Privacy Policy

COMMITMENTS TO PRIVACY

 

Franklin Virtual Schools and its affiliates (collectively, “Franklin“),  respects your privacy and has established this  privacy policy (“Privacy Policy“) to let you know  how we collect, use, manage, share, and protect information that we may  gather when you visit our  website, the websites of our  affiliated schools, or the websites for our student and education management systems (collectively, the “Franklin Sites“), or contact us by phone or other means. This Privacy Policy applies to the Franklin Sites where this  Privacy Policy is posted and to information we gather from you over  the phone, via conventional mail or in person.

 

This Privacy Policy has also  been compiled to better serve those who  are concerned with how  their “Personally Identifiable Information” (“PII”) is being used online. PII, as described in US privacy law and information security, is information that can  be used on its own  or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our  privacy policy carefully to get a clear understanding of how  we collect, use, protect or otherwise handle your  Personally Identifiable Information in accordance with our  website. Franklin reserves the right to change this  Privacy Policy at any time. If we make any
material changes to this  Privacy Policy, we will post any revised Privacy Policy on the Franklin Sites.  The most current version is always available by clicking on the “Privacy Policy” link located at the bottom of the Franklin Sites home page. Any changes to our  Privacy Policy will become effective upon posting of the revised Privacy Policy. BY USING ANY OF THE FRANKLIN VIRTUAL SCHOOL SITES, YOU AGREE TO THE TERMS OF THE PRIVACY POLICY IN EFFECT AT THE TIME OF USE.
IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, PLEASE DO NOT USE ANY OF THE FRANKLIN VIRTUAL SCHOOL SITES.

WHAT LAWS GENERALLY APPLY TO STUDENT RECORDS?

 

The Family Educational Rights and Privacy Act is a Federal law that protects the privacy of student educational records. Briefly, FERPA guarantees that students have the right to inspect and review their records, the right to request amendments, through informal and formal hearings, to their record if they  believe
the information is incorrect, misleading or in violation of their privacy rights and the right to have some control over  the release of PII from their educational records. Students also  have the right to file complaints with the Family Educational Rights and Privacy Act Office concerning alleged failures by the institution to comply with the Act.

Student’s education records will be  protected by Franklin as  required by FERPA
and applicable state laws  regarding the privacy  of student records or PII. We will only  disclose education records or provide access to them in compliance with  FERPA and applicable state laws,  and we will require third parties that
contract with  us  and have access to education records to do  the same. Franklin will not  use PII to target a student for advertising, sell PII or use PII to create
profiles about a student (other than for purposes of the student’s education in a Franklin course or program) when those activities are prohibited by law.
Franklin will not  use, or will seek permission to use, a student’s PII for
purposes unrelated to providing or improving their education where required by law to do  so.  If any  provision of this  Privacy  Policy conflicts with  FERPA or
other federal or state law, Franklin will comply with  the more protective standard for the education records.

 

Franklin does not  serve or otherwise collect  PII from students located in the
European Union  and, therefore, makes no  attempt to comply with  the
European Union  General Data Protection Regulation (GDPR).

 

WHAT IS NOT COVERED?

Under FERPA, schools may  disclose directory information contained in an educational record that would not  be considered harmful or an invasion of privacy if released.

Directory information at Franklin includes, but is not  limited to:
•    Name
•    Address (City and State of Residence Only)
•    Courses and programs
•    Dates of attendance

NON-U.S. USERS

The Franklin Sites are hosted and operated in the United States and are subject to United States law. Franklin does Any personal information that you provide to us is being provided to us in the United States and will be hosted on United Statesservers. You consent to the transfer of your  personal information to the United States in order to receive services from Franklin. If you are accessing the Franklin Sites from outside the United States, please be advised that United States law may not  offer  the same privacy protections as the law of your  jurisdiction.

 

HOW IS INFORMATION RELEASED?

 

Franklin requires written permission from the eligible student, parent or legal guardian to release any other information from a student’s education record, except under very limited conditions. FERPA allows Franklin to disclose those records, without consent, to the following parties or under the following conditions (34 CFR S 99.31):
•    School officials  with legitimate educational interest
•    Other schools to which  a student is transferring
•    Specified officials  for audit or evaluation purposes
•    Accrediting organizations
•    To comply with a judicial  order or lawfully issued subpoena
•    Appropriate officials  in cases of health and safety emergencies

 

The following persons have access to student records: (i) Franklin’s  CEO, administrative team, and professional staff; (ii) the appropriate administrative support staff members and other professionals who  have a legitimate educational or legal interest in student records as designated by the CEO; (iii) educational institutions, organizations or home based education programs with access to the student’s educational records; or (iv) an agent representative of the student or family.

 

All Franklin students are provided a unique password to access online courses. It is the student’s responsibility to keep his/her password in confidence.

 

Franklin (or educational institution, organization or homebased education program with access to the student’s educational records) provides an academic
transcript upon the request of the student, parent or legal guardian.

 

Some schools assign a site facilitator to coordinate online programs, blended learning, or after school and/or supplemental programs, which  may  be provided to help students who  use school labs  to access Franklin courses. Facilitators will haveaccess to students’ online work.  Facilitators may  have access to students’
demographics.

 

WHAT PERSONALLY IDENTIFIABLE INFORMATION DOES FRANKLIN COLLECT?

You can  use portions of the Franklin Sites without divulging any PII. Our site does not collect personal information about students, parents or legal guardians except when such students, parents or legal guardians specifically provide such information on a voluntary basis (for example, when enrolling for a Franklin course or program; requesting additional information by contacting us; signing up for a Franklin in-person event; posting a message to a message board; requesting help; engaging in an online chat; or accessing, adding to, or changing the information on your  account information page on the Student Information System (“SIS”).

 

When a student is registered for a Franklin course or program, we are provided
with information regarding the student, parent and/or legal guardian. This personal information may  be collected on the Franklin Sites, or via telephone, facsimile or conventional mail. The types of information that you may  be asked to provide include, but are not  limited to: first and last name; postal address; telephone number; the student’s names and age;  student registration and enrollment information; and an e-mail address where we can  contact the student, parent and/or legal guardian. If the student is enrolling in one of Franklin’s courses or programs, we may  also  collect debit or credit card information.

 

DOES FRANKLIN SHARE PERSONALLY IDENTIFIABLE INFORMATION?

 

Registration and enrollment information that is provided by the student, parent and/or legal guardian may  be provided to third parties as required by state or federal law.

 

To the extent that third party vendors assist Franklin in the provision of online products or services, those vendors are provided the minimum amount of data required to perform the tasks for which  they  have been engaged, consistent with legal requirements, such as FERPA. They have no independent rights to such data and have agreed to maintain the confidentiality of the data, to use it solely  for the

purpose of performing the school-based tasks for which  they  have been engaged and to safeguard the data as required by law and by contract.

 

Only if permitted by applicable state and federal law, Franklin may  share PII your information with other companies in order to improve the academic performance
of Franklin courses or programs or so that Franklin may  offer  products and services to you. You can  request that your  personal information not  be shared with third
parties by making a request in writing to  [email protected]

 

HOW DOES FRANKLIN USE PERSONALLY IDENTIFIABLE INFORMATION?

 

Franklin may  use the PII to provide educational services to the student enrolled in a course or program, and to otherwise support the student with regard to matters such as testing, academic progress, attendance, customer service, student affairs or for health or safety purposes. The PII is also  used to deliver services to the student or to carry  out activities that the student has requested. Franklin may  also  use PII to protect its own  legal rights.

 

Franklin will use or share PII if required to do so by law, such as a court order, or permitted to do so for law enforcement, health or safety purposes or to protect Franklin’s legal rights. If permitted by applicable state and federal law, Franklin may aggregate PII to improve the educational experience for the student.

 

WHAT NON-PERSONALLY IDENTIFIABLE INFORMATION DOES FRANKLIN COLLECT?

 

Each time you visit our  website, non-personally identifiable information is automatically entered into  an information system. Such information includes your IP address (that is, the unique string of numbers that identifies the device you are using to communicate over  the Internet), the name of the Web page from which you accessed the Franklin Sites, the page or pages you visit on the Franklin Sites, and how  much time you spend on each page.

 

HOW DOES FRANKLIN USE NON-PERSONALLY IDENTIFIABLE INFORMATION?

We use this  information to monitor and improve the Franklin Sites and for internal analysis. In particular, we use IP addresses to analyze traffic  trends, administer the Franklin Sites, and gather information for aggregate use. However, IP addresses, whether alone or in combination with other non-PII, are not  linked to PII.

 

WHEN DOES FRANKLIN SHARE NON-PERSONALLY IDENTIFIABLE INFORMATION?

 

We will neither share nor  sell non-PII to any third party, except that we may  share non-PII: (i) if required to do so by law, such as by a court order, (ii) if permitted to do so for law enforcement, health or safety purposes, (iii) to third parties that use it in connection with providing services related to the education of your  student, or (iv) where permitted, to protect Franklin’s legal rights.

 

DO FRANKLIN SITES USE “COOKIES”?

 

Cookies are pieces of information that a website places on the hard drive  of your computer when you visit the website. Cookies may  involve  the transmission of information from us to you and from you directly to us, to another party on our behalf, or to another party in accordance with its privacy policy. Franklin Sites may use cookies to bring together information we collect about you. You can  choose to have your  computer warn you each time a cookie is being sent, or you can  choose to turn off all cookies. You do this  through your  browser settings. Each browser is a little different, so look at your  browser Help menu to learn the correct way to modify your  cookies. If you turn cookies off, you won’t have access to many features that make your  guest experience more efficient and some of our  services may  not  function properly.

 

HOW DOES FRANKLIN TREAT INFORMATION ABOUT CHILDREN UNDER 13 YEARS OLD?

 

We understand that children who  are under age 13 need enhanced safeguards and privacy protection, as set forth in the Children’s Online Privacy Protection Act (“COPPA”). COPPA protects the information privacy of children under the age of 13 by requiring web  site operators and online services to post privacy policies and obtain verifiable parental consent before collecting information from those children.

The Franklin Sites are not  intended to solicit information of any kind from children under age 13, and we do not  and will not  knowingly contact or collect personally identifiable information from children under 13. The only personal information we receive about children under the age of 13 is information provided by the parent or legal guardian or information provided by the child as part of that child’s participation in a course as part of that child’s education program. By enrolling a child in such course, a parent or legal guardian consents to the collection of that information.

 

It is possible that by fraud or deception by others we may  receive information pertaining to children under age 13. If we are notified of the receipt of information under such circumstances, once verified, we will promptly obtain parental or legal guardian consent, and in the absence of such consent, will delete the information. If you want to notify  us that we have inadvertently received information for a child under the age of 13, please do so by emailing us at [email protected] 

 

WHAT ARE THE STUDENT’S CALIFORNIA PRIVACY RIGHTS?

 

California Online Privacy Protection Act (“CalOPPA”) is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require any person or company in the United States (and  conceivably the world)  that operates websites collecting PII from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared.  Students, parents and/or legal guardians can  visit our site anonymously.

 

WHAT INFORMATION IS COLLECTED OR SHARED ON MESSAGE BOARDS AND CHATS?

 

We may  offer  message boards and chat rooms to you on the Franklin Sites.  Please be aware that anyone may  read your  postings on a message board or in a chat room. Furthermore, all information which  you submit to be posted to a message board or in a chat room will be available to all users of that message board or chat room, and is therefore no longer private. We cannot guarantee the security of such

information that you disclose or communicate online in public areas such as message boards and chat rooms, and you do so at your  own  risk. We reserve the right,  but not  the obligation, to monitor the content of the message boards only and to republish your  postings from message boards or chat rooms elsewhere on the Web or otherwise in any format.

 

WHAT HAPPENS WHEN I LINK TO OTHER WEBSITES, CHAT ROOMS OR RESOURCES FROM FRANKLIN SITES?

 

The Franklin Sites may  contain links to other websites, chat rooms, or other resources that we provide for your  convenience (“Linked Sites“). These Linked Sites are not  under the control of Franklin, and Franklin is not  responsible for the content available on any Linked Site or the actions of any Linked Site. Such links do not  imply Franklin’s endorsement of material on any Linked Site, and Franklin expressly disclaims all liability with regard to your  access to such Linked Sites. Access  to any other websites linked to the Franklin Sites is at your  own  risk. You should review the Privacy Policy that may  be set forth on the Linked Sites as those websites are not  covered by this  Privacy Policy.

 

WHAT IS FRANKLIN’S COMMITMENT TO DATA SECURITY?

 

To reduce the risk of unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure the information we collect. We also  use Secure Sockets Layer (“SSL”) protocol on the student account information and registration pages to protect sensitive personal information. As effective as our  safeguards are,  no security system for data is completely impenetrable. Therefore, Franklin cannot guarantee that the PII supplied by the student, parent or legal guardian will not  be intercepted by others.

 

Student information is contained behind secured networks and is only accessible
by a limited number of persons who  have special access rights to such systems, and are required to keep the information confidential. All transactions are processed through a gateway provider and are not  stored or processed on our  servers.  Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your  visit to our  site as safe as possible.

 

FAIINFORMATION PRACTICESThe Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they  include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how  they  should be implemented is critical  to comply with the various privacy laws that protect personal information.  In order to be in compliance with the Fair Information Practices, in the event of a data breach, we will notify  the student, parent and/or legal guardian via email within  seven business days.
CAN-SPAM  ACT

 

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. We collect the student, parent and/or legal guardian’s email address in order to send information, respond to inquiries, and/or other requests or questions.  In compliance with the CAN-SPAM Act, we will:

 

•    Not use false or misleading subjects or email addresses.
•    Identify the message as an advertisement in some reasonable way.
•    Include the physical address of our  business or site headquarters,
•    Monitor third-party email marketing services for compliance, if one is used.
•    Honor opt-out/unsubscribe requests quickly.
•    Allow users to unsubscribe by using the link at the bottom of each email.

 

If at any time you would like to unsubscribe from receiving future emails from Franklin, please email us at [email protected] we will promptly remove the student, parent and/or legal guardian from future correspondence.

 

WILL THIS PRIVACY POLICY CHANGE?

 

We will occasionally amend this  Privacy Policy to reflect company and customer feedback or changes in the law. We reserve the right to change, modify, add, or remove portions of this  policy at any time. If Franklin materially changes its use of your  personal information, we will announce such a change on our  Franklin Sites, and will also  note it in this  Privacy Policy. If we make any changes to this  PrivacyPolicy, we will post the revised policy. The effective date of this  Privacy Policy is documented below.

 

CONTACT INFORMATION

 

If you have any questions regarding this  Privacy Policy, please contact us by email at [email protected] note that email communications will not necessarily be secure. Accordingly, you should not  include sensitive information in your  email correspondence with us.