This Privacy Statement provides information on how Expatiate Communications collects, uses, and protects personal information. Expatiate supports the most critical processes of managing student data on variety of its platforms and we are committed to the highest standards of protection for personal data at all times. When we refer to “us,” “we,” “our,” or “Expatiate” in this Privacy Statement, we are referring to Expatiate Communications and Expatiate Community Foundation.

This Privacy Statement governs all the manners in which Expatiate collects personal information directly from you as an individual. Whether you are a visitor to our website, request a trial of our products or a whitepaper, or any other communication with us (such as attendance at a conference or trade show), this Privacy Statement governs our use of personal information for products and services that we provide directly to you. How we collect information and how we use information may differ based on our relationship with you as an individual. We have identified below the different relationships we may have with you, and our respective use of information we collect.

When a client’s privacy statement/policy governs. If you are an end-user (parent or student, applicant or employee) of our client (a school or school district) and you are using Expatiate products and services through our client (your school or school district), we are considered a “data processor.” In these cases, your school or school district’s privacy statement or privacy notice governs the use of any personal information. Our Privacy Statement does not supersede the terms of any agreements between us and your school or school district (our client), nor does it affect the terms of any agreement between the student and the student’s school or school district.

What Information We Collect and How We Use It

The nature of the personal information we collect and how we use it depends on the context in which we collect that personal information. Please see the section below that applies to you.

A. Website Users.

You may visit our Expatiate website without having to log in or provide any personal information. If you are on a Expatiate website to access a service or product, you may need to log in to make use of the functionality of the particular product or service.

1. Information We Collect
   1. Directly from you. You may voluntarily provide us information when you complete a form or survey on our website or subscribe to our blog or newsletters. This may include some or all of the following categories of information: Name and Role; Job title; Signature; Profession; Social media account name; User name; Telephone Number; Street Address; and Email address.
      • You may also provide information when you register for an account through a Expatiate website to log in to use a product or service.
      If you submit an application or resume, Expatiate will collect and retain the submission, including your personal information and use this information to evaluate you for an employment position only.
   2. Indirectly from you. We collect information about the pages you visit and how you access and use the Expatiate websites using cookies, tracking technologies and other third party analytics tools. Specifically, We and our service providers use cookies and similar technologies such as local storage (HTML5), web beacons, Javascript, and eTags on our websites. This information includes information about the devices you use to access the Expatiate website including unique device identifiers, IP address, operating system, browser, and cookies. Depending on your device settings, we may also collect information about your geographical location and what websites you may travel from to our website. We use this information to better understand our clients and users, so that we may provide more relevant information to you.
   3. Information from third parties. We may supplement the information we collect with information from our affiliates and other third parties that we use to promote our products and services. For example, we may receive information from a third party about how well an online marketing or email campaign performed, or from conference and trade show organizers.
2. We may use the information collected to provide and improve our website services and our products and to analyze usage information for sales and marketing purposes. We also use the information collected to communicate with you in any manner that you have requested. This analysis is necessary to further our legitimate interest in understanding our users and their interactions with us and our websites to best iterate and improve on our websites and communications, and to provide you with content that you have requested. Third party information that we collect from social media may be used to provide you with requested information or our newsletter or contact you regarding our services, opportunities, products, and/or events
3. Where we use third-party analytics tools to help us understand how the our websites are used, these parties will have access to some of your personal information. This includes analytics tools such as Google Analytics. We also share information with our vendors and service providers and other third parties for legal or business purposes, but only as permitted and subject to required limitations.

B. Clients (Local Educational Agencies

If you are a client of Expatiate, we are providing our products and services directly to your school or school district and we only access data for purposes connection with the client accounts.

1. Information We Collect
   1. Directly from you. We collect information necessary to provide the educational services as directed by you. The information collected from you depends on the specific product and what is needed to integrate with your systems and to set up and maintain accounts. This includes information in the following data categories:
      • Account information: The exact elements will depend on the product and what specific information you as a client provide us, but often we receive from you include pupil records of students and parents of students enrolled in your school or district, such as directory information, email addresses, student IDs, account credentials, courses students are enrolled in, health information kept in student records.
      • We also collect employee account information including user names email addresses and titles to initially set up products and services for you.
      If you only.
   2. Indirectly from you. We collect device and usage information when you access and use our products and services, including information that your browser or the mobile app sends when you are using it. This data may include your unique device identifier, IP address, your browser type and configuration, the date and time of your use of the product or service and cookie data. Specifically, we and our service providers use cookies and similar technologies such as local storage (HTML5), web beacons, Javascript, and eTags. The purpose of collecting such information is for improvement of our products and services to better meet the needs of our clients and their users
   3. Information from third parties. We may receive information from our affiliates and other third parties. For example, we may receive limited personal information from third-party services that integrate with or complement the Expatiate products or services in order to provide you with the best possible user experience.
2. We use your information to provide you the features and functionality of the Expatiate products and services, as well as to communicate directly with you and allow you to communicate with other Expatiate users. It is necessary for us to use your information in this manner in order to provide you with the services your school district has requested pursuant to its agreement with Expatiate. We will use your information to provide you with news and information about new products and services. Any such marketing communications from us may be discontinued at any time. For absolute clarity, we do not provide any student data or personally identifiable information to any Partners.
3. We share information to provide the Expatiate products and services to you and further improve them. Within Expatiate, your information will be accessed only by those who have a need to provide the Expatiate products and services. We use vendors to help us provide the Expatiate products and services to your school or school district. For example, if your school or school district has a hosted Expatiate product or service, Amazon Web Services and Azure provide our cloud hosting facilities. Third-party analytics tools may also have access to your personal information to help us understand how the Expatiate products and services are being used.
4. Expatiate protects any student data with at all times and with respect to student personal information and the Expatiate client (school or school district) is the data owner. Where a Expatiate client enters into an agreement with Expatiate to provide products and services, that Expatiate client acknowledges that Expatiate is a data processor with respect to personal information received from that Expatiate client or from a student/parent in connection with the Expatiate products and services.
   1. Student Personal Data Ownership All student personal data remains the property of and is solely owned, and thereby controlled, by our Expatiate clients. You grant Expatiate a non-exclusive, royalty free license, to use equipment, software, your data or other material of yours solely for the purpose of providing, maintaining, and supporting you and other licensees with Expatiate products and services. Expatiate will only use student personal data for the purposes of providing the products and services that our clients (school or school districts) have contracted with us to provide and we will process student personal data according to instructions and the terms of our contract with our clients. Student personal data will never be used for targeted Advertising by Expatiate or any of its affiliates.

C. Data Retention

1. Website Users
   We keep website usage information for as long as necessary for the purposes described above. Account information is retained until you delete the account and for a limited period thereafter. Where you have provided information in forms, we retain the information as long as it is required, depending on the nature of the request. If you unsubscribe from receiving marketing communications from us, we will keep a record of this to ensure that you do not receive such communications in the future.
2. Customers (Schools and School Districts)
   We keep information collected on behalf of our clients for as long as necessary and pursuant to contractual terms. We dispose of information that is not held pursuant to contractual terms in a commercially reasonable time period or at the request of a client.

D. Student Privacy

We do not knowingly collect any information from children under the age of 16 unless and until the Expatiate client (school or school district) has provided authorization for a student under 16 to use the Expatiate products and services and for us to collect personal information from such student.

Please contact us at info@excomweb.com if you believe that we have inadvertently collected personal information from a child under 16 without proper consent. This will allow us to delete such information as soon as possible.

E. Security

Expatiate employs a variety of physical, administrative, and technological safeguards that are designed to protect personal information against loss, misuse, and unauthorized access or disclosure. We strive to continuously enhance our technical and operational security measures. Our measures consider the type and sensitivity of the data being collected, used, and stored, and the current state of technology and threats to information. Expatiate’s security measures include data encryption, firewalls, data use and access limitations for personnel and vendors, and physical access controls to our facilities. Expatiate independently verifies its security management system to the internationally recognized standard for security management and holds ISO 27001 certification. Expatiate also aligns its privacy and security operations to best practices and relevant international regulations.

F. United States Federal and State Education Privacy Laws

Expatiate, in its role as a vendor to educational agencies and institutions, both public and private entities (“Educational Agencies”), receives disclosures from the Educational Agencies, which include the personal information and other data (“Student Data”) contained in student records as well as directly from students and parents of students. Only information that is needed for Expatiate to perform services, which are outsourced to Expatiate by the Educational Agencies, is disclosed to Expatiate. These disclosures are authorized by the federal Family Educational Rights and Privacy Act (FERPA). Expatiate considers Student Data to be strictly confidential and do not use Student Data for any purpose other than improving and providing our products and services to the Educational Agencies or on the Educational Agencies’ behalf. Our collection, use, and sharing of Student Data is governed by our contracts with the Educational Agencies, the provisions of FERPA, the Children’s Online Privacy Protection Act (COPPA), and other applicable state and federal laws and regulations that relate to the collection and use of personal information of students. If you have questions about reviewing, modifying, or deleting personal information of a student, please contact the relevant Educational Agency(ies) directly.

G. Your California Privacy Rights

If you are a California resident, California Civil Code Section 1798.83 allows you to request information on how we disclose personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. You may make one request each year by emailing us or writing to us (see address below in “CONTACT US”).

H. Links to Other Sites

Our Expatiate websites may provide links to third party websites or resources. The information practices of those websites are not covered by this Privacy Statement or any other policies or terms applicable to the Expatiate websites or the Expatiate products or services. We recommend that you review any terms of use and privacy policy of any linked third party website before providing any information.

I. Changes to This Privacy Statement

We may update this Privacy Statement and its last updated date to reflect changes to our data governance practices. If we propose to make any material changes, we will notify you by means of a notice on this page prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

J. For U.S. Educational Agency Customers

Pursuant to state law, the following state specific language is hereby incorporated into this Privacy Statement, provided that Expatiate is providing and/or offering you Expatiate products or services in one of the following states (capitalized terms below which are not otherwise defined in this Privacy Statement are as defined either in the applicable state law or in your Expatiate agreement)

California - Expatiate will not use your data for any purpose beyond the indicated purposes in the Terms of Use, which includes this Privacy Statement. This includes, but is not limited to, Expatiate’s policy to never any personal identifiable information from a Pupil’s Records to engage in targeted advertising.

K. Contact Us

If you have any questions or concerns about your privacy or this Privacy Statement, please email us at info@excomweb.com

You may also write to us at:

Expatiate Communications
155 N Lake Ave, Suite 800
Pasadena, CA 91101 USA