1. Introduction

This Privacy Policy relates to the personal information that Cleverex Systems, Inc. (dba “Cleverex”) receives and stores through its application at www.myHeadStart.com and other sites owned and operated by Cleverex that refer to this Privacy Policy, and through all related technologies, software, and services provided by Cleverex, including its apps and its hosted products and services (collectively, the “Services”).

Cleverex provides Services to Head Start, Community Action, and other social services agencies (Customers) that manage their program participants (“Participants”) and services. This Privacy Policy does not impact or change any of the privacy policies, terms, and/or agreements between Participants and Cleverex Customers.

This Policy covers both the public-facing marketing web site operated by Cleverex (the “Public Site”) as well as Services provided only to registered users. As noted below, certain parts of the Privacy Policy apply only to the Public Site, and certain parts apply only to the Services.

If you are a Participant, we encourage you to review any applicable agency privacy policies, terms and agreements to see how your personal information may be used or disclosed by that agency (Customers, or Users).

2. Notice of Information Collected and Use

Customers

We will inform you when we need information that personally identifies you (personal information) or allows us to contact you or provide you with the Services. Generally, this information is requested when you register for our Services or when you fill out our contact form on our Public Site, or sign up for our newsletter or a webinar.

Participants

Cleverex may receive certain information about you from Customers during the program year for provision of Services. For example, Customers may provide basic Participant information, manually or through integration with student information or human resource systems, when they are setting up the Service for their use.

Customers and Participants

You may be able to log into our Services using your pre-registered credentials. Our services will authenticate your identity and may share certain personal information with us such as your name and email address.

Cleverex may also record information about how individuals access our Services. This information is typically not personally identifiable and may include internet protocol (IP) addresses (or the DNS name associated with it) of the individual's computer, the web site from which the individual linked to our Services, and the browser software the individual is using to access our Services. This information is used in the aggregate to administer computer systems and to make improvements to our Services.

Cleverex uses cookies and other technologies on our Public Site and as part of the Services for user session management and to provide a better user experience, including customization of content display. A cookie is text data that a website transfers to the individual's browser from a web server that is stored on the individual's computer hard drive. Cookies cannot be used by themselves to identify individuals.

3. Choice for Customers

If/When registration is available, you may choose not to register or provide personal information. You can still use the Public Site. But you will not be able to access Services that require registration.

If/When registration is available, you may register to select the kinds of information you want to receive from us by subscribing to various services and communications, like our electronic mailing list. If you do not want us to communicate with you about other offers regarding Cleverex products, programs, events, or services, you may select the option stating that you do not wish to receive marketing messages from Cleverex.

4. What We Do With the Information You Store In Our Systems

Cleverex will NOT share your personal information with any other third parties except in the following circumstances:

  • Trouble shooting issues with our database and software. We need to access your information only as necessary to provide these Services and to assist with supporting our users.
  • We may share your information in response to subpoenas, court orders, and other legal process or governmental request, or to establish or exercise our legal rights or defend against legal claims.
  • Cleverex may share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, protecting and defending the rights or property of Cleverex, its Services and its users, violations of Cleverex terms of use, or as otherwise required by law.
  • In the event that Cleverex is acquired by or merged with another company, Cleverex may share information regarding our users with that company. Cleverex will notify you before information about you is transferred that becomes subject to a different privacy policy.

5. Family Educational Rights and Privacy Act (FERPA)

Cleverex adheres to a policy of compliance with the Family Educational Rights and Privacy Act (FERPA). Cleverex employees, and Cleverex partner agencies all fully comply with FERPA when handing student data. At Cleverex, protecting student data is top priority. All student education data containing personally identifiable information (PII) is protected according to FERPA regulations and associated FERPA Agreement (NDA). A standard copy of Cleverex FERPA Agreement can be requested by Cleverex Customers. Cleverex operates at the explicit direction of the schools/divisions and when possible, Cleverex utilizes and shares properly de-identified data as its first option to limit the risk of unauthorized PII disclosure.

6. Access

Upon request, Cleverex will grant you reasonable access to personal information that it holds about you. In addition, Cleverex will take reasonable steps to permit you to correct, amend, or delete information that is shown to be inaccurate or incomplete.

7. Security

Cleverex takes reasonable technical, administrative and physical measures to protect the security of your personal information from unauthorized use, disclosure and alteration.

When you access all personal account information in our systems, you're utilizing a secure connection via SSL, which encrypts your personal information before it's sent over the Internet.

Cleverex provides information and training to all employees who have access to personally identifiable data maintained by Cleverex, and Cleverex employees are responsible for the internal security of such information.

Cleverex will not process personally identifiable information in any way that is incompatible or inconsistent with the purpose for which such information was collected.

Cleverex takes all reasonable measures to ensure that such information is reliable for its intended use, and is accurate, complete and current.

Inside the company, data is stored in password-controlled servers with limited access.

Cleverex Customers also have a significant role in protecting your information.

8. Dispute Resolution

Any questions or concerns regarding the use or disclosure of personal information should be directed to Cleverex pursuant to the contact information below. Cleverex will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy.

Cleverex and you agree that disputes that cannot be resolved after good faith discussions may be referred to the American Arbitration Association for resolution by binding arbitration.

9. In the Event of Merger, Sale, or Bankruptcy

In the event that all or part of Cleverex is acquired by or merged with a third-party entity, Cleverex may transfer or assign the personally identifiable information held by Cleverex as part of such merger, acquisition, or other change of control. In the unlikely event of Cleverex's bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, Cleverex may not be able to control how personal information is treated, transferred, or used.

10. Changes to This Privacy Policy

This Privacy Policy may be revised periodically by Cleverex, as reflected by the "last updated" date below. Please revisit this page to stay aware of any changes.

11. Contact Information

Cleverex welcomes questions and comments regarding this Privacy Policy. We may be contacted at info@cleverex.com.