Sprig Learning – Privacy Policy

Sprig Learning (“us”, “we”, or “our”) operates the spriglearning.com website and the various Sprig Learning web and mobile applications (hereinafter referred to as the “Service”). This Privacy Policy 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. 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.

 

Information Collection And Use

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

 

Types of Data Collected

Personal Data

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 (when required)
• Data of Birth for students (when required)
• Cookies and Usage Data

 

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.

 

Tracking and Cookies Data

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

Cookies are files holding a  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.

 

Examples of Cookies we use:

• 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.

 

Use of Data

Sprig Learning uses the collected data only for the following 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
• To ethically train our Artificial Intelligence, Machine Learning systems to create personalized learning trajectories and recommended instructional activities and practice, to help each student reach their full learning potential. This data is not sold, traded, or provided to any third party. Nor are any third party data sets used to manipulate, compare, or process our current algorithms.

 

Transfer Of Data

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 from those from your jurisdiction.

This will only occur in situations where our Canadian or United States data centres experience a catastrophic outage and data might be transferred to another in-country data center. Data will always be resident to the user’s country location. At no time will your data be sold, traded, or transferred to an external third party without your explicit knowledge and approval.

Sprig Learning will take all commercially reasonable  steps necessary to ensure that your data is treated securely and in accordance with both this Privacy Policy and the rules of the Personal Information Protection and Electronic Documents Act  (PIPEDA) in Canada and the Family Educational Rights and Privacy Act (FERPA) and the Children’s Online Privacy Protection Act (COPPA) in the United States.

 

Disclosure Of Data

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 with details of this data disclosure where legally permissible.

 

Security Of Data

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  implement these measures, there is still the possibility that methods of transmission over the Internet, or methods of electronic storage are still open to compromise.

All critical system data including user 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 using a Secure Development Lifecycle (SDLC).

 

Service Providers

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 service providers focus on our corporate aspect of our business and not the platform or services portion of our business operations.

Only registered and authorized Sprig Learning staff have access to perform these corporate tasks such as accounting, marketing, web design, UI/UX design on our behalf and are obligated to disclose any potential compromise.

 

Analytics

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 on its own advertising network.
• For more information on the privacy practices of Google, please visit the Google Privacy and Terms web page: https://policies.google.com/privacy?hl=en

 

Links To Other Sites

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.

 

Children’s Privacy

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. This is an ongoing process and will ensure that any new services, solutions, and updates to current offerings will consider both security and privacy for operations and development.

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. Any confidential data collected is only collected to provide services related to our platform and service offerings. This includes the usage of targeted advertising in any form that might result in the usage of our platform.

For any child under the age of 13 in the United States, parents are required to accept their locally implemented Terms of Usage agreement prior to any child using our assessment applications or platform. These approvals can be gained by their local school administrator(s), schools and/or teachers.. There are no exceptions to this requirement under any circumstances.

Parents can make a request to see their child’s collected data, however a user account will be required. This access will ensure that a parent, legal guardian, or caregiver is provided the precise view of the data elements that are collected, processed, and stored on our platform. These accounts are provided automatically when a school board or class has signed up for one or more of our service offerings.  No additional approval or costs will be incurred.

At no time is any child’s or user’s data sold or provided to external third parties.

The data collected via assessments performed by authorized teachers, parents, legal guardians, or caregivers is considered confidential to those users and is not sold, traded, or accessed by any third party.

In the event of a Sprig Learning merger or acquisition by another entity, we are committed to ensure that all data protections and limitations of data sharing will be upheld and protected.

 

Changes To This Privacy Policy

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.

 

Contact Us

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

• By email: letstalk@spriglearning.com