Gradelink Services Privacy Policy

Updated January 31, 2022

This Privacy Policy will explain how we, Gradelink Corporation (Gradelink), collect, use, and disclose personal data as part of our primary business processes for promoting and delivering student information systems. We collect data from you or about you or your child when:

1. Your school uses our Gradelink Student Information System, and/or
2. You or your organization are a current, previous, or potential customer for Gradelink.

Our processes are different for these two types of personal data. We detail our policies and processes for each of these two categories separately:

1. Gradelink’s Student Information System (SIS)

Schools in the U.S., E.U., and other countries across the world are subject to the regulations of their country and local region. These regulations typically mandate procedures and guidelines for school recordkeeping. Schools contract with Gradelink to provide a Student Information System to maintain their records. The U.S. FERPA regulations and the E.U. GDPR regulations assign the school (not Gradelink) the responsibility for administering privacy rights including informing parents and students about their privacy policies.

Therefore, students, parents, and school staff interested in privacy matters regarding their school’s use of Gradelink SIS should consult their school and request their FERPA Notice or GDPR Privacy Policy.

Nonetheless, in the spirit of transparency, Gradelink offers the following information regarding how personal information is collected, used, disclosed or sold.

What data do schools collect using Gradelink’s SIS?

1. Information is collected by teachers and administrators on school students, parent/guardians, staff, and volunteers. Student and parent information varies based on school and can include student demographics, family information, classes, grades, attendance, discipline, individualized education plans, medical records, tuition, billing and other information. Staff information includes demographics, course and student assignments. Volunteer information includes demographics, background checks, and volunteer records.
2. In some cases, parents and students may enter their personal information directly into the system. For example, students or parents who wish to receive school news, course assignments or grade reports from the system may supply their email address.

What is the business or commercial purpose for the data?

Gradelink’s customers, the schools, use the Gradelink SIS to maintain their records.

What information is disclosed or sold?

Gradelink contracts with a highly secure data center to operate its system. Gradelink keeps its data in this third-party data center. Gradelink does not disclose data to any third party nor sell any personal data. Consult your school regarding their policies regarding release of personal data. Regulations for US and EU schools prohibit schools from selling any student information. Gradelink has no information that any of its customers have violated this prohibition.

What are my rights regarding my information or my child’s information?

U.S. and E.U. regulations direct students and parents to communicate directly with their school regarding rights, for example, to access information and to correct inaccuracies.

Certain jurisdictions, including the state of California in the U.S., provide certain rights to all residents, which include:

1. The right to submit a consumer request to know what information regarding you is maintained by Gradelink,
2. The right to request deletion of your information,
3. The right to opt-out of sale of your personal information,

What are the processes and details for exercising my rights under California law?

1. These rights may be exercised by California residents by sending the request to our Data Protection Officer (see contact information below) via email.
2. An authorized agent may use the same process.
3. Our response will be to inform you that due to contractual obligations with your school, we are prohibited from releasing, altering, or deleting any personal information, and that you should contact your school to exercise these rights.
4. Gradelink does do not verify the identity of any individual exercising these rights.
5. Gradelink’s process for implementing these requests is simply to refer you to your school.

Final Comments

1. Gradelink will not discriminate against any individual for exercising their rights under California law.
2. Please contact the Data Protection Officer (see contact information below) via email for any questions or concerns regarding Gradelink’s Privacy Policy.

2. Current, Previous, or Potential Customers of Gradelink

What Personal Data does Gradelink Collect?

Gradelink collects school administrator names, titles, employer names, addresses, contact information (email, phone), correspondence history and notes regarding current, previous, and potential customers.

What Sources are used to collect Personal Data?

Gradelink collects personal information when you telephone or email us, from our website, referrals, trade shows, purchased lists, school websites, and during the customer service delivery process.

What is the Business or Commercial Purpose for the Personal Data?

Personal Data is collected as part of the sales and marketing effort, for the delivery of the Gradelink SIS, and in the case of previous customers, for our record retention requirements.

Will you use my data for any additional purposes?

There is no further purpose for your data intended.

Is my Personal Data sold (including consumers under 16 years)?

Gradelink does not sell personal data. Gradelink customers and prospective customers are adults.

What is the Legal Basis for collecting my Personal Data?

The legal basis under the GDPR regulation is consent in the case of potential customers and performance of contract for current and previous customers.

What Third-Parties receive my Personal Data?

Gradelink uses trusted service providers who provide business operations and communications services.

In Which Countries is my Personal Data stored?

Most data is stored in the United States. A small amount of data is kept in France, with a contracted service provider that helps improve Gradelink’s communications reliability.

How long is my data Retained?

Gradelink maintains current customer data including student attendance records and student transcript records indefinitely for as long as customer maintains service.

Unless otherwise mandated differently by applicable law or regulation, the general retention period for information is 3 years (36 months).

As an exemption, retention periods may be prolonged in cases such as:

1. Ongoing investigations from authorities, if there are records of personal data that are needed by the Company to prove compliance with any legal requirements; or
2. When exercising legal rights in cases of lawsuits or similar court proceeding recognized under local, State or Federal law.

Certain non-critical data such as individual assignment records older than 36 months may be purged periodically to improve system and resource efficiency.

Does Gradelink use any Automated Decision-Making?

Gradelink does not use any automated decision-making processes.

Am I Required to Provide my Personal Information?

Customers of the Gradelink system are obliged to provide their Personal Data since it is required for Gradelink to deliver the contracted services.

What are your data protection rights?

Your legal rights vary based on your residency. EU residents are granted rights under GDPR, US students and parents have rights under FERPA, and California residents have rights under CCPA. For information collected from

• Current, Previous, or Potential Customers of Gradelink
• Gradelink Employees, Contractors, Vendors and other Contacts

Gradelink uses the following processes to ensure that your rights are honored:

• The right to access – You have the right to request Gradelink for copies of your personal data. When you make a request, we may verify your identity by asking details regarding information you have provided us. We will then provide you, via email, the information that you have requested.
• The right to rectification – You have the right to request that Gradelink correct any information you believe is inaccurate. You also have the right to request Gradelink to complete information you believe is incomplete.
• The right to erasure – You have the right to request that Gradelink erase your personal data, under certain conditions. When you make a request, we will verify your identity by asking you details regarding information you have provided to us. We will complete your request unless other obligations prohibit us from honoring you request. We will send you a conformation when we have completed the process, and if we are prohibited from erasing your data, we will explain why.
• The right to restrict processing – You have the right to request that Gradelink restrict the processing of your personal data, under certain conditions.
• The right to opt out of sale of your data. You may make a request to opt out of any sale of your data. After you make a request, you will receive a reply that Gradelink’s policy is to not sell any data and your request is thereby honored.
• The right to withdraw consent – If you originally provided Gradelink consent to use your data, you have the right to withdraw this consent at any time.
• The right to lodge a complaint – You have the right to lodge a complaint. EU residents may lodge a complaint with your country or local data protection office. US residents may complain with the appropriate state agency.

If you would like to exercise any of these rights, send an email to our Data Protection Officer, whose contact information is listed under “How to contact us”. Please also note:

1. If you make a request, we will respond to you within one month.
2. Your authorized agent may exercise any of your rights on your behalf. Your agent should include the legal authorization such as power of attorney or other legal document valid in your local jurisdiction.
3. You have the right that we do not discriminate against you in any way for exercising your rights and we honor that right.

Obligations to Provide us your Personal Data

Current and Prospective customers must provide their personal data for us to discuss and/or deliver our service.

Changes to our Gradelink Services Privacy Policy

Gradelink reviews and updates its Gradelink Services Privacy Policy regularly and places any updates on this webpage. This Product/Service Privacy Policy was last updated on January 31, 2022.

Legal Compliance

Gradelink is subject to international, national, and state/provincial regulations. These include the European Union’s General Data Protection Regulation (GDPR), U.S. state laws including the California Consumer Protection Act (CCPA), and other regulations. Schools using the Gradelink service collect personal information on their students under 13 years of age. While neither these schools nor Gradelink are subject to the Children’s Online Privacy Protection Act (COPPA), our school customers are generally subject to the strict privacy regulations specified in FERPA.

How to contact us

If you have any questions or complaints about our Gradelink Services Privacy Policy, the data we hold on you, or you would like to exercise one of your data protection rights, please contact our data protection officer:

Officer: Jonathan Kim
Phone: +1.800.742.3083
Or Direct +1.949.504.8564

 

Or, via standard mail:
Attn: Jonathan Kim
Gradelink Corporation
26741 Portola Pkway #1E-649
Foothill Ranch, CA 92610
U.S.A.