Sprig Learning – Privacy Policy

Sprig Learning (“us”, “we”, or “our”) operates the spriglearning.com website and the Sprig Learning Applications mobile application (hereinafter referred to as the “Service”). This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. Our Privacy Policy for Sprig Learning is managed with the help of Privacy Policies. We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

We collect several different types of information for various purposes to provide and improve our Service to you.

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information includes, but is not limited to:

● Email address

● First name and last name

● Phone number

● Data of Birth for students (when required)

● Cookies and Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

● Session Cookies. We use Session Cookies to operate our Service.

● Preference Cookies. We use Preference Cookies to remember your preferences and various settings.

● Security Cookies. We use Security Cookies for security purposes.

Sprig Learning uses the collected data for various purposes:

● To provide and maintain the Service

● To notify you about changes to our Service

● To allow you to participate in interactive features of our Service when you choose to do so

● To provide customer care and support

● To provide analysis or valuable information so that we can improve the Service

● To monitor the usage of the Service

● To detect, prevent and address technical and security issues

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. This will only occur in situations where our Canadian data center experiences a catastrophic outage. At no time will your data be sold or transferred to an external 3rd party without your explicit knowledge and approval to this transfer.

Sprig Learning will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with both this Privacy Policy and the rules of PIPEDA.

Legal Requirements

Sprig Learning may disclose your Personal Data in the good faith belief that such action is necessary to:

● To comply with a legal obligation

● To prevent or investigate possible wrongdoing in connection with the Service

● To protect the personal safety of users of the Service or the public

● To protect against legal liability

Where possible, we will ensure data owners are notified to details of this data disclosure where legally permissible.

Sprig uses both a Secure-By-Design and Privacy-By-Design approach to system and application development. This includes multiple layers of controls to prevent and identify intrusions. While we do all of this there is still the possibility that methods of transmission over the Internet, or method of electronic storage are still open to compromise.

All critical system data is encrypted and all session data is actively monitored and recorded to track signs of compromise. We meet or exceed all current ISO/IEC standards for cyber security controls for system and application design and implementation. This includes regular penetration testing of our sites and evaluation of our source code.

We employ third party companies to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties do have access to your Personal Data but the systems that are under their management and administration. Only registered and authorized Sprig Learning staff have access to perform these tasks on our behalf and are obligated to disclose any potential compromise.

We use third-party Service Providers to monitor and analyze the use of our Service.

● Google Analytics

● Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

● For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Our Service contains links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

As a provider of education technology for school age children we take this responsibility very seriously. As such, we have performed Threat and Risk Assessments, Privacy Impact Assessment and other formal techniques to identify the potential risks of data exposure to our application and server hosting systems.

At this time, we only collect two data points to track each student. We only use these aspects to ensure that we can track student activities and assessments. This data will never be sold, traded or provided to any 3rd party for the purpose of generating revenue for our organization.

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

If you have any questions about this Privacy Policy, please contact us:

● By email: letstalk@spriglearning.com