information to comply with applicable laws.
</p>
</li>
<li>
<p>We may share information to respond to lawful requests and legal processes.
</p>
</li>
<li>
<p>We may share information in an emergency, such as protecting the safety of our employees and agents, our Users, or any person.
</p>
</li>
</ul>
<ul>
<li>
<p>We may share information to protect the rights and property of Flipgrid, our agents, employees, customers, and others, including by enforcing our agreements, policies, and terms of use.
</p>
</li>
<li>
<p>We may disclose or transfer your personal information in connection with the sale, merger, bankruptcy, sale of assets or reorganization, in whole or in part, of our company.
</p>
</li>
</ul>
<p>Flipgrid reserves the right to share Users’ personal information to respond to duly authorized information requests of governmental authorities or where required by law.
Flipgrid reserves the right to use or disclose personal information provided to Flipgrid in response to a lawful request by public authorities, including to meet national security or law enforcement requirements, or if Flipgrid reasonably believes that use or disclosure is necessary to protect Flipgrid’s rights and/or to comply with a judicial proceeding, court order, or legal process.
In exceptionally rare circumstances where national, state, or company security is at issue, Flipgrid reserves the right to share our entire database of visitors and clients with appropriate government authorities.
If we are going to share User personal information, we strive to provide the User with advance notice by e-mail unless prohibited by law from doing so.
</p>
<p>
<b>4.
Information Users Share</b>
</p>
<p>Each Group and Topic and the content submitted, will be displayed in the Group or Topic, respectively and will be visible to anyone who joins the Group or Topic as administered and permitted by the Discussion Owner, subject to the Discussion Owner’s ability to deactivate or moderate submissions.
The Discussion Owner, and not Flipgrid, sets the Group or Topic privacy settings.
</p>
<p>Discussion Owners choose whether Users are permitted to link to external sites.
External sites are governed by their respective privacy policies.
Flipgrid leverages Youtube.com's and Vimeo.com's enhanced privacy modes to mark links as 'do not track.
Discussion Owners may also record Shorts videos and may share the videos with others.
</p>
<p>We may publish comments or feedback from a User about Flipgrid only if we obtain that User’s consent.
</p>
<p>
<b>5.
Information Choices and Changes</b>
</p>
<p>Users may opt out of providing personal information to the Service at any time by uninstalling the application.
Users may also opt out of providing personal information by emailing <b>support@Flipgrid.com</b> to have their account removed or by asking their Discussion Owner to remove their content.
Flipgrid will stop collecting the User’s personal information in these cases, but may still retain the User’s personal information as outlined in the “Data Retention” (Section 8) of this Policy (below).
</p>
<p>Our communication email regarding events, news and other such topics explain how to opt out of receiving such emails.
If a User opts out, we may still send them operational emails that pertain to the User's account and notifications regarding our services.
</p>
<p>Users may send requests about their personal information to our contact information in Section 14 below, including to change contact choices, opt out of our sharing with others, and review, update, correct, or delete personal information.
Once the User has been authenticated, we will use commercially reasonable efforts to honor these requests.
We may retain an archived copy of User records as required by law.
Such opt outs may result in disruption or cancellation of the Service or impairment of certain Service functionality.
</p>
<p>Users may also contact the Discussion Owner and request that the video be removed.
If the Discussion Owner is not able to remove the video, Users can contact us at <b>support@Flipgrid.com</b> and request that such videos be removed.
However, we will only be able to remove the video if (a) the User provided their email address when posting the video and (b) the User sends the email request to us using that same email address.
Otherwise, we may not be able to remove a posted video.
Deletion of a video removes it from the Group or Topic.
</p>
<p>Discussion Owners have certain options with respect to the privacy settings of their Groups and Topics.
For example, Discussion Owners choose how Users gain access to their Groups and Topic and whether those Groups and Topics are moderated.
Parents and Students should send all requests regarding these privacy settings directly to the Discussion Owner.
</p>
<p>
<b>6.
COPPA AND STUDENTS</b>
</p>
<p>
<b>6.1 Notice to Parents and Schools</b>
</p>
<p>Under the United States Children’s Online Privacy Protection Act ("COPPA"), verifiable parental consent is needed to collect, use, or disclose personal information (e.g., full name and email address) from each User under 13 years old.
In accordance with COPPA, a teacher or Discussion Owner may act as the agent of the parent or legal guardian of a Student and provide consent on behalf of the parent for Flipgrid’s collection, use, and disclosure of the Student’s personal information.
By enrolling a Student under 13 to use the Service, the School provides such consent to us and agrees that the Students’ activities while on the Service are subject to our Terms.
Please see <b>Flipgrid’s Teacher Toolkit</b> (https://static.Flipgrid.com/docs/Flipgrid_dos_donts.pdf) and <b>Parent Consent Form</b> (http://static.Flipgrid.com/docs/Flipgrid_consent_form.pdf) for guidelines on how teachers and Schools should provide consent on behalf of parents.
</p>
<p>This Privacy Policy does not govern any School's collection, use, or disclosure of a Student User’s personal information through the Service, and we are not responsible for any such collection, use, or disclosure.
Parents should contact the teacher or Discussion Owner directly to understand the Discussion Owner’s privacy practices or to request to access, change or delete information collected by the Discussion Owner in connection with the Service that cannot otherwise be accessed, changed or deleted as described in this Privacy Policy.
</p>
<p>As required under COPPA, parents can make certain choices regarding how their child’s information is used.
(For more information, see “Parent’s Choices Regarding Information on Students Under 13,” in Section 6.2 below).
Parents should submit these requests to the teacher or Discussion Owners, and the teacher or Discussion Owners, as the parent’s agent, must pass those requests to us by emailing <b>support@Flipgrid.com</b>.
</p>
<p>
<b>6.2 Parent’s Choices Regarding Information on Students Under 13</b>
</p>
<p>Under COPPA, parents of Students under 13 have certain rights with respect to our collection, use, retention, and disclosure of their Student’s information.
This includes the right to review, update, or delete Student information, as well as prohibit our sharing Student information with third parties.
Parents can exercise these rights by contacting the Student’s Discussion Owner, and the Discussion Owner should submit these requests, on the parent’s behalf, to Flipgrid by emailing <b>support@Flipgrid.com</b>.
Notwithstanding any such requests, we may continue to share the Student information for non-Service purposes as described in Section 3, “Information We Share.” </p>
<p>A parent should request deletion of the Student’s information (such as videos submitted) through the Discussion Owner.
Upon receiving such requests, the Discussion Owner can request deletion of the Student’s information by emailing <b>support@Flipgrid.com</b>.
This will delete the Student information from our live databases.
We will not have any liability whatsoever for any termination of the account or related deletion of the Student information.
When we delete personal information, it will be deleted from our active databases but may remain in our archives for up to 30 days.
</p>
<p>Schools and Discussion Owners should always obtain parental consent for a Student under 13 to use the Service.
Please see <b>Flipgrid’s Teacher Toolkit</b> (https://static.Flipgrid.com/docs/Flipgrid_dos_donts.pdf) and <b>Parent Consent Form</b> (http://static.Flipgrid.com/docs/Flipgrid_consent_form.pdf) for tips on how to obtain proper consent from parents.
</p>
<p>
<b>7.
INFORMATION SECURITY</b>
</p>
<p>We use security technologies and procedures to help protect your personal information from loss, misuse, and unauthorized access, use, disclosure, alteration, and destruction.
Our security procedures and practices are consistent with industry standards applicable to our collection and use of personal information.
In the event of an unauthorized release, disclosure, or acquisition of User information, Flipgrid will notify affected individuals (either directly or through Discussion Owners), as required by applicable law.
While we use reasonable efforts to protect your personal information, we cannot guarantee its absolute security.
</p>
<p>
<b>8.
Data Retention</b>
</p>
<p>We store the information we collect for as long as you have an Account, or for up to 30 days in our archives when you ask for data to be deleted (as set forth in Section 6, above).
Additionally, we retain User information to resolve disputes, enforce our policies, and to comply with the law.
</p>
<p>
<b>9.
How to View, Correct, or Update Personal Information</b>
</p>
<p>Discussion Owners can update their information by logging into their accounts and visiting the Account Settings tab on the User profile.
Discussion Owners and Students may also update their information through my.flipgrid.com.
Parents and Students can correct, edit, or update Student information by submitting a request to the Discussion Owner.
If that is not effective, the Student can contact us directly at <b>support@Flipgrid.com</b>.
</p>
<p>Residents of the European Economic Area may have additional rights as set forth in Section 11, below.
</p>
<p>
<b>10.
Deleting Account or Content</b>
</p>
<p>A Discussion Owner may delete his or her own account or content, as well as any content submitted to Flipgrid under that(including videos submitted by Students), by emailing your requests to <b>support@Flipgrid.com</b>.
Discussion Owners and Students may also delete their own account or content through my.flipgrid.com.
Deleted accounts or account content may be retained by us for up to 30 days to provide customer support and prevent accidental deletion.
</p>
<p>
<b>11.
Personal Information Transferred from the European Economic Area or Switzerland to the United States</b>
</p>
<p>The Service is hosted and operated in the United States and is subject to United States law.
User personal information is hosted on United States servers.
Flipgrid is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
</p>
<p>Flipgrid adheres to the EU-U.S.
Privacy Shield Framework and Swiss-U.S.
Privacy Shield Framework as set forth by the U.S.
Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States (for more information, see the <b>list</b> of Microsoft U.S.
entities or subsidiaries adhering to the Privacy Shield Principles).
Microsoft Corporation has certified to the Department of Commerce that Flipgrid is a U.S.
subsidiary controlled by Microsoft that adheres to the Privacy Shield Principles.
If third-party agents process personal data on our behalf in a manner inconsistent with the principles of either Privacy Shield framework, we remain liable unless we prove we are not responsible for the event giving rise to the damage.
</p>
<p>If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
To learn more about the Privacy Shield program, and to view our certification, visit the <b>Privacy Shield website</b>.
</p>
<p>If you have a question or complaint related to participation by Flipgrid in the EU-U.S.
or Swiss-U.S.
Privacy Shield, we encourage you to contact us at <b>support@Flipgrid.com</b>.
For any complaints related to the Privacy Shield frameworks that Microsoft cannot resolve directly, we have chosen to cooperate with the relevant EU Data Protection Authority, or a panel established by the European data protection authorities, for resolving disputes with EU individuals, and with the Swiss Federal Data Protection and Information Commissioner (FDPIC) for resolving disputes with Swiss individuals.
Please contact us if you would like us to direct you to your data protection authority contacts.
As further explained in the Privacy Shield Principles, binding arbitration is available to address residual complaints not resolved by other means.
</p>
<p>
<b>12.
RIGHTS OF CALIFORNIA RESIDENTS</b>
</p>
<p>
<b>12.1 California Consumer Privacy Act</b>
</p>
<p>If you are a California resident, we process your personal data in accordance with the California Consumer Privacy Act (CCPA).
This CCPA section of our Privacy Policy contains information required by the CCPA and supplements our Privacy Policy.
</p>
<p>
<b>Sale.</b> We do not sell your personal information.
So, we do not offer an opt-out to the sale of personal information.
</p>
<p>
<b>Rights.</b> You have the right to request that we (i) disclose what personal information we collect, use, disclose, and sell and (ii) delete your personal information.
You may make these requests yourself or through an authorized agent.
If you use an authorized agent, we may request information from you or the agent demonstrating that the agent is acting on your behalf.
</p>
<p>If you are a Discussion Owner or Student, you must exercise your rights through my.flipgrid.com.
If you have an additional request or questions after contacting us through my.flipgrid.com, or if you are not a Discussion Owner or Student, you may exercise their rights by contacting Flipgrid by email at <b>support@Flipgrid.com</b>.
We may ask for additional information to validate your request before honoring the request.
</p>
<p>You have a right not to receive discriminatory treatment if you exercise your CCPA rights.
We will not discriminate against you if you exercise your CCPA rights.
</p>
<p>
<b>Personal Information Processing.</b> In the bulleted list below, we outline the categories of personal information we collect, the sources of the personal information, our purposes of processing, and the categories of third-party recipients with whom we share the personal information.
For a description of the data included in each category, please see the <b>Flipgrid Collects section</b>.
</p>
<p>Categories of Personal Information </p>
<ul>
<li>
<p>Owner Personal Information </p>
</li>
</ul>
<p>- Sources of personal information: Submission by Discussion Owner and third party account providers such as Microsoft or Google </p>
<p>- Purposes of Processing (Collection and Sharing with Third Parties): Provide, improve and develop the Service.
provide customer service.
communicate with Discussion Owners including as related to events, opportunities, news and technical or administrative messages.
comply with applicable laws.
and for other purposes with Discussion Owner permission </p>
<p>- Recipients: Service providers and Discussion Owner-directed individuals and entities including other Users and external sites </p>
<ul>
<li>
<p>Student Personal Information </p>
</li>
</ul>
<p>- Sources of personal information: Submission by Discussion Owner, Students and third party account providers such as Microsoft or Google </p>
<p>- Purposes of Processing (Collection and Sharing with Third Parties): Provide, improve and develop the Service, provide customer service, communicate with Students including as related to technical or administrative messages.
comply with applicable laws </p>
<p>- Recipients: Service providers and Discussion Owner-directed individuals and entities including other Users and external sites </p>
<ul>
<li>
<p>Automatically Collected Information </p>
</li>
</ul>
<p>- Sources of personal information: Interactions with Users, including Discussion Owners and Students </p>
<p>- Purposes of Processing (Collection and Sharing with Third Parties): Provide, improve and develop the Service.
provide customer service.
comply with applicable laws.
and for other purposes with User permission </p>
<p>- Recipients: Service providers and User-directed entities </p>
<ul>
<li>
<p>Personal Information Collected through Cookies and Similar Technologies </p>
</li>
</ul>
<p>- Sources of personal information: Interactions with Users, including Discussion Owners and Students </p>
<p>- Purposes of Processing (Collection and Sharing with Third Parties): Provide, improve and develop the Service.
provide customer service.
communicate with Users including as related to events, opportunities and news.
comply with applicable laws.
and for other purposes with User permission </p>
<p>- Recipients: Service providers and User-directed entities </p>
<p>While the bulleted list above contains the primary sources and purposes of processing for each category of personal information, we may collect personal information from any of the sources listed in the Information Flipgrid Collects section above.
Similarly, we may process any category of personal information for any of the purposes described in the Use of Personal Information above.
Disclosures of personal information for business or commercial purposes.
As indicated in the Information We Share section, we may share personal information with third parties for various business and commercial purposes.
The primary business and commercial purposes for which we share personal information are the purposes of processing listed in this section.
However, we may share any category of personal information for any of the business and commercial purposes in the Information We Share section of this policy above.
</p>
<p>
<b>12.2 Other Rights</b>
</p>
<p>Flipgrid complies with California's "Shine the Light" law, as applicable.
Flipgrid does not share Students’ personal information with third party marketers (notably, Flipgrid does not share the personal information of ANY User with third party marketers).
If you are a California resident you can request a list of personal information about you we have disclosed to third parties in the preceding calendar year, as well as the names and addresses of those third parties.
You may make such a request only once per year, and you don't have to pay for it.
To make a request, send an email to <b>support@Flipgrid.com</b> or send a written request to Flipgrid, 251 First Avenue North, Suite 500, Minneapolis, MN 55401.
</p>
<p>Flipgrid also complies with California's Digital Protection of Minors Act, as applicable.
</p>
<p>
<b>12.3 How We Respond to Do Not Track Signals</b>
</p>
<p>We do not currently respond to "do not track" signals or other mechanisms that might enable consumers to opt out of tracking on our website.
</p>
<p>
<b>13.
Changes to this Policy</b>
</p>
<p>We may make changes to this Privacy Policy from time to time.
If we make changes to this Privacy Policy that we believe will materially affect your rights, we will notify you by email about these changes and post a notice to the Service and change the "Last Updated" date above.
If you continue to use our service after we provide such notice, you are agreeing to accept these changes.
Otherwise, for non-material changes, the Privacy Policy will be updated on the Service.
You should consult this Policy regularly for any changes.
</p>
<p>
<b>14.
Contact Information</b>
</p>
<p>If you have any questions about this Privacy Policy or wish to contact us, please contact <b>support@Flipgrid.com</b> You can reach Flipgrid by mail at: </p>
<p>Flipgrid </p>
<p>251 First Avenue North </p>
<p>Suite 500 </p>
<p>Minneapolis, MN 55401, U.S.A.
</p>