The Mighty United (“Mightifier”, “company”, “we”, “our”, “us”) values highly the privacy of all its users. This Policy highlights important information regarding how we collect, use and disclose the data we collect from the users of our web application service (“Service”). Mightifier operates the Service on behalf of the teachers, schools or other entities (“customer”) using the Service with students, employees or other users (“user”).
In the Service the customer helps users to master their social and emotional skills through learning to give each other positive feedback based on their peers’ character strengths. E.g. it is teachers who help students master their social and emotional skills. Teachers are always the leaders of the feedback round. They start the rounds, monitor and lead it. In order for teachers to be able to use the Service, we may collect information of the Service users, such as users’ first names. We only collect personal information, such as first names, from the users on behalf of and at the direction of the customer.
Customers are in charge of providing consent to the collection and use of personal information of the users. With users under the age of 16 the customer must have consent from the users’ legal guardians. It’s also the customers’ responsibility to let guardians know about how information is being collected and used from the children under the age of 16.
WHO COLLECTS THE INFORMATION
WHAT SORT OF INFORMATION IS COLLECTED AND WHY
With the Service, customers can carry out positive feedback sessions (“Mightifying sessions”) and monitor group and user wellbeing progress. In schools the users’ wellbeing is tracked via specific regular questions relating to class atmosphere, school enthusiasm and experiences of bullying. In carrying out these activities, the customer may ask users to provide information like the first names of the users and opinions about the wellbeing topics. The Service does not make the decision to collect such information from the users, and we don’t need the users to give their names, contact information or other personal information. Still, when a customer asks for that information and the user provides it, the information is disclosed to the customer.
The customers, schools or other entities, using the Service for their educational purposes are responsible for making sure that collection and use of personal information complies with all applicable laws. As a parent if you have any questions about your child’s information and teacher’s use of it, you should discuss directly with your child’s teacher or school.
HOW INFORMATION IS COLLECTED
We may collect information about the users directly from users and customers, as well as automatically when the Service is used. We will not ask the users to provide more information than is necessary to use the Service. As already mentioned, we will not need to have specific information of user’s name, contact information or any other, unless the customer needs it.
INFORMATION THAT IS COLLECTED DIRECTLY
To log on to the Service, the customer needs to create a group consisting of the users, e.g. the students in the class. To use the Service, each user will need to have personal profiles. When the customer creates the group into the Service, they need to insert a specific name or nickname of each user in order to create personal login codes for them. The users access the Service by logging in with their individual login codes.
Legal guardians of children under the age of 16 have the right to ask us to stop collecting personal material of their children, but in such cases the child will not be able to use the Service with other children in the class under the teacher’s supervision.
INFORMATION TO BE COLLECTED AUTOMATICALLY
When a customer or a user uses the Service, some information is being collected automatically. This includes activities within our website and the Mightifier Service.
Users’ activities and performance in our Service, including participating in feedback sessions by giving feedback to other users, answering regular wellbeing questions, and the time they spent in each activity is information we collect. This personal information is then provided to the customer. We never use this personal information for our own commercial purposes. Before we analyze or use the data in any way for own commercial purposes, it’s always de-identified or aggregated.
HOW CHILDREN’S INFORMATION IS BEING USED
When any teacher uses the Service to collect own class names, assigns feedback sessions and asks children to answer the wellbeing questions, that information is being used by us for the following:
- to provide the Service
- to offer customer service and technical support
- to provide customer with information of users’ strengths and wellbeing
- Aggregated or de-identified data of the users may be used for research, analysis, and similar purposes. This may be to better understand how the users and customers use the Service and to improve the Service based on their needs and feedback, and for other research and analytical purposes.
HOW CHILDREN’S INFORMATION IS SHARED
We never sell customers’ or users’ personal information and users cannot make their own information public through Mightifier’s Service. We may disclose information of children to third-party Service providers who perform functions on our behalf. These parties are always committed to appropriate confidentiality and security obligations. Also in business acquisitions and mergers, bankruptcy proceedings, if we are part of such a business transfer, we may transfer the information to other company.
We may provide the information collected in order to comply with the law or with any legal procedure or if it’s necessary to investigate or take action against any illegal activities.
Aggregated and de-identified information may be shared with third parties on joint communication or research and development projects.
Mightifier has implemented necessary measures required by applicable law to ensure that the Service is protected against security threats. We also make sure that our personnel involved in our Services are instructed on security issues and bound by necessary confidentiality obligations.
CHANGES TO THIS POLICY
May 24th, 2018 – The Policy was updated to refer to also other entities than schools. The Policy was updated according to the General Data Protection Regulation of the European Union.
Oct 1st, 2018 – The rights of Mightifier to share infromation with third parties was narrowed down to communications or research and development purposes on joint projects with third parties.
This Policy is effective from the date below
May 24th, 2018
If you have questions, concerns or other feedback, please contact us.