Privacy Policy

Updated: March 25, 2024

At Plickers Inc (“Plickers,” “we,” “us,”), we take seriously our responsibility to protect your privacy, and we have created this Privacy Policy to help you understand how we collect, use, disclose, and protect information collected through our website and our mobile application (collectively, the “Services”). Plickers may enter into an agreement with a school, school district, or state or local board of education (“School Agreement”) to provide the Services for use in schools. The Services are made available to teachers (also referred to as “user” or “you”) who may use them as an aid to classroom instruction. When using the Services in the classroom, teachers or the schools may provide certain information to us about their students. Where we have a School Agreement, we collect and use information about teachers and students only in the ways permitted by the applicable School Agreement. For more information about the information we collect from students, please see the Information Collected From Students section below.

By visiting or using the Services, you acknowledge that you accept this Privacy Policy. Remember that your use of Plickers’ Service is also subject to the Terms of Service.

1. Information We Collect

• Information you provide to us directly: We may collect “Personal Information” that you provide when using the Services (which is information that identifies you as a specific individual, such as, for example, your name, email address, profile picture, and phone number), including when you register with the Services. We may ask for other information about individuals, such as demographic information (such as ZIP, gender, and age). When we combine this type of information with Personal Information, we will treat the combined information as Personal Information under this Privacy Policy. You may also register using your credentials with certain third-party platforms, such as your Google name and password. Unless provided by the school pursuant to a School Agreement, we also ask teachers who use the Services to provide the first and last names of the students and the class names in order to create a classroom. In addition, you may use the Services to: (1) post curriculum-related questions and content; (2) view and respond to questions and content posted by other educators; and (3) monitor how your students respond to your questions. The Services may include the use of video features on your device to scan the Plickers cards used in your classroom. These videos may contain images of your students, but Plickers does not transmit, collect, or store these videos or images. The video data is processed on your mobile device so that the only data transmitted are the responses decoded from scanned Plickers cards.
• Analytics information: We automatically collect the Internet Protocol (“IP”) address and Device Identifier associated with a user’s device. A Device Identifier is a unique string of letters, numbers and/or other characters that is automatically assigned to your device by the device manufacturer. We may also collect additional information such as the time and date when you logged in, the browser type and version, the operating system of the device, the make and model of your device, installed plug-ins, the number of clicks you make and the actions you take within the Services, the pages you visit and the referring/exit pages and URLs (“Analytics Information”). We use third-party service providers to assist us in collecting and understanding Analytics information.
• Location information: When you access the Services, we also may access, collect, monitor, and/or remotely store location data regarding the location of your device. This location data may be derived from your IP address or collected from the GPS features of your mobile device. Location data allows us to understand the geographic distribution of individuals who use our Services, and we may pair that with your personal information in order to understand how our Services are used. When we do so, the combined information will be treated as Personal Information. Some features of the Services, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled. To manage location services, check the settings on your mobile device or contact your mobile service provider or device manufacturer. Specific mobile applications may include additional terms that relate only to those apps.
• Aggregated de-identified Information: We may aggregate and de-identify information (by removing all Personal Information) collected from users and students. We store and use aggregated, de-identified information and Analytics information to demonstrate the effectiveness of our Services, including in the marketing of those Services, to develop and improve our educational products and Services, and for customized, adaptive learning purposes.

2. How We Use Information

We use the information we collect through the Services to: (a) create your account; (b) provide and communicate with you about the Services; (c) operate, maintain, enhance, and provide to you the features and functionality of the Services; (d) personalize content and remember your preferences; (e) monitor the effectiveness of our Services; (f) monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; (g) diagnose or fix issues with the Services; (h) update or improve the Services; (i) and for other legitimate interests disclosed at the time we collect the information or with your consent.

Users can create shared spaces for content and invite others, publish the space, or otherwise make the space visible to other users. When you’re a member of a shared space, we identify you to other members using your email address and your basic profile information (name, username, and profile picture). When you invite another user to a shared space, we send them a notification by email that includes your basic profile information. Content in a shared space is available to all members of that space; if the space is published, content in it is available to all users. Users with access to content may share it with others or otherwise make copies of it. In certain cases, we display your basic profile information alongside content you’ve contributed or edited.

Users may choose to make their profile public by selecting a username. When your profile is public, we display your basic profile information (name, username, and profile picture) to users who view your profile, and may use your profile and published content in promotional materials. To protect your privacy, we do not display your email address in your public profile. When you publish a shared space, we make that space visible to other users, and associate it with your profile. On your profile, we may list shared spaces you've published, as well as other public actions you’ve taken, such as reviewing, commenting on, or following other users or shared spaces.

We also may use your email address to send you newsletters, promotions and special offers. We do not send any such messages to students. If you do not want to receive such email messages, you will be given the option to opt-out or change your preferences. However, regardless of your email preferences, you may not opt-out of system-related messages or messages pertaining to your account. For more information about opting out of communications, please refer to the “Your Choices about Your Information” section of this Privacy Policy.

If you ask us to invite a friend to join the Services, we may send an invitation to them by email. The invitation may include your basic profile information for the purpose of identifying you as the sender. We’ll store the email address you provide for this invitation for the sole purpose of sending the invitation. If you’ve been invited in this way and would like us to delete your information, contact us at help@plickers.com.

3. Technologies Used

To collect Analytics information, we use a variety of technologies:

• Cookies: Cookies are small data files containing a string of alphanumeric characters sent by a website and stored on the computer or device at the request of that site. Cookies store information related to the browser to enable us to recognize the browser on return visits to the Services and to remember your preferences. Most browsers can be set to detect browser cookies and to let you reject them, but refusing cookies may make it difficult to use the Services, as some areas of our website may not work properly when cookies are disabled. To learn more about browser cookies, including how to manage or delete them, refer to the Tools, Help or similar section of your Web browser.
• Pixel tags: A pixel tag (also referred to as a “clear gif” or “web beacon”) allows us to anonymously track the online usage patterns of the Services and to understand which emails are opened and which links are clicked. This information allows for more accurate analysis and improvement of the Services.
• HTML5 local storage: HTML5 local storage is another way that browsers can distinguish your device from others as well as remember data that may be important for the functioning of the website. Typically HTML5 local storage is only deleted if all Internet history, cache, and cookies are deleted. You should check your browser software for how to delete HTML5 local storage in your particular case.
• E-tags: E-tags are used to prevent duplicative downloading of content to your browser, which can enhance browser performance. E-tags use unique identifiers for content that can also be used to distinguish your browser in certain instances from others. Typically e-tags are only deleted if all Internet history, cache, and cookies are deleted. You should check your browser software for how to delete e-tags in your particular case.

4. How We Disclose Your Information

We may share non-Personal Information, including, without limitation, aggregated information, de-identified information, and Analytics Information, with third parties in our discretion, unless prohibited by applicable law or School Agreement. We do not share Personal Information with third parties except as stated in this Privacy Policy or as described to you at the time that the information is collected or otherwise with your consent. We may disclose Personal Information for the following purposes:

• Third-Party Service Providers: We may share personal information with third-party service providers for the purpose of providing the Services. For example, we may disclose information to third parties that provide data storage and support features, customer communication and support, online hosting, data analytics, and other services. Those service providers are given access to information only as is reasonably necessary to deliver, maintain, and improve the Services. We require these contractors to maintain the privacy and security of the information, and they are subject to applicable laws.
• In the event of a change of control or reorganization: In the event of a sale, merger, divestiture, reorganization, assignment, bankruptcy, financing, dissolution or other business change or transaction, information may be transferred as part of such business change or transaction, including during the course of any due diligence process, but will remain subject to the terms of this Privacy Policy.
• Compliance with law and protection of rights: Regardless of any choices you make regarding your information, we may share your information (this may include information about students only if permitted by applicable law and any applicable School Agreement):
• (a) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; and/or
• (b) where we believe in good faith that disclosure is necessary to
• (i) enforce our Terms of Service or to protect the security or integrity of our Services; and/or
• (ii) exercise or protect the rights, property, or safety of Plickers, you, or other third parties.
• Interaction with other users: When you interact with other users on the Services, we may identify you to them using limited personal information. Please see the How We Use Information section for more details on how we disclose your information when you interact with other users.

5. How We Store and Protect Your Information

• Storage and Processing: Your information (or information about students) collected through the Services may be stored and processed in the United States or any other country in which Plickers or its third-party service providers maintain facilities, to the extent permitted by any applicable School Agreement.
• If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. laws, please note by using the Services, you expressly consent to the transfer, processing, and storage of information to the U.S. or any other country in which Plickers or its third parties maintain facilities and to the use and disclosure of information as described in this Privacy Policy.
• Keeping your information safe: Plickers cares about the security of Personal Information and uses commercially reasonable safeguards to preserve the integrity and security of all information collected through the Services. The Internet, however, is not perfectly secure, and we cannot fully eliminate security risks associated with the storage and transmission of your information.
• Plickers has a plan in place to contain and remedy a data breach if one occurs, as well as to notify relevant parties no later than 72 hours after becoming aware of the breach.
• Data Retention: Following termination or deactivation of your account, Plickers will retain Personal Information about teachers and students for a limited time period, but no longer than 120 days or as permitted by an applicable School Agreement and in accordance with applicable law, after which time we delete and destroy your Personal Information, as well as any Personal Information about students. We also delete Personal Information and other data when required by a School Agreement.
• However, Plickers may maintain aggregated, de-identified, or other non-personal data, including curriculum or other content you may have provided when using the Services as long as needed for our business purposes.
• If you would like to download a copy of your information prior to deletion, please email us at help@plickers.com.

6. Your Choices About Your Information

• Access to or removal of your information: You may access and amend your account information, as well as information about your students, at any time by accessing your account page within the Services. If you would like to access and amend or correct Personal Information about students, please email us at help@plickers.com. In addition, at any time, you may send a written request to have the information you provided to Plickers deleted, and we will comply with the request within a reasonable time frame unless prohibited by law or our contract with an applicable School Agreement through which you have set up your account. Note we cannot guarantee removal of the content you’ve shared, as that content may have been re-shared or otherwise copied by another user. However, if you’d like to prevent your Personal Information from being displayed alongside that content, you can delete your Plickers account. If you have any questions about reviewing or modifying your account information, you can contact us directly at help@plickers.com.
• Communication Settings: You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in all such communications. We make every effort to promptly process all unsubscribe requests, but please note that you may continue to receive emails for a time while our system updates your request. You may not opt-out of Service-related communications (e.g., account verification, changes/updates to features of the Services, technical and security notices, communications regarding your account). If you have any questions about promotional email communications, you can contact us directly at help@plickers.com.
• How We Respond to "Do Not Track" Signals: Some Internet browsers may be configured to send "Do Not Track" to the online services that you visit. There is no consensus among industry participants as to what "Do Not Track" means in this context. Like many websites and online services, the Services does not alter their practices when they receive a "Do Not Track" signal from a visitor’s browser. To find out more about "Do Not Track", please visit https://www.allaboutdnt.com.

7. Data Privacy Framework (DPF)

7.1. Data Privacy Framework for transfers between EU-US, Switzerland-US, and UK-US

Plickers complies with the EU-US Data Privacy Framework (EU-US DPF), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US DPF) as set forth by the US Department of Commerce. Plickers has certified to the US Department of Commerce that it adheres to the EU-US Data Privacy Framework Principles (EU-US DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-US DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-US DPF. Plickers has certified to the US Department of Commerce that it adheres to the Swiss-US Data Privacy Framework Principles (Swiss-US DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-US DPF. If there is any conflict between the terms in this privacy policy and the EU-US DPF Principles and/or the Swiss-US DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Plickers operates under the jurisdiction of the US Federal Trade Commission (FTC) and is subject to the regulatory enforcement powers of the latter. In certain situations, Plickers may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Plickers is accountable for personal data that it receives under the DPF and subsequently transfers to a third party as described in the DPF Principles. In particular, Plickers remains responsible and liable under the Data Privacy Framework if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the DPF Principles, unless Plickers proves that it is not responsible for the event giving rise to the damage.

Plickers evaluates its policies and data processing activities in order to comply with the choice principle of the DPF and the purpose limitation principle of the DPF and only processes personal data that is relevant to the purposes of processing as listed above in this privacy policy. Similarly, Plickers continuously evaluates its processing activities to process personal data only as long as necessary to achieve the purposes outlined in Section 2.

Plickers commits to respond promptly to inquiries and requests by the International Trade Administration for information relating to the DPF.

Please be informed that the FTC has jurisdiction to investigate any possible unfair or deceptive practices and violations of laws or regulations covering the privacy compliance of Plickers with the DPF.

7.2. Complaints mechanism

7.2.1. Internal complaints mechanism

In compliance with the DPF, Plickers commits to resolve DPF Principles-related complaints regarding our collection and use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the DPF should contact our Data Protection Officer (DPO) at dpo@plickers.com.

7.2.2. Alternative Dispute Resolution (ADR) mechanism

If you have contacted Plickers for support and your data privacy concern has not been satisfactorily addressed, please contact JAMS here. JAMS is an alternative dispute resolution provider based in the United States. The services of JAMS are provided at no cost to you.

7.2.3. Right to invoke arbitration

An individual has the opportunity, under certain conditions, to invoke binding arbitration for complaints regarding DPF compliance not resolved by any of the other DPF mechanisms. More information about how to invoke binding arbitration against Plickers and its compliance with the DPF can be found here.

8. GDPR Compliance

The EU’s General Data Protection Regulations (GDPR) took effect on May 25, 2018, and we are fully behind the spirit of these regulations for a safe and secure Internet. We aspire to embrace privacy by design and, whenever possible, to not collect and store personally-identifiable information. Overall, we aim for privacy by default: if data collection is not integral to the way our product works, then we won’t collect it.

9. Other Websites and Services

Our Services may contain links to third-party websites. Those links are provided for your convenience, and our inclusion of those links does not suggest an endorsement by Plickers. We have no control over, do not review, and are not responsible for these other websites, their content, or any goods or services available through the websites. Please remember that when you use a link to go from the Services to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on our website, are subject to that third party’s own rules and policies, and we encourage you to read them.

The Services integrate with YouTube via YouTube API Services to provide video search. To learn about YouTube/Google’s privacy practices, review the Google Privacy Policy.

10. Social Network Widgets

Our website may include social network sharing widgets that may provide information to their associated social networks or third-parties about your interactions with our web pages that you visit. Information may be transmitted from your browser and may include an identifier assigned by the social network or third party, information about your browser type, operating system, device type, IP address, and the URL of the web page where widget appears. If you use social network tools or visit social networking sites, you should read their privacy disclosures, to learn how they collect, use, and share information.

If you choose to share content or to otherwise post information through the Services to a third-party social networking site, or vice versa, that information may be publicly displayed. Similarly, if you post information on a social networking site that references Plickers, for example, by using a Twitter hashtag associated with Plickers in your Tweet), your post may be published in the Services in accordance with the terms of that social networking site. Also, both we and the social networking site may have access to certain information about you and your use of the Services and the social networking site. In addition, we may receive information about you if other users of a social networking site give us access to their profiles and you are connected to them or information about you is otherwise accessible through your web page, profile page, or similar page on a social networking site. If you choose to log in through a social networking site, we may collect Personal Information including your name and email address. The information we collect in connection with social networking sites is subject to this Privacy Policy. The information collected and stored by the social networking sites remains subject to their privacy practices, including whether the social networking site continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on that social networking site.

11. Information Collected From Students

Plickers strives to collect as little personal information about students as possible. We use this information solely to provide and improve our service.

We do not ask students to provide their name, address, phone number, location, photo, or any other type of directory or biometric data. We do not allow students to make any information publicly available through our service.

We do not sell information about students to anyone, including advertisers.

When students use Plickers cards:

• We collect nothing but the answers they submit in response to multiple-choice questions.
• The Plickers app processes images locally and immediately discards them, so images are not transmitted, collected, or stored in any way.

When students use my.plickers.com:

• When a student enters their unique code into Plickers, we send the code to our server and use it to associate the student’s device with the correct student record in your class.
• We collect only:
• Unique student code
• IP address
• Session token
• Online status/presence
• Basic usage data
• Referrer information
• User-Agent information
• Answers submitted in response to multiple-choice questions

Your rights as a teacher or school official with regard to information collected about students:

• You have the right to review the personal information we’ve collected about your students.
• If you would like us to stop collecting or using information about a student, or have a student’s data deleted, please contact us at help@plickers.com at any time.

We contract with third-party service providers to help us provide the Plickers service. Third-party service providers are not permitted to use information about students for their own purposes.

In rare cases, we may be required to disclose personal information about students to third parties. We only do so in the following cases:

• as required by a School Agreement
• as directed by a school official
• as required by applicable law

If you would like to correct or delete any information associated with your account, please contact us at help@plickers.com.

12. Future Changes to Our Privacy Policy

Plickers reserves the right to make changes to this Privacy Policy and will notify you in case of material changes via the email address associated with your account and by posting the Privacy Policy on our Services. Any changes will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified. We will not use your Personal Information in a manner materially different from the Privacy Policy in effect at the time we collected your Personal Information without your consent. However, you may need to consent to the new or revised policy in order to continue to access or use the Site.

13. Contacting us

If you have any questions about this Privacy Policy or the Services, please contact us at help@plickers.com.

To reach our Data Protection Officer, please email us at dpo@plickers.com.

If you are a resident of the EEA or UK and you want to raise a question to Plickers Inc., or otherwise exercise your rights in respect of your personal data, please contact our European Representative “DPR Group”. You can send an email to DPR Group at plickers@dpr.eu.com or contact them on our online webform at www.dpr.eu.com/plickers.