Privacy Policy

Last updated: April 24, 2019.

At Closegap, we are dedicated to protecting the privacy of our students and their families. Closegap, a website available at www.closegap.org (“the Site”), along with a web-based and mobile application (“Applications”)  make up a suite of services (collectively, “the Services”) owned and operated by Closegap Inc. (“the Company”, “we”, “us” or “our”).

We created Closegap as an emotional health inquiry and management tool that enables school staff and parents to support the emotional and mental health needs of students throughout the day. The privacy of our adult users: teachers, school social workers, school psychologists, school counselors, school staff, school administrators (collectively, “Educators”), and parents or legal guardians (collectively, “Parents”), and the privacy of children who use the Services are extremely important to us. We’ve created this Privacy Policy to clearly communicate how we protect, disclose and use the information we collect when Closegap Services are used. Closegap has developed privacy practices to align with applicable laws, including the Family Education Rights and Privacy Act (“FERPA”) and the Children’s Online Privacy Protection Act (“COPPA”).

 

Information We Collect

Educators and Parents

When creating an account, educators and parents are asked for the same personal information: first and last name, phone number, email address, password and role. After registration, they create profiles for their students (or children) and input personal information for them.  

Children

Personal

When creating profiles for children, educators and parents are asked for the child’s first and last name, grade, birthdate, homeroom teacher, whether or not they receive free or reduced price meals through the National School Lunch Program and whether or not they have a 504 plan. This information is not used beyond that needed for authorized educational and emotional health purposes for the student.

Emotional, Sensational & Behavioral

Through the use of the student facing Services, children record how they’re feeling, what those emotions feel like in their bodies and how much energy they have for the school day ahead.  

How We Use the Information

We’re committed to protecting the personal information of our users. We do not sell or rent user information. We do not sell or disclose any behavioral information that could be used to target advertising toward our students. We do not collect, maintain, use, or share users’ personal information beyond that needed for authorized educational and emotional health purposes. Our primary goal in collecting information is to provide and improve our Services for your use. The personal information we collect from parents, educators and students is used to provide and improve Closegap services, and notify you of any changes in our services.

The emotional, sensational and behavioral information we collect from students is used by educators and parents to better understand the experience of the kids they support. This information is sent to an easy-to-understand dashboard which parents and educators can access on a daily basis. Educators use this information to track the emotional experience of their students so they can respond to behavioral escalations and student needs in real-time, to inform their use of interventions, to carry out interventions and to track the efficacy of interventions. Parents use this information to understand the experience of their kids throughout the school day.

DATA ACCESSIBILITY

Student personal information may be accessed by educators, parents and students for review and correction at all times, either through school staff or by logging into their account.

DATA RETENTION

Closegap does not retain student personal information for longer than necessary to deliver services. If a student profile is inactive for more than 12 months, student data will be deleted immediately from all servers and technologies used by Closegap.

DISCLOSURE OF YOUR INFORMATION

Closegap partners with third party organizations to deliver a robust service offering for educators, parents and students. In some cases, we share personal, behavioral, emotional and/or sensational information of our users for the sole purpose of providing and improving our services for your use. We will not share personal information for any other purpose. All third party organizations we partner with have a mission similar to ours and goals that align with our vision of creating better life outcomes for all students. We will only contract and share student information with third party organizations consistent with the principles we’ve outlined in this Policy. Closegap will only contract with future companies that are consistent with the principles we’ve outlined in this Policy.

Successor Entities

If Closegap is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and a prominent notice on our website, of any change in ownership, with options regarding your personal information including removing it from Closegap systems entirely. Any company acquiring all or a part of Closegap’s assets will be required to agree to the terms of the Privacy Policy detailed here.

Children’s Privacy

We are proud to be in compliance with the Children’s Online Privacy and Protection Act of 1998, 15 U.S.C. 6501–6505 (“COPPA”) and the Family Educational Rights and Privacy Act of 1974, 20 U.S.C. § 1232g; 34 CFR Part 99 (“FERPA”). We securely store all information provided by our student users, and remain current on all applicable laws concerning student data.

Protection of Your Information

Closegap maintains a comprehensive security program that is reasonably designed to protect the security, privacy, confidentiality, and integrity of student personal information against risks - such as unauthorized access or use, or unintended or inappropriate disclosure - through the use of administrative, technological, and physical safeguards appropriate to the sensitivity of the information. We understand, however, that no system is perfect, and we cannot ensure or warrant the security of any or all of the information you transmit through our services.

NOTICE OF CHANGES TO PRIVACY POLICY

We reserve the right to make changes to this Privacy Policy at any time. When you use the Site, please check the Privacy Policy to ensure you are aware of any changes to our privacy practices. Our Privacy Policy will indicate the date it was last updated. When we make changes to our Privacy Policy we will notify you via email at the last email address you have provided to us. You will have a choice as to whether or not you accept the new terms of the Privacy Policy.

 
 
 

You can reach us directly at info@closegap.org regarding Closegap’s privacy practices or specific concerns about your personal information.