site_policies/seesaw_privacy.txt

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 
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-commissioner/.
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