Privacy Policy

Last updated: October 1, 2020


This privacy policy is provided on behalf of Behavior Pro, LLC (the “Company”).


This privacy policy has been compiled to better serve those who are concerned with how their Personally
Identifiable Information (PII) is being used online. PII, as used 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 this privacy policy carefully to get a clear understanding of how
Company collects, uses, protects or otherwise handles your PII in association with our BehaviorFlow application
(“App”). As a convenience to our Users, Company is also disclosing how Company uses information captured by
the App.


In addition to certain PII, Company also collects non-personal information, referred to as “Data Points,” that
includes information that does not personally identify you but may include (without limitation) tracking and usage
information about your location, demographics, transaction information, including latitude and longitude in-use
devices (“Location”) and summary statistics of your use of App functions.
The defined terms used in this Privacy Policy have the same meanings as in our Terms and Conditions of Service,
which can be found here: http://w1v.7ed.myftpupload.com/terms-and-conditions/


What personal information does Company collect from the people that visit our website, App or app?
The App automates methods that are part of Applied Behavior Analysis (“ABA”) which include:
1. Motivational Systems
2. Educational Programs
3. Behavior Observations
4. Common Tools
(each a “Method” and collectively “Methods”). The App is designed to be used primarily by students and teachers
(collectively referred to as “Users”).
Students: Company captures the following personal information about students including, first name and last name
initial, email address, password as well as summary statistics about number of Method sessions completed,
comments about performance while the Method is being used and, for Educational Programs, the trends in student
performance over multiple Method sessions.
Teachers: Company captures first and last names, email address, password as well as summary statistics about the
number of Methods created and used.
For all Users, Company also captures the Location of where services are being used. Location information can be
combined with a User’s PII at the User’s option to enable User to establish certain connections with individuals and
organizations within a certain geographic proximity.
Further, the Camera functionality of your computer is enabled with the App to capture relevant information needed
for use with the Services.
Additionally, all information, data, text, software, sound, photographs, graphics, video, messages, comments you
make in our knowledge base or other materials ("User Content"), whether publicly posted or privately transmitted by User will be contained in a database that Company controls.
Collectively, all of the information entered by User or otherwise captured by our App shall be referred to as
“Captured Information.”
When does Company collect information?
Company collects information from you when you register to use the App through the App or on Company’s
website, enter information or Content in the App, and in connection with your use of the App.

How does Company use your information?
Company will use the Captured Information for various commercial purposes including:
● To track student performance over multiple sessions to allow the Services to be personalized and adjusted
to improve student outcomes.
● To be stored with Educational Organizations.
● To improve our App in order to better serve you.
● To send periodic emails regarding our and other third party’s services.


Can you opt-out?
The nature of the Services are such that the sought PII is required for the functioning of the App, if you desire to
opt-out, you may do so by cancelling your subscription in the App Store.
How does Company protect User information?
Company implements a variety of security measures when a User enters, submits, or accesses their information to
maintain the safety of your personal information. Our app is implemented in the Google Cloud Platform and uses the
Cloud Firestore and Cloud Storage products to store user data. Both products are HIPAA compliant and are scanned
regularly. Company has executed a Business Associate Agreement (BAA) with Google as part of our overall
security strategy. No captured information is stored on the Company website. The Company website is secured via
the HTTPS protocol and is scanned regularly.
All information is encrypted in transit. Personal and sensitive information such as passwords and documents are
encrypted at rest. Company does not store any credit card information. All credit cards are processed and stored by
a third-party payment provider (Apple App Store).
Your personal information is contained behind secured networks and, except as stated above, 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. In addition, all sensitive information you supply is encrypted via Transport Layer Security (TLS)
technology, including information sent to the Google Cloud from the app and communication with our website.
All credit card transactions are processed through a gateway provider (Apple App Store) and are not stored or
processed on our servers.


Does Company use “cookies”?
Yes. Cookies are small files that an App or its service provider transfers to your computer’s hard drive through your
Web browser (if you allow) that enables the Apps or service providers systems to recognize your browser and
capture and remember certain information. For instance, Company uses cookies to remember and track your
progress with various Methods within the App. They are also used to help us understand your preferences based on
previous or current App activity, which enables us to provide you with improved services. Company also uses
cookies to help us compile aggregate data about App traffic and App interaction so that Company can offer better
App experiences and tools in the future.
Company uses cookies to:
● Understand and save user’s preferences for future visits.
● Compile aggregate data about App traffic and App interactions in order to offer better App experiences and
tools in the future. Company may also use trusted third-party services that track this information on our
behalf.
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 (like Internet Explorer) settings. Each browser is a little different, so look
at your browser’s Help menu to learn the correct way to modify your cookies.

If you disable cookies, some features will be disabled It can affect the user’s experience, making your app
experience less efficient and some of our services will not function properly.


Third-party disclosure
Does Company disclose the information collected to Third-Parties?
Company may disclose your PII with certain third parties, including school district, specific school, classroom or
other user circle, when you authorize Company to do so.
Third-party links
Occasionally, at our discretion, Company may include or offer third-party products or services (“Third Party Apps”)
on our App. These Third-Party Apps have separate and independent privacy policies. Company therefore has no
responsibility or liability for the content and activities of these linked Apps. Nonetheless, Company seeks to protect
the integrity of our App and welcome any feedback about these Apps.
California Online Privacy Protection Act (“CalOPPA”)
CalOPPA is the first state law in the nation to require commercial Apps and online services to post a privacy policy.
The law’s reach stretches well beyond California to require a person or company in the United States (and
conceivably the world) that operates Apps collecting personally identifiable information from California consumers
to post a conspicuous privacy policy on its App stating exactly the information being collected and those individuals
with whom it is being shared, and to comply with their policy.
According to CalOPPA Company agrees to the following:
Users cannot visit our App anonymously. This privacy policy can be found on the App and on our website
(http://w1v.7ed.myftpupload.com/privacy-policy/). Our Privacy Policy link includes the word ‘Privacy’ and can be easily
found on the page specified above.
Users will be notified of any privacy policy changes when you log in to your account.
Users can log into their account to correct, amend or delete certain information associated with their account,
including but not limited to, PII.


How does our App handle do not track signals?
Company honors do not track signals and do not track, plant cookies, or use advertising when a Do Not Track
(DNT) browser mechanism is in place.
Does the App allow third-party behavioral tracking?
Yes, Company does allow third-party behavioral tracking.
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under 13, the Children’s Online Privacy
Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection
agency, enforces the COPPA Rule, which spells out what operators of Apps and online services must do to protect
children's privacy and safety online. Although Company does not specifically market to children under 13,
Company does market to parents, guardians, teachers and others who may choose to use the App for children under
13.


Information regarding Children Under the Age of 13

Fair Information Practices
The 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.

In order to comply with Fair Information Practices, in the event of a data breach, Company will take the
following responsive action:
Company will email notification to users within 7 business days via the email address associated with their account.
Company also agrees to the Individual Redress Principle, which requires that individuals have a right to pursue
legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires
not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts
or government agencies to investigate and/or prosecute non-compliance by data processors.


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 identifies penalties for
violations.
Company collects your email address in order to:
● Identify your account
● Send information, respond to inquiries, and/or other requests or questions.
● Send information and updates pertaining to any service provided.
● Company may also send you additional information related to your product and/or service.
● Market to you (as part of our mailing list) to offer you products and services of Company or third parties.
To be in accordance with CANSPAM we agree to the following:
● 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 App 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, you can email us at
unsubscribe@behaviorflow.org.
Follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.
You may also unsubscribe from communications at: http://w1v.7ed.myftpupload.com/unsubscribe


Contacting Us
If there are any questions regarding this privacy policy you may contact us using the information below.
Behavior Pro, LLC
info@behaviorflow.org
+1 (908) 907-4226