Last updated: May 29th, 2018

This Privacy Policy describes Kami’s privacy practices in relation to information that we collect through the website www.kamihq.com operated by us from which you are accessing this Privacy Policy (the “Website”) and through the software applications made available by us for use on or through computers and mobile devices that link to this Privacy Policy (the “App”).

COPPA

This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”), and outlines our practices in the United States and Latin America regarding children’s personal information. For more information about COPPA and general tips about protecting children’s online privacy, please visit OnGuard Online.

The policies outlined in this COPPA Privacy Policy are intended to supplement the information appearing in our general Privacy Policy. Where the COPPA Privacy Policy conflicts with the general Privacy Policy concerning information about a Child, the terms of this COPPA Privacy Policy will prevail over the general Privacy Policy.

Teacher or schools consent in lieu of a parent

With regard to school-based activities, COPPA allows teachers and school administrators to act in the stead of parents to provide consent for the collection of personal information from children. Schools should always notify parents about these activities.

Kami collects limited personal information from minor students only where that student’s school, district, or teacher has contracted with Kami to provide service, which collects personal information solely for the use and benefit of the learning environment. Kami requires schools, districts, or teachers to obtain parental consent from parents.

If you are a parent and would like more information on parental rights with respect to a child’s educational record under the Family Educational Rights and Privacy Act (FERPA), please visit the FERPA site. If you believe that a student’s school, district, or teacher has not required parental consent prior to our collection of any personal information, contact us at privacy@kamihq.com.

If you are accessing Kami on behalf of a Class, School or District, the following provisions also apply:

  • You represent and warrant that you are solely responsible for complying with the Child Online Privacy Protection Act (COPPA) requirement to secure parental consent for accessing applications which require personal information from children under 13.
  • You must obtain verifiable parental consent (“Consent”) from all parents whose children will be accessing Kami and provide a copy to us upon our request. For more information on COPPA, please see www.ftc.gov/privacy.
  • When obtaining Consent, you must provide parents with a copy of our Privacy Policy.

Personal information

In order to create an account, Kami does require that all users create a username and password, which is stored on the site, and may collect personal information such as name or email, or other information if necessary, depending on the needs of your school or the service. Documents may be uploaded to Kami by users for online sharing or processing.

Please note that children can choose whether to share their information with us, but certain features may not function without it. As a result, children may not be able to access certain features if required information has not been provided. We will not require a child to provide more information than is reasonably necessary in order to participate in an online activity.

Kami collects limited personal information from minor students only where that student’s school, district, or teacher has contracted with Kami to collect personal information for the use and benefit of the learning environment. This information is not shared outside of the school or with any third parties except those needed for the provision of the service as outlined in this policy. Students of any age cannot share their profiles publicly outside of their classroom or school.

Teachers can annotate documents and provide comments to students. Students can annotate documents, submit assignments through your learning management system, add comments and take online tests; Teachers or students can record audio or video and attach these recordings to content in our system. None of this information is shared with any third parties without the teacher or school’s consent.

Cookies and similar technologies

Technologies such as cookies, beacons, tags and scripts are used by Kami. These technologies are used to make it easier for you to navigate our site, to store your passwords so you don’t have to enter it more than once, analyzing trends, administering the site, tracking users’ movements throughout our site and to gather app usage information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

As true of most Web Sites, we gather certain information automatically and store it in log files for trouble-shooting when problems arise. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically-collected data to other information we collect about you.

Kami collects and analyzes data on how the service is used in the aggregate for the purpose of improving and enhancing its service. Kami does not analyze information on how particular individuals use the service as part of general reporting procedures or in the usual course of business. However, information on individual usage of the system, including but not limited to individual IP addresses, may be analyzed on a case-specific basis to respond to a usage information request by the customer who registered for the service, or to resolve a technical difficulty or to assist in resolving or investigating any misuse of the service;

Disclosure and permissions

We do not disclose personal information collected from Children to third parties other than to persons who provide support for the operations of the service and who do not use the information for any other purpose, except as follows:

  • Parents;
  • Teachers & school administrators.

We may disclose any and all personal information collected from a Child to the parent or teacher who registered for the service in connection with such Child.

We may disclose your or your child’s personally identifiable information in connection with business transfers and purchases. As we continue to develop our business we may buy or sell business divisions or companies, we may merge or combine with another company, or our company itself and/or all or a significant part of its assets may be acquired by another company. We may provide any information we have to a potential counter-party in any such potential transaction. If such a transaction is completed, your or your child’s personally identifiable information may be one of the transferred and shared business assets. In the event that information is shared in this manner, notice will be posted on our Site.

In this event this privacy policy will continue to apply unless we contact you and ask you to opt in to any changes before they are implemented.

We reserve the right to disclose your or your child’s personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our Website.

Is the personal information secure?

Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but we cannot guarantee complete security. The transmission of information via the Internet is not completely secure. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

When you enter your information on our site we encrypt the transmission of that information using transport layer security (TLS). Firewalls are used to segregate application tiers and provide strict controls on access to resources within our networks. Your data is also encrypted at rest on the servers hosted by our cloud services partner Google Cloud Platform, which we selected because of their compliance with COPPA, and their stringent security measures, including compliance with the following certifications and third-party attestations:

  • SAS70 Type II audits
  • Level 1 service provider under the Payment Card Industry (PCI) Data Security Standard (DSS)
  • ISO 27001 certification
  • U.S. General Services Administration FISMA-Moderate level operation authorization

Third Party Service Providers

We work with a number of third-party service providers to help improve the quality of our service. These third parties do not share your information with any other third parties.

  • Kami uses the following third-party services in the App:
    • Intercom– Intercom is a platform for our Support Team to provide private customer support communication to our adult users. This service is not provided to users who have registered as students. Our support system is available for users to submit requests or questions to our team. Intercom’s privacy policy is consistent with our own, and our contract with Intercom stipulates that it does not share user information with any other third parties.
    • Google Adsense– The free-to-use, reduced-feature-set version of Kami only is supported by in-app advertising, provided by Google Adsense. No user data is shared by us with Google for the purpose of targeting ads. Furthermore, our app tags ad requests for treatment as child-directed, so that Google delivers only untargeted advertising; remarketing ads are disabled for all ad requests from Kami. No advertising at all is displayed in the paid-subscription, full-feature-set versions of Kami. Our contract with Google requires that it does not share user information with any other third parties. Google has signed the Student Privacy Pledge,  introduced by the Future of Privacy Forum (FPF) and The Software & Information Industry Association (SIIA).
  • Kami uses the following third-party services on the Website:
    • Google Analytics – Google Analytics is an analytics service used to help analyze your use of our Website and allow us to improve communication. We use the information we get from Google Analytics only to improve our Website. We do not use Google Analytics within the App. Our contract with Google Analytics requires that it does not share your information with any other third parties. Google has signed the Student Privacy Pledge.

We will only contract with future service providers that are consistent with this policy or allow users a choice to send information to the future provider.

For more information on any of these third parties please contact us at: privacy@kamihq.com

Review and Deletion of Personal Information

Parents have the right to refuse the site further contact with their child and to have access to their child’s information and to have it deleted by contacting the school administrator.

Parents have the right to consent to the site’s use of the child’s personal information without having to consent to its disclosure of that information to third parties by contacting the school administrator.

If you are the parent and guardian of a student using Kami, and cease to agree with Kami’s terms of use and privacy policy at some point in the future, you may opt-out by contacting your Subscriber (typically your school) Kami administrator if you are an Education account user, or contact us at privacy@kamihq.com if you are an individual account user.

If your or your student’s or your child’s personally identifiable information changes, or if you no longer desire our service, you may correct, update, or delete it by making the change directly in the user profile in the App, or email us at privacy@kamihq.com . We will respond to your request within 30 days.

We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at support@kamihq.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

In any correspondence such as e-mail or mail, please include the child’s username, the school or organization, and the teacher or parent’s email address and telephone number. To protect children’s privacy and security, we will take reasonable steps to help verify a teacher or parent’s identity before granting access to any personal information.

Changes to this Policy

We reserve the right to amend this Privacy Policy at any time. Please check this page periodically for changes.  If we intend to make a material change in the collection, use, or disclosure practices with respect to a Child’s previously-collected personal information to which a parent previously has consented, we will obtain the consent of the teacher or parent who registered for the service in connection with the child to such changes.

Links to Other Sites

If you click on a link to a third-party site, you will leave kamihq.com and be redirected to the site you selected. Because we cannot control the activities of third parties, we cannot accept responsibility for any use of your personally identifiable information by such third parties, and we cannot guarantee that they will adhere to the same privacy practices as Kamihq.com. We encourage you to review the privacy statements of any other service provider from whom you request services. If you visit a third-party website that is linked to the kamihq.com site, you should read that site’s privacy statement before providing any personally identifiable information.

Contact

Have questions or concerns about Kami, our Services and privacy? Contact us at privacy@kamihq.com

Kami Limited

340 S Lemon Ave 9019, Walnut CA 91789, USA

214 Karangahape Road, Auckland 1010, New Zealand

Or Call Us at: +1 (415) 799-7207