Effective Date: April 6, 2016

Mosyle Corporation (“we” or “us”) the company that owns and operates the http://screen.guide website (“Site”) and the ScreenGuide mobile application (“ScreenGuide App”) provides this Privacy Policy to better explain our practices concerning the information we collect from you when you use the ScreenGuide’s Services as described in our Terms of Use, including how we use and protect that information, how long we retain it, and with whom we share it.

By using ScreenGuide’s Services, you consent to our collection and use of your information as described in this Privacy Policy.

For the purposes of this Policy, the term “Users” refers to registered parents or guardians of the ScreenGuide App and Services, and “Monitored Users” refers to children and other individuals of mobile devices that will be monitored by Users.

1.1. Information We Collect. We collect the following types of information:

(a) Personally identifiable information (“PII”) you give us: PII is information that personally identifies one individual from another. As a User, you voluntarily provide us this information when you establish an account on the Service. As of the effective date of this Policy, to establish your account we only ask you to provide your email address and password. Once your account is established, you will be asked to provide a nickname of your choice, and a name for your family, as well as a nickname of your choice, gender and dates of birth of the children whose mobile device use you intend to monitor through the Services. It’s not necessary to provide a nickname (either for you, family of children) that corresponds to a real name. We strongly encourage you to provide nicknames in a way that allows only you and your family members to identify each other. Finally, when you log on to your account, we will record your geo-location, IP address and/or unique mobile device identifier and may tie it to your specific account. Under ordinary circumstances, an IP address recorded in isolation is not PII under the standard definition of the term. However, it may become PII when it is combined with other information, as in this case. We do not collect personal information from Monitored Users when they are fewer than 18 except where COPPA authorize us to collect personal information without verifiable parental consent. For this reason, the login of Monitored Users is always made by a code generated by us based on the nickname provided by a User. Our Service is not intended to be managed by Users under the age of 18. If we become aware that a person managing the Services and submitting information is under 18, we will delete the information as soon as possible. According to our Terms of Service, all users that manage the Service represent that they are at least 18. Please note, that if your child indicates that he/she is not under the age of 18 (or 13), your child WILL NOT be blocked from using our Services. In addition, if your child provides us feedback or contacts us (for support, for example), we will collect the data included in the communication. We use this personal information to assist your Child with his/her query or support request and then delete such information once we have fulfilled the Child’s query or support request.

2. (b) Usage Information:

Usage Information consists of information that is anonymous in nature and does not identify you as an individual. We get Usage Information from Users and Monitored Users. This includes the unique mobile device identifier, browser type, ISP or carrier name, and other persistent identifiers. This information gives us insights on how you and other users use the Services.

We additionally collect some special information necessary to provide the Services based on the nature of the user:

Users: we also collect information about your usage of our Service, including (i) geo-fence locations; (ii) requests of app install; (iii) requests of app removal; (iv) frequency and duration of some features; and (v) content of your blocked apps lists;

Monitored Users: we also collect several information about the mobile devices assigned to a Monitored User including (i) list of all apps installed on each device, including the date of installation; (ii) geo-location while ScreenGuide App is being used and while it is in background; (iii) device info, including but not limited to device name, serial number, model, storage, version and status of operation system, battery level, and any additional and potential information that we can get through mobile device management features; (iv) time of use per app installed.

3. (c) Cookies:

When you visit our Site we use cookies, or similar technologies like single-pixel gifs and web beacons, to record log data. We use both session-based and persistent cookies. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire. They are unique and allow us to do site analytics and customization, among other similar things. If you access our Site through your browser, you can manage your cookie settings.

2. How we use PII.
We use the PII we collect from and about you to enable us to interact with you on a personal level, and to enable you to better use the Services. We may also use PII for the following purposes: (a) to verify your eligibility for our Services; and (b) to otherwise perform functions associated with our Services. We use your email address to contact you regarding your account. We may also send you emails that may be of interest to you. You may stop receiving emails from us by clicking the unsubscribe link at the bottom of the email.

3. 3. How we share PII.
We will not sell, rent, or share PII with third parties outside of our company without your consent, except in the following ways:

(a) One feature of Services is to enable teachers to monitor and control the devices of their students over a set period of time. If your child’s teacher desires to utilize the Services in this fashion, he or she must first obtain your consent. If you provide consent, the teacher can have access to your PII;

(b) If requested or required by law enforcement authorities, courts, or regulators, we may disclose any information we have about our users. We also may disclose your PII to exercise or protect legal rights or defend against legal claims;

(c) We sometimes contract with other companies and individuals to perform functions or services on our behalf, such as software maintenance, data hosting, sending email messages, etc. We necessarily have to share your PII with such third parties as may be required to perform their functions;

(d) In some cases, we may choose to buy or sell assets. In these business transfers, customer information, including PII, is typically one of the business assets that are transferred. Moreover, if all or substantially all of our business assets were acquired, or in the unlikely event that we go out of business or enter into bankruptcy, customer information (including your PII), would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any assets may continue to be used according to your PII as set forth in this Policy;

(e) We may reserve and have the right to disclose any information about you or your use of our Service without your prior permission, if we in good faith believe that such action is necessary to: (i) protect and defend the rights, property or safety of our company or its affiliates and other users of the Services, or the public; or (ii) to enforce this Policy.

4. How we use and share Usage Information. We use the Usage Information for the following purposes: (i) to monitor the effectiveness of our Service; (ii) to monitor aggregate metrics such as use and demographic patterns; and (iii) to diagnose or fix technology problems reported by our Users or our employees; (iv) to provide usage trends reports (“Trends”) to support recommendation and statistics to our Users. The Trends will never use PII or nicknames and/or mobile line numbers, and will only be based on general information such as gender, age and geo-location combined through our algorithms with Usage Information. Also, we reserve the right to use the Usage Information to: (i) create, publish and sell any kind of public or private reports and other informational content that we believe can be interesting for our company; (ii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Services; or (iii) for any other business or marketing purposes decided by us.

5. How we protect your information. We take the security of your PII seriously and use appropriate technical and organizational measures to protect your personal information against unauthorized or unlawful processing and against accidental loss, destruction or damage. We also limit access to PII to employees who reasonably need access to it to provide products or services to you, or in order to do their jobs. However, because no security system can be 100% effective, we cannot completely guarantee the security of any information we may have collected from or about you.

6. How long we keep information. We retain PII for as long as your account is active, or otherwise as long as necessary to fulfill a business purpose or comply with a legal request. We may also choose to anonymize certain of the information you provide to us so that it can no longer be attributed to you if we would like to retain it for longer periods of time. We retain the Usage Information for how long we believe it can be necessary or relevant for our company.

7. Your choices about your information.
You may decline to provide PII, in which case we will not be able to establish your account or provide our Services to you. You may modify your account information, update or amend your personal information, or change your password at any time by logging in to your account.

8. Children under 13.
Our Services are not intended to be managed by individuals under the age of 13. If we become aware that person managing our Services and submitting information is under 13, we will delete the information as soon as possible. According to our Terms of Service, all users that manage our Services represent that they are at least 18. Please note, that if your child indicates that he/she is not under the age of 13, your child WILL NOT be blocked from using our Services.

9. Changes to this Privacy Policy.
We reserve the right to change, modify, add or remove portions of this Privacy Policy, without advance notice to you. We will notify you of any such changes by posting a notice on our Site, ScreenGuide App, and/or via email. The new Privacy Policy will reference the effective date at the top of this page together with a link to previous versions. Except as stated elsewhere, such amended terms will be effective immediately and without further notice. Your continued use of the ScreenGuide App after the posting of changes constitutes your binding acceptance of such changes.

10. Questions.
If you ever have any questions about our online Privacy Policy, please contact us. We respect your rights and privacy, and will be happy to answer any questions or concerns you might have. You may direct any such questions to us via email at [email protected].