Data Privacy Policy

Your privacy is very important to all of us at Willo Labs, LLC ("Willo"). We have established this data privacy policy ("Data Privacy Policy") to explain how data that includes personally identifiable information ("PII") and other non-public information, which includes, but is not limited to, student data, metadata, and user content (collectively "Data") is protected, collected, and used. PII includes information that can be used to distinguish or trace an individual’s identity either directly or indirectly through linkages with other information. The privacy practices of this Data Privacy Policy apply to our Services (as defined in our Terms of Use) available under the Willo website (the "Site"). By visiting the Site, using Site features, using Willo software, associated content, and/or any customizations made to the software provided by Willo, as provided through a learning management system or similar system, and/or portal (collectively, the "Services") you agree to be bound by the terms and conditions of this Data Privacy Policy. Your use of any Services constitutes use of the Site. If you do not agree, please do not use or access the Services. From time to time, Willo may modify this Data Privacy Policy to be in compliance with evolving state and federal laws and regulations. Willo shall post such modifications here on this Site. Your use of the Services after any such modification constitutes your acceptance of the modified Data Privacy Policy. We will not materially change our policies and practices to make them less protective of your privacy without the written consent of the Customer. The Customer may rely upon any and enforce any current or prior version of this policy unless otherwise agreed to in writing.

By submitting Data to us through the Services, you expressly consent to our use and disclosure of the Data in accordance with this Data Privacy Policy. This Data Privacy Policy is incorporated into and subject to the terms of the Willo Terms of Service and Use, available at http://www.willolabs.com/privacy.html.

Willo, in its role as a vendor to other educational vendors and institutions ("Customer(s)"), receives disclosures from the Customer of Data. Only information that is needed for Willo to provide Services for the Customer is disclosed to Willo. Willo will not sell, rent, share, or otherwise use, transfer, distribute, or redisclose such Data for any advertising or marketing purposes. Willo does not allow advertising within its Services. Willo uses Data only to deliver the Services contracted by the Customer. Willo may use de-identified, anonymized, non­PII data internally to improve the Services it delivers to the Customer.

Willo employs extensive technological and operational measures to ensure Data security and privacy, including advanced security systems technology, physical access controls, and annual privacy training for employees and partners. Willo will process any Data only within the country in which the Data was received.

All employees of Willo are required to sign an Acknowledgement and Agreement of Policies that commits the employees to comply with Willo's data privacy and security policies and receive required annual security and privacy training, including commitments and training regarding the prohibition on disclosure of Data.

Willo does not own any of the Data within its products. These Data within the products are property of, and under the control of the Customer. The collection, input, use, retention, disposal, distribution, transfer, and disclosure of any Data in our software applications and Services are controlled solely by the Customer.

In the event any third party seeks to access Data, Willo will immediately inform the Customer of such request in writing. Willo shall not provide access to Data or respond to such requests unless compelled to do so by court order or lawfully issued subpoena from any court of competent jurisdiction or directed to do so by the Customer. Should Willo receive a court order or lawfully issued subpoena seeking the release of Data, Willo shall provide immediate notification, along with a copy thereof, to the Customer prior to releasing the requested Data, unless such notification is prohibited by law or judicial and/or administrative order or subpoena.

In the event Willo becomes aware of a Data breach or inadvertent disclosure of Data, Willo shall take immediate steps to limit and mitigate such security breach to the extent possible. Willo will notify the affected Customer as specified in the applicable agreement. This typically will occur within 24 hours of confirmation of the event and would include the known relevant details.

In the event of termination of a license to use our products or Services, Willo shall work with the Customer, in accordance of the terms of the Customer's agreement, to destroy all Data contained in our systems and then shall permanently delete all archival or backup copies of the Customer's Data. Willo shall not knowingly retain copies of any Data once Customer has directed Willo as to how such Data shall be returned and/or destroyed. Furthermore, Willo shall ensure that it disposes of any and all Data received from Customer in a manner that maintains the confidentiality of the contents of such Data and complies with current industry standards. At the request of the Customer, Willo will provide a written certification of destruction.