I. Data processing for providing the website

Axio Networks, LLC provides its Communication Services, including videoconferencing, to primary and secondary schools, and allows students to access the videoconferencing feature, including associated applications (“Service”) exclusively in support of their educational mission, for example, to support virtual classrooms, educational office hours, counseling, and more.

Axio Networks, LLC permits students, including those under the age of 16, to use the Service with the consent of their respective schools and in accordance with the school’s rules for such usage and Axio Networks, LLC’s acceptable use policies. This Children’s Privacy Notice and School/Parental Notification (“Notification”) explains how Axio Networks, LLC complies with the requirements of the Children’s Online Privacy Protection Act (“COPPA”), the California Consumer Privacy Act (“CCPA”), the Federal Education Rights and Privacy Act (“FERPA”), and other applicable laws in connection with the Service.

What does this Notification cover?

This Children’s Privacy Notice and School/Parental Notification applies to Axio Networks, LLC’s Processing of any information or data collected from and relating to an identified or identifiable student (“Student Personal Data”) in connection with the Service. It also applies to Axio Networks, LLC’s treatment of records, files, documents, and other materials maintained by the School Partner that are directly related to a student (collectively, “Educational Records” as defined by FERPA).

Student Access to the Services

Students under the age of 16 may only access the videoconferencing feature of the Service as a guest participant. An authorized user (e.g., a school teacher, aide, or administrator with a Axio Networks, LLC account) can invite students to join a meeting as a guest participant by, for example, sending a copy of the meeting link or invitation to the student. Students may then join the meeting as a guest participant by clicking the meeting link and providing their name at the prompt without logging into a Axio Networks, LLC account.

Consent

Before Axio Networks, LLC collects Student Personal Data, we require the “School Partner,” which may be the students’ school district, school, or teacher, to provide verifiable consent to our collection, use, and disclosure of such information in accordance with this Notification. We collect and process Student Personal Data only to provide the videoconferencing feature to the School Partner as detailed below. With the limited exception of service providers discussed in more detail below, we do not share Student Personal Data with parties except as directed by the School Partner or required by law.

Student Personal Data and Educational Records We Collect

The types of Student Personal Data we collect may include, without limitation: a student’s first and last name; screen or user names that function as online contact information; telephone numbers; persistent identifiers such as School Partner ID or cookie IDs, IP address or MAC address; photos, videos, or audio files containing a child’s image or voice; log data including date and time stamp and clickstream data; and any information associated with these identifiers. More information about the Student Personal Data we collect, process, and maintain, and the source of that information, is provided below.

Student Personal Data we collect from School Partners and/or students on behalf of School Partners

In order to provide the Service to School Partners, Axio Networks, LLC may collect and process from School Partner, School Partner’s authorized users (e.g., teachers, aides, administrators, etc.), or from students at the direction of our School Partners, the following categories of Student Personal Data:

Usage Information – When a student uses the Service, we may collect:

Sharing and Disclosure of Information

Axio Networks, LLC processes Student Personal Data and Educational Records at the direction of our School Partners. All Student Personal Data and Educational Records collected about the students of a School Partner is available to that School Partner for its use and disclosure as permitted by law. In addition, Axio Networks, LLC may disclose Student Personal Data and Educational Records to third parties at the direction of the School Partner.

Depending on decisions made by a School Partner, including decisions about Service settings, Student Personal Data and Educational Records may be shared with others, including students, teachers, administrators, parents, and other third parties. For example, students’ names, chat messages, spoken contributions, and other content shared by a student in a meeting, webinar, or other interactive educational setting, including Student Personal Data, may be available to all other participants in that meeting. If a School Partner elects to record meetings, webinars, or interactive sessions, that School Partner may share that information with third parties as permitted by law or, when required or permitted by the applicable contract, direct Axio Networks, LLC to do so.Depending on decisions made by a School Partner, including decisions about Service settings, Student Personal Data and Educational Records may be shared with others, including students, teachers, administrators, parents, and other third parties. For example, students’ names, chat messages, spoken contributions, and other content shared by a student in a meeting, webinar, or other interactive educational setting, including Student Personal Data, may be available to all other participants in that meeting. If a School Partner elects to record meetings, webinars, or interactive sessions, that School Partner may share that information with third parties as permitted by law or, when required or permitted by the applicable contract, direct Axio Networks, LLC to do so.

Axio Networks, LLC may use third-party service providers, affiliates, and partners, and may provide them with access to Student Personal Data and Educational Records as needed to provide the Service and support Axio Networks, LLC’s internal operations. Axio Networks, LLC enters into binding contracts with service providers that may have access to Student Personal Data and Educational Records, which limit their use of such information to that which is strictly necessary to perform their work on behalf of Axio Networks, LLC. We prohibit service providers’ use of Student Personal Data and Educational Records for marketing or other commercial purposes, and we obligate them to take reasonable security measures to safeguard Student Personal Data and Educational Records.

Except as described above and as required by law, Axio Networks, LLC does not disclose Student Personal Data or Educational Records to third parties.

School/Parental Rights

Axio Networks, LLC does not require participating students to provide more Student Personal Data than is reasonably necessary to provide the Service on behalf of a School Partner. Under COPPA, a School Partner is entitled to:

(1) receive a description of the types of Personal Data collected from its students by Axio Networks, LLC;

(2) review a student’s Personal Data and/or have that information deleted;

(3) prevent further use or online collection of a student’s Personal Data. Parents or guardians of students using the Service at the consent of a School Partner should contact that School Partner to exercise any of their rights under COPPA.prevent further use or online collection of a student’s Personal Data. Parents or guardians of students using the Service at the consent of a School Partner should contact that School Partner to exercise any of their rights under COPPA.

Further Information

Additional information about Axio Networks, LLC’s privacy and security practices is available on our website. Note that the Axio Networks, LLC Privacy Notice governs Axio Networks, LLC’s collection, use, and disclosure of all personal data aside from to Student Personal Data and Educational Records. For example, information about teachers and school administrators will be treated in accordance with the general Axio Networks, LLC Privacy Notice, except to the extent it qualifies as Student Personal Data or an Educational Record.

Contact Us

If you have any questions about how Axio Networks, LLC collects, uses, or discloses Personal Data about students using RCV for Schools, please contact us via Postal Mail:

Privacy,

Axio Networks, LLC

1309 Coffeen Avenue

Ste 1200

Sheridan, WY 82801