Last Updated: March 14, 2023

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Thank you for using SoundTown (“SoundTown”), a service of Hoogalit. Hoogalit ("we" or "us") is passionate about supporting teachers in the classroom, and that’s why we created SoundTown, an interactive platform for preschool children to build their pre-reading skills in 5 minutes a day.  This Privacy Policy applies whether you login to use SoundTown through informational website located at mysoundtown.com (the “Site”), the SoundTown Platform, hoogalit.com or any of our other products or services that SoundTown may provide now or in the future (collectively, “SoundTown” or the “Services”). This privacy policy ("Privacy Policy") is incorporated by reference into the SoundTown Terms of Use. By visiting the SoundTown Services and the Site you are accepting and consenting to the practices described in this policy. It’s important to us that information you provide us to achieve the goal of saving you time, is properly handled and that your privacy is respected.

We strive to be transparent in our data collection and use practices and will only collect, use, and share your personal information in accordance with this Privacy Policy.  Please take your time in reviewing this policy and our resources, so that you can understand our practices. 

TYPES OF INFORMATION WE COLLECT

We collect the following types of information:

INFORMATION WE COLLECT FROM TEACHERS

We will collect the following data:

• Account Sign-up and Profile Information. Only teachers or school administrators may create a SoundTown account. In order to create a SoundTown account, you will be asked to provide some basic information such as your first and last name, email address, state, telephone number, password and school information, such as school name, role, grade.
  
  
• Information You Give To Us. The categories of personal information that we may collect from you or receive about you include, but are not limited to, the following: including a name, school name, school district, school email address and/or account name and password, phone number and message content. To facilitate classroom activities, teachers may add information to the SoundTown Services. Personal information does not include anonymous or aggregate statistical information that does not allow a third party to identify a specific individual. We reserve the right to use anonymous or aggregate data for any purpose, including, but not limited to, improving the content of SoundTown and the functionality of SoundTown, marketing, and analyzing the use of SoundTown. We may also disclose such anonymous aggregate information to our partners or third-party service providers, excluding any personal information, except as otherwise provided in this Privacy Policy.
  
  
• Testimonials. We may collect certain personal information from teachers (such as your name, photo, and/or video) if teachers choose to give us a testimonial. We post testimonials on SoundTown which may contain teacher or school administrator personal information in the testimonial. We obtain teacher or school administrator consent in advance to ensure we have permission to post this content publicly. To request removal of teacher or school administrator personal information from our testimonials, please contact us at team@mysoundtown.com.

INFORMATION ABOUT SCHOOLS

We ask for certain information when a school administrator registers a School with SoundTown, or if the school administrator corresponds with us online, including a name, school name, school district, school email address and/or account name and password, phone number and message content. We may also retain information provided by a School if the School sends us a message, posts content to our website or through our SoundTown Services, or responds to emails or surveys. Once a School begins using the SoundTown Services, we will collect content and information provided by the School through the School's use of the SoundTown Services and we will keep records of activities related to the SoundTown Services. We use this information to operate, maintain, and provide the features and functionality of the services, to analyze and improve our service offerings and functionality, and to communicate with our Schools and visitors to our Site.

STUDENT DATA

Through the course of providing its Services to a School, SoundTown may have access to personally identifiable information about students ("Student Data") that is provided by the School, by the parent or guardian, or by the student. SoundTown has access to Student Data only as requested by the School and only for the purposes of performing Services on the School's behalf. The type of Student Data we collect will depend on how the School uses the Service. 

Student Data is used only for educational purposes at the direction of the School. SoundTown considers Student Data to be confidential and does not use such data for any purpose other than to provide the Services on the School's behalf, in accordance with contractual agreements with the School. Our collection, use, and disclosure of Student Data is governed by our Terms of Use for schools and any other agreement with the School, by the provision of the Family Educational Rights and Privacy Act (“FERPA”), the Protection of Pupil Rights Amendment (“PPRA”) the Children's Online Privacy Protection Act (“COPPA”), and applicable state laws which relate to the collection of Student Data. If you are a student or parent, please contact your School if you have questions about the School's use of SoundTown.

See How We Use Your Information below for more information on the limited ways in which we share School and Student Data. See Children’s Privacy below for more information on how we collect and use the personal information of children under 13.

INFORMATION WE COLLECT FROM PARENTS

As a parent of a child using the SoundTown Site or as a parent user of the SoundTown Service, you may choose to provide us with your personal information, such as a name, email address and telephone number as well as personal information relating to your child or your child’s use of the SoundTown Services.

SITE VISITORS

• Contact Information. As a general visitor to the SoundTown Site or as a parent, teacher or school administrator user of the SoundTown Service, you may choose to provide us with your personal information, such as a name, email address and telephone number. Some examples include when you send us an email asking a question, participate in a video testimonial about SoundTown, or choose to participate in any research efforts with SoundTown to improve SoundTown.
  
  When you send us a message using the "Contact Us" page or via email, the email addresses and phone numbers collected are not further used to market to the individual beyond providing the services requested or responding to the requests.
  
  

INFORMATION COLLECTED AUTOMATICALLY

When parents, teachers or school administrators use SoundTown, we (or SoundTown providers) may automatically collect information, including personal information, about the services teachers use and how teachers use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve SoundTown. For example, this could include the frequency and duration of your visits to SoundTown. If you use SoundTown on different devices, we may link the information we collect from those different devices to help us provide a consistent service across your different devices. If we do combine any automatically-collected information with personal information, we will treat the combined information as personal information, and it will be protected as explained in this Privacy Policy.

The technologies and information we automatically collect include:

• Cookies and Similar Technologies: We (or our service providers) may use cookies or similar technologies to identify your browser or device. We (or our service providers) may also use these technologies in connection with advertising of SoundTown that may appear on other sites or in connection with advertising their products outside of SoundTown (e.g., if you view an embedded YouTube video player on SoundTown, YouTube may place cookies or similar technologies on your browser when you play the video off our site). We don’t allow these third-parties to advertise directly on SoundTown. 
• Local Storage: We may also use, collect, and store information locally on your device using mechanisms such as browser web storage and application data caches. Like many services, SoundTown uses these technologies to analyze trends, gather demographic information, understand your engagement with SoundTown, administer SoundTown, tailor SoundTown for teachers, and to help SoundTown work better for you - for example, by remembering your language preferences.
• Device Information: We collect device-specific information such as your device type, device brand, operating system, hardware version, device settings, file and software names and types, battery and signal strength, and device identifiers. This helps us measure how SoundTown is performing, improve SoundTown for you on your particular device, and send you push notifications if you’ve opted in to receive them.
• Server Log Information: Like most online services, when you use SoundTown or the SoundTown Site, even if you have not created an SoundTown account or logged in, we automatically collect and store certain information in our server logs such as:
  - Details of how you used our service, such as your activity on SoundTown, and the frequency and duration of your visits to SoundTown or the SoundTown Site IP address
  - Device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL

• Location Information:  When you use SoundTown or browse the SoundTown Site, we may collect information about your geographic location, for example based on your IP address. We collect both coarse (i.e., city-level) location data and precise location data. We never collect precise geolocation data from students. We will not store or track your device location on an ongoing basis or without your permission. We do not share precise geolocation data with third-parties, other than our service providers as necessary to provide the SoundTown Services. If you no longer wish to allow us to track your location information, you may opt-out at any time by turning it off at the device level.
  

INFORMATION RECEIVED FROM THIRD-PARTY SOURCES     

We may also obtain information, including personal information, from third-party sources to update or supplement the information you provided or we collected automatically. This may include aggregated anonymous information or certain personal information that may be provided to us. If we receive personal information from third-parties, we will handle it in accordance with this Privacy Policy. If we directly combine information we receive from other third-parties with personal information that we collect through SoundTown, we will treat the combined information as personal information and handle it in accordance with this Privacy Policy. Additionally, we may use any aggregated anonymous information received by third-parties as set forth in this Privacy Policy. Local law may require you to authorize the third-party to share your information with us before we can acquire it. We do not control, supervise, or respond to how third parties providing your information process your personal information, and any information request regarding the disclosure of your personal information to us should be directed to such third-parties.

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HOW WE USE YOUR INFORMATION

We use information about you in the following ways:

• Information You Give To Us. We will use this information:
  - to provide you with the information, products and services that you request from us;
  - to provide you with information about other goods and services we offer that are similar to those that you have already purchased or inquired about;
  - to provide you with information about goods or services we feel may interest you. We will only contact you by electronic means (e-mail or SMS) where you have consented to this, or where we can otherwise lawfully do so.
  - to notify you about changes to SoundTown;
  - to ensure that content from SoundTown is presented in the most effective manner for you and for your computer.
  

• Information Automatically Collected. We will use this information:
  - to administer SoundTown and for internal operations, including troubleshooting, site traffic, data analysis, testing, research, statistical and survey purposes;
  - to improve SoundTown to ensure that content is presented in the most effective manner;
  - as part of our efforts to keep SoundTown safe and secure;
  - to make suggestions and recommendations to you and other users of SoundTown about goods or services that may interest you or them.
  

• Information We Receive From Third-Party Sources. We will combine this information with information you give to us and information we collect about you for the purposes set forth above.
  

• Third Party Tracking. SoundTown does not permit third party advertising networks to collect information about your use of our website and Services over time and across websites for the purpose of serving targeted advertising and we will never use Student Data for targeted advertising. SoundTown does not sell or rent any of your personal information to any third-party for any purpose, including for advertising or marketing purposes. Student Data is only shared in limited circumstances – and never shared with or sold to third parties for marketing purposes.
  
  

We use the information we collect from you to provide you with the best SoundTown experience. More specifically, this information collected from the Services is used to:

• Provide and improve SoundTown, for example by developing new products and features
• Respond to your emails, submissions, questions, requests for information or customer support from teachers and school administrators
• Customize SoundTown for you, and improve your experience with it
• Send you information about features on SoundTown or changes to our policies and Services
• Provide information about events, announcements, offers, promotions, products, including third-party products, and services we think will be of interest to our teacher and school administrator users
• To ensure that SoundTown remains safe and secure

We use automatically collected information to provide and support SoundTown, and for the additional uses described in this section of our Privacy Policy.

We process this information to improve SoundTown and our users’ experience with it, in protecting SoundTown, where necessary for the adequate performance of the contract with you, and to comply with applicable laws.

SoundTown does not share personal information and Student Data with any third-parties except in the limited circumstances described in this Privacy Policy and as set forth below:

• Other Teachers You Share And Communicate With on SoundTown: No teacher or school administrator information is made available to the general public through SoundTown. If you are a teacher or school administrator you may choose to share information or content with other SoundTown teacher or school administrator users. 
• Parents: SoundTown, teachers or school administrators may share information or content with a parent or guardian regarding their child’s use of the SoundTown Services. If you are a Parent you may choose to have information or content shared with you regarding your child’s use of the SoundTown Services.
• Service Providers: We do work with vendors, service providers, and other partners to help us provide SoundTown by performing tasks on our behalf. We may need to share or provide information (including personal information) to them to help them perform these business functions, for example sending emails on our behalf, database management services, database hosting, providing customer support software, and security. These providers have limited access to your personal information to perform these tasks on our behalf, and are contractually bound to protect and use it only for the purpose for which it was disclosed and consistent with this Privacy Policy. Contractors and service providers who may have access to Student Data in the course of performing their services are subject to confidentiality and data security requirements.

• Analytics Services: We use analytics services, including mobile analytics software, to help us understand and improve how SoundTown is being used. These services may collect, store and use information in order to help us understand things like how often you use SoundTown, the events that occur within the application, usage, performance data, and from where the application was downloaded. 
• Aggregated Information and Non-identifying Information: We may share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other non-personally identifiable information, including with users, partners or the press in order to, for example, demonstrate how SoundTown is used, spot industry trends, or to provide marketing materials for SoundTown. Any aggregated information and non-personalized information shared this way will not contain any personal information or Student Data.
• Legal Requirements:  We may disclose personal information if we have a good faith belief that doing so is necessary to comply with the law, such as complying with a subpoena or other legal process. We may need to disclose personal information where, in good faith, we think it is necessary to protect the rights, property, or safety of SoundTown, our employees, our community, or others, or to prevent violations of our Terms of Service or other agreements. This includes, without limitation, exchanging information with other companies and organizations for fraud protection or responding to law enforcement and government requests. Where appropriate, we may notify users about the legal requests, unless (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law; (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon SoundTown, or its users. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

Change of Control: In the event that all or a portion of SoundTown or its assets are acquired by or merged with a third-party, personal information that we have collected from users would be one of the assets transferred to or acquired by that third-party. This Privacy Policy will continue to apply to your information, and any acquirer would only be able to handle your personal information as per this policy (unless you give consent to a new policy). We will provide you with notice of an acquisition within thirty (30) days following the completion of such a transaction, by posting on our homepage, or by email to your email address that you provided to us. If you do not consent to the use of your personal information by such a successor company, you may request its deletion from the company.

‍FAMILY EDUCATIONAL RIGHTS AND PRIVACY ACT (“FERPA”)

If You are employed by a school or district subject to FERPA, You agree to appoint SoundTown as a “school official” as that term is defined in FERPA and as interpreted by the Family Policy Compliance Office, and determine that SoundTown has a “legitimate educational interest” for the purpose of delivering the services in accordance with these Terms of Use. SoundTown agrees that it shall be bound by all relevant provisions of FERPA, including operating under the direct control of your school or district with respect to handling of “personally identifiable information” from “education records,” as those terms are defined in FERPA.  SoundTown further agrees that personally identifiable information from students will not be disclosed to third parties except as required to provide the SoundTown Services to users contemplated in this Agreement. Any third party users will be bound to manage personally identifiable information in compliance with the Privacy Policy, security policies and all applicable laws, and to use the personally identifiable information for the sole and limited purpose of providing the SoundTown Services to its users.

SoundTown may use education records that have been de-identified for product development, research or other purposes permitted by applicable law (“De-Identified Data”), including: to demonstrate the effectiveness of SoundTown, including in our marketing materials; and develop and improve our educational products.  De-Identified Data means data from which all personally identifiable information, including direct and indirect identifiers, has been permanently removed or obscured so that the remaining information does not reasonably identify an individual and there is no reasonable basis to believe that the information can be used to identify an individual.

SoundTown agrees not to attempt to re-identify the De-Identified Data and not to transfer the De-Identified Data to a third-party unless that party agrees not to attempt re-identification.

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CHILDREN'S PRIVACY

SoundTown does not knowingly collect any information from children under the age of 13 (or the applicable age of consent in local jurisdictions) unless and until the School has obtained appropriate parental consent for the student to use the Services. Because SoundTown collects and uses Student Data at the direction of and under the control of a School, SoundTown relies on each School to provide appropriate notice to parents of the School's use of third party service providers such as SoundTown, and for the Schools to provide consent, if necessary, and authorization for SoundTown to collect Student Data, as permitted by COPPA and other applicable data protection laws. Please contact us  at team@mysoundtown.com.  if you believe we have inadvertently collected personal information of a child without proper consent so that we may delete such data as soon as possible.

HOW WE PROTECT YOUR INFORMATION

SoundTown uses commercially reasonable information security safeguards to protect its databases and servers against risks of loss, unauthorized access, destruction, misuse, modification, or inadvertent or improper disclosure of data.  SoundTown segregates certain personally identifiable and other information about your use of SoundTown's services into separate databases, some of which can be accessed only by a limited number of employees.  Your SoundTown account is protected by a password. You can help us protect against unauthorized access to your account by keeping your password secret at all times.

We restrict access to personal information to authorized SoundTown employees, agents or independent contractors who need to know that information in order to process it for us, and who are subject to strict confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations. All of our employees with access to Student Data are required to have passed a background check and receive annual training on how to maintain the security and confidentiality of student records.

In the event of an unauthorized release, disclosure or acquisition of Student Data that compromises the security, confidentiality or integrity of the Student Data maintained by SoundTown (a “Security Incident”), SoundTown will promptly notify the SoundTown account owner of any affected Schools via email and will use reasonable efforts to cooperate with their investigations of the incident. To the extent known, this notice will identify (i) the nature of the Security Incident, (ii) the steps we have executed to investigate the Security Incident, (iii) the type of Student Data affected, (iv) the cause of the Security Incident, if known, (v) the actions we have taken or will take to remediate any deleterious effects of the Security Incident, and (vi) any corrective actions we have taken or will take to prevent a future Security Incident. If, due to a Security Incident caused by the acts or omissions of SoundTown or its agents, a notification to an individual, organization or government entity is required under applicable privacy laws, the School agrees that, as the owner of the Student Data, the Schools are responsible for the timing, content, cost, and method of any required notice and compliance with those laws and SoundTown will indemnify Schools for all reasonable costs related to legally-required notifications.

WHERE WE STORE YOUR PERSONAL DATA

SoundTown is operated in the United States. If you are located outside of the United States, please be aware that the information we collect about you, including personal information, will be transferred to the United States. By using SoundTown, you consent to the transfer, processing and storage of your information, including personal information, in the United States in accordance with this Privacy Policy.

YOUR RIGHTS

SoundTown may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

If you would like to review, correct, or update our use of your personal information that you have previously provided directly to us, you may contact us at team@mysoundtown.com. In your request, please make clear what information you would like to have changed, whether you would like to have your personal information suppressed from our database, or if you have other questions about your personal information. We will try to comply with your request as soon as reasonably practicable. Student Data is provided and controlled by the Schools. If you have any questions about reviewing, modifying, or deleting personal information of a student, please contact your School directly.

DELETING YOUR ACCOUNT

How long we keep User Content: Following termination or deactivation of a School account, SoundTown may retain School profile information and content for a commercially reasonable time for backup, archival, or audit purposes, but any and all Student Data associated with the School will be deleted promptly. SoundTown may maintain de-identified or aggregated data, including usage data, for analytics purposes. SoundTown also may not be able to delete information that was previously shared with other users (such as through messages) or information previously shared with third-party applications. If you have any questions about data retention or deletion, please contact us team@mysoundtown.com.

If a parent, teacher or school administrator user wants to delete their account they can contact us at team@mysoundtown.com. We only keep a parent, teacher or school administrator’s personal information for as long as their account is active, unless we are required by law to retain it, need it to ensure the security of our community or SoundTown, or to enforce our Terms of Use. If an account is inactive for twelve months or more, SoundTown will automatically delete the account.
When a teacher or school administrator deletes their account, we delete the profile information and any other content the parent, teacher or school administrator provides in their profile and information collected through the permissions the parent, teacher or school administrator has granted.  

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We aim to maintain SoundTown in a manner that protects information from accidental or malicious destruction. Because of this, even after you update or delete personal information you have provided us from SoundTown, your personal information may be retained in our backup files and archives for a reasonable period of time as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety.

For example, if we suspend a SoundTown account for fraud or safety reasons, we may retain certain information from that account to prevent that user from opening a new account in the future. Also, we may retain and use your personal information to the extent necessary to comply with our legal obligations.

HOW TO OPT-OUT OF FUTURE COMMUNICATIONS

If a parent, teacher or school administrator user does not want us to contact you with marketing communications or other information regarding our products and services, you can let us know by following the unsubscribe instructions on any communications sent to you. You can also unsubscribe at any time by contacting us at team@mysoundtown.com.

NOTICE TO CALIFORNIA RESIDENTS

We do not rent, sell or share personal information about you with third parties who are not our partners or affiliates for their own direct marketing purposes unless you have opted-in to such a disclosure or were offered the opportunity to opt-out of such a disclosure at the time you provided your personal information and elected not to opt-out.

Do Not Track: Currently, various browsers offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to web sites visited by the user about the user’s browser DNT preference setting. SoundTown does not track its users over time and across third-party websites to provide behaviorally-targeted advertising and therefore does not respond to Do Not Track (DNT) signals. 

CHANGES TO OUR PRIVACY POLICY

We may modify this Privacy Policy from time to time. Any changes we make to our Privacy Policy in the future will be posted on this page. Please visit this page to see any updates or changes to our Privacy Policy. The date the Privacy Policy was last revised is identified at the top of this page.  We encourage you to check this page periodically for any changes. Your continued use of the Site following the posting of changes to this Privacy Policy constitutes acceptance of those changes. If we make any material changes that affect information we have previously collected about you we will provide notice via email or within the Site. 

CONTACT

If you have any further questions about this Privacy Policy or SoundTown's privacy practices, please contact us at the information below: team@mysoundtown.com or by mail at Hoogalit, PO Box #43 Palo Alto, CA 94304-1290.

By sharing your email, you agree to this Privacy Policy and our Terms of Use.

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