Privacy Policy

Effective Date: September 26th, 2014

Welcome to Sangha!

Sangha Inc. (“Sangha”) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of Personally Identifiable Information we receive when you download and use the Sangha mobile application or use the web client. If you have questions or concerns regarding this Privacy Policy, you should first contact Sangha at feedback@sanghapp.com . For information about your obligations and use of the Application, please see our Terms of Use policy.

This Privacy Policy may be updated from time to time to reflect new technology, your needs, and business developments. We will notify you of any material changes by posting the new Privacy Policy on the Application. You are advised to consult this Privacy Policy regularly for any changes.

1. Our Policy Towards Children.

The Children’s Online Privacy and Protection Act (“COPPA”) requires that online service providers obtain parental consent, with limited exceptions, before they knowingly collect personally identifiable information online from children who are under 13. Sangha does not knowingly collect or solicit personally identifiable information from a child under 13, except for that child’s name, email address, and child’s parent’s email address, which is the limited amount of personally identifiable information we are allowed to collect in order to provide notice to parents regarding the fact that we may contact their child multiple times for the purpose of providing the service that their teacher has signed up for. If we learn we have collected personal information from a student under 13, except for that child’s name, email address, and child’s parent’s email address, without parental consent being obtained from his or her parent or guardian, or if we learn a student under 13 has provided us personal information beyond what we request from him or her, we will delete that information as quickly as possible. If you believe that a student under 13 may have provided us personal information in violation of this paragraph, please contact us at feedback@sanghapp.com .

References to “Personal Information” in this Privacy Policy shall apply to personal information of individual users of the Application.

2. Definitions.

Before you review this Privacy Policy, we recommend you are familiar with the following concepts and terms so that you can best understand how Sangha uses data about you and to enhance your experience using the Application.

2.1 We.

“We” is defined as “Sangha Inc.”.

2.2 API.

An application programming interface or “API” is a particular set of rules and specifications that allows one software program to access and make use of another software program. It helps facilitate the interaction between applications, similar to the way the user interface facilitates interaction between humans and computers. Sangha uses APIs to enable programming or other similar third-party technologies, products, or activities available through the Application.

2.3 Cookies and other Tracking Technologies.

Cookies are small text files that web servers typically send to users’ computer when they visit a website. Cookies can be used on mobile applications as well. Cookies can be read or edited when the user loads a website or advertisement from the domain that wrote the cookie in the first place. Cookies are used by companies to collect and send information about a user’s visit – for example, number of visits to the application, average time spent, pages viewed, navigation history through the website, and other statistics. This information can be used to improve a user’s online experience by saving passwords, or allowing companies to track and improve website loading times, for instance. Cookies can also be used to track a user’s browsing or online purchasing habits and to target advertisements to specific users. Cookies cannot be used to access any other data on a user’s mobile device, to personally identify them, or to act like malware or a virus. Users who prefer not to accept cookies on the web can set their Internet browser to notify them when they receive a cookie or to prevent cookies from being placed on their hard drive. You can read more about cookies at http://www.allaboutcookies.org/cookies/. We may also use “pixel tags,” “web beacons,” “clear GIFs” or similar means (individually or collectively “Pixel Tags”) in connection with our Application to collect usage, demographic and geographical location data. A Pixel Tag is an electronic image, often a single pixel that is ordinarily not visible to users and may be associated with cookies on a user’s hard drive. Pixel Tags allow us to count users who have visited certain screens of the Application, to deliver branded Application and to help determine the effectiveness of promotional or advertising campaigns.

2.4 Personally Identifiable Information.

We define personally identifiable information (or “PII”) as “information that can be usedto uniquely identify, contact, or locate a single person or can be used with other sources to uniquely identify a single individual.” e. g. name, address, social security number, e-mail address etc. This is the common industry definition used by most Internet companies. Information thatcall “non-PII.”

Certain Non-Personally Identifiable Information would be considered a part of your Personally Identifiable Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. However, the same pieces of information are considered Non-Personally Identifiable Information when they are taken alone or combined only with other Non-Personally Identifiable Information (for example, your viewing preferences).

3. Information Collection and Use.

Our primary goals in collecting information are to provide and improve our Application, including communication features and capabilities, to administer your account, and to enable users to enjoy and easily navigate the Application.

3.1 What We Collect.

  1. Personally Identifiable Information.
    1. In the course of using the Application, we will ask you to provide us with certain Personally Identifiable Information that can be used to contact or identify you and administer your account. Personally Identifiable Information includes, but is not limited to, your name, mobile number, e-mail address, school affiliate and or student affiliation, if applicable.

  2. Required Account information.
    1. Please be aware that when you register with Sangha and set up an account (each a “User”), you will at minimum have to download the Application onto your mobile device.
    2. We may track your mobile device using an identifier (“User ID”) assigned by Sangha. This is a number different from your unique mobile device identification (such as “UDID”) or phone number.
    3. No other information is required to participate; however you may choose to provide additional information such as personal or corporate email addresses, photographs, and other contact information.

  3. Information regarding your use of the Application.
    1. Our Application also automatically collects log data about your use of the Application, for example, how you communicate with teachers, guardians, administrators, which features you use most, when you are active on the Application, when you have read communications sent through the Application, and what device you are using.

3.2 Why We Collect Your Information and How We Use It.

  1. Primary Use.

    We use your Personally Identifiable Information (in some cases, in conjunction with your Non-Personally Identifiable Information) mainly as follows:

    1. to administer your requests;
    2. as part of our efforts to keep the Application and integrations safe and secure;
    3. to protect Sangha’s or User content rights or property;
    4. for internal operations, including troubleshooting, data analysis, testing, research and Application improvement.

  2. Combined Data.

    We may combine your Personally Identifiable Information with Non-Personally Identifiable Information and aggregate it with information collected from other Users to attempt to provide you with a better experience, to improve the quality of the Application and to analyze and understand how our Application are used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions.


  3. Notifications.

    We also use your Personally Identifiable Information to contact you with marketing or promotional materials and other information about the Application that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications. We will endeavor to comply with your request as soon as reasonably practicable. Please note that if you opt-out as described above, we will not be able to remove your Personally Identifiable Information from our databases or those of our third party service providers to which we have already provided your Personally Identifiable Information as of the date that we implement your opt-out request. Sangha does not share, sell, rent or trade your Personally Identifiable Information with third parties for such third party’s direct marketing purposes.

3.3 What We Share.

  1. Your Contacts on the Application.

    By using the Application, users that you have connected with through the Application such as Teachers, Guardians, or Admins will have access to the following information about you:

    1. Knowledge that you use the Application when they join.
    2. Your profile picture.
    3. Whether you’ve volunteered for an event.

  2. Permissible Use.

    While you are allowing us to use the information we receive about you, you always own all of your information. Your trust is important to us, which is why we don’t share information we receive about you with others unless we have:

    1. received your permission;
    2. given you notice, such as by telling you about it in this policy; or
    3. removed your name or any other personally identifying information from it.

  3. Third Party Services That You Access.

    Of course, for information others share about you, they control how it is shared. Please note that third parties sites and applications that you access from the Application may use cookies and track your information as well. When using third party services, we suggest you familiarize yourself with their privacy policies and terms and conditions.


  4. Your Contacts on the Application.

    By using the Application, users that you have connected with through the Application such as Teachers, Guardians, or Admins will have access to the following information about you:

    1. Knowledge that you use the Application when they join.
    2. Your profile picture.
    3. Whether you’ve volunteered for an event.

  5. Other.

    We may make your personally identifiable information available to other companies, applications or people. For example we may share:

    1. Information you choose to provide in the course of your use of the Application by communicating it to other users of the Application, by being associated with an event, a child’s class or activity group communications.
    2. Information you allow us to share when you register with us, or through a subsequent affirmative election.or
    3. Information used when and if we hire or partner with third parties to provide specialized services on our behalf, such as credit card processing, data processing, customer/support services and other products or services that we choose to make available to our Users.
    4. We may share your information with a third party when we jointly offer a service or a feature with that third party, such as connectivity with other websites or applications, to provide personalization to the Application.
    5. We may share your information in order to (i) protect or defend the legal rights or property of Sangha our business partners, employees, agents and contractors (including enforcement of our agreements); (ii) protect the safety and security of Sangha users or members of the public including acting in urgent circumstances; (iii) protect against fraud or risk management purposes; or (iv) comply with the law or legal process.
    6. We also may use and share non-personally identifiable information, such as general demographic or location information, or information about the mobile device or desktop from which you access the Application. Additionally, we may de-identify personally identifiable information and share it in a de-identified or aggregated form with third parties, advertisers and/or business partners in order to analyze Application usage, improve the Application and User experience, or for other similar purposes. The use and disclosure of such information is not subject to any restrictions under this Privacy Policy.

4. Notifications and Other Messages.

We may send you notifications and other messages using the contact information we have for you, like your operating system.

If we make changes to this Privacy Policy we will notify you by publication here.

If the changes are material, we will provide you additional, prominent notice as appropriate under the circumstances.

5. Change of Control.

If the ownership of our business changes, we may transfer your information to the new owner so they can continue to operate the Application. But they will still have to honor the commitments we have made in this Data Use Policy.

6. Aggregate Information and Non-Personally Identifiable Information.

We may share aggregated information that does not include Personally Identifiable Information and we may otherwise disclose Non-Personally Identifiable Information and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Personally Identifiable Information.

7. Service Providers.

We may employ third party companies and individuals to facilitate the Application available therein, to provide the Application on our behalf and to perform Application related to administration of the Application (“Service Providers”). The types of Service Providers we use include, without limitation, Application providers that provide the following types of Application: website and application maintenance, hosting, database management, data analytics and administration. These third parties have access to your Personally Identifiable Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

8. Compliance with Laws and Law Enforcement.

Sangha cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Sangha or a third party, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate the foregoing.

9. Deleting and Deactivating your Account.

All Users may delete their account. If you choose to delete your account, Sangha may retain an archive copy of your account information for up to one (1) week after which the content will be fully purged. Sangha will only retain archive copy for longer than one (1) week if required by law or for legitimate business purposes. Users may delete their accounts by uninstalling the Application. Sangha may retain an archived copy of your records as required by law or for legitimate business purposes.

10. Security.

Sangha is very concerned with safeguarding your information. We are not in the business of providing information security. We use our best commercial efforts to employ limited data security measures, such as encryption, on some but not all systems. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while Sangha strives to use commercially acceptable means to protect your Personally Identifiable Information, Sangha cannot guarantee its absolute security. Do not provide your Personally Identifiable Information if you are concerned with its disclosure. We do our best to keep your information secure. We try to keep the Application available, bug-free and safe, but do not make guarantees about any part of our Application.

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via e-mail or conspicuous posting via the Application in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

We store data for as long as it is necessary to provide the Application to you and others, including those described above. Typically, information associated with your account will be kept until your account is deleted. For certain categories of data, we may also tell you about specific data retention practices.

11. International Transfer.

Your information may be transferred to - and maintained on - computers located outside ofyour state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to transfer of data across servers located in various states and countries.

12. Phishing.

Identity theft and the practice currently known as “phishing” are of great concern to Sangha. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.

13. Your California Privacy Rights.

California law permits residents of California to request certain details about what Personally Identifiable Information a company shares with third parties for the third parties’ direct marketing purposes. Sangha does not share your information with third parties for the third parties’ own and independent direct marketing purposes unless we receive your permission. If you have questions about our sharing practices or your rights under California law, please write us at feedback@sanghapp.com .

14. Contacting Sangha.

If you have any questions about the Privacy Policy, please contact Sangha at feedback@sanghapp.com .