Introduction
Welcome! GoGuardian (formally — Liminex, Inc. doing business as GoGuardian) and its family of company Affiliates including Pear Deck, Inc. (“Pear Deck”), Edulastic (formally - Snapwiz, Inc. doing business as Edulastic — referred to throughout as “Edulastic”), Zorro Holdco, LLC dba TutorMe (“TutorMe”), and Giant Steps (“Giant Steps”) (together, Liminex, Inc. dba GoGuardian, Pear Deck, Edulastic, and Giant Steps as “Liminex”, “we”, “us”, “our”) is an educational technology company that provides K-12 schools and school districts, and colleges and universities with digital learning tools designed to supercharge the learning potential of every student. Our Website refers to each of our general-audience, public-facing websites with a main landing page of goguardian.com, peardeck.com, edulastic.com, tutorme.com or giantsteps.app (each, the "Website"). This Website Privacy Policy applies to visitors and users of our Website and explains how we collect, use, share, disclose, and protect information from these visitors and users of our Website ("Website Privacy Policy").
This Website Privacy Policy does not apply to:
- the use of our Offerings (as defined in our Liminex Products Terms of Service and End User License Agreement) by one of our school or school district customers or other organizational customers ("School(s)" or "your Organization"). For more information about how we treat information in our products, please visit our Privacy Policy for Product Users ("Product Privacy Policy"), and, as applicable to Schools in the European Economic Area ("EEA"), our Data Processing Addendum ("DPA"); or
- organizations or third parties that we do not own or manage, or to individuals that we do not employ or manage. For example, there may be links to third parties available on our Website or support center. We encourage you to review the applicable third party privacy policies and terms of use before submitting any information through those sites or services.
- Data submitted as a job applicant to GoGuardian and its Affiliates.
By using our Website, you are declaring that you have read and understand this Website Privacy Policy.
Note About Our General Audience Website: Our general audience Website is not geared towards children, nor meant to be used or accessed by children. If we become aware that we have collected "personal information" (as defined by the United States Children's Online Privacy Protection Act ("COPPA")) from a child in the United States under the age of thirteen (13) without legally-valid parental or school consent or that we have collected data through our Website from an European Union resident under the age of sixteen (16) without parental consent, we will take reasonable steps to delete it or obtain valid consent as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.
THE INFORMATION WE COLLECT AND THE WAYS WE USE IT
Information Provided Directly
We collect the following information directly from you as a visitor of our Website or from your School, if it lists you as a representative:
- Requests for Information: If you submit a request for information or otherwise contact us through our Website, we collect your request and your identifying contact information (for clarity, references to contact information throughout this Website Privacy Policy includes name, email address, phone number and address).
- Chats: We use chat technologies provided by a third-party vendor that employs cookies and software code to operate the chat features you can use to communicate with us. We and such third-party vendors may access and use information about webpages visited on our website, your IP address, your general geographic information (e.g., city, state), and other personal information you share through online chats for the purposes described in this Website Privacy Policy.
- Support Requests: If you submit a support request or question about our Website through our Support Center (e.g., Support Center and Help Center), we receive your request/question and your associated identifying contact information.
- Online Forums: If you use our Website to sign up as a member of our online community, blog, or similar options on our Website, we receive your contact information and your associated messages.
- Partner Submissions: When a partner of a School and/or Liminex (e.g., a reseller partner helping a School obtain equipment and software from Liminex) first signs up as a partner of GoGuardian or submits a request through our reseller portal on our Website, we collect both that partner organization's and partner representative's contact information as well as both the School and School Official's contact information. If you are a School Official or partner representative, then we collect this information about you.
We use contact information, requests for information, support messages, online forums information, and partner submissions for our business purposes, including to:
- provide customer service, provide you support and respond to your requests;
- notify you via email of new features and products that may be of interest to you through updates and marketing communications;
- notify you of company updates and notable events update and marketing communications;
- help secure our Website, prevent fraud and enforce our legal terms; and
- administer and troubleshoot our Website.
Information We Collect Automatically
As you visit or use our Website, we may automatically collect network activity and device usage information including:
- Device information and related identifiers: including your IP address, browser type, browser language, operating system, device identifiers, operating system, the state or country from which you accessed the Website, and software and hardware attributes. From your IP address, we may be able to infer your general location (e.g., city/state or postal code).
- Usage Information: including referring and exit pages and URLs, platform type, the number of clicks, files you download, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Website, error logs, language preferences, and other similar information. This includes analytics information which we collect via Google Analytics and other similar services and information we collect when you click on an advertisement for our products and services on other websites and services. If you then interact with our Website, we may combine the information about your activity with our advertisement with the information we subsequently collect and/or you subsequently submit on our Website.
- Location Information: When you use the Services, we and our service providers collect general location information from your computer or mobile device. “General” location information means information about the city and state in which your device is located based on its IP address. We may also obtain general location when you input your zip code or use location features on the Services, such as to find nearby merchants.
- Cookies: We and our third party partners use Cookies. To learn more about our use of Cookies and your choices about Cookies, please see our Cookies Notice below.
We use the information that we collect through our Website for our business purposes, including to:
- provide you with our Website;
- respond to your requests and provide you with support;
- notify you via email of new features and products that may be of interest to you;
- notify you of company updates and notable events;
- analyze and improve our Website;
- audit and understand the effectiveness of our placement of our advertisements on third party websites;
- remind you of us through advertisements after you have used our Website;
- secure our Website and help prevent fraud and enforce our legal terms; and
- administer and troubleshoot our Website.
How We Disclose Information Collected Through Our Website
We may disclose any of the information collected from our Website in the following ways:
- Third Parties Supporting Our Website: We disclose information with service providers that assist us in performing business-related functions that support or improve our Website. For example, we use hosting services and customer service tools to support our Website. When we employ another company to perform a function of this nature, we provide them with the information that they need to perform their specific function.
- Third Parties that Provide Advertising Services. We may use third party advertising services that collect or receive certain information about you and/or your visit to the Website to provide ads about our products and services on other sites or to measure and analyze ad performance.
- Our Protection and Others: We may share or disclose the information if we believe in good faith that doing so is necessary or appropriate to (i) protect or defend the rights, safety, or property of us or our third parties, including to defend or enforce our Website Privacy Policy, our Website Terms of Service, or our EULA, or any other contractual arrangement or (ii) to respond to claims that content violates the rights of third parties.
- Legal Requirements: We may share or disclose the information if we believe in good faith that doing so is necessary or appropriate to comply with any law enforcement, legal, or regulatory process, such as to respond to a warrant, subpoena, court order, or other applicable laws and regulations.
- With Your Consent / At Your Direction: We also may share or disclose the information collected through our Website with your consent or at your direction.
- Business Transfer: We may share or disclose the information, in connection with or during negotiations of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. If such transfer is subject to additional mandatory restrictions under applicable laws, GoGuardian will comply with such restrictions. The successor entity will be subject to all applicable federal and state laws, including privacy laws.
Data Controller vs. Processor; Our Legal Basis for Using Your Information
Under applicable law, we are considered the "data controller" of information from or about our Website visitors. In other words, we are responsible for deciding how to collect, use, share, and disclose this information.
The laws of some jurisdictions such as the laws of the European Union ("EU") require companies to tell you about the legal ground that they rely on for using, sharing, or disclosing your information. To the extent those laws apply, our legal grounds are as follows:
- Contractual Commitments: We may use, share, or disclose information to honor our contractual commitments to you. For example, to comply with our Website Terms, which you accept by browsing our otherwise using our Website.
- With Your Consent: Where required by law, and in some other cases, we use, share, or disclose information on the basis of your consent.
- Legitimate Interests: In many cases, we use, share, or disclose information on the ground that it furthers our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as customer service, certain promotional activities, analyzing and improving our business, providing security for our Website, preventing fraud, and managing legal issues.
- Legal Compliance: We need to use, share, and disclose information in certain ways to comply with our legal obligations.
How Long We Keep Information
We generally retain information for so long as it may be relevant to the purposes above. We consider the nature and sensitivity of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests in determining how long to retain information. The purposes for which we use information may dictate different retention periods for the same types of information. For example, if you opt out of email marketing, we maintain your email on our suppression list for an extended time to comply with your request. To dispose of any personal information, we may anonymize it, delete it or take other appropriate steps. Information may persist in copies made for backup and business continuity purposes for an additional time period of time.
How We Protect Your Information
We take the security and privacy of your data very seriously. For these reasons, we have implemented various technical, administrative, and physical safeguards to protect your information. These safeguards vary depending on the sensitivity of the information at issue.
We are committed to preventing unauthorized access to our systems and data, and will investigate any possible occurrence. In the event of a breach of personal data, we will comply with all relevant breach laws.
Your Rights and Choices
Privacy Rights
Residents of certain jurisdictions (including the EEA, UK, California, Colorado, and Virginia) may request that we:
- provide access to and/or a copy of certain information we hold about you
- update information which is out of date or incorrect
- delete certain information which we are holding about you
- restrict the way that we process and disclose certain of your information
Please note that your rights may vary depending upon your jurisdiction and be subject to exceptions under law.
To exercise any of these rights, please contact us at privacy@goguardian.com. Authorized agents for California residents may submit requests at: https://www.goguardian.com/ccpa-requests. We may require proof of the written authorization you have given.
We will consider all of your requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include needing to continue processing your information for our legitimate interests or to comply with a legal obligation. We may request that you provide us with information necessary to confirm your identity before responding to your request.
Virginia residents may appeal the denial of a request here: privacy@goguardian.com. We will respond within the legally required time period, including a written explanation of the results of your appeal. In addition to those rights, you may have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.
Privacy Choices: Do Not Sell or Share or Process My Personal Information for Targeted Advertising
Residents of certain states such as California and Virginia and Colorado may opt out of the “sale” of their personal information. Such residents may also opt out of the sharing or processing of their personal information for targeted advertising. Applicable law broadly defines “sale” or “share” in a way that may include allowing third parties to receive certain information such as cookies, IP address, device identifiers, browsing behavior and/or other activity for targeted advertising. As such, we may share or process for targeted advertising to you the following categories of information for such purposes which may be considered a sale: device information and identifiers, such as IP address, and unique advertising identifiers and cookies; connection and usage information, such as browsing history or app usage, geolocation information, such as city; and inference data.
If you or your authorized agent would like to opt out of the use of your information for such purposes, you may do so as outlined on the following page: Do Not Sell My Personal Information.
You may still receive advertising; it just may not be tailored to your interests. Please note, if you use different browsers or devices, you will need to make your choice on each browser or device you want your choice to apply. In some cases, you may also be presented with a form field to complete, in those cases we ask for your email address or other information so we may add it to an appropriate suppression list.
Please note that if you have a legally recognized browser-based opt out preference signal turned on via your device browser (such as Global Privacy Control), we recognize such preference in accordance with and to the extent required by applicable law (in the locations required).
In addition to the rights and choices identified above with respect to specific jurisdictions, you have certain rights and choices with respect to your information such as:
- Marketing Communications: You can decline promotional communications at the point information is requested for such purpose on our Website (e.g., by checking or un-ticking (as directed) the relevant box) or, by following the unsubscribe instructions on communications sent to you. You can also contact us as described in the "How to Contact Us" section below.
- Cookies & Analytics. You can opt out of certain cookie-related and analytics processing by following the instructions in our Cookie Notice below.
- Do Not Track: Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. At this time, we do not recognize or respond to browser-initiated DNT signals, but we do recognize opt out preference signals as set forth above.
If you are a California resident, California law requires us to provide you with some additional information. We collect the following categories of personal information: identifiers (such as your name and email address); internet or other network information (how you interact with the our Website); location information (because your IP address may indicate your general location); inference data about you (for example, what product you may be interested in); and other information that identifies or can be reasonably associated with you (such as your correspondence with us). For more information about what we collect, the sources of such collection, please see the “The Information We Collect and the Ways We Use It” section above. For more information about how we treat information in our products, please visit our Privacy Policy for Product Users.
We collect personal information for the following purposes:
- provide you with our Website;
- respond to your requests and provide you with support;
- notify you via email of new features and products that may be of interest to you;
- notify you of company updates and notable events;
- analyze and improve our Website;
- audit and understand the effectiveness of our placement of our advertisements on third party websites;
- remind you of us through advertisements after you have used our Website;
- secure our Website and help prevent fraud and enforce our legal terms; and
- administer and troubleshoot our Website.
As described above, California law broadly defines “sale” or “share” in a way that may include allowing third parties to receive certain information to enable the delivery of targeted advertising on the or other sites. As such, we may share the following categories of information for such purposes which may be considered a sale (as defined by California law):device information and identifiers, such as IP address, and unique advertising identifiers and cookies; connection and usage information, such as browsing history or app usage, geolocation information, such as city; and inference data.
- If you or your authorized agent would like to opt out of the use of your information for such purposes (to the extent this is considered a sale), you may do so as outlined on the following page: Do Not Sell My Personal Information.
- Shine the Light Disclosure: The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.
We retain your information as long as it is necessary to fulfill the purposes for which we collect it, unless a longer retention is required or permitted by law. We consider the nature and sensitivity of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests in determining how long to retain information. Different processing purposes may dictate different retention periods for the same types of information. For example, if you opt out of email marketing, we maintain your email on our suppression list for an extended time to comply with your request.
Notice to EU and Other Non-U.S. Residents
Our Website is operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to and/or accessed within the United States. The recipients of information described in the relevant "How We Share Information" sections above may be located in the United States. This information may be subject to United States law, including laws that may require disclosure of personal information to government authorities.
- European Union-United States and Swiss-United States Privacy Shield: GoGuardian has certified with the European Union-United States and Swiss-United States Privacy Shield as set forth by the United States ("U.S.") Department of Commerce regarding the collection, use, and retention of "personal data" (as defined under the Privacy Shield principles) from applicable European countries. GoGuardian has certified that we adhere to the Privacy Shield Principles of notice, choice, purpose limitation, onward transfer, security, data integrity, access, recourse, liability, and enforcement for such personal data. To learn more about the Privacy Shield Framework, visit the Department of Commerce's Privacy Shield list by clicking here.
- As required under the principles, when GoGuardian receives personal data under the Privacy Shield and then transfers it to a third-party service provider acting as an agent on our behalf, we have certain liability under the Privacy Shield if both (i) the agent processes the information in a manner inconsistent with the Privacy Shield; and (ii) GoGuardian is responsible for the event giving rise to the damage.
- Other Legal Rights: Some international users (including those whose information we collect under the Privacy Shield) of our Website have certain legal rights to access certain information we hold about them and to request its deletion. For example, some international laws may permit you to:
- request that we provide access to and/or a copy of certain information we hold about you; prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling);
- update information which is out of date or incorrect; delete certain information that we are holding about you; restrict the way that we process and disclose certain of your information; transfer your information to a third party provider of services; and
- revoke your consent for the processing of your information.
Please see the "Choices about Information Collected through Our Website" Section above for more information.
- How to Contact Us for Non-U.S. Residents: If you are located outside the United States and have questions or concerns regarding GoGuardian's Website Privacy Policy or practices, you may direct a complaint in writing to GoGuardian Privacy Officer, Liminex, Inc. dba GoGuardian, 2030 East Maple Avenue, Suite 100 El Segundo, California 90245. Tel: 1-888-310-0410 Email: privacy@goguardian.com. Within a reasonable time of receiving the written complaint, we will review and address your complaint, as appropriate, and inform you of the results of such review and any steps taken to address your complaint.
- Dispute Resolution for EU and Swiss Residents: If you are a resident of the EU or Switzerland and are dissatisfied with the manner in which we have addressed your concerns, you may seek further assistance, at no cost to you, from our designated Privacy Shield independent recourse mechanism, the JAMS Privacy Shield Program, which you can learn more about by visiting https://www.jamsadr.com/eu-us-privacy-shield. Residents of the EU or Switzerland may, in certain circumstances, elect to arbitrate unresolved complaints by invoking binding arbitration pursuant to the Privacy Shield’s Recourse, Enforcement and Liability Principle and Annex I of the Privacy Shield but prior to initiating such arbitration, you must: (1) afford us the opportunity to resolve the issue; (2) seek assistance via GoGuardian's recourse mechanism above; and (3) contact the U.S. Department of Commerce (either directly or through a European Data Protection Authority) and afford the Department of Commerce time to attempt to resolve the issue. Each party shall be responsible for its own attorney's fees. Please be advised that, pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the individual. GoGuardian is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
Cookies Notice
What are cookies?
Cookies are small text files stored on your computer that allow us to understand usage of our Website. Cookies include cookies, Internet server logs, tags, Software Development Kit/SDKs, tracking pixels, and other similar tracking technologies. A number of Cookies that we use last only for the duration of your session, expiring when your session ends (the so-called "session cookies"). Other Cookies are used to help our systems recognize you if you return to our Website and will thus retained longer (the so-called "persistent cookies"). Some of the cookies used on our Website are set by us, and some are set by third parties that are delivering services on our behalf.
What types of Cookies does GoGuardian use and what data do they collect?
We use Cookies on our Website that automatically collect information to:
- understand how many unique visitors frequent our Website;
- analyze usage of our Website, including to improve our Website;
- authenticate your account for our Website services;
- remember your settings and account information for our Website services;
- understand the effectiveness of GoGuardian advertisements placed on third party websites; and
- show you advertisements about GoGuardian after you visit our Website such as our blog.
We do not use any advertising Cookies in our Products and we do not place advertisements in our Products.
What are your choices about Cookies?
You can learn more about how Cookies work and how to turn them off in your particular browsers. Please remember that if you replace, change or upgrade your browser, or delete your Cookies, you may need to use these opt-out tools again.
For information about Cookies used by the developers of these browsers, please visit:
- Internet Explorer
- Google Chrome
- Internet Explorer
- Mozilla Firefox
- Safari (Desktop)
- Safari (Mobile)
- Android Browser
For controls specific to advertising and analytics services offered by Google, click here and here from each of your browsers.
For more information about advertising and how you can turn off certain advertisements in general, please visit youronlinechoices.com and www.youronlinechoices.com.au and www.youradchoices.com.
Changes to this Privacy Policy
We may change this Website Privacy Policy to reflect changes in the law, our information practices, or components of our Website. At the top of our Website Privacy Policy, we will indicate the date of the most recent update to this Website Privacy Policy. Where required by applicable law, we will apply changes only after notifying and/or obtaining your consent before any material changes to our Website Privacy Policy apply to you.
How to Contact Us
If you have questions or concerns, the best way to reach us is by emailing privacy@goguardian.com. You can also reach us by calling 888-310-0410 or by writing to Liminex, Inc. dba GoGuardian, Attn: Privacy Officer, 2030 East Maple Avenue, Suite 100, El Segundo, California 90245.
Additionally, please feel free to consult additional resources such as the ones listed below.
Student Privacy Resource List: