diff --git a/seesaw_privacy.txt b/seesaw_privacy.txt index 5557087..3e5a3d2 100644 --- a/seesaw_privacy.txt +++ b/seesaw_privacy.txt @@ -2,638 +2,3 @@ SITE: seesaw_privacy URL: https://web.seesaw.me/privacy-policy - 1. Introduction - Seesaw's mission is to create an environment where students can be - their best. Protecting your privacy is fundamental to our mission and - business. This Privacy Policy governs the use of Personal Information - collected by our websites at seesaw.me, the Seesaw Applications, and - any other online or offline offerings (collectively "the Seesaw - Service", "the Service", "Seesaw", "we", "us", or "our"). This - includes, for example, personally identifiable information that we - collect when you create an account ("Account Information"), content - added to class journals ("Journal Content"), activities teachers create - ("Activities"), and messages ("Messages") sent via Seesaw. - - In order to use Seesaw, you must create an account and agree to this - Privacy Policy. If you don't agree with this Privacy Policy, you cannot - use Seesaw. You can contact us anytime with questions about this policy - at privacy@seesaw.me. - - For purposes of this Privacy Policy, "Personal Information" means any - information about an identifiable individual or information that can be - used to identify an individual, and includes "Personal Data" as that - term is defined under the European Union General Data Protection - Regulation ("GDPR"). "Student Data" means any personal information, - metadata, or content directly attributable to a student user. - - 2. Changes to Our Privacy Policy - - Seesaw may from time to time make changes to this Privacy Policy to - account for changes to our practices or applicable law. If we make - changes to this Privacy Policy that materially affect your rights, we - will notify you by email about these changes, and post a notice to our - service, or otherwise contact you as required under applicable law. - Your continued use of the Services following notification by Seesaw - means you thereby agree to the new Privacy Policy. - - 3. Seesaw and FERPA - - Data collected by Seesaw includes Student Data from education records - that are subject to the Family Educational Rights and Privacy Act, - "FERPA", ("FERPA Records"), including student names, parent or guardian - (collectively, "Family Member") names, Messages, and Journal Content. - To the extent that Student Data includes FERPA Records, you designate - Seesaw as a "School Official" (as that term is used in FERPA and its - implementing regulations) under the direct control of the school with - regard to the use and maintenance of the FERPA Records and Seesaw - agrees to comply with FERPA. - - 4. Seesaw and COPPA - - The Children's Online Privacy Protection Act protects personal - information belonging to a child younger than 13. How we collect - information from users under 13, the types of information we collect, - and the reasons for collecting this information are described in - Sections 7, 8, and 9, respectively. We do not require users younger - than 13 to disclose more information than is reasonably necessary to - use the Services. - - We use a handful of analytics providers in relation to all users, - including users under 13, to help us improve the Services. These - third-party service providers do not use your data for any purpose - other than to provide the Services. You can view a list of Seesaw's - third-party service providers and review their privacy policies here: - https://seesaw.com/subprocessor. If you have questions about our - third-party service providers, you can contact us at privacy@seesaw.me. - - Information for parents or guardians on how to correct, edit, download, - update, or delete data about your student can be found in Sections 17 - and 18 below. - - 5. Who does Seesaw collect information from? - - We collect information from individuals who create accounts on Seesaw, - which includes teachers, students, and Family Members. We also collect - limited log data from all visitors to our marketing website. - - 6. How does Seesaw obtain my information? - - We receive information from the information that you and others - provide, from your device(s), and from third-party services. The - categories of sources from which we've collected or received - information include: - * You: We collect the content, communications, and other information - you provide when you use Seesaw. - * Other people: We collect information that other people provide when - they use Seesaw, such as when a teacher adds a parent's phone - number to send updates about a student's work. - * Your device(s): We collect information from and about the - computers, phones, and other web-connected devices you use with - Seesaw. - * Third-Parties: When you create a Seesaw account using a third-party - service (e.g. Google or Clever), we access the name, profile - picture, and email address (if available) provided by these - services. - - 7. What information does Seesaw collect? - - Account Information: When you create an account on Seesaw we collect - your name, email address, password, and optional profile picture. - Seesaw may also collect your phone number if you enter it in your - Account Settings. Teachers using Seesaw may add a Family Member's email - or phone number to Seesaw in order to send messages or updates about - school work. We do not collect student phone numbers. - Students are not permitted to create an account by themselves but must - be invited to a Seesaw class by a teacher or school administrator. - Where students have permission to use Seesaw, Seesaw collects - personally identifiable information that is necessary to provide the - Service, including a student's name, email address, and optional - profile picture. This information may be entered by a teacher or the - student or populated from the student's account with a third-party - sign-in service, such as their Google account. - - Users can make changes to their profile, messaging preferences, and - other account details in Account Settings. - - Journal Content: Seesaw collects content that is added to a class or - student journal. This content may include photos, audiovisual content - (including from your device's camera, microphone, or photo/video - library), drawings, files, notes, hyperlinks, and other ways of - documenting student learning. We regularly add types of information - that can be uploaded to a Journal, and these are all covered by this - Policy. We also collect comments on posts in the class and student - journals, including text and voice recordings. Journal Content that is - uploaded by a student or teacher may be considered a student education - record as defined by FERPA. - - Messages: Seesaw collects all messages that are sent and received in - Seesaw. Messages may include text, audio, video, photos, drawings, - files, notes, hyperlinks, or other information. - Activities: Teachers may use Seesaw to create activities to use with - their students. Activities may include text or voice instructions for - how to complete the activity, an example of a correct response, or a - template for students to edit. - - Activity Author Profiles: Teachers who choose to publish their - activities to the Community Activity Library or the Activity Library - managed by their school or district can also create an Activity Author - Profile. This includes the name and profile picture they choose to - publish on their Author Profile, as well as their school name and - location. - - Communications: Seesaw collects any information you send to us - directly, such as email, phone, or chat communications, or through your - responses to our optional surveys. - Information from your Google Account or other Third-Party Sign-in - Service: Seesaw allows school administrators, teachers, Family Members, - and students (after being invited by a teacher) to sign up for and log - into our service using a Google or Clever Account. Teachers can also - create student accounts on behalf of students in their class. When you - create a Seesaw account using one of these Third-Party Services, we use - the name, profile picture, and email address (if available) provided by - these services. Seesaw does not share your information with these - services. - - Log Data: When you use Seesaw or visit our website, we receive log data - such as your IP address, cookie identifiers, browser type, operating - system, device information and identifiers, and your mobile carrier. In - addition, we may receive or collect additional information such as the - referring web page, referring search terms, pages visited, and other - information about your interactions with Seesaw. - - 8. How does Seesaw use this information? - We use this information to: - * Allow you to access and use the Service by verifying your identity - and storing your Journal Content, Activities, and Messages. - * Provide support to teachers, school administrators, and Family - Members. - * Provide school administrators with information about how Seesaw is - performing in their school(s). - * If you've enabled notifications, notify you about activity on and - updates to your account or your student's account. - * Research, understand, and analyze user trends to improve and - develop new features for our products. - * Promote and advertise the Services and enhancements to Seesaw - relevant for teachers, schools, and families. - * Investigate, prevent, and detect activities on our service that we - believe may violate the law, applicable regulations, or Seesaw - policies. We may, at the request of a school, investigate accounts - to determine whether they comply with school policies. - - You can withdraw consent for the collection of your Personal - Information at any time, but you will no longer be able to use Seesaw. - - 9. Does seesaw allow third-party advertising or share data for - advertising third-party products? - - No. Our business model is straightforward: we charge for optional, - additional features on top of our free product and we have no interest - in advertising third-party products or services within Seesaw. We never - display third-party ads, share data for advertising or marketing - third-party products or services, or allow data collection by - third-party advertisers or data brokers to use for their own purposes. - - We also do not allow in-app purchases for student accounts. - - 10. In what limited circumstances may seesaw need to share my - information? - - * We share data with third parties in the limited circumstances - detailed below: - * We use a small number of third-party service providers in order to - operate and improve Seesaw - for example, a data center operator - that manages our servers or a notification service that helps us - send you messages about your account. These services need access to - your Personal Information in order to work (i.e. your email address - is required to send you an email), but are contractually obligated - to meet our strict security standards, maintain the accuracy of the - data they collect, and must only use Personal Information in - identifiable form for purposes of providing the Seesaw service. - When these third-party services transfer the Personal Information - (Personal Data, as that term is defined in the GDPR) of EU, UK, or - Swiss residents, we take steps to comply with the GDPR in order to - protect your data privacy and security. A list of our third-party - service providers can be found here. - * We may provide school administrators with information about how - Seesaw is performing in their school(s). - * Seesaw may disclose your information to a third party to comply - with applicable laws or regulations, or a valid legal request - - including to meet national security or law enforcement - requirements. If we are compelled to release your data, we will do - our best to provide you with advance notice by email, unless we are - prohibited from doing so by law. - * Seesaw may disclose student Account Information, Journal Content, - and Messages to the child's school or district upon request, - including as required by FERPA. - * By default, Activities teachers create are private to their - account. Optionally, teachers may choose to publish Activities they - create to the Community Activity Library or the Activity Library - managed by their school or district. In these cases, the activity - and the teacher's Activity Author Profile will be shared publicly - (in the case of the Community Library) or with other teachers at - their school or district. No student responses to Activities are - ever shared in the Community Activity Library or the school or - district Activity Library. - * We may share activities published to the public Community Activity - Library with teachers who we think may be interested in using them - with their class. - * We may disclose or transfer your Account Information and Journal - Content in connection with the sale, merger, bankruptcy, sale of - assets, or reorganization of our company. You will be notified via - email or some other means as required by law of any change in - ownership or uses of your Personal Information, as well as any - choices you may have regarding your information (including the - right to delete your information). The promises in this Privacy - Policy will apply to your data as transferred to the new entity. If - Seesaw goes out of business without a successor, Seesaw will delete - your information. - - - 11. Do you collect data about [blank]? - - We've listed all the data we collect in Section 8 above ("What - Information Does Seesaw Collect?"). We intentionally limit our data - collection to only what we need to provide the Seesaw service for you. - - 12. Who can view content posted in Seesaw? - - Student work is private to the classroom by default. Users cannot view - a student's Journal Content or Messages in Seesaw unless they are the - teacher or school administrator or invited to Seesaw by the teacher or - school administrator. Teachers control who can access a student's - account by authorizing specific people to connect to that student's - account. Teachers decide whether families can view, like, share, or - comment on their student's work and whether students can view, like, - and comment on classmates' work. Teachers can turn on settings that - require teacher approval of student work, allowing teachers to moderate - and, when necessary, remove content shared by students before it is - posted. Teachers may also choose to publish some class content to a - public class web page managed by Seesaw. In addition to controlling - what student work is published, teachers have the option to password - protect the public class web page. - - Teachers also control whether or not students or Family Members can - save Seesaw content to their device or get a link to specific Journal - Content. However, Seesaw cannot prevent all forms of sharing (e.g. by - taking a screenshot and posting to social media), so it is important - that teachers only grant access to authorized parties and discuss their - policies with families. - School administrators can access all Journal Content and Messages - shared in their Seesaw organization, including Messages that have been - edited or deleted. - - 13. Do you work with third-party analytics services? - - Seesaw is constantly improving, and we use aggregate data about how - Seesaw is used -- for example what buttons you click on or what pages - you visit -- to inform those decisions. - To help us analyze this data, we use a small number of third-party - services such as Google Analytics. For more information, please visit - Google's Privacy Policy. To learn more about how to opt out of Google - Analytics' use of your information, please click here. - - 14. How do you use cookies? - - Cookies are small text files that we transfer to your web browser that - allow us to identify your web browser and store information about your - account. We use these cookies to keep you logged into Seesaw, customize - your Seesaw experience, understand how you use Seesaw, and promote - Seesaw to relevant teachers and schools. You can choose to remove or - disable cookies via your browser settings. Please be aware that Seesaw - may not work properly if you disable or decline all cookies. - - 15. How does Seesaw handle abandoned accounts? - - Seesaw reserves the right to permanently delete accounts that have not - been accessed by the account holder for a period of more than one year. - Seesaw will permanently delete an account that has not been accessed by - the account holder for more than seven years, except where we are - required to keep the information for legal or compliance purposes. - Prior to permanently deleting an abandoned account, Seesaw will attempt - to notify the account holder by email. - - 16. How to View, Correct, Edit, Export, or Update Your Personal - Information - - You have the right to access, correct, or download for transport to a - similar service any of your Personal Information collected by Seesaw, - where permitted under applicable law. If you are an administrator, - teacher, or Family Member you can update the information associated - with your Seesaw account directly by logging into your Seesaw account - and viewing the Account Settings tab on your profile. If you are a - parent or guardian and want to correct, edit, download, or update - information about your child, please work directly with your teacher or - school, or you can contact us at privacy@seesaw.me. - - 17. Account Suspension And Termination - - If you would like to delete your Seesaw account or delete your child's - Seesaw account, follow these steps or contact privacy@seesaw.me. If you - request that your account or any content submitted to Seesaw be - deleted, Seesaw may still retain information as needed to provide - customer support and prevent accidental deletion, or as required or - permitted by law. If you terminate your account, all of your data will - be unavailable to you immediately, but be aware that Messages and - Journal Content with others in which you participated will remain - available to those other users. - - If your school or district has purchased Seesaw for Schools and the - school or district ends their contract with Seesaw and requests - deletion of accounts, we will attempt to notify impacted users by email - or another method and provide the option for users to establish or - maintain an account with Seesaw for the purpose of storing - student-generated content. - - If you are a teacher or school administrator within the US, please be - aware that FERPA requires Seesaw to retain student education records - once a valid request to inspect those records has been made. - - 18. How does seesaw keep your data safe? - - Seesaw takes protecting your security and privacy seriously and we've - put a number of measures in place to protect the integrity of your - information, including the use of access-controlled data centers, - routine 3rd party security audits, restricted employee access to user - information, and data encryption in transit. For more information, - please read this article. - - In the event of a security breach, Seesaw will notify affected account - holders within the amount of time required by law so that you can take - steps to keep your data safe. - - 19. How does seesaw handle data from international visitors? - - This section applies to schools and users in the EEA or UK. - - Seesaw has certified to the U.S. Department of Commerce that it adheres - to the EU-U.S. Data Privacy Framework Principles ("EU-U.S. DPF - Principles") with regard to the processing of Personal Information - received from the European Union or European Economic Area ("EU/EEA") - in reliance on - - the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance - on the UK Extension to the EU-U.S. DPF. Seesaw has certified to the - U.S. Department of Commerce that it adheres to the Swiss-U.S. Data - Privacy Framework Principles ("Swiss-U.S. DPF Principles") with regard - to the processing of Personal Information received from Switzerland in - reliance on the Swiss-U.S. DPF. If there is any conflict between the - terms in this Privacy Policy and the EU-U.S. DPF Principles and/or the - Swiss-U.S. DPF Principles, the Principles shall govern. To learn more - about the Data Privacy Framework program, and to view our - certification, please visit www.dataprivacyframework.gov. - - Seesaw is responsible for the processing of Personal Information it - receives, under each Data Privacy Framework and subsequently onward - transfers to third parties to perform processing functions or to - provide services on our behalf. Seesaw remains responsible and liable - under the Principles if third-party agents that it engages to process - the personal data on its behalf do so in a manner inconsistent with the - Principles, unless Seesaw proves that it is not responsible for the - event giving rise to the damage. - - Seesaw has further committed to cooperate and comply respectively with - the advice of the EU/EEA data protection authorities (collectively "EU - DPAs"); the UK Information Commissioner's Office (ICO) and the - Gibraltar Regulatory Authority (GRA); and the Swiss Federal Data - Protection and Information Commissioner (FDPIC) with regard to - unresolved privacy or Personal Information use concerns. - - Additionally, Seesaw is subject to the investigatory and enforcement - powers of the U.S. Federal Trade Commission for compliance with the - EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. - DPF. As further explained on the Data Privacy Framework program website - at - www.dataprivacyframework.gov, you may also invoke binding arbitration - when other dispute resolution procedures have been exhausted. - - Finally, in compliance with the EU-U.S. DPF and the UK Extension to the - EU-U.S. DPF and the Swiss-U.S. DPF, Seesaw Learning, Inc. commits to - refer unresolved complaints concerning our handling of personal data - received in reliance on the EU-U.S. DPF and the UK Extension to the - EU-U.S. DPF and the Swiss-U.S. DPF to BBB National Programs DPF - Services, an alternative dispute resolution provider based in the - United States. If you do not receive timely acknowledgment of your DPF - Principles-related complaint from us, or if we have not addressed your - DPF Principles-related complaint to your satisfaction, please contact - https://bbbprograms.org/programs/all-programs/dpf-consumers for more - information or to file a complaint. The services of BBB National - Programs DPF Services are provided at no cost to you. - 20. Does seesaw comply with your state's laws? - - In accordance with applicable privacy law, you have some or all of the - following rights in respect of your Personal Information that we hold. - - If you are in the EEA or UK: - - Right of access. You have the right to obtain. - * confirmation of whether, and where, we are processing your Personal - Information; - * information about the categories of Personal Information we are - processing, the purposes for which we process your Personal - Information and information as to how we determine applicable - retention periods; - * information about the categories of recipients with whom we may - share your Personal Information; and - * a copy of the Personal Information we hold about you. - - Right of portability. You have the right, in certain circumstances, to - receive a copy of the Personal Information you have provided to us in a - structured, commonly used, machine-readable format that supports - re-use, or to request the transfer of your Personal Information to - another person. - - Right to rectification. You have the right to obtain rectification of - any inaccurate or incomplete Personal Information we hold about you - without undue delay. - - Right to erasure. You have the right, in some circumstances, to require - us to erase your Personal Information without undue delay if the - continued processing of that Personal Information is not justified. - - Right to restriction. You have the right, in some circumstances, to - require us to limit the purposes for which we process your Personal - Information if the continued processing of the Personal Information in - this way is not justified, such as where the accuracy of the Personal - Information is contested by you. - - Right to withdraw consent. If you have provided consent for the - processing of your Personal Information, you have the right to withdraw - your consent. If you withdraw your consent, this will not affect the - lawfulness of our use of your Personal Information before your - withdrawal. - - You also have the right to object to any processing based on our - legitimate interests where there are grounds relating to your - particular situation. There may be compelling reasons for continuing to - process your Personal Information, and we will assess and inform you if - that is the case. You can object to marketing activities for any - reason. - - You can also opt out of sharing your personal data with third parties - (other than parties that provide services to us as our agents or - processors) or before we use it for a purpose other than that for which - it was originally collected or subsequently authorised. - - If you are in Australia: - - Right of access. You have the right to request access to Personal - Information we hold about you. - - If you wish to access any of your personal information that you have - provided to us, please contact us using the details set out in Section - 22 `How to contact us'. - - Right to rectification or correction and notification to third parties. - You have the right to request the correction of personal information we - hold about you. You also have the right to have any correction notified - to third parties to whom we have provided your personal information. - - Right to opt out: You have the right to opt out of receiving marketing - and to the disclosure or use of your personal information for - marketing. - - Seesaw will take reasonable steps to ensure that your personal - information is accurate, up to date, complete and not misleading. - However, to assist us to do this, we request that you keep your - personal information up to date on the Seesaw Service or inform us of - any changes to your Personal Information to ensure our records remain - accurate and current. - - If you believe that any of your Personal Information held by us is - incorrect and you cannot amend such in the Seesaw Service then please - request us to amend that Personal Information via the details in the - section headed "How to Contact us" above. - - If you are in New Zealand: - - Right of access. You have the right to request access to Personal - Information we hold about you. - - If you wish to access any of your personal information that you have - provided to us, please contact us using the details set out in Section - 22 `Contact Information'. - - Right to rectification or correction. You have the right to request the - correction of personal information we hold about you. - - Right to opt-out. You have the right to opt-out of marketing. You can - contact us to do so or use the unsubscribe mechanism included in each - electronic direct marketing message we send to you. - - Seesaw will take reasonable steps to ensure that your personal - information is accurate, up to date, complete and not misleading. - However, to assist us to do this, we request that you keep your - personal information up to date on the Seesaw Service or inform us of - any changes to your Personal Information to ensure our records remain - accurate and current. - - If you believe that any of your Personal Information held by us is - incorrect and you cannot amend such in the Seesaw Service then please - request us to amend that Personal Information via the details in the - section headed "How to Contact us" above. - - How to exercise any of the above rights - - If you wish to exercise one of the rights, please contact us using the - contact details set out in the "How to contact us" section above. Due - to the confidential nature of data processing, we may ask you to - - confirm your identity when exercising the above rights. - - If you contact us to exercise rights on behalf of your child, we will - assess whether your child is competent to exercise those rights - themselves based on their age. In accordance with guidance from the - Information Commissioner's Office, we will normally assume that - children aged 12 or over are able - - to exercise the rights mentioned above. Where that is the case, we may - ask you to provide authorisation from your child to exercise their - rights on their behalf. - - Complaints - - Information for schools and users in the EEA or UK - - If you are in the UK or EEA, you also have the right to lodge a - complaint to your local data protection authority. If you are in the - UK, information about how to contact your local data protection - authority is available here. If you are in the European Economic Area, - information about how to contact your local - - data protection authority is available here and here (if you are in - Switzerland). - - Information for schools and users in Australia - - If you are in Australia, if you have any concerns about how we handle - your personal information, believe we have breached the Privacy Act - 1988 or any Australian Privacy Principles, if you wish to make a - complaint or need further information, please contact us via the - details noted in Section 22 `Contact Information'. You will need to - provide us with sufficient detail regarding your complaint and any - supporting evidence. - - We will investigate the issue and determine the steps to be taken to - resolve the complaint and will notify you in writing if we require any - additional information and also of the outcome of our investigation. - - If you are not happy with the outcome of our investigation, you may - complain to the Office of the Australian Information Commissioner by - way of their website www.oaic.gov.au or by phone to their hotline 1300 - 363 992. - - If you are using the Seesaw Service through a school, for complaints - about how your Personal Information is being handled by your school we - recommend that you first refer your complaint to the relevant school - and note their contact details should be included in that school's - privacy policy. - - Information for schools and users in New Zealand - - If you have any concerns about how we handle your personal information, - believe we have breached the Privacy Act 2020 or any of the New Zealand - Information Privacy Principles, if you wish to make a complaint or if - you need further information, please contact us via the details noted - in Section 22 `Contact Information'. You will need to provide us with - sufficient detail regarding your complaint and any supporting evidence. - - We will investigate the issue and determine the steps to be taken to - resolve the complaint. We will notify you in writing if we require any - additional information and also of the outcome of our investigation. - - If you are not happy with the outcome of our investigation, you may - complain to the Office of the Privacy Commissioner by way of their - website - www.privacy.org.nz/your-rights/making-a-complaint-to-the-privacy-commis - sioner/. - - If you are using the Seesaw Service through a school, for complaints - about how your Personal Information is being handled by your school, we - recommend you first refer to the relevant school's privacy policy. - 21. Rights Of California And Nevada Residents - - If you are a California resident, please see here for more information - about our practices and your rights with respect to your information. - - If you are a resident of Nevada, you have the right to opt-out of the - sale of certain Personal Information to third parties who intend to - license or sell that Personal Information. You can exercise this right - by contacting us at privacy@seesaw.me with the subject line "Nevada Do - Not Sell Request" and providing us with your name and the email address - associated with your account. Please note that we do not currently sell - your Personal Information as sales are defined in Nevada Revised - Statutes Chapter 603A. If you have any questions, please contact us as - set forth below. - - 22. Contact Information - - If you have any questions or feedback about this Privacy Policy, please - contact privacy@seesaw.me. - - You can reach Seesaw by mail at: - Seesaw Learning, Inc. - 548 Market St - PMB 98963 - San Francisco, CA 94104-5401 - - Last Updated Oct 1, 2023