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Platform & Service
Verge is the name of a solution offering from Verge Learning, Inc. In this policy, we refer to our teletherapy platform, content, and services as “Verge” and to the Verge Learning, Inc.. entity as “Company”, “our” or “we.”
SCOPE OF POLICY
This Policy describes the types of information we may collect, or that you may provide, when registering with, accessing or using Verge. This Policy does not apply to information we collect offline or on any other Company websites (such as our company site at www.vergeusa.com) or to information that you may provide to, or is collected by, third parties.
ROLE OF SCHOOL AND SCHOOL OFFICIALS
Although the balance of this Policy will focus largely on what we do — and what we confirm we will not do — with information entered in Verge, we believe schools and school officials are critical partners in our collective efforts to protect and ensure only appropriate use of student-related information entrusted to them and to us. In that regard, it is important that schools and school officials using Verge be mindful that in granting or allowing access to Verge, they are controlling who has access to student information. When we reference “granting or allowing access,” we are referring to both intentional actions, such as an administrator authorizing a Verge account for a staff member, as well as unintentional actions or consequences that may flow from, for example, allowing students access to Verge login credentials or a school’s failure to maintain sufficient data governance or security practices. In cases where FERPA applies (more below), access to certain student information remains the legal responsibility of the applicable school. In all situations, it is incumbent upon our customers to make an affirmative determination prior to furnishing access to anyone that the party has a legitimate need for access to Verge and the sensitive information that may be accessible to that party through Verge.
INFORMATION ABOUT STUDENTS
FERPA AND EDUCATION RECORDS
Although the Family Educational Rights and Privacy Act, or FERPA, was enacted roughly 40 years ago, and certainly well before internet-based services became ubiquitous in academic settings, one of its core tenets was and remains the protection of the privacy of personally identifiable information (often called “PII”) in students’ education records. As defined in FERPA, “education records” are “those records, files, documents and other materials which (i) contain information directly related to a student; and (ii) are maintained by an educational agency or institution or by a person acting for such agency or institution.” PII from education records includes information, such as a student’s name or identification number, that can be used to distinguish or trace an individual’s identity, either directly or indirectly through linkages with other information.
FERPA generally requires that educational institutions and agencies that receive certain federal funds (for example, public schools) get prior consent from a parent before disclosing any education records regarding that student to a third party. Consequently, if you are using Verge on behalf of an educational agency or institution and FERPA applies, before you enter, upload or access any data concerning a minor student, you must confirm that your agency or institution has (1) obtained appropriate consent from the parent or guardian of that student or (2) determined that one of the limited exceptions to the consent requirement applies. You can find more information on FERPA and related guidance at www2.ed.gov/policy/gen/guid/fpco/index.html, and a summary of the limited exceptions at http://ptac.ed.gov/sites/default/files/FERPA%20Exceptions_HANDOUT_horizontal_0.pdf.
Although we hope it goes without saying, we will only use PII from students’ education records to enable school officials and parents to access and use Verge. Unless a school official expressly instructs otherwise, we will not share or reuse PII from education records for any other purpose. While we think those statements are clear, to avoid any doubt, we will not use student PII to target students or their families for advertising or marketing efforts or sell rosters of student PII to third parties.
COPPA AND CHILDREN UNDER THE AGE OF 13
Some people tend to link (and sometimes confuse) FERPA and COPPA. The intent of the Children’s Online Privacy Protection Act, or COPPA, is to give parents control over commercial websites’ and online services’ collection, use and disclosure of information from children under the age of 13. Many assume COPPA applies to all internet-based services, regardless of the identity of the end user. When Verge is used as intended by school officials, clinicians and parents, although that use may involve information relating to students under 13, we do not collect from the student PII nor do we market to the student users, therefore, COPPA does not apply.
INFORMATION ABOUT AUTHORIZED USERS
We collect information from and about you when you provide it to us, and automatically when you use Verge. (Again, “you” refers to an authorized adult user such as a school official or staff member, not students.)
INFORMATION YOU PROVIDE TO US
When you register with or use Verge, you are expected to provide certain PII about you, such as first and last name, email address and associated school or organization. You may also be asked to provide certain PII or other information as a means of validating that you are who you say you are. In addition, you may be asked to provide information from time-to-time to assist with ongoing support and maintenance; this may include information like records and copies of your correspondence (including email addresses and phone numbers) if you contact us.
AUTOMATIC INFORMATION COLLECTION AND TRACKING
When you access and use Verge, it may use technology (such as cookies, discussed further below) to automatically collect:
certain details of that access and use, including traffic data, location data and logs, and
information about your computer or other device and internet connection, including the device’s unique device identifier, IP address, device location, operating system, and browser type.
With respect to technology that automates this information collection and tracking, we may use the following on Verge’s web pages and in emails from us to you:
cookies, which are small files placed on the hard drive of your computer or other device, and
small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us to, for example, count users who have visited those pages or opened an email and for other related statistics.
THIRD-PARTY INFORMATION COLLECTION
As discussed further under Disclosure and Retention of PII, we may use third-party providers to support elements of the Verge’s infrastructure or functionality. These providers may, like us, use automatic information collection technologies to enable or streamline certain features they are providing on our behalf. In all cases, these providers will be contractually bound to us to keep PII confidential and to only use it in order to fulfill their responsibilities to us.
HOW WE USE YOUR INFORMATION
We will use information that you, as a school official or authorized staff member, provide through Verge to (as applicable):
provide Verge and any other products or services you may request from us,
give you notices about your subscription, including expiration and renewal notices,
carry out our rights and responsibilities under agreements between us and your school or organization, and
notify you of changes to Verge (including substantive changes to this Policy or other user policies).
DISCLOSURE AND RETENTION OF PII
Except as expressly set forth below and under the Third-Party Information Collection heading above, and only in those limited circumstances, we will not disclose any PII relating to students, parents, staff members or school officials to third parties without your consent or the consent of your associated school or organization.
We may disclose PII to those contractors and other service providers that we use to support our business. These may include individuals (such as data scientists and software developers) and commercial vendors that provide or support elements of Verge’s infrastructure or functionality. In all cases, these providers will be bound by contractual obligations to keep PII confidential and to use it only for the purposes for which we disclose it to them.
If a third-party were to purchase all or most of our ownership interests or assets, or we merge with another organization, it is possible that we would need to disclose PII to the other organization following the transaction, for example, were we to integrate Verge with the other organization’s product offerings. To the extent any such transaction would alter our practices relative to this Policy, we will give our customers advance notice of those changes and any choices they may have regarding PII.
We may also disclose PII to comply with a court order, law or legal process (including a government or regulatory request), but before we would do that, we would provide the applicable school with notice of the requirement so that, if the school so chooses, it could seek a protective order or other remedies. If after providing that notice we remain obligated to disclose the demanded PII, we will disclose no more than that portion of PII which, on the advice of our legal counsel, the order, law or process specifically requires us to disclose.
We will retain PII for as long as the applicable organization maintains its Verge subscriptions in good standing. Once those subscriptions lapse or terminate, unless a written agreement between us and a school provides otherwise, we will retain PII for up to 12-months, after which time it will be destroyed. Any retained PII will of course remain subject to the restrictions on disclosure and use outlined in this policy for as long as it resides with us.
Finally, although we outlined earlier in this Policy what constitutes PII, we also want to be clear what information is not PII. Once PII, whether relating to a school official, staff member, parent or student has been de-identified, that information is no longer PII. PII may be de-identified through aggregation or various other means. The U.S. Department of Education has issued guidance on de-identifying PII in education records at http://ptac.ed.gov/sites/default/files/data_deidentification_terms.pdf. In order to allow us to proactively address customer needs, we anticipate using de-identified information to improve Verge products and services. That said, we will use reasonable de-identification approaches to ensure that in doing so, we are not compromising the privacy or security of the PII you entrust to us.
We have implemented measures designed to secure PII from accidental loss and from unauthorized access, use, alteration and disclosure. Among other things, PII is encrypted in transit to and from Verge using SSL technology. In addition, all PII is stored on secure servers behind firewalls by our hosting providers. Consistent with guidance from the U.S. Department of Education that storing sensitive education records within the United States is a “best practice”, all the servers used by Kickboard are located in the United States. All that said, unfortunately, the transmission of information via the internet is not completely secure and, although we do our best to protect PII, neither we nor any other hosted service provider can absolutely guarantee the security of all personally identifiable information.
2007 W Hedding St, Suite 214 San Jose, CA 95128 (800) 982-9430 email@example.com
Ⓒ 2020 Verge Learning, Inc. All Rights Reserved.
Verge is the name of a solution offering from Verge Learning, Inc.. In this policy, we refer to our teletherapy platform, content and services as “Verge” and to the Verge Learning, Inc. entity as “Company”, “our” or “we.”
YOUR USE OF VERGE IS SUBJECT TO THIS ACCEPTABLE USE POLICY
You will not attempt to obtain an account fraudulently (for example, by providing fake contact information).
You will not take any actions intended to compromise the security of Verge.
You will not attempt to alter, disable, interfere or work-around any aspect of Verge’s features or technology.
Once you do have a legitimate account, you must not share your login credentials with others or take other actions that jeopardize the security of Verge data.
Verge is protected by copyright and other intellectual property laws and is owned by the Company. By granting you access rights, you are acquiring a limited license to use Verge for its intended, non-commercial, educational purposes. You may not copy all or portions of Verge or attempt to reverse engineer any aspect of the program.
Anything you enter or otherwise provide through Verge is your “User Submission.” Either you or your organization (depending on your organizations’ policies) own your User Submissions.
You commit that you will not enter or otherwise provide through Verge any data, content or materials that you don’t own or have appropriate rights to use, or anything that is unlawful or defamatory.
2007 W Hedding St, Suite 214 San Jose, CA 95128 (800) 982-9430 firstname.lastname@example.org