Student Data Policy

Effective as of March 2021

The Plickers Student Data Policy outlines our commitment to student privacy. It limits how we may collect, store, use, and disclose information about students and places requirements on how we protect information about students from unauthorized disclosure.

1. Collection, Storage, Use, and Disclosure of Student Data
2. Targeted Advertising and Selling of Student Data
3. Security of Student Data
4. Retention of Student Data
5. De-Identified Data
6. Information collected from Children Under 13 years old (COPPA Compliance)
7. Other Disclosures

Definitions:

Disclose/Disclosure: Any act that makes Personal Information available or accessible to a third party, either by transferring the Personal Information to the recipient or by allowing the recipient to view or access the Personal Information remotely.

Identifying Information: Any information that can be used to identify, locate, or contact an individual, such as a person's name, photo, email address, or IP address.

Student: An individual interacting with Plickers in a student capacity.

Student Data: Any Personal Information pertaining to Students.

Personal Information: Any information tied to an individual. This includes both Identifying Information and any other information related to an individual, such as a person's sign-up date or responses to questions. Information that has been de-identified is not Personal Information.

Targeted Advertising: Selecting and sending advertisements to a person using the person's Identifying Information or any information about the person obtained or inferred over time. Targeted Advertising does not include adaptive learning, personalized learning, or customized education.

User: A district, school, teacher, parent, or student using the Plickers website, app, or cards.

Policy Statements:

1. Collection, Storage, Use, and Disclosure of Student Data

Plickers shall not collect, store, or use Student Data except as needed for authorized educational purposes.

Plickers shall not disclose Student Data to any third party unless:

• Such third parties are data processors acting on our behalf,
• The disclosure is required by law, or
• The disclosure is made at the request of the User for educational purposes.

2. Targeted Advertising and Selling of Student Data

Plickers shall not:

• Use any Student Data for Targeted Advertising.
• Create Student profiles for advertising or for any other non-educational purpose.
• Sell Student Data for any purpose.

3. Security of Student Data

Plickers shall protect Student Data using appropriate security measures, including encryption, and disclose the information only to third parties that are contractually obligated and able to maintain its confidentiality and security.

4. Retention of Student Data

Plickers shall not retain Student Data longer than needed to fulfill the educational purposes for which it was collected. Plickers shall also delete Student Data upon valid request of the applicable User.

5. De-Identified Data

Plickers may use de-identified data for product development, research, and other purposes. This data shall not include any Identifying Information, nor any links to such information. Plickers shall not attempt to re-identify any de-identified data and shall prohibit any recipients of the de-identified data from attempting to re-identify individuals.

6. Information collected from Children Under 13 years old (COPPA Compliance)

Plickers may rely on the district, school, or teacher to authorize the collection of Personal Information from children under 13. In compliance with COPPA:

• Plickers shall obtain consent from the district, school, or teacher prior to collecting Personal Information from children under 13;
• Personal Information collected from children under 13 may only be used for educational purposes and not for any commercial purposes;
• To the extent feasible and upon request, Plickers shall provide parents access to their child's Personal Information to review and/or have deleted;
• To the extent feasible, Plickers shall give parents the opportunity to prevent further use or collection of their child's Personal Information; and
• Personal Information collected from children under 13 shall only be retained for as long as is necessary to fulfill the educational purpose for which it was collected.

If you are a parent or guardian of a child under 13 and would like to exercise your rights under COPPA, please email us at help@plickers.com.

7. Other Disclosures

In the event of any merger, acquisition, or similar transaction involving the Plickers business or assets, Plickers may transfer Student Data to another entity, provided the successor is subject to these same commitments for the previously collected Student Data.