Modified: April 22^nd 2023

1. Overview

Study Smart is dedicated to making learning enjoyable and keeping students’ personal information safe is a priority. This Student Privacy Policy explains how we use the personal information we collect from and about students when they engage with Study Smart through the products that are offered to schools and individual plans for teachers (the “assessment”). As set forth below, we use such personal information solely as a service provider or “data processor” to our school and school district customers.

To learn about our practices with respect to other users, including teachers who sign up for Study Smart and student accountholders who use Study Smart outside of the school environment, please read our Privacy Policy.

2. Our handling of student information

As a trusted provider of tools that help teachers and schools make learning awesome for students, Study Smart is particularly concerned about the use of students’ personal information. We only request the personal information of students that we need to provide the assessment, and we comply with the following privacy laws:

• The Personal Information Protection and Electronic Documents Act (“PIPEDA”)
• Family Educational Rights and Privacy Act (“FERPA”)
• Children’s Online Privacy Protection Act (“COPPA”)

Study Smart does not collect, retain, use or share students’ personal information, except as necessary for authorized school purposes, at the direction of our school and school district customers. Without limitation, this means that:

• We do not sell students’ personal information.
• We do not serve targeted ads on our platforms and do not use information we collect to serve targeted ads on other services. Study Smart does not use or disclose information collected through our services for any targeted advertising purposes.
• We do not build a profile of a student other than in support of authorized school purposes.
• We do not retain students’ personal information beyond the time period required to support the authorized school purposes.

We support our school customers in providing parents and eligible students with access to their personal information and in fulfilling other requests that parents and eligible students may make, such as to request deletion of students’ personal information or to refuse its further collection or use. Study Smart maintains a comprehensive program designed to protect the security, privacy, confidentiality and integrity of students’ personal information.

3. Students’ Personal information

3.1 Personal information we collect from students

Student players: Study Smart collects a nickname and email address, the former can be anonymous but is linked to a persistent identifier (email address) in order to make appropriate recommendations.

Personal information collected at a teacher’s direction: Certain features of the assessment permit a teacher to collect information about the class, as well as about individual students, such as usage, results, answers submitted when completing a Study Smart assessment (including in response to open-ended questions) and performance on Study Smart challenges. We use such information only to provide the services to the teacher, such as to permit the teacher to interact with students and track their progress over time. A school or teacher may permit students to share information with others, such as with other teachers, parents and students in the same class, school, or school district.

3.2 Information collected automatically

No personal information is collected automatically from students who engage with Study Smart through the assessment. Product usage data that is collected by Study Smart from the assessment is always anonymized or aggregated and cannot be linked to individual students.

3.3 Anonymized information

We may anonymize and/or aggregate personal information so that it no longer identifies any student. We may use and disclose such anonymized and/or aggregated information for any purpose, including for analytics purposes, to help us understand how our products are used and improve upon them.

4. Security

Study Smart maintains a comprehensive security program designed to protect the security, privacy, confidentiality and integrity of Personal Information within our organization. We have in place appropriate and reasonable technical and organizational measures designed to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. Our security measures include data encryption, firewalls, data use, and access limitations for our personnel and service providers, and physical access controls to our facilities. Our service providers that process payment data, maintain the applicable Payment Card Industry (PCI) compliance levels.

If you have any questions about the security of your Personal Information, you may contact us at privacy@studysmart.ca.

5. Compliance with PIPEDA, FERPA and COPPA

We comply with PIPEDA, FERPA and COPPA when applicable to us. When FERPA applies, we act as a ”school official” to our school or school district customer, which means that we are under the direct control of the school or district and use students’ personal information only to provide our services to the school or district and not for our own purposes. To the extent COPPA applies, the school or district provides us with any necessary consent on behalf of students’ parents or guardians to permit use of Study Smart in the classroom.

6. Changes to this Policy

We may change this Student Privacy Policy at any time and from time to time. The most recent version of the Privacy Policy is reflected by the version date located at the top of this Student Privacy Policy. We encourage you to review this Student Privacy Policy often to stay informed of changes that may affect you.

If we make material changes in the Privacy Policy, for example if we seek to use personal information in a materially different way than we had previously, we will provide prior notice by, for example, email or a pop-up so that you have sufficient time to evaluate the change in practice. Of course, you can always opt-out by deleting your account if you do not accept the change.