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Privacy Policy

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This Privacy Policy describes how Edge Factor Inc. (“Edge Factor”, “We”, or “Us”) collect, use, and share your personal information.

We are committed to protecting your personal information and satisfying all applicable legal requirements, including the Children’s Online Privacy Protection Act (“COPPA”), PIPEDA (Personal Information Protection and Electronic Documents Act), and the Family Educational Rights and Privacy Act (“FERPA”), through our compliance with this Privacy Policy. If any translated version of this policy conflicts with the English version, the English version will prevail.


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Edge Factor is committed to the following principles when collecting, using, and sharing your personal information:
  • We take the protection of your information seriously.

  • We do not use any personal information from students in Primary/Secondary (K-12) schools to send targeted ads.

  • We store user data on servers located in Canada and the United States.

  • We maintain a security program reasonably designed to protect the privacy, security and confidentiality of your personal information against risks through administrative, technological, and physical safeguards.

  • We do not sell your personal information to third parties.

  • We do not share your personal information with others except in compliance with this Privacy Policy.


This Privacy Policy was last modified on July 2, 2021.

Edge Factor (“we”, “our”, “us”) understands that privacy is important to people who visit our website ("Site Visitors"), to schools or organizations who use our Service ("Schools"), and to students whose information we may access on behalf of a School ("Students"). This policy describes how we collect, receive, use, store, share, transfer, and process your Personal Data. It also describes your choices regarding use, as well as your rights of access and correction of your Personal Data.

This Privacy Policy applies to the information and data collected by Edge Factor through any of its products and services, including but not limited to our website (the “Site”) our business and education services, and any, electronic publications, newsletters and/or announcements (collectively, the “Services”). This Privacy Policy is incorporated into and forms part of our Terms of Use, which outlines the terms and conditions you agree to when using our Site and Services. We will only collect, use and disclose your personal information in accordance with this Privacy Policy.

If you are a minor, and reside in the EU or USA, you may only use the Site and Services and disclose personal information with your parent or guardian’s express consent. Please read this Privacy Policy carefully with your parent or guardian and confirm that they acknowledge and agree to the terms of this Privacy Policy.

By using our Site and Services and supplying your personal information, you acknowledge that you have read and understood this Privacy Policy, and you agree and consent to the collection, use, disclosure and other processing of your personal information as outlined in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use our Site or Services or supply your personal information to us.



1. Use of the Services

Our online Service allows users (typically schools, post secondary institutions, companies, and workforce development organizations) to help students and job-seekers make an informed career decision. The Content added to the Service, either by Users or by Edge Factor, provides users an extensive library of learning objects that will guide students and job-seekers on their career journey. The information added to the service, either by users providing their User Data or when a User adds the information, is stored and managed on our service provider’s servers. Edge Factor provides the Service to our users for their own career exploration and workforce development needs.


2. Personal information of children

When someone accesses and interacts with our website, we may automatically collect certain information about those visits (see the “Information Collected Through Technology” section below).

For the protection of children’s privacy, we require parental consent from users who wish to use our Services and have not reached the age of majority in their country of residence. Edge Factor does not knowingly collect any information except as previously described from minors (“Student Data”) unless and until the School from which Edge Factor is collecting information (the “School”) provides such information to Edge Factor. Because Edge Factor collects and uses Student Data at the direction of and under the control of a School, Edge Factor relies on each School to provide appropriate notice, where legally required, to parents of the School's use of third party service providers such as Edge Factor, and for the School to obtain all required consent and authorization for Edge Factor to collect student data, as permitted by the Children's Online Privacy Protection Act (COPPA) and other applicable laws.

If a minor has provided us with personal information without parental or guardian consent, the parent or guardian may contact us. We will remove the information and unsubscribe the child. Where required by applicable law, we may ask children for consent from their parents or guardians before we allow them to create a user account or provide a product or service to them.

If you are a minor and have not obtained the consent of your parent or guardian to use the Services, please do not send us any personal information about yourself or use the Services .

If you are a School, you represent and warrant to Edge Factor that you have obtained all necessary consent to the collection, use, and disclosure of any Student Data that you transmit to Edge Factor in any form, and that you will keep such consent current.

Please contact us at info@edgefactor.com if you believe we have inadvertently collected personal information of a minor without proper consent so that we may delete such data as soon as possible.



3. What Personal Information do we collect?

Personal information means any information about an identifiable individual. Anonymous Data means data that is not associated with or linked to any individual’s personal information or will not permit the identification of individuals. This includes data about how users interact with the Services, if anonymized.


Students & Child Data

Through the course of providing its Service to a School, Edge Factor may have access to Student Data that is provided by the School, another organization, by the parent or guardian, or by the Student. The types of Student Data we collect may include:
  • your full name;

  • email address;

  • grade;

  • the School you attend and the city and state/province in which you go to school;

  • all content that you create or share in video, text, images, and other media files that you provide on or through the Services, or that are provided on your behalf; and

  • any other personal information you provide through the Services.

When a School provides Student Data to us, Edge Factor has access to Student Data for the purpose of performing Services on the School's behalf. In some instances, Edge Factor receives Student Data only from the School and never interacts with the Student directly. In some instances a School may allow Students to create their own user account or login using an authentication method such as Google, Clever, or D2L.



General User Data

We ask for certain information when someone creates a subscription for our Services, when you add a user (i.e. Administrator or Educator) to your account, or when you corresponds with us online, including:
  • full name;

  • email address;

  • phone number;

  • role;

  • if applicable, the grade and subject you teach;

  • school/organization name;

  • if applicable, school district;

  • if applicable, industry;

  • school/organization address;

  • your organization/school’s website;

  • if applicable, size of the student population;

  • all content that you create or share in video, text, images, and other media files that you provide on or through the Services, or that are provided on your behalf; and

  • any other personal information you provide to us through the Services.

We may also collect information provided by a School if the School sends us a message, posts content to our website or through our Service, or responds to emails or surveys. Once a School begins using the Edge Factor Service, we will collect content and information provided by the School through the School's use of the Service and we will keep records of activities related to the Service.



4. Why do we collect your Personal Information?

We collect, use and disclose your personal information in order to provide you with our Services. We also collect, use and disclose your personal information to comply with legal and regulatory requirements and as otherwise may be permitted or required by applicable laws. We will only use the personal information that we collect for the purposes for which it was collected. We collect your personal information for the following purposes and in accordance with applicable laws:
  • to provide you with access to our Services;

  • to establish and maintain commercial relations with you;

  • to identify and contact you when you request our Services;

  • to respond to your questions that you send by email or through our Site;

  • to contact you about the Services, including notifying you about updates;

  • subject to applicable law, to notify you about other services provided by Edge Factor, which may be of interest to you;

  • subject to applicable law, to provide you with newsletters and articles;

  • to customise the appearance of the Site and Services displayed to you;

  • to obtain your feedback regarding our Services, including our surveys;

  • to track behavioural information on the Site to serve similar content to you upon future visits;

  • to improve the Site and help us develop new services, apps, tools and Site features;

  • to support our business functions such as internal business processes; and

  • to meet any legal or regulatory requirements.

If you are a Student or parent, please contact your School if you have questions about the School's use of technology service providers like Edge Factor.



5. When do we collect Personal Information?

We may collect your personal information when you voluntarily provide it to us by using our Services. For example, we may ask you to provide personal information when you:
  • use our Site and our Services;

  • register, update or create an account directly on our Site;

  • sign into your account;

  • send us a question or comment by email or phone;

  • register to receive newsletters, articles and updates about our services; and

  • otherwise participate in features of our Site and our Services that ask for personal information.

We also collect personal information when your school or organization provides it to us so that it may be uploaded to the Services and to your account.

Any personal information you post, use or disclose on a Facebook page, YouTube page or other social networking page or site is subject to that website’s privacy policy, and is not subject to this Privacy Policy.


Third-Party Services

If you link, connect, or login to the Edge Factor Platform with a third party service (e.g. Google, Clever, D2L|BrightSpace), you direct the service to send us information such as your registration and profile information as controlled by that service or as authorized by you via your privacy settings at that service.


6. Limiting collection of Personal Information

We limit the collection of personal information to that which is necessary to fulfill the purposes identified in this Privacy Policy and we collect, use and disclose your personal information in accordance with this Privacy Policy.


7. Compliance with FERPA

FERPA does not require or recognize audits or other certifications, so any academic institution that is subject to FERPA must assess for itself whether and how its use of our Service affects its ability to comply with FERPA requirements. However, Edge Factor has made the following contractual commitments that attest to its compliance:

  1. Edge Factor agrees to be designated as a “school official” with “legitimate educational interests” in user data as defined under FERPA. (User Data would include any student records provided through a school’s use of Edge Factor services.) When handling student education records, Edge Factor agrees to abide by the limitations and requirements imposed by 34 CFR 99.33(a) just as school officials do.

  2. Furthermore, Edge Factor commits to using user data only to provide organizations with its services and compatible purposes, and does not mine user data for advertising.

  3. Edge Factor also contractually commits not to disclose user data except as the educational institution directs, as described in this Privacy Policy, or as required by law. Records provided by Schools are subject to stringent contractual restrictions regarding their use and disclosure.

As a result of these contractual commitments, customers that are subject to FERPA—both educational institutions and third parties to whom they give access to sensitive student data—can confidently use the Edge Factor services to process, store, and transmit that data.



8. How we share your information

Edge Factor only shares personal information in the circumstances described below. We do not rent or sell information for marketing purposes and we will never share or sell Student Data with third parties for marketing purposes.

Who we may share information with:

  1. We share information within the Service as needed to perform the Service and/or at the direction of the School. For example, information including Student Data, will be shared between and among authorized School users such as Instructors and School Administrators. This sharing will depend on the settings and functionality selected by the School.

  2. Some elements of our Service enable Schools to interact with parents, students, instructors, and third party applications, for the benefit of the student’s education. Edge Factor facilitates sharing of Student Data with third parties on the Service when the School has authorized a third party or application to access Student Data through the Service.

  3. We may share information with our trusted third party service providers who perform technology services on our behalf (i.e. web hosting and analytics services), but strictly for the purpose of carrying out their work for us. Contractors and service providers who may have access to Student Data in the course of performing their services are subject to confidentiality and data security requirements. These service providers are prohibited from using your Personal Data except for these purposes, and they are required to maintain the confidentiality of your information. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and user data handling policies. Examples of these third-party service providers can be found in our DPA.

  4. We may be required to share information with law enforcement or other third parties when compelled to do so by court order or other legal process, to comply with statutes or regulations, to enforce our User Agreement, or if we believe in good faith that the disclosure is necessary to protect the rights, property or personal safety of our users.

  5. We may share information in an aggregated and/or anonymous form that does not reasonably identify an individual or School. For example, we may use and share aggregate or anonymized data to study and improve our Service, user functionality, and product offerings.

  6. We may share your information when otherwise requested or permitted to do so by you.

How we transfer data we collect:

International Transfers within Edge Factor’s Entities

To facilitate our global operations, we may transfer information to either Canada or the United States and allow access to that information from countries in which the Edge Factor Affiliates have operations for the purposes described in this policy.

This Privacy Policy shall apply even if we transfer Personal Data to other countries. We have taken appropriate safeguards to require that your Personal Data will remain protected. When we share information about you within and among Edge Factor’s Affiliates, we make use of standard contractual data protection clauses, which have been approved by the European Commission. Edge Factor will process European Data in compliance with the Privacy Shield Principles.


International Transfers to Third Parties

Some of the third parties described in this privacy policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share information of customers in the European Economic Area or Switzerland, we make use of a variety of legal mechanisms to safeguard the transfer, including the European Commission-approved standard contractual data protection clauses or other appropriate legal mechanisms. For transfers to or from the United Kingdom, we make use of the standard contractual clauses. Please contact us if you need more information about the legal mechanisms we rely on to transfer Personal Information outside the EEA, Switzerland and the United Kingdom.

Privacy Shield Notice

Edge Factor, Inc. is responsible for the processing of personal data it receives under each Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. Edge Factor complies with the Privacy Shield Principles for all onward transfers of personal data from the EEA, the United Kingdom, and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Edge Factor is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Edge Factor may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

EU, United Kingdom and Swiss individuals may direct any inquiries or complaints related to our Privacy Shield compliance to privacy@edgefactor.com. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Information in accordance with the principles contained in this Policy. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please visit https://ec.europa.eu/info/about-european-commission/contact, where you can find the relevant DPA and/or Commissioner contacts for more information or to file a complaint (free of charge).

Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.


In the event of a change of control or sale of the business:

We may transfer any Personal Information that we have about you in the event that we merge with or are acquired by a third party or should any such transaction be proposed. We will not transfer the personal information of our customers unless the new owner intends to maintain and provide the Service and unless the new owner has agreed to data privacy standards no less stringent than our own.


9. How we store and protect your information

Storage and processing:

We store user data on servers located in Canada and the United States. For more information on how we store and process Personal Data please refer to our Data Processing Agreement.

Keeping information safe:

Edge Factor maintains administrative, technical and physical procedures to protect information stored in our servers. Access to information stored on our servers is limited (through user/password credentials) to those employees who require it to perform their job functions. We use industry-standard encryption technology to safeguard the account registration process and sign-up information in-transit. We have implemented technologies to ensure that stored data is encrypted at rest. Other security safeguards include but are not limited to device encryption, firewalls, and physical access controls to buildings and files. Please refer to the ‘Security Measures’ section of our DPA for more information.

Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us.

We take reasonable steps to verify your identity before granting you access to your account on our Site, however, you are solely responsible for maintaining the secrecy of your username, password and any other account information. We also take reasonable steps to ensure that our employees are aware of the importance of maintaining the confidentiality of personal information and that unauthorized persons do not gain access to personal information that we have disposed of or destroyed.


Data Breach Response Plan

In case of a Personal Data breach, Edge Factor shall promptly take remedial measures to terminate the breach and to mitigate any possible damages. Edge Factor will notify your organization or district by email of any information security incident that may impact the processing of the Personal Data covered by our Privacy Policy, without undue delay after discovering or becoming aware of such incident by contacting the individual who purchased the membership (either in writing or by phone). Edge Factor will provide the following information when reporting a security incident: the date and time the breach was discovered, the nature of the Personal Data Breach including where possible, the categories and approximate number of Data Subjects concerned and the categories and approximate number of Personal Data records concerned, the known and expected consequences of the breach, the measures taken by Edge Factor to address the breach, the measures taken by Edge Factor to limit the consequences of the breach, and contact information for further information about the breach and any other relevant information the district/school may reasonably require.


10. Choices about your information

Account information and settings:

Schools may update account information and modify Services by signing in under an administrator’s account. Schools and other website visitors can opt-out of receiving promotional emails from us by clicking on the “unsubscribe” feature at the bottom of each email. You cannot unsubscribe from Service-related messaging while you are using the Services.

If you have any questions about reviewing or modifying account information, visit our Contact Us page.


How long we keep User Data:

We retain your personal information only for as long as we need it to fulfill the purposes for which it was collected, to ensure your compliance with our User Agreement, and to comply with our legal obligations.

User Data collected during your use of the Service is retained in accordance with the provisions of the DPA and is retained for as long as you have a Subscription and/or remain an active user on the platform. Your data is deleted upon your written request or after an established period following the termination of all agreements. In general, Customer Data is deleted after your paid Subscription ends and your user account becomes inactive.


How long we keep User Content:

Following termination or deactivation of an account, your Organization profile page and any content that your Organization has posted will no longer be visible to the public. Unless otherwise requested, Edge Factor may retain your Organization’s subscription history, profile page, and any posted content (i.e. Career Profile, Program Profile, etc.) allowing you to quickly restart your Organization’s Subscription. However, any and all personal information associated with your Organization will be deleted promptly.


11. Links to other sites

We are not responsible for the practices employed by websites, applications or services linked to or from our Service. Other sites may collect and treat information collected differently. We encourage you to carefully read and review the privacy policy of each site you visit.


12. Information collected through technology

Tracking Technologies

Like most websites and online services, we and our third party partners automatically collect certain types of usage information when you visit our Services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, file information and similar technology (collectively, "Tracking Technologies"). For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account, and other such information. We also collect information about the way you use our Service, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, how frequently you access the Service, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, and other actions you take on the Service. When you access our Service from a mobile device, we may collect unique identification numbers associated with your device or our mobile application, mobile carrier, device type, model and manufacturer, mobile device operating system brand and model. We may be able to determine your approximate location by analyzing other information, like an IP address to associate a user with their School. This allows us to prioritize local content for users. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service. We use a variety of tools to do this, including Google Analytics. You can learn more about how they safeguard data Here. We also use HubSpot to manage outgoing communications. You can learn more about HubSpots commitment to privacy Here. We do our best to honor the privacy preferences of our visitors, we are not able to respond to Do Not Track signals from your browser at this time.

Cookies and related technology allow us to provide you with a better user experience. For example, we may use the data collected through cookies to: (a) remember information so that a user will not have to re-enter it during subsequent visits; (b) provide custom, personalized content and information; (c) to identify you across multiple devices; (d) to provide and monitor the effectiveness of our Service; (e) monitor aggregate metrics such as total number of visitors, traffic, and usage on our website and our Service; (f) diagnose or fix technology problems; (g) help users efficiently access information after signing in, and (h) otherwise to plan for and enhance our Service.

Cookies

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed an email and performed certain functions with it.

Third Party Tracking

We do not permit third party advertising networks to collect information about your use of our website and Service over time and across websites for the purpose of serving targeted advertising and we will never use Student Data for targeted advertising.

Data Practices and Service Data

We may collect, and we may engage third party service providers, to collect information about your use of the Service, including evaluating how you and your Users interact with and use the Service. We use this information to develop and improve the Services and the Consulting Services, and to inform our sales and marketing strategies. We may share or publish this information with third parties in an aggregated and anonymized manner, but we will not include any User Data or identify Users.

When you use the Service, we automatically collect log files. These log files contain information about a Users’ IT system, a User’s IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times, and referring website addresses. We use this information to ensure the optimal operation of the Subscription Service and for security purposes. We may link log files to Personal Data such as name, email address, address, and phone number for these purposes.

You can log in to our site using a Single Sign-on (SSO) service like your Google or Clever account. This service will authenticate your identity and provide you the option to share certain Personal Data with us such as your name.


Enrichment Data

When you add information about your Organization to Edge Factor we may use certain fields as Enrichment Data. These properties may include information such as company name, company location, and company address. This data is obtained from public and third party sources. We do not use User Data to populate Enrichment Data.


13. Individual access and accuracy of Personal Information

You may request access to your personal information which we may hold by contacting us at the contact information set forth below, and we will respond within the time periods provided for under applicable laws. We will need to verify your identity before providing you with the personal information we hold about you. We may not be able to provide you with access to your personal information if the information cannot be separated from the personal information of others, cannot be disclosed for reasons of security or commercial confidentiality, or is protected by legal privilege. If we cannot provide you with access to your personal information, we will advise you of the reasons access is being denied, unless we are prohibited by law from doing so. If it is possible to separate your information from the personal information of others by redacting it, we will do so before providing you with access.

You may log into your account and update your personal information. In addition, you can request for us to update and change your personal information at the contact information set forth below. We shall endeavor to correct or complete any personal information which you advise us is inaccurate or incomplete. Where appropriate, the amended information shall be transmitted to third parties having access to such information in accordance with this Privacy Policy. If you have any concerns about your information that was provided by your school, school district and/or instructor, please contact these parties directly.



14. Changes to this Privacy Policy

We may modify or update this Privacy Policy from time to time so you should review this page periodically. If we change the policy in a material manner, for example if we seek to use personal information in a materially different way than we had previously, we will provide notice to the Schools so that they have sufficient time to evaluate the change in practice. Of course, you can always opt-out by deleting your account before the changes take effect. Your continued access or use of the Site or Services after any such changes constitutes your acceptance of the Privacy Policy as revised.


15. Your consent to the Terms of this Privacy Policy

By using our Services and providing us with your personal information, you agree that Edge Factor may collect your personal information and you voluntarily consent to the collection, use, disclosure and transfer of your personal information in accordance with this Privacy Policy. If you do not agree with any terms of this Privacy Policy, please do not use our Site or our Services or provide us with any personal information. If you do not understand the nature, purpose and consequences of us collecting, using and disclosing your personal information, please do not use our Site or our Services or provide us with any personal information, and contact us at the contact information set forth below so that we can address your questions or concerns.

Subject to legal and contractual requirements, you may refuse or withdraw your consent for certain purposes identified in this Privacy Policy at any time by contacting us at the contact information below. If you refuse or withdraw your consent, you acknowledge that we may not be able to provide you or continue to provide you with certain services or information, which may be of value to you.



16. How to contact us

We welcome your feedback. If you have questions, comments or concerns about this Privacy Policy, or would like to do any of the following:
  • access your personal information that you have already sent us so that you can correct, update or delete it from our files;

  • if your child is a minor in your country of residence and has used this Site or Services without the appropriate consent and sent us personal information, delete that personal information from our files;

  • ask that we not send you electronic communications or otherwise contact you; or

  • report any violation of this Privacy Policy,

If a Student contacts Edge Factor with a question about our Service, we will collect personal information from that Student only as necessary to respond to the Student's request and direct the Student to contact the Student's School, and we will then delete or anonymize the personal data of the Student after providing our response.

If you have any questions about this Privacy Policy or the Service, you can contact our Privacy Officer (Data Protection Officer) at privacy@edgefactor.com.