Packback Privacy Policy

Last Updated: August 1, 2019

Overview of the Packback Privacy Policy

Packback, Inc. (“Packback,” or “we” or “us”) operates an online platform that provides educational products and services for students and professors (collectively, “Users”), through its Packback.co website and other websites, domains, sub-domains and technology products associated therewith (collectively, the “Packback Website”) and all other products and services offered by Packback (together with the Packback Website, the “Packback Platform”)

Packback is committed to protecting your privacy. To support fearless curiosity, we are committed to providing a safe, secure platform that protects our Users’ privacy and personal information.

As an education company that provides services and support to college students, we are particularly aware of the sensitive nature of some student data, and we have worked hard to ensure FERPA compliance (and compliance with other applicable laws) and to build a system that can accommodate the needs individual campuses where definitions of personally identifiable information or personal information may differ. If at any time you have questions or concerns about the collection, storage or usage of your personal information or User Generated Content, or if you notice any oversights in our Privacy Policy, please contact us at Holla@packback.co. We are a young company and are continuously working to better support and serve the security needs of our growing userbase and University partners.

This Privacy Policy explains our collection, use and any potential disclosure of your information. The terms within this Privacy Policy apply to all personal information collected by Packback on the Packback Platform.

The Packback Platform may be accessed in the United States and abroad. In such cases, certain data and information will be transferred to the United States. For personal information protection purposes, Packback is the controller and, unless otherwise noted, is also the processor of the personal information. User account information remains in your Packback account until you choose to delete it.

If you are using the Packback Platform outside of the United States, your data and the information collected may be subject to the data protection laws of the country in which you are located, regardless of whether or not your data is transferred to the United States. To the extent permitted by applicable law, if you would like to request to review, correct, restrict or delete personal information that you have previously provided to us, object to the processing of personal information, or if you would like to request to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), please contact us at Holla@packback.co. We will respond to your request in accordance with the applicable law that governs the collection, use and deletion of your data and information. The requested deletion will be as comprehensive as possible but is always subject to issues outside of our control, including applicable regulations and laws, your actions and the actions of third parties. It is important to note that we may retain a copy of the information for archival purposes and to avoid identity theft or fraud. Certain users may have additional personal information rights and choices based on where they live. Please see section on “Your Data Rights” for more information.

What Information We Collect

Age Restrictions

We do not intend to solicit or collect personal information from anyone under the age of 18 without parental consent. By creating an account or using this website, you verify that you are at least 18 years of age. If you believe we might have any information from or about a person under 18, please contact us at holla@packback.co.

Collection of Necessary Subscriber Information to Create an Account

By using Packback products and accessing the Packback Platform, either on your own or through a class, some information is collected about you to be able to create a user account and fulfill the necessary functions of the purpose of the Packback Platform. See section on FERPA for complete details on our FERPA compliance.

You may always choose not to provide subscriber information (by opting not to create an account) and may choose to remove an account that was created for you by your professor or the Packback team at any time, but if you so choose, certain products and services may not be available to you (including Packback Questions). We intentionally require as little subscriber information as possible to be able to create your user account and provide you with the services of our site.

By either registering for your own account on Packback, or by accepting an account created for your behalf, you consent to Packback collecting and storing the required subscriber information to create your account:

  • Information collected when you register including;
  • Your first and last name;
  • Password;
  • Email address;
  • Campus name;
  • Information processed when you make a purchase including your credit card number and billing address. (Note: this information is processed in Level 1 PCI compliant processor Braintree, to further protect your billing information and online security, but since Packback is not able to see any of this information, it is not collected or stored on the Packback Platform.)

Your continued usage of the Packback Platform represents your continued consent to the Terms of Use and this Privacy Policy.

To learn about Packback’s commitment and adherence to FERPA in protecting and storing all student information, please read the section below entitled “FERPA”.

Collection of Non-Required or Optional Subscriber Information

Demographic information (e.g., your occupation, hobbies, gender, or interests) may also be collected and may be linked to your account if you choose to provide any of the above non-required information.

Any supplemental information you provide is optional (like career interests, graduating year, gender, race, etc).

You will be explicitly informed if there is any intent to use your subscriber information combined with your User Generated Content in any way other than what is outlined in this document. Any additional usage will require your explicit secondary opt in.

Consent to Collection of Non-Personal Information

When visiting the Packback Platform, certain kinds of non-personal information, such as the website that referred you to us, your IP address, browser type, operating system, and access times which are collected automatically as a part of the Packback Platform’s operation. This information is collected to help troubleshoot any software issues or “bugs” you may encounter by providing our team with appropriate system data.

We also may collect navigational information, including information about the pages you view, the links you click, and other actions taken in connection with the Packback Platform for the purpose of product development, customer service, and support.

Collection of User Generated Content

A registered Packback User may generate and publish their own User Generated Content on the Packback Platform, including the use of the Packback Questions discussion forum. Please see the section on “Use of ‘User Generated Content’” for more information on how this content is stored and shared.

Use of Subscriber Information and User Generated Content

Use of Subscriber Information

Packback collects and uses the above outlined subscriber information to:

  • Create and manage your membership account;
  • Process your transactions;
  • Provide customer service;
  • Perform research and analysis aimed at improving our products, services, curriculum, educational outcomes, and technologies;
  • To display content that is customized to your preferences;
  • If you are a forum contributor on Packback Questions, to identify your uploaded content as your own authenticated content for the purposes of tracking your usage for grading purposes; and,
  • If you are an employee, contractor, or paid contributor for Packback, to compensate you and to prepare tax information slips; and,
  • To communicate with you about your transactions, new products and services.

We may send transaction-related communications such as welcome letters, billing reminders, and purchase confirmations. If you do not wish to receive surveys or marketing communications, you may adjust your “Personal Information Preferences” as described below or follow the “unsubscribe” instructions included within each email communication. Please keep in mind that, if you choose not to receive marketing communications, you may continue to receive transactional or account communications (e.g., confirmation emails, password reset emails, digest emails, etc).

If you would like to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to Holla@packback.co.

Use of User Generated Content

Packback collects, stores and uses “User Generated Content” to:

  • Provide the core functionality of the Packback Questions discussion forum, including displaying User Generated Content to other Packback Users to read and respond to;
  • Combining subscriber information with User Generated Content data to allow School Officials to assign a grade to a student’s participation on the Packback Platform; and
  • To share in the limited and protected ways outlined in the section entitled “How and When We Share Your Information.”

FERPA

FERPA stands for the Family Educational Rights and Privacy Act (20U.S.C. 1232g, 34CFR§99) and is designed to ensure that student’s personally identifiable education information is protected.

Packback takes FERPA compliance extremely seriously, and we have designed our system to provide options to accommodate each school’s definition of Directory Information and/or Personally Identifiable Information (PII).

Packback acknowledges that in the course of Subscriber’s use of the Services, personally identifiable information about students (“Sensitive Student Data”) may be disclosed to Packback through account creation and usage of the services of the Packback Platform. Packback acknowledges that it will be considered a “School Official” (as outlined in FERPA) and will comply with the requirements in FERPA concerning the confidentiality and release of Sensitive Student Data. Packback agrees that officers, employees, and agents of Packback who access Sensitive Student Data may use such data only for the purposes for which such data has been made available to Packback and ways outlined within this Privacy Policy.

Packback’s definition of “Sensitive Student Data” on Packback includes student name, email address, course title/information, and final participation grade information.

User Generated Content posted by student Users in the Packback Questions forum–when completely disaggregated from any identifiable information about the student who posted the content–would not be considered Sensitive Student Data. Our system gives students the right to control who can view their subscriber information combined with their student posted content, and we have a sophisticated authorization and privacy system that prevents any unauthorized user from connecting student posted data to any subscriber information at the backend API level.

Subscriber information is not simply “obscured” on the website, but rather actively disaggregated at the server level, and cannot be connected to User Generated Content unless requested by an authorized School Official (with proper permissions in the Packback system) or if the User has secondarily opted-in to make their profile public.

Please read the section entitled “How and When We Share Your Information” to learn more about the limited ways in which we share and or use collected information.

How and When We Share Your Information

Disclosing Your Subscriber Information

Except as set out in this Privacy Policy, Packback does not disclose or sell your personal information to any third-parties without your affirmative consent through a secondary optional opt-in process.

We disclose subscriber information to third-party service providers who perform necessary services on our behalf to provide you with the best and most secure experience possible, including, but not limited to, to handle the processing of payments, to provide data storage, to host websites, to fulfill orders and shipments, to assist in marketing, to conduct audits, etc. Those third-party service providers (i) shall be permitted to obtain only the personal information they need to provide the service, (ii) must protect personal information to the same extent as Packback, and (iii) shall be prohibited from using it for any other purpose.

The Service Providers used by Packback with respect to personal information are of the highest tier compliance, security and reputability.

Sharing User Generated Content

We are an education company with the mission of supporting curiosity in all students, promoting cross-campus collaboration, and helping students be exposed to other perspectives. For this reason, our platform has been designed from the ground-up to promote the sharing of User Generated Content outside of class boundaries, while still retaining compliance to FERPA and protection of student privacy.

Packback Questions User Generated Content

“Packback Questions” is a product owned by Packback, that offers online discussion, coaching and collaboration tools. A key component of this product is the creation of User Generated Content in the form of “Questions” and “Responses” generated by students.

By participating in the Packback Questions platform, any User Generated Content you submit, including (but not limited to) Questions and Responses, may be shared by the Packback team in an anonymous format disaggregated from any personally identifiable information.

By posting User Generated Content through your account on Packback, this Content will be subject to this Privacy Policy and our Terms of Use. You, as the original poster of your content, retain non-exclusive ownership over your User Generated Content and may edit or delete your User Generated Content at any time, as well as use your own content again in any way for.

By uploading User Generated Content, you grant the right for any user, both member or non-member, to view and interact with (read, respond, cite, share, etc) your posted content.

By uploading User Generated Content, you also give Packback a perpetual, non-exclusive, non-transferable and royalty-free license to use such Content in furtherance of the Packback Platform.

Only you, as the original author of the content –and no other Member– shall ever have the right to sell for any value your User Generated Content (except as you expressly agree in writing), except that Packback may use such Content in furtherance of the Packback Platform.

General Usage Questions

If you are a school administrator and you would like more information about how we protect student privacy, autonomy and control over their data, please contact us at holla@packback.co.

We will always work with each campus to clarify or tailor our services to ensure that our privacy standards meet the needs and expectations for your specific campus.

Your Data Rights

Your Right to Decline Consent

If you are being asked to use Packback products for a class, but do not consent to the Packback Terms of Use and Privacy Policy, please contact our team at Holla@packback.co; we will be happy to work with you to answer your questions and make best effort to accommodate your needs. The right to the “at-request” access or removal of your personal information If you would like to review or revise information that you previously provided to us, you may access and change your personal information in the “Account Settings” section of the website. You may also, at any time, request a deletion of your account. We will respond to such request within the applicable period prescribed by law (and usually within 48 hours). The requested deletion will be as comprehensive as possible but is always subject to issues outside of our control, including applicable regulations and laws, your actions and the actions of third parties. It is important to note that we may retain a copy of the information for archival purposes and to avoid identity theft or fraud.

As a User of Packback Questions, an account deletion will remove all record of your personal information from the Packback Platform (email, name, posting statistics, etc.).

At any time, you are able to manage your own User Generated Content by navigating to your Profile. You can edit and delete your own posts, so long as this deletion does not remove any other user’s responses.

Personal Information and Email Preferences

Packback respects your right to make choices about the use and disclosure of your personal information. If at any time you have questions or concerns about the collection, storage or usage of your personal information or User Generated Content, please contact our customer support team by emailing holla@packback.co.

If you choose not to receive marketing communications, you may request to be unsubscribed at any time. Please be advised that you may not receive transactional, password reset, or account communications (e.g., confirmation emails and account balance statements). You can request to be re-subscribed at any time by emailing us at Holla@packback.co.

More Information on Data Protection Rights

Certain Users may have additional personal information rights and choices based on where they live. We have tried to provide links to websites that provide more information below. If you feel that this list does not cover your rights, please send an email to Holla@packback.co.

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy.

If you are a Canada resident, Canadian law may provide you with additional rights regarding our use of your personal information. To learn more about your Canada privacy rights, visit https://www.priv.gc.ca/en/.

If you are a resident of the European Union or European Economic Area, the General Data Protection Law (“GDPR”) may provide you with additional rights regarding our use of your personal information. To learn more about your GDPR privacy rights, visit https://eugdpr.org/the-regulation/.

You also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your personal data infringes applicable law.

A list of European Union data protection authorities is available at:

 http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080 .

Security of Your Personal Information

The security of your personal information is important to us. We follow generally accepted industry standards to help protect your personal information including without limitation:

  • Limiting access to your personal information to those of our employees who require it to provide services to you;
  • Requiring employees to sign confidentiality agreements to protect customer and other confidential information;
  • Ensuring that third-party service providers sign confidentiality agreements to maintain the confidentiality of your personal information and not to use it for any unauthorized purposes;
  • Use of HTTPS protocol for secure communication over a computer network which is widely used on the Internet;
  • Not storing your billing information or credit card information within our system directly, but instead using Level 1 PCI compliant processor Braintree to store all payment information;
  • Rigorous evaluation of all third-party service providers before implementation;
  • Annual Security Reviews internally to reevaluate all service providers and our system, to continue to ensure the highest level of security;
  • Storing your personal information in secure systems which protect it from unauthorized access or use.

No method of transmission over the Internet, or method of electronic storage, is ever 100% secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security. If a password is used to protect your account and personal information, it is your responsibility to keep your password confidential.

Other Details About Privacy and Data at Packback

Links

We (Packback) or Users on the Packback Questions forum may share “link” to websites, including those of our subsidiaries and third-party content providers, that have different privacy policies and practices from those disclosed here. We can assume no responsibility for the policies or practices of such linked sites, and encourage you to become acquainted with them prior to following links.

Content Posting Agreement and the Use of Copyrighted Content

By posting User Generated Content on Packback, you agree to the Content Posting Agreement as outlined here:

  • You assert that you are not posting Copyrighted Content without proper licensing for sharing, distributing or otherwise remixing;
  • If you share content with a Creative Commons License, you agree to provide proper attribution as the “Source” when posting;
  • You will not post inflammatory, inappropriate, derogatory, or otherwise egregious content that limits or detracts from other users’ ability to have a safe and professional educational environment on the platform.

If you do post Copyrighted Content, Packback claims no responsibility or ownership over the Copyrighted Content. We will look for Copyrighted Content and remove it, and will comply with a removal request from any owner of inappropriately posted Copyrighted Content promptly.

By posting User Generated Content on Packback, you agree to give Packback the right to Edit, Delete or “Moderate” your User Generated Content to ensure compliance with the Community Guidelines and Content Posting Agreement without limitation.

Privacy Personnel

We have personnel at Packback who are be accountable for our policies and practices with respect to the management of personal information. You may forward any questions, comments or complaints that you might have about this Privacy Policy to holla@packback.co. We are happy to answer any questions.

Contests or Giveaways (If applicable)

If you have entered into and/or won a Packback contest, we or a contest sponsor may publish your name and city of residence. Information about our customers, including personal information, may be disclosed as part of any merger, acquisition, or sale of the company and/or its assets, as well as in the unlikely event of insolvency, bankruptcy, or receivership, in which personal information would be transferred as one of the business assets of the company. We will notify you of such an occurrence as described in the “Changes to This Privacy Policy” section below. We reserve the right to disclose your personal information if required or permitted to do so by law.

Where Your Information is Physically Stored

Personal information collected by Packback may be stored and processed in the United States or any other country in which Packback or its affiliates maintain facilities, and by providing us with your personal information and using the Packback Platform, including our sites or services, you consent to any such transfer of information outside of your country. If you would like to exercise any of your personal information protection rights (including the right to have your personal information deleted), please contact us using the “Contact Information” below.

We employ the use of cloud-based storage with distributed physical servers through companies with the highest tier compliance, security and reputability. Currently, all of our servers are in the United States.

If you would like to request to review, correct, restrict or delete personal information that you have previously provided to us, object to the processing of personal information, or if you would like to request to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), please contact us at Holla@packback.co. We will respond to your request in accordance with the applicable law that governs the collection, use and deletion of your data and information. The requested deletion will be as comprehensive as possible but is always subject to issues outside of our control, including applicable regulations and laws, your actions and the actions of third parties. It is important to note that we may retain a copy of the information for archival purposes and to avoid identity theft or fraud.

Changes to this Privacy Policy

While we reserve the right to change the terms of this Privacy Policy at any time, we will make every best effort to only make material changes the Privacy Policy between class terms to avoid any potential disruption.

When we make changes, we will revise the “last updated” date at the top of the policy. If there are material changes to this statement or in how Packback will collect or use your personal information, we will notify you by prominently posting a notice of such changes here or on our home page, or by sending you an email. We encourage you to review this Privacy Policy whenever you visit the Packback Platform. If applicable law requires your affirmative consent, we will require such affirmative consent the next time you access the Packback Platform.