BocaVox LLC – Privacy Shield Policy

I. NOTICE

This Privacy Policy details the practices BocaVox, LLC has established in order to comply with the EU-U.S Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use and retention of personal information transferred from the EU to the US. BocaVox, LLC has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

Collection and use of personal data

BocaVox, LLC provides Maestro SIS a software solution for learning institutions, and as a default to its members, students and parents/guardians.  Throughout Maestro SIS we collect various types of personal information when users register at the chosen learning institution, create and log in into their accounts. For BocaVox, the information collected is used solely to provide access to the learning intuitions who have selected Maestro as their administrative system for admission to a learning institution, and thereafter to manage personal academic data and communications once a student / parent or guardian becomes accepted to such learning institution. Nothing herein is shared with or sold to any other organization for any commercial purposes.

The personal information we collect may vary according the learning institution and the school district involved, and is not limited to: user name, user id, first and last name, role, organization affiliation,  email address, phone number, birth date, personal records and billing information (which may include credit card and /or bank information) site tracking data (IP address and browser type, Operating system, java script version, cookies, activity, event) and in general the actions users take when they visit Maestro, class information (assignments, files, notes, discussions, mail messages, links, reminders, and all other documents that you submit to Maestro SIS), and potentially any information submitted when creating an account in Maestro SIS.

BocaVox uses personal data that it collects for the below business purposes:

  1. Maintain and support of Maestro SIS and contractual obligations with its schools
  2. Verify identity of users
  3. Storing and processing data in computer databases located in the US

 

 II. CHOICE

In accordance to the Privacy Shield principles, BocaVox offers its users the choice to apply to their learning institution through the Maestro SIS site, or to contact their learning institution directly for other means of applying for admission.

In the event of Personal Data covered by this policy will be used for a new purpose, that is materially different from that for which is was intended, BocaVox will take the actions necessary to inform its customer and the users of Maestro SIS of the new purpose and provide the choice to whether to have their Personal Data use or disclosed.

 

III. DISCLOSURES / ONWARD TRANSFERS OF PERSONAL DATA

While we promise to never share or sell your data to other organizations, there are a few instances where we may have to provide it to other entities. The only situations where we will share your personal information are under the following, circumstances:

  • When you wish to make an online payment through a third party such as e-commerce application, or enroll in a course offered via a Learning Management System (LMS) and/or other integrated applications in order to perform BocaVox’s contractual obligations with your learning institution.
  • We will only transfer the data only if the third party has made contractual assurances that it will (i) process the Personal Data for limited and specified purposes consistent with any consent provided by the Data Subjects, (ii) provide at least the same level of protection as is required by the Privacy Shield Principles and notify us if it makes a determination that it cannot do so; and (iii) cease processing of the Personal Data or take other reasonable and appropriate steps to remediate if it makes such a determination.
  • When necessary to share your information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.

Notice for School users:This Privacy Policy does not govern your learning institution’s use or disclosure of personal information though Maestro SIS. BocaVox, the developer of Maestro SIS, is not responsible for your learning institution’s collection, use or disclosure of personal information. Contact your learning institution or visit its website for its privacy practices.

 

IV. SECURITY

BocaVox, LLC maintains reasonable and appropriate measures to protect personal data from loss, misuse, unauthorized access, disclosure, alteration and destruction in accordance to the Privacy shield Principles.

 

V. DATA INTEGRITY AND PURPOSE LIMITATION

BocaVox, LLC limits the collection of Personal Data covered by this Privacy Shield Policy to information that is relevant for the purpose of complying with it contractual obligations with your learning institution, and does not process such Personal Data in a way that is not compatible with the express purposes for which it has been collected.

BocaVox, LLC complies with the requirement under the Privacy Shield Policy of retaining the Personal data in an identifiable form as long as it serves it purposes and complies with the Privacy Shield Principles.

 

VI. ACCESS

You have the right to access and modify or update to your personal information all the time. Changes to this information will be dependent on the requirements of the Learning Institution you are associated with, therefore,  contact your learning institution regarding to modifications to your personal information after the account creation.

 

VII. RECOURSE, ENFORCEMENT AND LIABILITY

BocaVox’s participation in the EU-U.S. Privacy Shield Framework is subject to investigation and enforcement by the Federal Trade Commission.

In compliance with the Privacy Shield Principles, BocaVox commits to resolve complaints about your privacy and our data collection or use of your personal information. EU Individuals with inquiries or complaints regarding our Privacy Shield policy should first contact BocaVox at:

BocaVox – Privacy Shield
2900 Glades circle, Suite 500
Weston, FL 33327
(954) 453-9705
info@bocavox.com

BocaVox has further committed to refer unresolved Privacy Shield complaints to JAMS an independent alternative dispute resolution provider based in the U.S. To contact JAMS and or learn more about the company’s dispute resolution services including instructions for submitting a complain visit https://www.jamsadr.com/. The services of JAMS are provided at no cost to you.

For residual complains not fully or partial resolved by other means, you may able to invoke a binding arbitration as detailed on the Privacy shield Annex I principles (https://www.privacyshield.gov/article?id=ANNEX-I-introduction)

 

VIII. CHANGES TO THIS POLICY

This Policy may be amended consistent with the requirements of the EU-US Privacy Shield frameworks and applicable data protection and privacy laws and principles. We will notify employees of available changes to this policy as it is updated. BocaVox will informs its customers and data subjects of the changes in this Policy when the changes made affect the data collection and we will allow them to choose to accept/reject the changes.

 

IX. QUESTIONS OR COMPLAINTS

Customers may contact BocaVox, LLC with questions or complaints concerning the Policy at info@bocavox.com