Screenbeam, Inc. Privacy Policy for Products and Services

Screenbeam (“we”, “us”, and “our) takes your privacy very seriously. This privacy Policy (Policy), explains our information collection, use, and sharing practices for our Services. The Privacy Policy for our Websites can be found here: https://www.screenbeam.com/privacy-policy/ . We reference our Website policy here to illustrate the differences between it and the stricter privacy measures of our Services. Furthermore, we follow an internal operational privacy policy to ensure we meet or exceed the level of privacy protection outlined in this policy.

We may update this Privacy Policy from time to time, including to reflect changes to our practices, or for other operational, legal, or regulatory reasons. We will post our revised Privacy Policy on the Site, update the “Last updated” date and take any other steps required by applicable law.

Unless otherwise stated, this Policy describes and governs the information collection, use, and sharing practices of ScreenBeam with respect to your use of our applications and the products and services (“Services”) we provide and/or host on our servers, or third party servers.

Screenbeam makes devices, and offer services, to enable secure sharing of cross platform Video, audio and written data for our Customer (which shall be referred to as “you”, “your” “customer”, and in addition, “school”, “school district”, “local Education Authority”, or “LEA” for our Services. ) It is also understood that Staff and Students of the Customer are included in those definitions.

Before you use or submit any information through or in connection with one of our Products or Services, please carefully review this Privacy Policy. By browsing our websites, registering a product, or using any part of our Services, you understand that information from you, your employees, staff and/or students may be collected, used, and disclosed as outlined in this Privacy Policy.

Our Services are intended for users over the age of 18, and are not directed at children under the age of 13. If we become aware that we have collected personal information (as defined by the Children’s Online Privacy Protection Act), without parental/guardian consent, from children under the age of 13, or personal data (as defined by the EU GDPR) from children under the age of 16, we will take reasonable steps to delete it as soon as practicable.

Our Principles

Here at ScreenBeam, we ground our privacy commitments in strong data governance practices, so you can trust that we’ll protect the privacy and confidentiality of your data and will only use it in a way that’s consistent with the reasons you provided it. As such, we have designed this policy to be consistent with the following principles:

We value, protect and defend data privacy.
We understand that when you use our services, you’re entrusting us with one of your most valuable assets—your data.
Data collection, storage, and processing should be simplified as much as possible to enhance security, ensure consistency, and make the practices easy for users to understand.
We make every effort to ensure our data practices meet the NIST 1.1 Framework, Federal, State, and International standards including COPPA, FERPA, and GDPR
We do not sell or share information and/or data about you to external parties for marketing and/or sales purposes. Any data shared is strictly used to provide contracted services.

Applicability

Our policy applies to our Products, Services and Websites only. It does not apply to non-Screenbeam Services and Websites that are used in conjunction with, or simultaneously with, our Services and Websites. Those Services and Websites may have their own privacy policies, but they do not affect or supersede our Privacy Policy. Our Policy also does not affect any existing Customer privacy policy.

For our Services, we do not directly obtain any Student or Teacher personal data, as each School sends that data to us to enable our Services to be functional. Please be aware every school controls how it deploys our Services, and that we will never receive any Student or Teacher personal data from a School without it having previously obtained the necessary approval to share it with us. If you have any question regarding a School’s privacy policy, please contact them directly.

Information You Provide Directly to Us

We will collect any information you provide to us. We may collect information from you in a variety of ways, such as when you: (a) create an offline/online account, (b) make a purchase, (c) your SIS and/or Roster information, (d) use our products or services. This information may include but is not limited to name, email address, class information, school ID, mailing address, your geographic location or other relevant information needed to provide services. For Students of any age using our Services which you contract, the only personally identifiable information you provide us is their name and teacher name. If you send us any other personally identifiable information, it will be destroyed immediately on intake.

Information that Is Automatically Collected

Device/Usage Information

We may automatically collect certain non-personally identifying information about the computer or devices (including mobile devices or tablets) you use to access our Websites, Online Stores and Services. As described further below, we may collect and analyze (a) device information such as IP addresses, location information (by country and city), unique device identifiers, IMEI and TCP/IP address, browser types, browser language, operating system, mobile device carrier information, and (b) information related to the ways in which you interact with our Services, the date and time you used our Services, the frequency of your use of our Services, error logs, and other similar information. As described further below, we may use third-party tools and technologies to assist in providing services.

Other Collected Information

For our Websites and Online Stores, we may use cookies and other means to track user activity and to assess the effectiveness of our marketing. We may use third parties to help us evaluate the information collected. We will not sell, or allow to be used, collected information for Marketing or any other commercial purposes. For our Online store, we use Shopify. Their cookie policy applies while you are making a purchase ( https://www.shopify.com/legal/cookies )
For our Services, we use only temporary cookies necessary to support the current web browser session, and do not use any web browser based tracking of any kind. However we may obtain your contact and/or school information from public records, Sales Partners, Conferences and other informational events.

Information We do not Collect

We do not collect any direct communication between Students and Teachers/School employees using our Services. This information is logged to your data storage provider and never enters our hosted systems, as such, it is governed by Your Privacy Policy.

Who Has Access to Your Information

Employees of ScreenBeam and our contractors have access to information collected. We limit access to only those select employees and contractors that have need of the information to provide services. Contractors and/or Subcontractors hired by ScreenBeam to perform work that requires access to your data can perform only the functions they were hired to provide. They’re bound by the same contractual privacy commitments that ScreenBeam makes to you.

We routinely train and update employees and contractors on best practices for securing and handling data.

How We Use Your Information

We may use the information we collect from and about you to:

Fulfil the purposes for which you provided it.
Provide and improve our Services, including to develop new features or services, take steps to secure our Services, and for technical and customer support.
Process transactions.
Send you information about your interaction or transactions with us, account alerts, or other communications.
Process and respond to your inquiries, or to request your feedback.
Comply with the law and protect the safety, rights, property, or security of ScreenBeam Inc, our Services, our users, and the general public.
Enforce our Terms of Use, including to investigate potential violations thereof.

All Student and Teacher data We obtain through our Services will only be used for the purpose of providing the Services You have contracted for, and will not be disclosed to any other entity unless legally necessary.

Screenbeam does not sell any personally identifying information to anyone. We will only share your personal data with those who have a legitimate business need for it. Whenever we permit a third party to access your personal data, we will ensure the personal data is used in a manner consistent with this privacy notice (and any applicable internal data handling guidelines consistent with the sensitivity and classification of the personal data). We may disclose and/or share your information under the following circumstances:

In order to carry out the purposes of our personal data processing as described above
To comply with our legal obligations, regulations, government clearances, or contracts, or to respond to data subject rights, a court order, administrative or judicial process, such as a subpoena, government audit or search warrant. Categories of recipients would include counterparties to contracts, judicial and governmental bodies;
In response to lawful requests by public authorities (such as regulatory bodies, law enforcement authorities, and national security organizations);
To seek legal advice from external lawyers and advice from other professionals such as accountants, management consultants, etc.;
As necessary to establish, exercise or defend against potential, threatened or actual litigation;
Where necessary to protect ScreenBeam, your vital interests, such as safety and security, or the vital interests of other persons;
In connection with the sale, assignment or other transfer of all or part of our business (such as a potential purchaser and its legal/professional advisers); or
Otherwise in accordance with your consent.

Security Measures

ScreenBeam is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data against the loss, misuse, and/or alteration of personally identifiable and any other information, unauthorized access, or disclosure. For example, we store the personal data you provide on limited access computer servers that are located in controlled facilities, and we protect certain highly confidential or sensitive personal data through encryption in transfer and at rest using industry standards. For our Services, no unauthorized user can communicate with an authorized user.

These safeguards vary based on the sensitivity of the information that we collect and store. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information since despite our efforts, no Internet and/or other electronic transmissions can be completely secure.

All equipment with access to data is encrypted and requires two factor authentication to ensure all data is protected and secure. Should an employee or contractor leave or be terminated, we will take appropriate measures to ensure that their access to data is removed.

Monitoring and Notifications

We and our third party partners monitor the security of our systems used to provide services. In the event of a breach or attempted breach We are notified and appropriate actions taken to maintain the security of data collected.
Should your data be compromised or unauthorized access occur, you will be notified as required by law. We will cooperate with law enforcement and security experts as needed to respond to unlawful activities and threats to data collected. We will take necessary steps to mitigate any current or future threats.
We annually review our policies and tools used to secure data collected and perform penetration testing to ensure systems are up to date.

Disclosure of Your Information

Third Party Service Providers.

We may disclose your information with third parties who perform services on our behalf, including without limitation, data storage, data analysis and processing, and/or development tools/resources.
We do not disclose any Student or Teacher data with any third party aside from the originating School, although we may transmit and store such information in encrypted form in third party data networks and storage.

Screenbeam is a member of the Student Data Privacy Consortium

Data Retention

We will store personal data in accordance with applicable laws or regulatory requirements and retain data for as long as necessary to fulfill the purposes for which the personal data was collected.

If you browse our websites we may use cookies to identify your session(s) in order to help us analyze your usage of our websites and the effectiveness of our business efforts.

If you make a purchase from our Online Stores, we use Shopify, and their Privacy Policy ( https://www.shopify.com/legal/privacy ) governs the data you provide them. We do this to protect your credit card information, which we never see.

If you have registered a product with Us, we will keep your registration information for the duration of the warranty terms.

If you are a School or LEA, we will only keep your Student and Teacher data until your next upload, although any given days’ data will be retained for 7 days in backup form. Should you not upload new Student or Teacher information within 30 days, it will be automatically deleted from our Service. As we do not store Student or Teacher data other than above, or alter it, please retain a copy of your upload files if you need historical records of the data. Your LEA account information (i.e. School ID, mailing address, contact information, class information) will be retained for the term of the contract or as long as legally necessary.

Legal Compliance and Protection of Creative Commons and Others.

We may disclose your information if required to do so by law or on a good faith belief that such disclosure is permitted by this Privacy Policy or reasonably necessary or appropriate for any of the following reasons: (a) to comply with legal process; (b) to enforce or apply our Terms of Use and this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) enforce our Charter including the Code of Conduct and policies contained and incorporated therein, (d) to respond to your requests for customer service; and/or (e) to protect the rights, property, or personal safety of ScreenBeam, our agents and affiliates, our users, and the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.

Consent.

Where required by law, and in some other cases where legally permissible, we handle information on the basis of consent. Where we handle your information on the basis of consent, you have the right to withdraw your consent; in accordance with applicable law.

By using our Services, you are providing consent and agree that we may disclose your information to any third parties as needed to provide Services. LEAs also agree that you will seek any consent necessary with your staff, parents/legal guardians of minor children and legally adult students using our services at your institution on ScreenBeam’s behalf.

Processing Personal Data

The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose information that can be directly linked to or used to identify you. We may use your personal data when necessary to comply with laws and regulations, including collecting and disclosing personal data as required by law. To the extent those laws apply, our legal grounds for processing such information are as follows:

To Honor Our Contractual Commitments to You.

Much of our processing of information is to meet our contractual obligations to provide services to our users.

Legitimate Interests.

In many cases, we handle information on the ground that it furthers our legitimate interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, these include:

Customer service.
Managing user accounts.
Analyzing and improving our business.
Managing legal issues.

We also may collect and use your personal data when it is necessary for other legitimate purposes, such as disclosures for auditing and reporting purposes, management of network and information systems security, administration of business applications and systems, business operations, security, life safety, improvement of services, physical security and cybersecurity, data protection, to protect the life and safety of employees and others.

Your Choices and Data Subject Rights

You have various rights with respect to the collection and use of your information through the Services.
You may cancel services or subscriptions. Upon termination of services, any data collected by ScreenBeam will be destroyed.

Account Preferences

If you have registered for an account with us through our Services, you can update your account information or adjust your email communications preferences by logging into your account and updating your settings.

GDPR and EU Data Subject Rights

ScreenBeam operates globally and therefore personal data may need to be transferred to countries outside of where the personal data was originally collected. For example, because we are headquartered in the United States, personal data collected in other countries may routinely transferred to the United States for processing. We may transfer personal data from the European Economic Area, the United Kingdom, and Switzerland to other countries as needed in order to provide services.
Individuals in the European Economic Area (“EEA”) and other jurisdictions have certain legal rights with respect to the collection and use of their information through the Services. These rights include:

Right of Access: You have the right to obtain confirmation of whether we hold certain information about you and to request a copy of that information.
Right to Rectify: You can request the correction or updating of any inaccurate or incomplete personal information we hold about you.
Right to Object: You have the right to object to the processing of your personal data on specific grounds, such as for marketing purposes or where we rely on legitimate interests.
Right to Withdraw Consent: Where we process your information based on your consent, you have the right to withdraw that consent at any time.
Right to Complain: If you believe that your data protection rights have been violated, you have the right to lodge a complaint with the relevant supervisory or legal authority.

To exercise any of these rights or if you have any questions about how we handle your data, please email us at privacypolicy@screenbeam.com. We are committed to responding to your requests promptly and within the timeframes required by GDPR. If necessary, this response time may be extended in certain circumstances.

International Transfers

As described above in the “When We Disclose Your Information” section, we may share your information with trusted service providers or business partners in countries other than your country of residence in accordance with applicable law. This means that some of your information may be processed in countries that may not offer the same level of protection as the privacy laws of your jurisdiction. By providing us with your information, you acknowledge any such transfer, storage or use.
If we provide any information about you to any third parties information processors located outside of the EEA, we will take appropriate measures to ensure such companies protect your information adequately in accordance with this Privacy Policy and other data protection laws to govern the transfers of such data.

Third-Party Links and Services

ScreenBeam Services, may enable staff to send links or directly open websites to third-party locations and other services. If you choose to use this feature, you may disclose your information not just to those third-parties, but also to their users and the public more generally depending on how their services function. ScreenBeam is not responsible for the content or privacy practices of such third party websites or services. The collection, use and disclosure of your information will be subject to the privacy policies of the third party websites or services, and not this Privacy Policy.

Changes to this Privacy Policy

We will continue to evaluate this Privacy Policy as we update and expand our Services, and we may make changes to the Privacy Policy accordingly. We will post any changes and revise the date last updated above. We encourage you to check this page periodically for updates to stay informed on how we collect, use and share your information. If we make material changes to this Privacy Policy, we will provide you with notice as required by law.

Questions About this Privacy Policy

If you have any questions about this Privacy Policy or our privacy practices, you can contact us at: privacypolicy@screenbeam.com