Community Education Center and its parent company Community Outreach Center Inc. (collectively, “COC”) is committed to protecting the privacy of personally identifiable information we collect in connection with your use of the TRAC portal (“Portal”). This Privacy Policy (“Policy”) describes our policies and practices regarding our collection, use and disclosure of information you submit, or we obtain in connection with your use of the Portal. This Policy is incorporated into and subject to the Terms of Use trac.coconline.org.

We reserve the right to change this Policy at any time. In the event we make material changes to the Policy, we will provide notice through the Portal. You understand and agree that your continued use of the Portal after the effective date means that the collection, use, and sharing of your information is subject to the updated Policy.

Please read this Policy carefully before using the Portal or submitting personally identifiable information to us. BY ACCESSING OR USING THE PORTAL, YOU CONSENT TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR INFORMATION AS SET FORTH IN THIS PRIVACY POLICY.

1. Information We Collect

We collect personally identifiable information that you provide when you access or use the Portal as a COC employee, or as a teacher or employee of a school, school district, or nonpublic school to whom COC provides contracted services (“Client”). We use the information we collect to operate the Portal, carry out our business, comply with laws and for other purposes described herein.

In connection with the actions listed above, you may provide or we may collect the following personal types of personally identifiable information

• Portal Users, generally: We collect usernames and passwords from Portal users when they register and access a Portal account and information related to Portal access and utilization.
• COC employees: We collect information from and about COC employees including name, address, email address, phone number, Social Security number, photo ID, hours worked, worked assignments, payroll and bank account information, and data related to Portal access and use. We also collect information that COC employees input relating to their work assignments such as school district student ID numbers, addresses, dates of birth, grade level, test scores, information about student services, and similar information.
• Client personnel (e.g., teachers, agents, school district employees): We collect name, address, school name, title or role, and school license. We also collect information that the Client chooses to provide.

2. How We Use Your Personally Identifiable Information

COC uses the personally identifiable information we collect only for the purpose it was collected, for compatible purposes, as permitted or required by law, as necessary to carry out our contractual duties and obligations, and as otherwise provided in this Policy. For example, we may use personally identifiable information in the following ways:

• Administer and manage your user account and the Client account.
• Communicate with you including delivering relevant information.
• Manage the employment relationship with COC employees, perform HR functions including time and attendance, process payroll, and review and management of work assignments.
• Manage the Client relationship and contract; provide contracted services; perform invoicing.
• Provide technical support to the Portal and users (including debugging and troubleshooting).
• Verify identify of users; enforce compliance with the Portal Terms of Use and policies that govern the Portal.
• Conduct research and development; monitor and analyze trends, usage, and activities relating to the Portal; make improvements to the Portal and our services.
• For everyday business purposes (e.g., HR functions, financial account management, IT and website administration, corporate governance, records management, reporting and legal compliance, employee training).
• Prevent, detect, and investigate fraud and other suspected illegal activities; protect the rights, property, security, and safety of COC and its employees, students, and Clients.
• Investigate claims or allegations; establish, exercise or defend a legal claim.
• Comply with legal and regulatory obligations.
• Fulfill any other purpose for which you provide it.

3. Disclosure of Personally Identifiable Information

In general, COC will not disclose your personally identifiable information except with your consent or as described in this Policy unless otherwise permitted or required by law. To carry out such purposes, we may disclose Personal Information to the following categories of third parties:

• Related entities and authorized COC personnel. For example, to perform HR functions related to COC employees, for Client contract management and provision of contracted services, or for other purposes consistent with a need-to-know based on the recipient’s role and responsibilities.
• Service Providers and Vendors. For example, to third parties who collect or process information on our behalf; software providers; website/platform host; email services support; security and fraud protection vendors; payroll or payment processing support; data analysis, IT services and data storage providers.
• Professional advisors. For example, to lawyers, accountants, or auditors.
• Client personnel and agents (e.g., authorized teachers, school district staff).

We reserve the right to disclose your personally identifiable information to third parties as necessary to

• Comply with federal, state, or local laws.
• Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities.
• Cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws.
• Investigate allegations or claims and establish, exercise or defend legal claims.

If another entity acquires us or all or substantially all of our assets, or assets related to the Portal, in connection with a merger into another entity or any consolidation, share exchange, combination, reorganization, or similar transaction, personally identifiable information that we have collected about the Portal users may be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets. If any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.

Notwithstanding the preceding paragraph, we do not sell, lease or rent personally identifiable information we obtain through your use of the Portal.

4. Safeguarding Your Information

We take reasonable and appropriate steps to safeguard the personally identifiable information we collect through the Portal. For example, we have implemented practices to safeguard your data from unlawful use, unauthorized access or disclosure such as encrypting data at rest and in transit. However, no system for safeguarding personal or other information is 100% secure and even though we take steps to protect your personally identifiable information from being intercepted, accessed, used or disclosed by unauthorized persons, we cannot fully eliminate security risks associated with personally identifiable information.

5. Text Messaging (SMS) Communications

If you provide your mobile phone number, you consent to receive SMS text messages from Community Outreach Center Inc. related to your account, including one-time passcodes for multi-factor authentication, account and profile change confirmations, and approval workflow notifications. Message frequency varies depending on your account activity. Message and data rates may apply. You may opt out of receiving text messages at any time by replying STOP to any message you receive. For help, reply HELP or contact us at info@coconline.org.

We do not share your mobile phone number or SMS opt-in consent information with any third parties for marketing or promotional purposes. Your mobile information will not be shared with third parties or affiliates for marketing or promotional purposes.

6. Your Choices

You can always limit the personally identifiable information you provide to us or opt out of providing certain personally identifiable information. However, if you choose not to provide certain requested information, you may be unable to access parts of the Portal or receive the contracted services. For COC employees, you may be unable to perform your job responsibilities or we may be unable to manage the employment relationship.

7. Contact Us

If you have any questions regarding this Policy or the privacy of your personally identifiable information, please contact us at info@coconline.org.