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At BoulayBank, student privacy and security is number one.




Read below to see what are the student privacy laws and to view our privacy policy.  

What is FERPA?

FERPA is ‘The Family Educational Rights and Privacy Act’. It protects the privacy of students’ “Educational Records” by specifying how and with whom schools can share information from these records.

FERPA says that schools cannot share student information without parent consent. Without that written consent, FERPA only allows a school to share student information if an ‘exception’ is met. The two most common exceptions specified by FERPA are: the “Directory Information” and “School O ffi cial” exceptions.

Under FERPA, schools can use the school official exception to share some information with third-parties that provide a legitimate educational function. BoulayBank teaches students financial literacy through an online mock bank. Alternatively, schools can choose to not rely on school official exception and get parental consent for each technology used. If a school prefers to get parental consent for BoulayBank, they must first send out the consent form found here .

FERPA is very vague about whether the virtual deposits and withdrawals, and general account transaction of student actions would legally be considered an Educational Record. So, it’s really up to each school to decide. If deposits and withdrawals and general transactions on a student's virtual bank account is deemed to be an “Educational Record”, then one of the exceptions must be met, or parent consent must be obtained.

What is COPPA ?

How to comply with Children's Online Privacy Protection Act

COPPA is the “Children’s Online Privacy Protection Act” created and put into effect on April 21, 2000. This act applies to students under the age of 13 to protect their personal information. A website operator must include in a privacy policy when and how to seek parental consent and what responsibilities BoulayBank has to protect students privacy and safety online.

To address COPPA, BoulayBank does not collect students’ addresses, telephone numbers or email addresses. The only information collected from a student is a username and name. This information is given directly from the student or through the teacher. There is no marketing back to the student, no contest winners and no way to make information publicly available to any external sites.

No student information is rented, or sold to third parties, ever.

If we employ other companies and people to perform tasks on our behalf and need to share any information with them to provide products or services to BoulayBank, they do not have any right to use the personal information or student’s personal information we share with them beyond what is necessary to assist us. We also take steps to ensure that they agree to protect the personal information or student’s personal information shared with them.

Parents can request that their student has a pseudonym in place of their name when accessing BoulayBank. Parents can review the student’s personal information, ask to have it deleted and refuse to allow any use of the information throughout the year. All parents need to do is tell the teacher and the teacher will need to delete the student’s profile on BoulayBank.

Privacy Overview :

BoulayBank takes student privacy seriously. That is why we collect only the minimal amount of information from a student to provide the service, just a first name, username and password. We don’t ask for anything else, such a gender, SSN, email, address, student ID, or age.

Below, we give an overview of the website, its educational function, and how we protect student privacy and security.


Privacy Policy

Overview

Personal information is any information you provide to us that personally identifies you, like your name or email address, or other information which could be linked to such identifying information by us. We will only collect, use, and share your personal information in accordance with this Privacy Policy.

This policy applies whether you use BoulayBank through https://boulaybank.com, our mobile application or any of our other products or services that link to this Privacy Policy (collectively, the “Service”).

Moreover, this Privacy Policy covers BoulayBank’s treatment of any personal information about our users that teachers or other services might share with us, for example responses to a teacher survey collected through   Google forms.

This policy does not apply to websites or services or practices of companies that BoulayBank doesn’t own or control, such as third party services you might access through links or other features (e.g., social media buttons, lesson plan resources, etc.) on the Service. These other services have their own privacy policies, and we encourage you to review them before providing them with personal information.

Please take the time to get to know our privacy practices. If you have any questions you can email us at support@boulaybank.com .  

By using the Service, you acknowledge that you accept and agree to this Privacy Policy.



What is BoulayBank?

BoulayBank is an education software platform that allows teachers to manage their classroom while teaching essential finance skills to students. Students create a profile under a secure teacher’s account that they can login to, set up a profile picture (the student’s teacher is prompted to approve the photo taken by the student before it can be shared with other students) and resume. Students then manage virtual (not real) checking, savings and credit accounts. Students pay bills, purchase assets and learn the advantages of saving. Teachers can use BoulayBank to help incentivize behaviors they want to see in the classroom like completing work and showing the school’s norms through deposit and withdrawals, called Action Items. Teachers can also teach essential financial literacy skills through the use of BoulayBank and its functions. Students have access to see, but not alter in any way, other students profile pictures, resumes and personal account information. Students can see other students in their class, a news log of virtual deposits and withdrawals made each day, a leaderboard to see the virtual net worth and ranking of students, their virtual bills and virtual assets, the teacher approved profile pictures and student created resumes of that teacher’s class.

When students set up a BoulayBank account, they input their first name and then create a unique username and password. We don’t ask students to enter any other personal information when setting up an account. If a student’s school or teacher wants to use any of the data created by a student such as their resume or transaction history, the school will be responsible for obtaining any necessary parental consent under COPPA .

School administration or other decision makers in the school may choose to purchase a school account in BoulayBank. This allows the administration access to teacher and student accounts to add, edit or delete student accounts transactions (deposits and withdrawals).


How does BoulayBank protect student’s personal information?

Protecting student privacy and overall security is number one at BoulayBank.

What information does BoulayBank collect from students, and how is it used?

BoulayBank  collects the minimal amount of information from students necessary to create accounts on our Service: we ask students to provide a unique username, a first name, a password, and the unique code (similar to Google Classrooms) they have been given by their teacher to connect with a classroom. We will not use or ask for parent or student emails and have no intention of spamming or marketing to anyone. We don’t ask students to enter any other personal information when setting up an account.

Photos and Videos

When students create an account, they are able to upload a picture of themselves. This photo is sent to be approved by the teacher prior to the class being able to see it.

If we discover that we have collected information from a student in a manner inconsistent with COPPA, we will take appropriate steps to either delete the information, or immediately seek the parent’s consent for that collection. We do not disclose any personal information about students to third parties, except to service providers when necessary to provide the Service, as required by law or to protect the security of the Service or other users. Information collected from students (including personal information and information collected automatically) is never  used or disclosed for third party advertising or for any first- or third-party targeted advertising, and student’s personal information is never  sold or rented to anyone, including marketers, advertisers, banks or other financial institutions.

If a teacher chooses to set up their students’ accounts, he or she can choose to provide full names for students (e.g., first name and last name) when setting up their class; they can also opt to only provide non-identifying information (e.g., just first name, only initials, or even just seat numbers).



What Student’s Information is Visible to Others?

S tudent’s profile, picture and resume is never made available or visible to the public through BoulayBank. Teachers may share their classroom profiles with other teachers and administration in the building but without a media release and/or written permission from a legal guardian, students information is not available to use for any reason outside of the school. In addition, students can see each other’s profile pictures, resume, classroom jobs, networth, net currency, and transactions through the news log and class ranking - this is similar to how a teacher might display classroom jobs, behavior charts and progress toward a specific goal around the classroom. The only other time student information or teacher information is visible to others is when the teacher contacts BoulayBank to assist in setting up, managing, navigating, editing or deleting their account. BoulayBank staff will also periodically access teacher accounts to see if they are using the account and send follow up emails with how to better use the software but they will not change, alter or delete any information unless asked to do so by the teacher.


How Long Does BoulayBank Keep Student Information?

We only keep a student’s personal information for as long as his or her student account is active for the school year, unless we are required by law to retain it, need it to ensure the security of our community or our Service, or to enforce our Terms. More specifically, BoulalyBank operates a 3-tier student data protection policy to protect all students’ information ( 3-Tier Student Data Protection Policy ):

  1. Minimal information:  As mentioned before, BoulayBank collects the minimal amount of information from students necessary to create accounts on our Service: we ask students to provide just the unique student code given by their teacher, a username, a name and a password.
  2. One year deletion policy for account profiles and transaction history: To protect students, BoulayBank sets limits on how long students account profiles and transaction history is retained. Teachers can also delete students individually or the entire class by entering their password.
  3. Deleting inactive accounts: If a student’s account is not in use for twelve months or more (meaning there has been no logins) BoulayBank will automatically delete the student account, including all personal information provided by the student.

Teachers also have the abilitly to delete their students from their account by logging into their account and then typing in their password to confirm that they would like to delete all of their students. BoulayBank strongly encourages teachers to delete all student data at the end of their time with that student to help protect student data.



Parental Choices

If you are the parent or legal guardian of a student who has created a BoulayBank account and you do not want your student to have a BoulayBank account, talk to your teacher about alternatives or to have him/her delete your child’s account and/or email us at support@boulaybank.com .



What information does BoulayBank collect?

BoulayBank asks for some limited information directly from teachers and students (such as account information), and also collects some information automatically (such as crash reports when errors occur) in order to provide you with the best possible BoulayBank experience.



Information you provide to us

There are currently three categories of users on our Service: schools, students and teachers. We describe the information collected from students above; for other users, we collect and store the following types of information from each type of user:

  • Account Sign-up and Profile Information: To create a BoulayBank account as a school, you may be asked to provide some basic information such as your first name, last name, school, location, username and password. Schools may view teacher’s in that school’s account; however, no teacher, or student profile is made available or visible to the general public through the functionality of our Service.If you create a BoulayBank account as a student, you will be asked to enter the code (similar to Google Classroom) you have been given by your teacher (students are unable to sign up for the Service without this), along with a name, unique username and password. Teachers may also give a letter of consent to use BoulayBank located here.   We don’t ask students to enter any other personal information to create their student accounts. If you are a teacher, the only information we ask for is a first name, last name, school name, email, location and how you heard about us.
  • School Information and Collaboration Features: If you are a teacher, as part of the profile information you provide, you may choose to associate your account with a school account or may enter a new school name, location and how you heard about BoulayBank. By connecting you with your school, the Service may enable and provide additional collaboration features for teachers and school leaders within the same school such as depositing and withdrawing different action items (incentivized behaviors) for students in different classes such as specials teachers.
  • Class Information: As a teacher you can enter the class grade and the names of the students in your class. If teachers need help with their account, they can contact the staff at BoulayBank to access their account and help with training, which allows the staff to see some class information like a students name, grade, networth and virtual bank account amounts. However, none of the boulaybank staff are permitted to share any of the information outside of the BoulayBank staff that they see when aiding a teacher in using the software.
  • Deposits and Withdrawals: As a teacher or school, you can customize a list of incentivized behaviors, in the form of deposits or withdrawals, that you want to encourage or recognize in student actions. These transactions can be seen and edited by the teacher or the banker job- a student in the class with access to editing and assigning bills to students in their individual class.
  • Contact Information: When you choose to provide us with your personal information through the Service in some other manner (e.g., when you send us an email asking a question, submit a support request through Google Forms, participate in a written or video testimonial about our Service, or choose to participate in any research efforts with BoulayBank to improve the Service) we will store your contact information on Insightly.



Information collected automatically

Like most web-based services, we may automatically receive and log information on our server logs from your browser or your device when you use the Service. For example, this could include the frequency and duration of your visits to BoulayBank on Google Analytics. If we combine any automatically-collected information with personal information, we will treat the combined information as personal information, and it will be protected as per this Privacy Policy.

The technologies and information we automatically collect include:

  • Cookies and other similar technologies: We may use various technologies to collect and store information when you visit our Service including, Google Analytics. Like many services, BoulayBank uses these technologies to tailor the Service for you, and to help the Service work better for you.
  • Device information: We collect device-specific information such as your operating system, hardware version, device settings, file and software names and types, battery and signal strength, and device identifiers. This helps us measure how the Service is performing and improve BoulayBank for you on your particular device.
  • Log information: Like most online services, when you use our Service, we automatically collect and store certain information in our server logs. Examples include things like:
  • Details of how you used our service, such as your activity on the Service, and the frequency and duration of your visits to the BoulayBank Website or BoulayBank App
  • SMS routing information
  • 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
  • This information helps us make decisions about what we should work on next or improve upon on BoulayBank.
  • Location information: When you use our Service we may collect and process information about your geographic location, for example through GPS, Bluetooth, or WiFi signals on Google Analytics. We collect both coarse (i.e., city-level) location data and precise location data. If we collect precise geolocation information (“precise” meaning sufficient to identify street name and name of city or town) from you (such as when a teacher is searching for a school), we ask for your explicit opt-in permission. We do not  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 Service.



How does BoulayBank use the information it collects?

BoulayBank  does not sell or rent any of you, or your student’s personal information to any third party for any purpose - including for advertising or marketing purposes. Targeted advertising is not permitted on BoulayBank. We only use information you provide us to:

  • Provide and improve the Service, for example by fixing problems or developing new features
  • Respond to your requests for information or customer support
  • Customize the Service for you, and improve your experience with it
  • Send you information about new features and BoulayBank products we believe you may be interested in
  • Most crucially, to protect our community by making sure the Service remains safe and secure


Will BoulayBank share any information it collects?

No.

  • Other Users You Share and Communicate with on BoulayBank: No teacher, administrator, parent or student profiles are made available to the general public through our Service. Please keep in mind that information (including personal Information or student's personal information) or content that you voluntarily disclose to others - including to other BoulayBank users you interact with through the Service (such as messages you might send other users or other teachers and administration you collaborate with) - can be viewed, copied, stored, and used by the people you share it with. We cannot control the actions of people with whom you choose to share information.
  • If teachers need help with their accounts, they can contact the staff at BoulayBank to access their accounts and help with training, editing, deleting or adding information the account. When the BoulayBank staff accesses the teacher’s account, they can see the class information like a students names, grades, networth, virtual bank account amounts, etc. However, none of the boulaybank staff are permitted to share any of the information outside of helping the teacher in using the software to it’s fullest extent.
  • Third-party integrations on our Service: When, as a teacher or administrator, you use third-party apps, websites or other services that use, or are integrated with, our Service, they may receive information about what you post or share. For example, when you invite others via Facebook or Twitter, these services receive the information that you share through this functionality, and information that you are sharing from BoulayBank. Information collected by these apps, websites or integrated services is subject to their own terms and policies.
  • Service Providers: Targeted advertising is not permitted on BoulayBank. We do work with vendors, service providers, and other partners to help us provide the Service by performing tasks on our behalf. I’m busy teaching in the classroom as well and don’t have time to do it all! 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 service providers do not have the right to use your personal information we share with them beyond what is necessary to assist us. Additionally, these service providers must adhere to confidentiality and security obligations in a way that is consistent with this Privacy Policy.
  • Testimonials: We post testimonials on our Service which may contain personal information such as the name, photo and/or a video of the individual in the testimonial. We obtain the individual’s consent in advance to ensure we have permission to post this content publicly. To request removal of your personal information from our testimonials, please contact us at support@boulaybank.com
  • Analytics Services: By way of Google Analytics, we collect user information including but not limited to IP address, geolocation, browser information and usage behavior.
  • Google Analytics will use this website to install tracking cookies in addition our session cookie which holds user state across multiple pages.
  • Using this website implies consent for allowing us to install cookies on your computer.
  • Aggregated Information and Non-Identifying Information: We may share aggregated, non-personally identifiable information publicly, including with users, partners or the press in order to, for example, demonstrate how BoulayBank is used, spot industry trends, or to provide marketing materials for BoulayBank. Any aggregated information shared this way will not contain any personal information.
  • 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 to protect the rights, property, or safety of BoulayBank, our employees, our community, or others, or to prevent violations of our our Terms of Service or other agreements. This includes, without limitation, exchanging information with other companies and organizations for fraud protection or responding to government requests.
  • Sharing with BoulayBank Companies: Over time, BoulayBank may grow and reorganize. We may share your personal information with affiliates such as a parent company, subsidiaries, joint venture partners or other companies that we control or that are under common control with us, in which case we will require those companies to agree to use your personal information in a way that is consistent with this Privacy Policy.
  • Change of control: In the event that all or a portion of BoulayBank 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.
  • In the event that BoulayBank goes out of business, or files for bankruptcy, we will protect your personal information, and will not sell it to any third party.
  • With your consent: Other than the cases above, we won’t disclose your personal information for any purpose unless you consent to it. Additionally, as discussed above, we will never sell or rent your personal information to advertisers or other third parties.



How does BoulayBank protect and secure my information?

Your BoulayBank account is protected by a password. You can help us protect against unauthorized access to your account by keeping your password secret and complex at all times.

The security of your personal information is important to us. We work hard to protect our community, and we maintain administrative, technical and physical safeguards designed to protect against unauthorized use, disclosure of or access to personal information.

We make every effort to maintain the security of personal information, and we work hard to ensure the integrity and security of our systems, no practices are 100% immune, and we can’t guarantee the security of information. Outages, attacks, human error, system failure, unauthorized use or other factors may compromise the security of user information at any time. If we learn of a security breach, we will attempt to notify you electronically (subject to any applicable laws) so that you can take appropriate protective steps; for example, we may post a notice on our homepage (www.BoulayBank.com) or elsewhere on the Service. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.



Can I opt-out of providing information?

You can always decline to share personal information with us, or even block all   cookies. However, it’s important to remember that many of BoulayBank’s features may not be accessible, or may not function properly.



How can I access and manage my personal information?

BoulayBank  aims to provide you with easy access to any personal information we have collected about you. If that information is incorrect, we give you easy ways to update it, or to delete it, unless we have to keep that information for legitimate business (e.g., we need at least an email address for your account) or legal purposes.

  • Accessing and Changing Your Information: Upon request, BoulayBank will provide you with information about whether we hold any of your personal information, and, if you are a user of BoulayBank, you may request access to all your personal information we have on file by contacting us at support@boulaybank.com. In some cases, we won’t be able to guarantee complete access due to legal restrictions - for example, you will not be allowed to access files that contain information about other users or information that is confidential to us. We may not be able to fulfill requests that are unreasonably repetitive, require disproportionate technical effort or would be extremely impractical.


How can I delete my account?

You can delete your account at any time by contacting us at support@boulaybank.com . If you are a school, teacher or student, you can delete your account anytime by logging into your account and delete your profile.

When you delete your account, we delete your profile information and any other content you provide in your profile (such as your name, username, password, email address, and profile photo).



How long does BoulayBank keep information about me?

We store your personal information for as long as it is necessary to provide products and Services to you and others, including those described above. Personal information associated with your account will be kept until your account is deleted.

Please note that we may have to retain some information after your account is closed, to comply with legal obligations, to protect the safety and security of our community or our Service, or to prevent abuse of our Terms. You can, of course, delete your account at any time as stated above.



Social Media Features/Widgets

The Service may now or in the future include social media features, such as the Facebook, Twitter, Pinterest or Instagram. These social media features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. Your interactions with these social media features are governed by the privacy policy of the company providing each social media feature.



How will BoulayBank notify me of changes to this policy?

We may occasionally update this Privacy Policy - you can see when the last update was by looking at the “Last Updated” date at the top of this page. We won’t reduce your rights under this Privacy Policy without your explicit consent. If we make any significant changes, we’ll provide prominent notice by posting a notice on the Service.

We encourage you to review this Privacy Policy from time to time, to stay informed about our collection, use, and disclosure of personal information through the Service. If you don’t agree with any changes to the Privacy Policy, you may terminate your account by contacting us at support@boulaybank.com. By continuing to use the Service after the revised Privacy Policy has become effective, you acknowledge that you accept and agree to the current version of the Privacy Policy.