About this Privacy Policy

At Wakelet, the privacy of you and your students is very important to us.

We do not sell any personal information to advertisers or third parties.

We only share data with third parties when necessary to provide and improve the service - never for advertising or to monetize that data.

As stated in our terms and conditions, Wakelet does use your personal information for certain stated purposes, such as providing and improving the service and communicating with Registered Users (but not anonymous users).

Our Privacy Policy below describes what information we collect from you, how we use that information, and the legal basis we have to process your information.

This Privacy Policy governs how Wakelet Limited (“we” or “us”) a limited company incorporated under the laws of England and Wales with company number 07483296 and with its registered office and main trading address at Wakelet, Bright Building, Manchester Science Park, Pencroft Way, Manchester M15 6GZ, United Kingdom uses and shares personal information collected by our website at Wakelet.com, the Wakelet mobile app, and any associated services and content (the “Service”). We are the data controller in respect of any information we collect about you on or through Wakelet.

This policy only applies to us and to our Agents and how we will use your personal information. Please be aware that once personal information has been posted on Wakelet this will be visible to the public (unless you tell us that you do not want it to be publicly available) and we cannot control what other Wakelet users do with any information you share on or through Wakelet. Be careful with your own information and what you are willing to share.

The Definitions at the end of this Policy set out the meaning of any capitalised words used in this Policy.

1. Wakelet is a Curation and Collaboration Platform

Wakelet is for both public and private use. Whenever you add Content through Wakelet that is not created as a private display it will be public, and when you provide us with User Content or make User Comments on a non-private collection it is published so that anyone can view it.

For users signed up to the Wakelet Individual and Wakelet Individual Pro plans, Content published and shared publicly is accessible to everyone, including search engines, and you may lose any privacy rights you might have regarding that Content. In addition, information shared publicly may be copied and shared throughout the Internet, including through features native to Wakelet Services, such as commenting and embedding.

If you are a teacher or parent who is using Wakelet with or for children under the age of 13, then you should ensure that children are registered onto an Education or Education Pro plan, and that you have selected the privacy controls available to you. If we become aware that children are posting content on Wakelet that is publicly accessible, then we can require verifiable parent or teacher consent as a condition to continue public access or, in the absence of such consent, convert the postings to private use.

2. Information Wakelet Collects and how it is used

Wakelet may collect personal information from Registered Users as described below.

3. Information We Share

Wakelet does not sell User personal information.

We never share information we receive from you unless:

• We have your permission to share that information

• We have given you prior notice that the information will be shared, and with whom

• That information is aggregate information or other information that does not identify you

4. The Purposes for our use of your information

We collect, use and share the data that we have in the ways described above:

• As necessary to fulfil our Rules and Terms of Service

• To provide the Service, including updating, securing, troubleshooting and providing support

• To improve, develop and personalise the Service

• To send the User information including confirmations, technical notices, updates, security alerts, and support and administrative messages

• To identify specific Users in our system

• To comply with applicable laws, including website accessibility laws that may require transcription of audio or other methods to make User content available on the Service

5. Information Security

All information provided to us is stored on our secure servers. Where we have given you (or you have chosen) a password to access certain parts of Wakelet, you are responsible for keeping this password confidential and not sharing it with anyone. It’s important for you to prevent unauthorized access to your account and personal information by choosing and protecting a strong third-party service password and by limiting access to your computer and browser by signing off after you have finished using Wakelet. We will never email you to ask for your password or other Account Information; if you receive such an email, send it to us so that we can investigate and take any appropriate action.

We have put appropriate security measures in place to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to only those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information under our instructions and they are subject to a duty of confidentiality.

While we use reasonable efforts to protect your personal information, we cannot guarantee its absolute security. We have put in place procedures to deal with any suspected data breach and will notify you, and any applicable regulator, of a breach where we are legally required to do so.

If Wakelet becomes aware of a systems security breach by an unauthorized party or that any user data was used for an unauthorized purpose, we will comply with relevant state and other data breach laws. We will notify users of any breach resulting in unauthorized release of data electronically within 72 hours, at minimum, and without unreasonable delay so that you can take appropriate steps. The notification will include: date of the breach, the types of information that were subject to the breach, general description of what occurred, and steps Wakelet is taking to address the breach.

6. Data Retention

We store the information we collect only for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

We store the information we collect from Registered Users for as long as you have an Account and for 14 days thereafter. After this time, it will be purged from our data store and caches. Logs may contain some user information and are retained for up to 30 days. The incremental back-up system of the AWS Dynamo data store can roll back tables over a time period of up to 35 days. Therefore, data is completely erased after 49 days. Anonymous aggregated analytic data is held in Google Analytics indefinitely.

We store the information we collect from Users (without a Wakelet account) for 30 days, until logs are cleared. Anonymous aggregated analytic data is held in Google Analytics indefinitely.

We periodically cleanse all information stored and will delete your IP address 30 days after collection.

For users who are a part of a school or district paid plan (Education or Education Pro) as part of their institution, we provide the opportunity for them to transfer their account to a personal account to take with them should they leave the school or district (for example a student who has built a digital portfolio on Wakelet), with the permission of their school or district. To authorise and provide instructions on the handover of accounts, please email support@wakelet.com and a member of the team will assist. If permission for transfer of their data is not granted, Wakelet will follow the instructions of the school or district on termination of their contract.

Users undertaking a free trial will be given an option at the end of that trial to upgrade to retain their content generated during the trial, or end the trial and return to their free account. At the end of the free trial period if the user does not upgrade, all data generated in the trial will be deleted.

7. GDPR

Under the General Data Protection Regulation, you have the right to access, rectify, port and erase your data.

You also have the right to:

• Request access to your personal information and receive a copy of the personal information we hold about you to check we are processing this lawfully

• Request that the personal information we hold about you is corrected or updated

• Request that personal information we hold about you is erased. You can exercise this right where we have no good reason for continuing to process your personal data (subject to any legal reasons for needing to continue holding the personal data)

• Object to our processing of your personal data where we are relying on a legitimate interest or are processing for direct marketing purposes

• Restrict our processing of your personal data

• Request the transfer of your personal data to you or a third party in a structured, commonly-used and machine-readable format

You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us before escalating your complaint.

8. Marketing

We will only send you marketing emails about collections, Users and Content we think may be of interest to you.

Wakelet does not send you marketing communications about third-party products or services. Users may display any content, including advertising, so long as it does not conflict with our Code of Conduct.

You can ask us to stop sending you these emails at any time by using the “Unsubscribe” link in each email.

If you do unsubscribe, we will still use your information to present Content on Wakelet, which we think will be of interest to you, but will not send you messages about these.

9. Information Choices and Changes

Registered Users may access or modify the personal information you have provided to us and that is associated with your account at any time. You can log in to Wakelet and visit your account settings page or email us at admin@wakelet.com to exercise your rights at any time.

We cannot delete your personal information without deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Content from Wakelet or request we do so, please note that User Content might have been copied or stored by other users. Please note, if you are part of an Education or Education Pro plan, User Content created by the group is owned by that group and any of these Users can request for the content to be deleted.

If you want to delete your user account, you can do this in your account settings page. Given the sharing, commenting, and dialogue that takes place on Wakelet, some of the public activity on your account prior to deletion may have been copied to third-party servers outside of our control and so may remain accessible to the public indefinitely.

10. COPPA and Students

General provisions for Children over the age of 13:

You must be over the age of 13 to be a Registered User of Wakelet as part of our Individual or Individual Pro plans.

Children under 13 years of age may only use Wakelet under the supervision of a responsible adult (over the age of 18) who has agreed to our Terms and the provisions in respect of their responsibilities as a 'Group Registered User', as part of an Education or Education Pro plan. We do not send any marketing messages or advertising targeting children under the age of 13. In order to create an account in Wakelet we require every user to verify that they are not under 13 years of age, and we do not permit children under the age of 13 to create an account.

We expect that use by children will only be done with the guidance, supervision and consent of their parents, guardians and/or authorized school officials. Further, we rely on parents and guardians to ensure minors only use the Service if they can understand their rights and responsibilities as stated in our Rules, Terms and this Privacy Policy. We encourage parents to educate their children about safety online and to carefully monitor their children's use of social features to ensure they do not disclose their personal information through them.

We at Wakelet as a data processor are compliant with COPPA (Children Online Privacy Protection Act) and FERPA (Family Educational Rights and Privacy Act). We encourage schools and teachers to be aware of these regulations and not share any Children's or Student's PII outside of a Wakelet Classroom. If Schools prefer to collect parental consent directly from the parent or guardians that is at the Schools or Teachers discretion. Again, please do not disclose or share any Students personal identifiable information. For more information on complying with COPPA, see the Federal Trade Commission's website at http://www.ftc.gov/privacy.coppafaqs.shtm

If you are outside of the United States, please ensure that you are complying with any laws applicable to you before using Wakelet with students.

If you become aware that your child has provided us with personal information without your consent, please contact us at privacy@wakelet.com. If we become aware that a child under 13 has provided us with personal information without verification of parental consent, we will take steps to remove such information and terminate the child's account. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.

K-12 Educators:

Children that are under the age of 13 that are associated with an Educational Entity, follow the parental consent process through the policies and procedures established by the Educational Entity.

Prior to a student submitting any information within a School setting by accessing Wakelet's online classroom, the Teacher must certify that he/she received permission and either a) chose to act as an agent of the Parent and consented on Parents behalf under what is commonly referred to under COPPA as school consent or b) collected the appropriate parental consent.

Teachers and the onboarding process for Students in an Educational environment are as follows, as part of our Education and Education Pro plans.

Teachers can invite students under the age of 13 as follows as the Student accounts created as part of the Classrooms feature are private and they have limited features for use in a classroom environment. For example, Students with one of these "private accounts" will, by default, not be able to use certain features embedded in the service that are not suitable for students under 13, including YouTube and Twitter. Students imported in this way cannot publish any content publicly or make any content publicly available. Students in this online classroom environment only share their class work and profiles with other students in the same classroom.

Teachers should ensure that they do not publish information containing Student data within their own collections (which can be made public) without relevant consent.

Process for creating student accounts and Classrooms (legacy users)

The teacher can go to the 'Classrooms' area and import a class of students by using one of the available single sign-on apps.

Once the classroom is imported, the system will create individual student accounts for everyone in the online classroom. The Student can then login using their usual single sign on details. Only the teacher will have the ability to create the Student Account as well as sharing and monitoring any of the content in the online classroom. Teachers will also have the option of removing any of the students or adding new students to the online classroom.

Our Data Handling, including, collection, involves specifically:

• first name and last name

• E-Mail address

• other student ID

• date of birth

• school name

• teams/clubs

• photographs, video or audio file

• browser type

• access time

• time spent on Wakelet App

• page views

• referring URLS

• grade year

Process for creating student accounts and Classrooms (Education and Education Pro users)

All student accounts for these plans will be created through a rostering tool such as Clever or Classlink. Once this data connection has been established with the school or district, students will be set up within secure classroom environments and will be able to log in via the chosen single sign on method.

The school/district administrator will have access to a dashboard view of all of the accounts created and set sharing permissions and integrations by age group as well as view analytics and monitor usage within individual accounts as required.

Should you or your parent have any questions, concerns or requests about these COPPA provisions of this Privacy Policy and are a User or parent of a User of an Educational Entity, you should as a first level of support, contact the administrator at the Educational Entity. If questions, concerns or requests are not addressed by the administrator at the Educational Entity, you or your parent should, as a second level of support, contact us as follows:

If you have any questions about this Privacy Policy or wish to contact us, please contact support@wakelet.com. You can reach Wakelet by post at:

Wakelet Limited
Bright Building
Manchester Science Park
5 Pencroft Way
Manchester
M15 6GZ
United Kingdom

Our data protection manager can be contacted at DPManager@wakelet.com

11. Spaces (legacy users)

Spaces is an built-in feature of Wakelet accessible to legacy users which provides a streamlined way to organize a collection, Learning Project, Research Project or create any Spaces for the purpose of formulating rich content in an online environment.

A teacher may create Spaces for collaborative activities in the Wakelet Spaces feature. If invited Users are Students, they would be able to create their own collections with the supervision of the Teacher.

Students may be invited to join as a member of a Space by the teacher in one of the two methods described below:

1) The Teacher can provide a link to join by sharing this with the Student through a Student/Parent email account.

2) The Teacher can provide a Spaces Code to the Student/Parent by an in-Class Slip or an Email Account of the Student/Parent.

Once the Student has joined and become a member of the Space, the Teacher will be involved in the creation of the Collections prepared by individual students. Students submissions to the Space will be supervised and approved by the teacher. The Space will be marked as Private by the teacher in the Profile Visibility Setting. Only the Teacher will have the ability to control this setting in the Space.

12. Rights of California Residents

Under California Civil Code sections 1798.83-1798.84, California residents have the right to request a list of all third parties to which we have disclosed personal information during the previous year for direct marketing purposes. Wakelet does not share users' personal information with third-party marketers.

If you are a California resident, you can request a list of personal information about you we have disclosed to third parties in the preceding calendar year, as well as the names and address of those third parties. You may make such a request only once per year, and you don't have to pay for it. To make a request, send an email to support@wakelet.com or send a written request to Wakelet, Bright Building, Manchester Science Park, Pencroft Way, Manchester M15 6GZ, UK.

13. Changes to this Policy

We may make changes to this Privacy Policy from time to time. If we make changes to this Privacy Policy that we believe will materially affect your rights, we will provide at least 30 days prior notice before any changes take effect, except that we may make changes necessary or advisable to improve security or comply with law without prior notice. If you are a Registered User, we will notify you of these changes via email and/or by asking you to review and acknowledge or accept the changes to this Policy the next time you login to Wakelet. Otherwise, for non-material changes, the Privacy Policy will be updated on the Service. You should consult this Policy regularly for any changes.

14. Contact Information

If you have any questions about this Privacy Policy or wish to contact us, please contact support@wakelet.com. You can reach Wakelet by post at:

Wakelet Limited
Bright Building
Manchester Science Park
5 Pencroft Way
Manchester
M15 6GZ
United Kingdom

Our data protection manager can be contacted at DPManager@wakelet.com

Wakelet participates in the iKeepSafe Safe Harbor program. If you have any questions or need to file a complaint related to our privacy policy and practices, please do not hesitate to contact the iKeepSafe Safe Harbor program at COPPAprivacy@ikeepsafe.org.

15. Definitions

Here are some definitions of capitalized words we use in these Terms:

"Agents" means service providers, consultants and other third-parties and agents not employed by us.

"Content" means any information, text, graphics, photographs, images, illustrations, logos, tools, written posts, executable files, scripts, software, interactive features, creative expression, data or other information materials generated, provided, uploaded, downloaded, appearing or otherwise accessible on or through Wakelet.

"Interactive Services" means message boards, chat rooms, personal web pages or profiles, forums, bulletin boards and other interactive features.

"Registered User" means a User who has registered and created an account to use Wakelet.

"Service" means Wakelet.com and all other domains, products, applications, services and Content provided by Wakelet.

"Terms" means these terms of agreement between us and you.

"User" means any person or entity using Wakelet.

"You" means you, whether you are a person or someone acting on behalf of an entity you are authorized to represent, and whether you are a Registered User or not.

"User Comments" means any comments, recommends, feedback, likes, or other Content posted by Users that is not included in the body of a Wakelet post.