Last Updated: April 25, 2020
COPPA is the acronym for Children’s Online Privacy Protection Act (“COPPA”) – created and put into effect on April 21,
2000. This act applies to students under the age of 13 in the US (or the minority age in other jurisdictions) to protect
their personal information. A website operator must include in a privacy policy (“Privacy policy”) when and how to seek
parental consent and what responsibilities the website operator, such as PayGrade has to protect its students’ privacy
and safety online.
To comply with COPPA, PayGrade does the following:
-
Teachers or school consent on behalf of parents: COPPA allows schools and teachers to act on behalf of parents. This
means that we will only collect information from students after obtaining consent from their teachers or school. The
teachers and schools have the duty of ensuring the parents of the students are aware of these practices. The teachers
and schools are also responsible for providing a copy of this Privacy Policy to the parents.
-
PayGrade collects minimal information: We do not collect students’ addresses, telephone numbers, or email addresses or
other unnecessary information from students. The only information collected from a student is a username and name. This
information is given directly by the student or teacher. There is no marketing back to the student, no contest winners,
and no way to make information publicly available to any external sites.
-
No student information is rented or sold to third parties: If we employ other companies (third party service providers)
to perform tasks on our behalf and need to share any information with them to provide products or services to PayGrade,
they do not have any right to use the personal information or students’ personal information we share with them beyond
what is necessary to assist us. We also take steps to ensure that they agree to protect the personal information or
students’ personal information shared with them.
-
Parental Access: Parents can request that their student has a pseudonym in place of their name when accessing PayGrade.
Parents can review the student’s personal information, ask to have it deleted, and refuse to allow any use of the
information throughout the year. All the parent needs to do is tell the teacher, and the teacher will need to delete the
student’s profile on PayGrade.
PayGrade takes student privacy seriously; that is why we collect only the minimal amount of information from a student
to provide the Service – just a first name, username, and password. We do not ask for other information, such as gender,
SSN, email, address, student ID, or age.
Below, we give an overview of the website, its educational function, and how we protect and secure student privacy.
“Personal information” is any information you provide to us that personally identifies you, such as your name or email
address, or other information that could be linked to such identifying information by us. We will only collect, use, and
share your personal information in accordance with this Privacy Policy.
This Privacy Policy applies whether you use PayGrade through https://paygrade.io, our mobile application, or any of our
other products or services that link to this Privacy Policy (collectively, the “Service”).
Moreover, this Privacy Policy covers PayGrade’s treatment of any personal information about our users that teachers or
other services might share with us.
This Privacy Policy does not apply to websites or services or practices of companies that PayGrade doesn’t own or
control, such as third party services you might access through links or other features (e.g., social media buttons,
lesson plan resources, etc.) on our website. These other services have their own privacy policies, and we encourage you
to review them before providing them with personal information.
Please take the time to get to know our privacy practices. If you have any questions, you can email us at
support@paygrade.io, and we will respond as soon as reasonably possible.
By using the Service, you acknowledge that you accept and agree to this Privacy Policy. If you do
not accept this
Privacy Policy, you may not use the Service.
PayGrade is an education software platform that allows teachers to manage their classroom while teaching essential
finance skills to students. Students create a profile under a secure teacher’s account that they can log in to, set up a
profile picture (the student’s teacher is prompted to approve the photo taken by the student before it can be shared
with other students), and resume. Students then manage virtual (not real) checking, savings, and credit accounts.
Students pay bills, purchase assets, and learn the advantages of saving. Teachers can use PayGrade to help incentivize
behaviors they want to see in the classroom like completing work and showing the school’s norms through deposit and
withdrawals, called Action Items. Teachers can also teach essential financial literacy skills through the use of
PayGrade and its functions. Students have access to see, but not alter in any way, other students’ profile pictures,
resumes, and personal account information. Students can see other students in their class, a news log of virtual
deposits and withdrawals made each day, a leaderboard to see the virtual net worth and ranking of students, their
virtual bills and virtual assets, the teacher approved profile pictures and student created resumes of that teacher’s
class.
When students set up a PayGrade account, they input their first name and then create a unique username and password. We
do not ask students to enter any other personal information when setting up an account. If a student’s school or teacher
wants to use any of the data created by a student such as their resume or transaction history, the school will be
responsible for obtaining any necessary parental consent under COPPA.
School administration or other decision-makers in the school may choose to purchase a school account in PayGrade. This
allows the administration access to teacher and student accounts to add, edit, or delete student accounts transactions
(deposits and withdrawals).
PayGrade collects the minimal amount of information from students necessary to create accounts on our Service: we ask
students to provide a unique username, a first name, a password, and the unique code (similar to Google Classrooms) they
have been given by their teacher to connect with a classroom. We also collect some information automatically through
some tools or software. We will not use or ask for parent or students’ email addresses and have no intention of spamming
or marketing to anyone. We do not ask students to enter any other personal information when setting up an account. See
below for more information regarding the information we collect:
-
Information users provide to us
There are currently three categories of users on our Service: schools, students, and teachers. We described the
information collected from the students above. For other users (schools and teachers), we collect and store the
following types of information from each type of user:
-
Account Sign-up and Profile Information: To create a PayGrade account as a school, you may be asked to provide some
basic information such as your first name, last name, school, location, username, and password. Schools may view
teachers in that school’s account; however, no teacher or student profile is made available or visible to the general
public through the functionality of our Service. If you create a PayGrade account as a student, you will be asked to
enter the code (similar to Google Classroom) you have been given by your teacher (students are unable to sign up for the
Service without this), along with a name, unique username, and password. Teachers may also give a letter of consent to
use PayGrade located here.
We do not ask students to enter any other personal information to create their student accounts. If you are a teacher,
the only information we ask for is a first name, last name, school name, email, location, and how you heard about
PayGrade.
-
School Information and Collaboration Features: If you are a teacher, as part of the profile information you provide, you
may choose to associate your account with a school account or may enter a new school name, location, and how you heard
about PayGrade. By connecting you with your school, the Service may enable and provide additional collaboration features
for teachers and school leaders within the same school, such as depositing and withdrawing different action items
(incentivized behaviors) for students in different classes such as specials teachers.
-
Class Information: As a teacher, you can enter the class grade and the names of the students in your class. If teachers
need help with their account, they can contact the staff at PayGrade to access their account and help with training,
which allows the staff to see some class information like a students’ name, grade, net worth, and virtual bank account
amounts. However, none of the PayGrade staff is permitted to share any of the information outside of the PayGrade staff
that they see when aiding a teacher in using the software.
-
Deposits and Withdrawals: As a teacher or school, you can customize a list of incentivized behaviors in the form of
deposits or withdrawals that you want to encourage or recognize in student actions. These transactions can be seen and
edited by the teacher or the banker job- a student in the class with access to editing and assigning bills to students
in their individual class.
-
Contact Information: When you choose to provide us with your personal information through the Service in some other
manner (e.g., when you send us an email asking a question, submit a support request through Google Forms, participate in
a written or video testimonial about our Service, or choose to participate in any research efforts with PayGrade to
improve the Service), we will store your contact information on Insightly (a third party service provider). This applies
only to teachers or school managing an account with us as we do not collect any contact information from students.
-
Information PayGrade automatically collects
Like most web-based services, we may automatically receive and log information on our server logs from your browser or
your device when you use the Service. For example, this could include the frequency and duration of your visits to
PayGrade on Google Analytics. If we combine any automatically-collected information with personal information, we will
treat the combined information as personal information, and it will be protected as per this Privacy Policy. The
technologies and information we automatically collect include:
-
Cookies and other similar technologies: Cookies are tiny pieces of data that are attached to your browser – to track
certain preferences about your online behavior. We may use various technologies to collect and store information when
you visit our Service, including through cookies and Google Analytics. Like many services, PayGrade uses these
technologies to tailor the Service for you and improve your user experience. See our Cookie Policy for more information
regarding cookies and other similar technologies.
-
Device information: We collect device-specific information such as your operating system, hardware version, device
settings, file and software names and types, battery and signal strength, and device identifiers. This helps us
measure
how the Service is performing and improve PayGrade for you on your particular device.
-
Log information: Like most online services, when you use our Service, we automatically collect and store certain
information in our server logs. Examples include things like: (i) Details of how you used our service, such as your
activity on the Service, and the frequency and duration of your visits to the PayGrade Website or PayGrade App; (ii)
SMS
routing information; (iii) IP Address; and (iv) Device event information such as crashes, system activity, hardware
settings, browser type, browser language, the date and time of your request, and referral URL. This information helps
us
make decisions about what we should work on next or improve upon on PayGrade.
-
Location information: When you use our Service, we may collect and process information about your geographic location,
for example, through GPS, Bluetooth, or Wi-Fi signals on Google Analytics. We collect both coarse (i.e., city-level)
location data and precise location data. If we collect precise geolocation information (“precise” meaning sufficient
to
identify street name and name of city or town) from you (such as when a teacher is searching for a school), we ask for
your explicit opt-in permission. We do not collect precise geolocation data from students. We will not store or track
your device location on an ongoing basis or without your permission. We do not share precise geolocation data with
third
parties other than our service providers as necessary to provide the Service.
PayGrade does not sell or rent any of you, or your student’s personal information to any third party for any purpose,
including for advertising or marketing purposes. Targeted advertising is not permitted on PayGrade. We only use the
information you provide us to:
-
Provide and improve the Service, for example, by fixing problems or developing new features;
- Respond to your requests for information or customer support;
- Customize the Service for you and improve your experience with it;
- Send you information about new features and PayGrade products we believe you may be interested in; and
- Most crucially, to protect our community by making sure the Service remains safe and secure.
When students create an account, they are able to upload a picture of themselves. This photo is sent to be approved by
the teacher prior to the class being able to see it.
If we discover that we have collected information from a student in a manner that is inconsistent with COPPA, we will
take appropriate steps to either delete the information or immediately seek the parent’s consent for that collection. We
do not disclose any personal information about students to third parties, except to service providers when necessary to
provide the Service, as required by law or to protect the security of the Service or other users. Information collected
from students (including personal information and information collected automatically) is never used or disclosed for
third party advertising or for any first- or third-party targeted advertising, and student’s personal information is
never sold or rented to anyone, including to marketers, advertisers, banks, or other financial institutions.
If a teacher chooses to set up their students’ accounts, he or she can choose to provide full names for students (e.g.,
first name and last name) when setting up their class; they can also opt to only provide non-identifying information
(e.g., just first name, only initials, or even just seat numbers).
The student’s profile, picture, and resume are never made available or visible to the public through PayGrade. Teachers
may share their classroom profiles with other teachers and administrators in the building, but without a media release
and/or written permission from a legal guardian, students’ information is not available to use for any reason outside of
the school. In addition, students can see each other’s profile pictures, resume, classroom jobs, net worth, net
currency, and transactions through the news log and class ranking. This is similar to how a teacher might display
classroom jobs, behavior charts, and progress toward a specific goal around the classroom. The only other time student
information or teacher information is visible to others is when the teacher contacts PayGrade to assist in setting up,
managing, navigating, editing, or deleting their account. PayGrade staff will also periodically access teacher accounts
to see if they are using the account and send follow up emails with how to better use the software but they will not
change, alter, or delete any information unless asked to do so by the teacher.
PayGrade will not share or disclose any information about teachers, schools, and students unless under the below
circumstances. And even if we share information under these circumstances, it will be in line with this Privacy Policy
and the COPPA law.
-
Other Users You Share and Communicate with on PayGrade: No teacher, administrator, parent, or student profiles are made
available to the general public through our Service. Please keep in mind that information (including personal
information or student's personal information) or content that you voluntarily disclose to others, including to other
PayGrade users you interact with through the Service (such as messages you might send other users or other teachers and
administration you collaborate with), can be viewed, copied, stored, and used by the people you share it with. We cannot
control the actions of people with whom you choose to share information.
-
PayGrade Staff/Employees: If teachers need help with their accounts, they can contact the staff at PayGrade to access
their accounts and help with training, editing, deleting, or adding information to the account. When the PayGrade staff
accesses the teacher’s account, they can see the class information like a students’ names, grades, net worth, virtual
bank account amounts, etc. However, none of the PayGrade staff is permitted to share any of the information outside of
helping the teacher in using the software to its fullest extent.
-
Third-party integrations on our Service: When, as a teacher or administrator, you use third-party apps, websites, or
other services that use, or are integrated with our Service, they may receive information about what you post or share.
For example, when you invite others via Facebook or Twitter, these services receive the information that you share
through this functionality and information that you are sharing from PayGrade. Information collected by these apps,
websites, or integrated services is subject to their own terms of use and other policies.
- Third Party Service Providers: Targeted advertising is not permitted on PayGrade. We do work with vendors, service
providers, and other partners to help us provide the Service by performing tasks on our behalf. We may need to share or
provide information (including personal information) to them to help them perform these business functions. For example,
sending emails on our behalf, database management services, database hosting, data analytics, providing customer support
software, and security. These service providers do not have the right to use any personal information we share with them
beyond what is necessary to assist us. Additionally, these service providers must adhere to confidentiality and security
obligations in a way that is consistent with this Privacy Policy.
- Testimonials: We post testimonials on our Service which may contain personal information such as the name, photo, and/or
a video of the individual in the testimonial. We obtain the individual’s consent in advance to ensure we have permission
to post this content publicly. To request removal of your personal information from our testimonials, please contact us
at support@paygade.io.
-
Aggregated Information and Non-Identifying Information: We may share aggregated, non-personally identifiable information
publicly, including with users, partners, or the press in order to, for example, demonstrate how PayGrade is used, spot
industry trends, or to provide marketing materials for PayGrade. Any aggregated information shared this way will not
contain any personal information.
-
Legal Requirements: We may disclose personal information if we have a good faith belief that doing so is necessary to
comply with the law, such as complying with a subpoena or other legal process. We may need to disclose personal
information where, in good faith, we think it is necessary to protect the rights, property, or safety of PayGrade, our
employees, our community, or other users, or to prevent violations of our Terms of Use or other agreements. This
includes, without limitation, exchanging information with other companies and organizations for fraud protection or
responding to government requests or summonses.
-
Sharing with PayGrade Companies: Over time, PayGrade may grow and reorganize. We may share your personal information
with affiliates such as a parent company, subsidiaries, joint venture partners, or other companies that we control or
that are under common control with us, in which case we will require those companies to agree to use your personal
information in a way that is consistent with this Privacy Policy.
-
Change of control: In the event that all or a portion of PayGrade or its assets are acquired by or merged with a third
party, personal information that we have collected from users would be one of the assets transferred to or acquired by
that third party. This Privacy Policy will continue to apply to your information, and any acquirer would only be able to
handle your personal information as per this Privacy Policy (unless you give consent to a new policy). We will provide
you with notice of an acquisition within thirty (30) days following the completion of such a transaction, by posting on
our homepage or by email to your email address that you provided to us. If you do not consent to the use of your
personal information by such a successor company, you may request its deletion from the company.
In the event that PayGrade goes out of business, or files for bankruptcy, we will protect your personal information, and
will not sell it to any third party.
-
With your consent: Other than the cases above, we will not disclose your personal information for any purpose unless you
consent to it. Additionally, as discussed above, we will never sell or rent your personal information to advertisers or
other third parties.
Your PayGrade account is protected by a password. You can help us protect against unauthorized access to your account by
keeping your password secret and confidential at all times.
The security of your personal information is important to us. We work hard to protect our community, and we maintain
administrative, technical, and physical safeguards designed to protect against unauthorized use, disclosure, or access
to personal information.
We make every effort to maintain the security of personal information, and we work hard to ensure the integrity and
security of our systems; however, no practices are 100% immune, and we cannot guarantee the security of information at
all times. Outages, attacks, human error, system failure, unauthorized use, or other factors may compromise the security
of user information at any time. If we learn of a security breach, we will attempt to notify you electronically (subject
to any applicable laws) so that you can take appropriate protective steps. For example, we may post a notice on our
homepage (www.paygrade.io) or elsewhere on the Service. Depending on where you live, you may have a legal right to
receive notice of a security breach in writing.
You can always decline to share personal information with us, or even block all cookies. However, it is important to
remember that many of PayGrade’s features may not be accessible or function properly.
PayGrade aims to provide you with easy access to any personal information we have collected about you. If that
information is incorrect, we give you easy ways to update it, or to delete it, unless we have to keep that information
for legitimate business (e.g., we need at least an email address for your account) or legal purposes.
Upon request, PayGrade will provide you with information about whether we hold any of your personal information, and if
you are a user of PayGrade, you may request access to all your personal information we have on file by contacting us at
support@paygade.io. In some cases, we will not be able to guarantee complete access due to legal restrictions. For
example, you will not be allowed to access files that contain information about other users or information that is
confidential to us. We may not be able to fulfill requests that are unreasonably repetitive, require disproportionate
technical effort, or would be extremely impractical.
You can delete your account at any time by contacting us at support@paygade.io. If you are a school, teacher, or
student, you can delete your account anytime by logging into your account and deleting your profile from the profile
options.
When you delete your account, we delete your profile information and any other content you provide in your profile (such
as your name, username, password, email address, and profile photo).
If you are the parent or legal guardian of a student who has created a PayGrade account and you do not want your student
to have a PayGrade account, talk to your teacher about alternatives or to have him/her delete your child’s account
and/or email us at support@paygade.io.
We only keep a student’s personal information for as long as his or her student account is active for the school year –
unless we are required by law to retain it, need it to ensure the security of our community or our Service, or to
enforce our Terms of Use. More specifically, PayGrade operates a 3-tier student data protection policy to protect all
students’ information (3-Tier Student Data Protection Policy):
-
Minimal information: As mentioned before, PayGrade collects the minimal amount of information from students necessary to
create accounts on our Service: we ask students to provide just the unique student code given by their teacher, a
username, a name, and a password.
-
One-year deletion policy for account profiles and transaction history: To protect students, PayGrade sets limits on how
long students account profiles and transaction history is retained. Teachers can also delete students individually or
the entire class by entering their password.
-
Deleting inactive accounts: If a student’s account is not in use for twelve months or more (meaning there have been no
logins), PayGrade will automatically delete the student account, including all personal information about that student.
Teachers also have the ability to delete their students from their account by logging into their account and then typing
in their password to confirm that they would like to delete all of their students. PayGrade strongly encourages teachers
to delete all student data at the end of their time with that student to help protect student data.
We store your personal information for as long as it is necessary to provide products and Services to you and others,
including those described above. Personal information associated with your account will be kept until your account is
deleted.
Please note that we may have to retain some information after your account is closed, to comply with legal obligations,
to protect the safety and security of our community or our Service, or to prevent the abuse of our Terms of Use. You
can, of course, delete your account at any time, as stated above.
The Service may now or in the future include social media plugins, such as Facebook, Twitter, Pinterest, or Instagram.
These social media plugins may collect your IP address, which page you are visiting on our site, and may set a cookie to
enable the plugin to function properly. Social media plugins and widgets are either hosted by third parties or hosted
directly on our website. Your interactions with these social media plugins are governed by the privacy policy of the
company providing each social media plugin.
We may occasionally update this Privacy Policy. You can see when the last update was by looking at the “Last Updated”
date at the top of this page. We will not reduce your rights under this Privacy Policy without your explicit consent. If
we make any significant changes, we will provide prominent notice by posting a notice on the Service.
We encourage you to review this Privacy Policy from time to time to stay informed about our collection, use, and
disclosure of personal information through the Service. If you do not agree with any changes to the Privacy Policy, you
may terminate your account by contacting us at support@paygade.io. By continuing to use the Service after the revised
Privacy Policy has become effective, you acknowledge that you accept and agree to the current version of the Privacy
Policy.