Privacy Policy for Intellispark Products

Intellispark is committed to helping schools improve educational outcomes for kids, and we do that by providing schools, school districts, and community-based organizations and their end users (including employees, students, and families) with tools to track student progress, recommend interventions and activities, communicate, and report outcomes. We are similarly committed to ensuring that our users understand how we use and disclose the information we collect and host in the course of providing our educational software products (“Products”). Our Products include online services and software applications. We have prepared this Privacy Policy for Intellispark Products to describe our practices.

As described below, we use the information we collect from school administrators, teachers, support staff, parents, guardians, and students in connection with their use of our Products, to provide the Products and related services to our users, to inform and improve support services our users provide to students, and to enhance our Products. We do not use information that identifies an individual or relates to an identifiable individual (“Personal Information”) for any other purpose.

For the purposes of this Privacy Policy, any individual enrolled for studies in an elementary or secondary school in the United States or worldwide shall be considered a Student. To the extent that any personally identifiable information or any indirect identifiers such as e-mail addresses, IP addresses, and other information that could reasonably identify (or be used in conjunction with other available data to identify) a Student, that information shall be considered Student Personal Information.

Information We Collect

In providing our Products, we may collect:

• Information submitted by a user about himself or herself, such as first and last name, email address, photo and other profile information, and username and password.
• Information submitted by a user about the students in a particular school or classroom, such as first and last names, student ID numbers, usernames and passwords, gender and other demographic information, learning level, special needs, test scores, behavior, attendance, case notes and other performance related data. Sometimes schools, school districts, or community-based organizations with which we work permit us to access a database from which we retrieve this information. We may combine information about a student with information about his or her school or an organization that provides the student with services, such as its location.
• Information about a student’s parent or guardian, such as names and email addresses. This information may be submitted by a user (e.g., a teacher, administrator, or the parent or guardian), and we may associate it with the student’s information.
• Information and content submitted by a school administrator or teacher, such as student support plans and notes.
• Information and content submitted by a student using our Products, such as notes, responses to questions, activities, assessments, and assignments. Depending on the Product, a student’s notes and responses may be provided through open text fields, voice recordings, photographs, or video recordings.
• For certain of our Products, the name and email address of an individual to whom a user wishes to send content from the Product. We use the information only to send the message.
• Information about how, where (in a general sense, based on IP address), when, and for how long a user accesses and uses our Products, as well as what content he or she views, what actions he or she takes (including, for example, clicks, touches, and hovers using a mouse), and how he or she navigates through our Products. We may use cookies, pixel tags, and other technologies to collect this information.
• Information from and about the user’s device, such as device type, browser type and version, operating system name and version, IP address, and referring URL. We collect this information automatically when a user accesses our services, to help us understand usage, diagnose problems, administer our Products, and provide support.
• Information collected through cookies and similar technologies, which are pieces of data stored directly on a user’s computer, and other persistent identifiers. We use cookies, IP addresses, and other persistent identifiers to authenticate users in order to ensure that only authorized individuals are permitted access to our Products.
• Information collected through pixel tags (also known as web beacons and clear GIFs) or other, similar technologies to track how a user navigates through our Products, so that we can understand, for example, what links are clicked and what content is accessed and for how long. This information allows us to improve our user interface and create a better product, such as by making commonly accessed content easier to reach or by more prominently displaying content that has been less frequently accessed.

How We Use the Information We Collect

In addition to the uses described above, and subject to any restrictions imposed by applicable law or our agreement with our customer, we may use and disclose the information we collect:

• To provide our customers with the products and services they have requested.
• To permit our customers and their authorized end users to tailor and optimize the use of our Products to the needs of a particular school, classroom, or student.
• To permit school administrators and teachers to review students’ work, monitor students’ performance, attendance, behavior, and progress, and otherwise support students’ academic performance and personal development.
• So school districts can permit parents and guardians to review their children’s work and monitor their performance and progress.
• So school districts can offer students immediate feedback and continuous support, permit them to access information shared by their teachers and support personnel, suggest other content or activities for them, help them track their own progress and maintain a file of their work.
• To personalize user experience, such as displaying his or her name on the user dashboard or permitting a student to view a profile picture of his or her teacher, administrator, or other support staff personnel.
• For analytics purposes, to understand how our Products are accessed and used, and how they perform, so that we may improve upon their design and functionality and otherwise develop and improve upon our products and services. We also develop analytics studies that contain only aggregate information that does not permit the identification of any individual user or organization. We may disclose these studies to third parties, including to market our products and services to them.
• To provide our customers, as well as their administrators and teachers with various types of reports, such as reports detailing the performance and progress of a particular school district, school, classroom, or student.
• To communicate with administrators, teachers, students, and parents or guardians, subject to any communications preferences they express.
• To ensure that our Products run properly and are presented optimally, and for Product improvement.
• To diagnose problems, troubleshoot issues, and provide maintenance and support.
• To calculate the royalties due to the owners of content appearing in our Products.

We may use non-personal information collected from the users of our Products for any reason, subject to any restrictions imposed by applicable law or our agreement with our customer.

We do not allow third parties to use cookies, pixel tags, or other technologies to track our users’ use of the service for their own purposes.

How We Use and Share Google User Data

When you connect your Google account to our service, we access and use certain information from your Google Calendar and Google Drive accounts to provide you with core functionality, including:

• Displaying your Google Calendar events within our application
• Allowing you to attach Google Drive files to content created in our system

We access this information using Google’s secure APIs with your explicit consent, and only use it to deliver features you have requested.

We do not share, sell, or disclose your Google user data to third parties except if required by law, regulation, or legal process. We do not use Google user data for advertising or for any purposes unrelated to the core functionality of our application. Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

How We Disclose Personal Information We Collect

We do not disclose Student Personal Information or personal information about any users of our Products to any third party, except in accordance with applicable law and:

• As directed by our customer to which the information relates.
• To third-party service providers known as Subprocessors that provide services such as cloud hosting, to permit them to provide those services to us. Subprocessors must agree to conform to privacy practices outlined herein. (Please see below for a current list of our Subprocessors.)
• To the extent we believe necessary or appropriate to comply with legal process or to respond to requests from government authorities.
• To the extent we believe necessary or appropriate to protect our rights, safety, or property and/or that of our affiliates, our customers, our users or others.

In the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business (including in connection with any bankruptcy or similar proceedings), the transferred information will remain subject to the terms of this Privacy Policy.

Subprocessors

We use the following Subprocessors as part of the Products we provide to our customers. Not every Subprocessor is used for the Student Personal Information and/or other personal information of every customer. The Subprocessors used for a particular customer may vary based on how they choose to integrate other systems with us and which features of our Products they use. We do not give Subprocessors any greater right to use or disclose Student Personal Information and/or other personal information than we are given by the customer that owns that information.

Subprocessor Headquarters Activity(ies) Amazon Web Services Inc. (AWS) United States Cloud hosting and database services. ClassLink Inc. United States Data integration, rostering, and single sign-on. Clever Inc. United States Data integration, rostering, and single sign-on. Ednition Inc. United States Data integration, rostering, and single sign-on. Google LLC United States Single sign-on and Google Drive integration.

Advertising

Intellispark does not permit advertising, targeted or otherwise, to students in its Products, nor does Intellispark use the data in its Products to advertise to students or to enable any third-party to advertise to students.

Sale of Data

Intellispark does not rent or sell student data under any circumstances.

Linked Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third party operating any site or service to which our Products may link. The inclusion of a link in any of our Products does not imply our endorsement of the linked site or service. In addition, we are not responsible for the privacy, information or other practices of other organizations, such as Apple, Google, Microsoft, Samsung, or any other device manufacturer, app developer, or provider of an app, social media platform, operating system, or wireless service.

Information Security

Intellispark maintains a comprehensive information security program based on cybersecurity principles established by the National Institute of Standards and Technology and outlined in the NIST Cybersecurity Framework Version 1.1. We use a variety of physical, administrative, and technological security measures that are designed to protect personal information against loss, misuse, and unauthorized access, or disclosure. Our measures consider the type and sensitivity of the data being collected, used, and stored, and the current state of technology and threats to information. Our security measures include data encryption (both in transit and at rest), firewalls, data use and access limitations for personnel and vendors, and physical access controls to our facilities.

Retention Period

Unless otherwise requested in writing by an authorized representative of our customer, we will retain your data for as long as you remain a customer and – to avoid service disruption in the event of a delayed renewal – for a minimum of 30 days and maximum of 90 days thereafter. We will also retain your data as necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.

User Access

All personal data in our Products is the property of and solely owned by our customers. Any student, parent, or guardian may request access to their own information in accordance with applicable law and our customers’ policies. If you would like to seek such access, or to request a correction, please contact your school, school district, or other organization that provides you access to our Products.

Opting Out

The school, school district, or organization that provides you with access to our Products may allow students or their parents or guardians to opt out of using our Product. If you would like to opt out, please contact that school, school district, or organization.

Updates to the Policy

Intellispark may update this policy from time to time. The “Last Updated” legend at the bottom of this page indicates when this Privacy Policy was last revised. To the extent permitted by law, any changes will become effective when we post the revised Privacy Policy or, in the case of any material change, such changes will become effective after the revised Privacy Policy has been posted to our Product(s), notice has been provided to our customer via e-mail, and the revised Privacy Policy has been accepted by an authorized representative of the customer affirmatively accepting the terms online or in conjunction with a contract renewal.

Contact Us

Please contact security@intellispark.com to report a potential security incident. For inquiries regarding data collection or privacy practices for Intellispark products or sites, please contact privacy@intellispark.com.

Last updated: May 15, 2025

Summary of changes

June 24, 2025:

• Added subsection titled How We Use and Share Google User Data to explain how data is managed if you choose to use Google Drive and Google Calendar with Intellispark.
• Updated our list of subprocessors to remove Pipe Services S.R.L.

May 15, 2025:

• Updated language in the section titled “How We Disclose Personal Information We Collect” to define third-party providers as “Subprocessors” and added a list of Subprocessors we use.

April 21, 2025:

• Removed the Student Privacy Pledge link and logo from our website because the Future of Privacy Forum retired the Student Privacy Pledge and requested that all signatories (of which Intellispark is one) remove references to the Pledge from their websites. Intellispark has not made any changes to its privacy policy or practices as a result of this request.

August 19, 2021:

• Clarified the definition of the terms Student and Student Personal Information.
• Clarified that advertising to students is neither allowed within our Products nor enabled by Intellispark in any manner.
• Clarified that Intellispark does not rent or sell personal information of any kind.
• Updated the security practices to reflect the NIST Cybersecurity Framework Version 1.1.
• Clarified the data retention policy.
• Clarified the process by which students, parents, and guardians may request access and corrections to data hosted within our Products.
• Clarified the conditions under which material changes to this policy may take effect.

December 18, 2019:

• Initial version