Evolution Labs, a New Jersey Corporation (The “Company”, “we”, or “us”) and Shell College have developed Franklin 360 (the “Site”).
Our Privacy Commitment
Transparency - We will always tell you what data we’re collecting about you and how we use it. We only share your data with Shell College.
Security - We implement security practices based on presiding legislation and industry best practices to ensure your data is stored safely and securely. We protect the confidentiality, accuracy and availability of the information we collect about you.
Control - We always give you control over your data and the communications you receive from us and protect your rights under prevailing legislation including GDPR.
Information We Collect and Store About You
- Personal and contact information when you register an account with us online (or update that information in your account). This personal data provided when you register with the Site will include your name, email address, telephone number(s), and date of birth.
- We may also receive personal data directly from Shell College. In such circumstances, we may also store additional personal data including your school name, class, academic ID(s) and grade.
- Details of your communications and interactions with us via contact forms, email, online webchats, internal messaging and posts to forums or social walls.
- Information about how you use the Site including which content you have viewed, survey responses and other interactions on our Site.
- Technical information about your device or browser when you use our app or website, including geolocation data to determine what country you are accessing the Site from, your internet protocol (IP) address, device ID, browser type/version and time zone setting (which may in some circumstances be personal data).
IP address and other personally identifying data
Franklin 360 collects information about users’ IP addresses, including usage of our Website. We collect this data to help us develop our Website to better suit our Website users’ requirements and experience. We may use information about your IP address to help identify and resolve problems with our server, administer our Website, analyze trends, track visitor movements, and gather information that assists us in identifying visitor preferences. We also may use your IP address to enhance our security and investigate an actual or potential security incident. This use of your information is necessary for our legitimate interests in understanding how the Website and our Services are being used by you, to improve your experience and to ensure network and information security.
How We use Information we Store About You
We use the Personal Data we collect from you to:
- Provide and tailor the content and services of the Site. For EU Data Subjects, such use is necessary for the performance of the contract between you and us.
- Respond directly to your information requests (including registrations or other specific requests) or other inquiries. For EU Data Subjects, such use is necessary to respond to or implement your request.
Communication and marketing
We also use your contact information to contact you by email regarding information that we think may be of interest to you. If you do not wish to receive marketing materials, brochures, or emails from you may inform us of your preference by sending a letter, email or updating your preferences within “My Profile” or contacting us at the contact information below. You may also submit a contact form through the Site and unsubscribe from our communications by clicking on the “unsubscribe” link located on the bottom of all of our e-mails.
We will send you marketing information or notifications only with your consent, which was given at the time your personal data was provided. If you do not provide us with your consent to the processing of your Personal Data for this purpose, we will not send you this information.
How we share your data with third parties
We sometimes share the data we collect from you with the following trusted third parties:
- Shell College for the purpose of updating Shell College with your preferences and details of your interaction on Franklin 360.
- Law enforcement agencies as part of an investigation or otherwise for legal or regulatory purposes.
- Appropriate agencies when you indicate that you are at significant risk of self-harm, through chat, text, survey or other forms of communication.
- Shell College when you've provided actionable feedback about the institution that we feel warrants follow-up.
- Appropriate agencies when we respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims;
We will disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request. We do this in order to protect our rights, property or safety.
We may also share your information as part of a business transfer. Your information may be transferred to a successor organization if, for example, we transfer the ownership or operation of this Site to another organization or if we merge with another organization. If such a transfer occurs, the successor organization’s use of your information will still be subject to this Policy and the privacy preferences you have expressed to us.
How long do we store your personal data
Personal data that we process and store will not be retained for longer than is necessary for the purpose(s) for which it has been obtained. In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In these instances, we will determine the period of retention based on customary business practice.
Notwithstanding any contrary provisions in this Policy, however, we may retain your Personal Data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
How do we protect your personal data
We are committed to taking reasonable efforts to secure the information that you choose to provide us. We use a variety of security procedures to help protect against unauthorized access to or alteration, disclosure, or destruction of Personal Data. We restrict access to Personal Data to Evolution Labs and Shell College employees who need to know the information to operate, develop, or improve our services.
Franklin 360 is accessed using https rather than http to ensure information that is sent and received is encrypted for additional security. You can check this is always the case in the address bar of your browser.
You have the right:
- to ask us not to use your personal data for direct marketing or communications with you. To do so, visit your profile and communication settings within your account.
- to ask us not to process your personal data where it is processed on the basis of legitimate interests, if there are no compelling reasons for that processing;
- to request from us access to personal information held about you
- to ask for the information we hold about you to be rectified if it is inaccurate or incomplete;
- to ask that we stop any consent-based processing of your personal data after you withdraw that consent;
- to ask, in certain circumstances, to delete the personal data we hold about you;
- to ask, in certain circumstances, for the processing of that information to be restricted; and
- to ask, in certain circumstances, for data portability.
- to request and obtain from us, once a calendar year, information about the personal information we shared, if any, with other businesses for marketing uses.
Access to Your Information
If you would like to review, correct and update the personal information you have provided to us through this Site, please contact us by email at email@example.com. We will respond to your request within the time limit set out by the applicable privacy legislation. We will use reasonable efforts to comply with your request as required by applicable law.
Links to Other Websites
This Policy shall be governed under the laws of the State of New Jersey, the United States of America without regard to its conflicts of law provisions.
Age requirements and children
Students are encouraged to use this website with parental or other guidance from an adult.
Special Notice to Parents, Teachers and Children
Parents and Teachers: When using this Service, we encourage parents, guardians and teachers to spend time with their children, especially if the child is 12 and under (“Child” or “Children”). We will never request personally identifiable information from a Child in any of our public postings areas. We will not require a Child to disclose more personally identifiable information than is reasonably necessary to participate in any online activity. WE ASK PARENTS TO HELP US PROTECT THEIR CHILDREN’S PRIVACY BY INSTRUCTING THEM NEVER TO PROVIDE PERSONALLY IDENTIFIABLE INFORMATION ON THIS SERVICE OR ANY OTHER SITE WITHOUT FIRST GETTING PARENTAL/GUARDIAN OR TEACHER PERMISSION.
Children: Please do not give your full name, email address, home address, telephone number or any other personally identifiable information that would enable someone to contact you either online or offline, without first asking your parent/guardian or teacher for permission.
We do not knowingly collect personally identifiable information from Children either directly or passively except when a Child voluntarily submits such information through a “Contact Us“ link or a public posting area within the Service, if such feature is available. If a Child emails us via a “Contact Us“ link on any child-directed area of this Site and we can identify the sender as a Child, any personally identifiable information submitted will only be used to respond on a one-time basis to such Child. In addition, if we have actual knowledge that a Child is sending or posting personally identifiable information on any area of the Service, we will use commercially reasonable efforts to delete such personally identifiable information as soon as practicable.
Strictly necessary cookies
These are required for the operation of Franklin 360 and related apps. Without these cookies you will not be able to use some functionality on Franklin 360 such as registering and signing into your account, completing surveys or interacting with content.
These cookies collect information about how you use Franklin 360 and help us improve the way our website and app work by making it easier for you to navigate to and interact with Franklin 360.
These cookies allow us to identify whether you are logged into your account, to remember choices you make and your preferences in order to provide you with tailored content and improve your experience or provide additional functionality of Franklin 360.
Conditions of Use
By mail to:
Data Protection Officer
Evolution Labs Inc
83 South Street
Morristown, NJ 07960
By email to: firstname.lastname@example.org