Oppti Privacy Policy

(Last updated 9/1/20)

Oppti is a web-based college and career readiness platform for grades 9-12. Oppti helps high school students discover internships, volunteering opportunities, and other work-based learning opportunities, while operating as the system of records for schools and districts.

Your privacy is important to us and we are committed to protecting your information. This Privacy Policy explains how we collect, use and protect information in Oppti. This Privacy Policy must be read together with the Terms of Service.

Data will be protected subject to this Privacy Policy and applicable law, which may be different from the laws in your country. By using Oppti, you agree to this.

Information Provided by Schools and Districts ("Clients"):
When Clients decide to use Oppti, they submit information necessary to create their school or district accounts, including first and last names, ID numbers, email addresses, and passwords for the school and district staff users.

When school and district staff users create their accounts, they are asked to enter the following:

District Users:First name
Last name
Phone Number
Email
Photo (optional)
District Name
Role/Title within District
School Users:First name
Last name
Phone Number
Email
Photo (optional)
District Name
School Name
Role/Title within District

Information Provided by Students:
Students log in and create their own accounts, used for school purposes to allow Clients to view student activity within Oppti. Students are asked for their:

Upon initial sign-in:First name
Last name
Birthday
Age
Phone Number
Email
Grade Level
Graduation Class
School Pathway Teacher (if applicable)
Unique Student ID Number
Gender
After Logging in:Brief Description
Ideal Future Profession
Certifications Earned
Desired Certifications
Awards Earned

Additional information Clients would like to host about their students within Oppti is done at the Clients' discretion for their internal review, analysis and reporting. This may include student personal information and academic records, including student first names, contact information, date of birth and other demographic information, grades, test results and performance data. Clients may also host information about a student's parent or legal guardian, including, but not limited to names, street addresses and other contact information.

A Special Note About Students Under the Age of 13:
Oppti operates in compliance with the Children's Online Privacy Protection Act (COPPA). Subject to the configuration options selected by Clients, students under the age of 13 may be asked to submit personal information. Any such information is used only for their school purposes.

Oppti relies on Clients to provide consent for collection of that data on behalf of the parents or legal guardians, as agreed to in advance by Clients.

Clients may also make any information provided by students under the age of 13 available to parents or legal guardians to review through each Client's product dashboard.

Information Provided by Employers:
Employers and Business Partners must create accounts to post work-based learning opportunities. These users are asked for their:

Prior to Verifying Email:First name
Last name
Phone Number
Email
Photo (optional)
After Verifying Email:Company Name
Company Address
Company Zip
Company State
Company Website
Company Type
Company Industry
Company Logo
Company Description
Role/Title within organization

Oppti Usage Information and Cookies:
When using Oppti, our servers automatically collect the Internet Protocol ("IP") address associated with the user's computer. We may also collect additional information such as login timestamp, the browser type and version, and the operating system of the computer. This information is logged to help us to diagnose technical problems and to administer Oppti.

To collect information about the use of Oppti, we use cookies. Cookies are small data files sent by a website or application and stored on the computer or device at the request of that site or app. Cookies store information related to the browser to enable us to recognize the browser on return visits to Oppti and to remember your preferences. We use third-party service providers to assist us in collecting and understanding the usage information. Most browsers can be set to detect browser cookies and to let you reject them, but refusing cookies may make it difficult to use Oppti. To learn more about browser cookies, including how to manage or delete them, look in the Tools, Help or similar section of your Web browser.

We use Google Analytics to assist us in collecting and understanding Log Data. For more information about Google Analytics, see the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from collecting information about you and recognizing you on return visits to our Platform by disabling cookies on your browser or by installing the Google Analytics opt out plug in. Note that we are not responsible for the Google Analytics opt-out tools.

How We Use and Disclose Information:
WE DO NOT SELL DATA, and we do not use personally identifiable information for commercial purposes. In addition, we do not disclose, distribute, access or reference any personal information except as noted at the time that we request the information or in the following circumstances:

  • When directed by Clients on behalf of their employees or students
  • To our third party service partners to permit them to provide features and services on our behalf and as requested by Clients (see Third Party Services section )
  • To postsecondary institutions when a Client has specifically requested the availability of features that allow their users in grades 9-12 to connect with such institutions
  • To resolve a problem or support issue on behalf of a Client
  • To investigate a suspected violation of the Terms of Service.
  • As may be required by law or as ordered by a court, in which event we shall notify Clients and shall work with Clients to seek to limit the scope of the required disclosure
  • In the event of a reorganization, merger, sale, assignment, bankruptcy or other disposition of our business, in which case the transferred information will remain subject to the terms of this Privacy Policy.

We may use non-personal information, including aggregated, de-identified data for a variety of purposes subject to applicable law, including:

  • to improve our educational products for adaptive learning purposes and for customizing the student experience
  • to demonstrate the effectiveness of Oppti, including in our marketing materials
  • to develop and improve our products

Third Party Services:
All third parties have agreed to handle the information in compliance with this Privacy Policy and the Oppti security policy. They may use the information for the sole purpose of providing the service to Clients and their students.

We work with third-party partners who help provide our Services to Clients and their students. We do not sell any of your information to anyone, and we never will. We also impose restrictions on how our partners can use and disclose the data we provide. Designated Partners, with written consent from Oppti, may utilize the Oppti infrastructure to provide a service that meets the needs of Clients and their students.

Oppti also provides Clients and students with links to third party websites and allows Clients to add links to websites that they may then share with their students in all grades. We do not control, and therefore are not responsible for, the content or privacy practices of those websites. Those websites are governed by their own privacy policies, and we encourage Clients and students to read them.

How Clients Can Modify Information:
Clients may update or change their institution's information by contacting us, or in some cases, may update their records through the relevant areas of Oppti. We also provide Clients with a dashboard that allows them to access and modify student information, as may be required by law or otherwise deemed necessary from time to time.

Oppti is used at the direction of the Client, but parents and eligible students can directly access or modify their information within Oppti.

Security:
We are committed to protecting the security, integrity and confidentiality of the data through the use of physical and technical safeguards. Oppti uses Transport Layer Security (TLS) encryption and server authentication technology to protect data when Oppti is accessed using a supported web browser.

We host Client data in secure server and cloud-based environments that use a firewall and other industry-standard technology in an effort to prevent interference or access from outside intruders. We also require unique account identifiers, user names, and passwords that must be entered each time Clients, students or parents sign on to Oppti. We also implement invisible reCAPTCHA within Oppti to prevent malicious attacks and login attempts. This feature is subject to the Google Privacy Policy and Terms of Use, and the data use is further restricted by the Google Service Terms.

The Internet, however, is not perfectly secure and Oppti is not responsible for security breaches not reasonably within its control.

We require that Clients maintain the confidentiality of their user names and passwords. If Clients become aware of any unauthorized use of an account, loss of their or their students' or parents' account credentials or suspect a security breach, notify us immediately.

Data Retention:
As a system of record for its Clients, Oppti retains the data at the sole discretion of Clients, and for as long as they have active agreements for Oppti. After termination of an agreement, Oppti will retain Client data for a limited time period in accordance with the Student Data Privacy Agreements signed with each of the Clients, so that they may retain continuity of their experience should they choose to reengage with Oppti. At the end of the data retention period, we securely delete and destroy personal information from Clients.

However, at any time upon termination of an agreement or otherwise at their discretion, Clients may submit a written request to have their personal information provided to Oppti deleted. We will comply with such written requests within (30) days.

Note that in the event that a user chooses to submit data to a work-based learning opportunity provider, we are unable to delete or otherwise retract that information from the receiving institution.

Notwithstanding the above, we do retain aggregated, de-identified data for the purposes described in the section titled, "How We Use and Disclose Information."

Opt-Out Policy:
We send emails to Clients and students in alignment with user notifications within Oppti. Users may opt out of receiving email messages from Oppti by contacting us at [email protected] or by clicking on the "unsubscribe" link found at the bottom of every email that we send.

If Clients have opted out of receiving communications from us, we may still send essential communications regarding Oppti to Clients' or students' accounts, such as password change messages.

We do not send email messages on behalf of third parties.

Notice for California Residents
California residents have certain rights with respect to their personal information, as described below. Before we may fulfill your requests, we are required by law to verify your identity in order to prevent unauthorized access to your data.

We Don't Sell Your Personal Information.

Right to Know and Access Information: You may access information we maintain about you using the methods provided below. If we grant your request, we will provide you with a copy of the personal information we maintain about you in the ordinary course of business. This may include what personal information we collect, use, or disclose about you. We may not fulfill some or all of your request to access as permitted by applicable law.

Deletion of Information: You may request that we delete your personal information. Depending on the scope of your request, we may refrain from granting your request, as permitted by applicable law. For example, we may be legally required to retain your information in our business records. You may submit a deletion request using the methods provided below.

Authorized Agent: California residents may use an authorized agent on their behalf to exercise a privacy right discussed above. If you are an authorized agent acting on behalf of a California resident to communicate with us or to exercise a privacy right discussed above, you must be able to demonstrate that you have the requisite authorization to act on behalf of the resident and have sufficient access to their laptop, desktop, or mobile device to exercise these rights digitally. If you are an authorized agent trying to exercise rights on behalf of an Oppti user, please contact the user's school or district with supporting verification information, which includes a valid Power of Attorney in the State of California, proof that you have access to the consumer's interface, and proof of your own identify.

To Exercise Your Rights
Since Oppti is used at the direction of the Client, and since FERPA requires that we remain under the direct control of the education institution with respect to our use and maintenance of student data that is part of the education record, please contact your education institution to exercise your rights, and we will work with them to facilitate your request.

Please note that your exercise of the above rights is subject to certain exemptions to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege). We will try to comply with your request as soon as reasonably practicable. Requests to exercise these rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. Where required by applicable law, we will notify you if we reject your request and notify you of any reasons we are unable to honor your request.

Non-discrimination: We shall not discriminate or otherwise penalize anyone for exercising their rights under this Privacy Policy.

Categories of Personal information we collect
  • Identifiers such as a real name, unique personal identifier, online identifier, Internet Protocol address, email address, account name
  • Personal Information (name, education) described in subdivision (e) of California Business and Professions Code Section 1798.80
  • Internet or other electronic network activity information regarding your interaction with Oppti
  • Geolocation information in the form of your school location
  • Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
Categories of sources from which the Personal Information is collected
  • We collect the Personal Information directly from you or from your educational institution.
Business or commercial purpose for collecting or selling Personal Information

We collect your Personal Information to provide the services and for the following business purposes:

  • Performing services in accordance with our contract with the Customer and the terms of use including maintaining or servicing accounts, providing customer service, and verifying customer information.
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
  • Sending you email communications for important notifications.
Categories of third parties with whom we share Personal Information

Categories of third parties with whom we share Personal Information We do not share your Personal Information with "third parties" as the term is defined in CCPA. That is, we do not share your Personal Information with individuals or organizations to use for their own commercial purposes.

We disclose your personal information only to service providers who support us in delivering the services as described above.

Specific pieces of Personal Information we have collected

Client information, including first and last name, ID numbers, email addresses, user names and passwords for the school and district staff users.

Additional information Clients would like to host about their students within Oppti is done at the Clients' discretion for their internal review, analysis and reporting. This may include student personal information and academic records, including student first names, contact information, date of birth and other demographic information, grades, test results and performance data. Clients may also host information about a student's parent or legal guardian, including, but not limited to names, street addresses and other contact information.

Updates to This Policy:
As our product evolves, we may make changes to this Privacy Policy. The "last updated" note at the top of this page indicates when it was last revised. Material changes to the Privacy Policy will be provided to the business contacts for our Clients, and such changes will be effective when accepted by Clients on behalf of their employees, students and parents and when the Privacy Policy is posted within Oppti. Non-material changes will become effective when we post the revised Privacy Policy within Oppti.

Contact:
If you have any questions regarding this Privacy Policy, please contact us at:

Oppti, Inc.
15191 Beach Blvd
Westminster, CA 92683
Attn: Privacy Office

- or -

Email: [email protected]

Copyright © 2020, Oppti Corp.