Effective starting: August 1, 2022
What this policy covers
Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you. This policy is intended to help you understand:
- What information we collect about you
- How we use the information we collect
- How we share information we collect
- How we store and secure the information we collect
- How to access and control your information
- Other important privacy information
This policy also explains your choices surrounding how we use information about you, which include how you can object to certain uses of information about you and how you can access and update certain information about you. If you do not agree with this policy, do not create an account, access, use our Services or interact with any other aspect of our business.
Where we provide the Services under contract with an organization (for example, your employer) that organization controls the information processed by the Services. For more information, please see Notice to End Users below. This policy does not apply to the extent we process personal information in the role of a processor on behalf of such organizations.
What information we collect about you
We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below.
Information you provide to us
We collect information about you when you input it into the Services or otherwise provide it directly to us.
Account and Profile Information: We collect information about you when you register for an account, create or modify your profile, set preferences, sign-up for or make purchases through the Services. For example, you provide your contact information and, in some cases, billing information, when you register for the Services. You also have the option of adding a display name, profile photo, job title, and other details to your profile information to be displayed in our Services. We keep track of your preferences when you select settings within the Services.
The content you provide through our products: The Services include the openSIS products you use, where we collect and store content that you input. This content includes any information about your institution and its users. Content also includes the files and links you upload to the Services.
The content you provide through our websites: The Services also include our websites owned or operated by us. We collect other content that you submit to these websites, which include social media or social networking accounts owned by us. For example, you provide content to us when you provide feedback or when you participate in any interactive features, surveys, promotions, sweepstakes, activities, or events.
Information you provide through our support channels: The Services also include our customer support, where you may choose to submit information regarding a problem you are experiencing with a Service. Whether you designate yourself as a technical contact, open a support ticket, speak to one of our representatives directly, or otherwise engage with our support team, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.
Payment Information: We collect payment and billing information when you register for certain paid Services. For example, we ask you to designate a billing representative, including name and contact information, upon registration. You might also provide payment information, such as payment card details, which we collect via secure payment processing services.
Information we collect automatically when you use the Services
We collect information about you when you use our Services, including browsing our websites and taking certain actions within the Services.
Your use of the Services: We keep track of certain information about you when you visit and interact with our Services.
Device and Connection Information: We collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you install, access, update, or use our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience. How much of this information we collect depends on the type and settings of the device you use to access the Services.
Information we receive from other sources
We receive information about you from other Service users, from third-party services, from our related companies, social media platforms, public databases, and our business and channel partners. We may combine this information with information we collect through other means described above. This helps us to update and improve our records, identify new customers, create more personalized advertising and suggest services that may be of interest to you.
Other users of the Services: Other users of our Services may provide information about you when they submit content through the Services. We also receive your email address from other Service users when they provide it in order to invite you to the Services. Similarly, an administrator may provide your contact information when they designate you as the billing or technical contact on your company's account or when they designate you as an administrator.
openSIS Partners: We work with a global network of partners who provide consulting, implementation, training, and other services around our products. Some of these partners also help us to market and promote our Services, generate leads for us, and resell our Services. We receive information from these partners, such as billing information, billing and technical contact information, company name, what openSIS Services you have purchased or may be interested in, evaluation information you have provided, what events you have attended, and what country you are in.
Other Partners: We receive information about you and your activities on and off the Services from third-party partners, such as advertising and market research partners who provide us with information about your interest in and engagement with, our Services and online advertisements.
Third-Party Providers: We may receive information about you from third-party providers of business information and publicly available sources (like social media platforms), including physical mail addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses and social media profiles, for the purposes of targeted advertising of products that may interest you, delivering personalized communications, event promotion, and profiling.
How we use the information we collect
How we use the information we collect depends in part on which Services you use, how you use them, and any preferences you have communicated to us. Below are the specific purposes for which we use the information we collect about you.
To provide the Services and personalize your experience: We use information about you to provide the Services to you, including to process transactions with you, authenticate you when you log in, provide customer support, and operate, maintain, and improve the Services.
For research and development: We are always looking for ways to make our Services smarter, faster, secure, integrated, and useful. We use the information and collective learnings (including feedback) about how people use our Services to troubleshoot, identify trends, usage, activity patterns, and areas for integration and improve our Services, and develop new products, features, and technologies that benefit our users and the public. We also test and analyze certain new features with some users before rolling the feature out to all users.
To communicate with you about the Services: We use your contact information to send transactional communications via email and within the Services, including confirming your purchases, reminding you of subscription expirations, responding to your comments, questions, and requests, providing customer support, and sending you technical notices, updates, security alerts, and administrative messages. We also send you communications as you onboard to a particular Service to help you become more proficient in using that Service. These communications are part of the Services and in most cases, you cannot opt-out of them. If an opt-out is available, you will find that option within the communication itself or in your account settings.
To market, promote and drive engagement with the Services: We use your contact information and information about how you use the Services to send promotional communications that may be of specific interest to you, including by email. We also communicate with you about new Services, product offers, and promotions. You can control whether you receive these communications as described below under "Opt-out of communications."
Customer support: We use your information to resolve technical issues you encounter, respond to your requests for assistance, and repair and improve the Services. Where you give us express permission to do so, we share information with a third-party expert for the purpose of responding to support-related requests.
For safety and security: We use information about you and your Service use to verify accounts and activity, to detect, prevent, and respond to potential or actual security incidents and to monitor and protect against other malicious, deceptive, fraudulent, or illegal activity, including violations of Service policies.
To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests, and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
With your consent: We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission.
Legal bases for processing (for EEA users):
If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:
- We need it to provide you the Services, including to operate the Services, provide customer support and personalized features, and protect the safety and security of the Services;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services, and to protect our legal rights and interests;
- You give us consent to do so for a specific purpose; or
- We need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.
How we share information we collect
Managed accounts and administrators: If you register or access the Services using an email address with a domain that is owned by your employer or organization and such organization wishes to establish an account, certain information about you including your name, profile picture, contact info may become accessible to that organization’s administrator and other Service users sharing the same domain.
Community Forums: Our websites offer publicly accessible blogs, forums, issue trackers, and wikis. You should be aware that any information you provide on these websites - including profile information associated with the account you use to post the information - may be read, collected, and used by any member of the public who accesses these websites. Your posts and certain profile information may remain even after you terminate your account. We urge you to consider the sensitivity of any information you input into these Services. To request the removal of your information from publicly accessible websites operated by us, please contact us as provided below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to and why.
Sharing with third parties
We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Services.
Service Providers: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis, and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including appropriate security and confidentiality procedures designed to protect your information.
openSIS Partners: We work with third parties who provide consulting, sales, support, and technical services to deliver and implement customer solutions around the Services. We may share your information with these third parties in connection with their services, such as assisting with billing and collections, providing localized support, and providing customizations. We may also share information with these third parties where you have agreed to that sharing.
Third-Party Services: We may offer you the ability to interact with or share information with third parties through the Services. For example, we may offer users the ability to log in to the Services via a third-party service like Google, access embedded maps through Google Maps, or interact with social media networks via links on the Services. When you intentionally interact with these third parties, we may share certain information with those third parties or receive information with those third parties, consistent with your privacy settings on the third-party service. Such information may include contact information, identification, and demographic information, and device information and identifiers. You should always check the privacy settings and notices in these third-party services to understand how those third parties may use your information.
With your consent: We share information about you with third parties when you give us consent to do so. For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside the testimonial.
Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies, and terms of service, (c) protect the security or integrity of our products and services, (d) protect openSIS, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
How we store and secure the information we collect
Information storage and security
We use industry-standard technical and organizational measures to secure the information we store.
While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.
If you use our server or data center Services, responsibility for securing storage and access to the information you put into the Services rests with you and not openSIS.
How long do we keep information?
How long we keep the information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or de-identify your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
Account information: We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, support business operations, and continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.
Managed accounts: If the Services are made available to you through an organization (e.g., your employer), we retain your information as long as required by the administrator of your account. For more information, see "Managed accounts and administrators" above.
Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us or ceased using your openSIS account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
How to access and control your information
You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them, and any limitations.
Access and update your information: Our Services and related documentation give you the ability to access and update certain information about you from within the Service. You can update your profile information within your profile settings and modify information about you using the editing feature.
Deactivate your account: If you no longer wish to use our Services, you or your administrator may be able to deactivate your Services account. If you can deactivate your own account, that setting is available to you in your account settings. Otherwise, please contact your administrator. If you are an administrator and are unable to deactivate an account through your administrator settings, please contact our help and support team. Please be aware that deactivating your account does not delete your information; your information remains visible to other Service users based on your past participation within the Services.
Opt out of communications: You may opt-out of receiving promotional communications from us by using the unsubscribe link within each email, updating your email preferences within your Service account settings menu, or by contacting us as provided below to have your contact information removed from our promotional email list or registration database. Even after you opt-out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services.
Send "Do Not Track" Signals: Some browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, our Services do not currently respond to browser DNT signals. You can use the range of other tools we provide to control data collection and use, including the ability to opt-out of receiving marketing from us as described above.
Data portability: Data portability is the ability to obtain some of your information in a format you can move from one service provider to another (for instance, when you transfer your mobile phone number to another carrier). Depending on the context, this applies to some of your information, but not to all of your information. Should you request it, we will provide you with an electronic file of your account information and the information you created within the Services.
Other important privacy information
Notice to End Users
Our products are intended for use by organizations. Where the Services are made available to you through an organization (e.g. your employer), that organization is the administrator of the Services and is responsible for the accounts and/or Service sites over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the Services is subject to that organization's policies. We are not responsible for the privacy or security practices of an administrator's organization, which may be different than this policy.
Administrators are able to:
- require you to reset your account password;
- restrict, suspend or terminate your access to the Services;
- access information in and about your account;
- access or retain information stored as part of your account;
- install or uninstall third-party apps or other integrations
In some cases, administrators can also:
- restrict, suspend or terminate your account access;
- change the email address associated with your account;
- change your information, including profile information;
- restrict your ability to edit, restrict, modify or delete information
Exercising your rights: If you are a California resident, there are some additional rights that may be available to you under the California Consumer Protection Act (“CCPA”). This policy explains the tools that we have made available to you to exercise your data rights under the CCPA, such as the right to deletion and the right to request access to the categories of information we have collected about you. We encourage you to manage the depth of your information within our Services. You will not be discriminated against for exercising any of your privacy rights under the CCPA. In order to protect your information from unauthorized access or deletion, we may require you to provide additional information for verification. If we cannot verify your identity, we will not provide or delete your information.
Sharing your personal information: We don't sell your personal information. We do share your information with others as described in the “How we share information we collect” section of this policy.
Processing your information: This policy describes the categories of personal information we may collect, the sources of that information, and our deletion and retention policies. We’ve also included information about how we may process your information, which includes for "business purposes" under the CCPA - such as to protect against illegal activities and for the development of new products, features, and technologies. If you have questions about the categories of information we may collect about you, please be sure to visit the section of this policy called, “What information we collect about you.” For more details about our processing activities, please be sure to visit the section called, “How we use the information we collect.”
Our policy toward children
The Services are not directed to individuals under 18. We do not knowingly collect personal information from children under 18. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact the appropriate help and support team.
Your information is controlled by Open Solutions for Education, Inc. If you have questions or concerns about how your information is handled, please contact us directly or via our Services or help and support services.