SpacesEDU is committed to the following principles with respect to your personal information:
- We take the protection of your information seriously.
- We do not use the personal information of K-12 students for any marketing or targeted advertising.
- We store data in a highly secure Microsoft Azure datacenter. Microsoft Azure provides industry-leading compliance and privacy certifications to keep student data in SpacesEDU safe.
- We maintain a comprehensive security program reasonably designed to protect the privacy, security, and confidentiality of your personal and sensitive information against risks – such as unauthorized access or use, or unintended or inappropriate disclosure - through administrative, technological, and physical safeguards appropriate to the sensitivity of the information.
- We do not sell your personal information to third parties.
- We do not own your personal information. As it pertains to SpacesEDU, you are the owner of the data, including any rights afforded by Copyright.
- We do not use your personal information to build a personal profile of you other than for supporting authorized purposes of the Educational Institution or other educational objectives or as authorized by you or your parent or guardians.
Compliance with Privacy Laws
- Although SpacesEDU does not currently participate in a Safe Harbor program, its practices and procedures are fully compliant with both United States Federal and State law, as set out more fully below.
- SpacesEDU fully complies with the requirements of the United States Family Educational Rights and Privacy Act ("FERPA") and is considered a "School Official” in its contracts with an Educational Institution.
- When contracting with individuals outside of an educational setting, SpacesEDU fully complies with the United States Children’s Online Privacy Protection Act (“COPPA”).
- SpacesEDU fully Complies with California State law, including Education Code section 49073.1.
- SpacesEDU fully complies with Canadian law, including the Personal Information Protection and Electronic Documents Act (“PIPEDA”), as well as provincial enactments such as the the Personal Information Protection Act (Alberta), the Personal Information Protection Act (British Columbia), the Freedom of Information and Protection of Privacy Act (Ontario), and An Act Respecting the Protection of Personal Information in the Private Sector (Quebec).
SpacesEDU (“SpacesEDU,” “we,” “our,” “us”) recognizes the importance of your right to privacy and wants you to be familiar with how we collect, use, and disclose any personal information that individually identifies you (e.g., name, phone number, e-mail address). It also describes your choices regarding use, access, and correction of your personal information.
Any user who is subject to the negative activities listed below can report them to their Educational Institution or to SpacesEDU. Any appeal by the user for reinstatement will be addressed by the contracting Educational Institution. Any request for reinstatement by the Educational Institution will be considered by SpacesEDU and its decision shall be supported by substantial evidence.
Educators have the ability to remove specific content which they believe to be harmful.
Parent/Guardian Consent Requirement
An Educational Institution may elect to proceed under the School Official exception to the consent rule, under section 99.31 of the Family Educational Rights and Privacy Act ("FERPA") or similar legislation.
We provide Educational Institutions, school administrators and teachers with notices required under applicable law. Additionally, upon request from an Educational Institution, school administrator or teacher that has established an account with SpacesEDU for use in the classroom, we provide the Educational Institution with a description of the types of personal information that we collect, an opportunity to review the personal information of students, and/or have the information deleted, and the opportunity to prevent further use or online collection of a student’s personal information as required by applicable law.
In some instances, SpacesEDU's duties regarding the collection of Student Personal Data will be set forth in a Data Privacy Agreement ("DPA") In those cases SpacesEDU will ensure that the data protections set forth in the DPA will be no less than stated here in this Policy. Where applicable, SpacesEDU collects data only as necessary to the proper administration of lawfully authorized educational activity and serves as a contracted School Official. SpacesEDU does not disclose Directory Information.
What Personal Information do we collect?
Personal information means any information about an identified or identifiable individual. The types of personal information that we may collect when using our Site, App or Services include, but is not limited to:
- your name;
- your e-mail address;
- all content that you create or share in video, text, images, and other media files that you provide on or through the Services, or that are provided on your behalf;
We do not collect Geolocation or Biometric data, nor do we collect Sensitive Data, as that term is defined in the GDPR. When you use our Services, we will also know what Educational Institution you attend and the city and state or province in which your Educational Institution is located, and we may combine that information with information we have from your account. However, we do not collect data that indicates whether you are participating or are eligible to participate in any free or reduced lunch programs.
The data we collect from you will be the data generated in your use of the Service. We do not collect your data through "cookies" or "beacons", except as stated below. The data you create when using the system remains your property, or that of your Educational Institution as it pertains to SpacesEDU, as applicable law designates.
SpacesEDU also creates Anonymous Data from the data you provide. Anonymous Data means data that has been modified so that it is not associated with, or linked to any individual personal information, or will not easily permit the identification of the individual. This includes data about how users interact with the Services. SpacesEDU does not consider personal information to include Anonymous Data.
Why Do We Collect Your Personal Information?
We collect, use, and disclose your personal information only in order to provide you with our Services. We may disclose your personal information to comply with legal and regulatory requirements and as otherwise may be permitted or required by applicable laws. We will only use the personal information that we collect for the purposes for which it was collected. We collect your personal information for the following purposes and in accordance with applicable laws:
- to provide you with access to our App and Services;
- to allow you to use and benefit from our App and Services;
- to establish and maintain commercial relations with you;
- to identify and contact you when you request our Services;
- to respond to your questions that you send by email or through our Site;
- to contact you about the App and Services, including notifying you about updates;
- subject to applicable law, to notify you about other App and services provided by SpacesEDU, which may be of interest to you;
- subject to applicable law, to provide you with newsletters and articles;
- to customise the appearance of the Site, App and Services displayed to you;
- to obtain your feedback regarding our App and Services;
- to track behavioural information on the Site and App to serve similar content upon future visits;
- to improve the Site, App or Services and help us develop new services, apps, tools, and Site, App or Service features;
- to support our business functions such as internal business processes; and
- to meet any legal or regulatory requirements.
We do not collect, maintain, use, or share your personal information beyond that needed to provide you with our Services, for authorized educational purposes, or for the purposes listed above as authorized by you or your parent or guardian.
When Do We Collect Personal Information?
We may collect your personal information when you voluntarily provide it to us by using our Services. As described elsewhere in this Policy we do not begin to collect or release your data to other parties your data until consent from you or your parent has been obtained or through the application, or where appropriate, of the School Official exception under FERPA. Consent and the process of consent will be determined by your Educational Institution. For example, we may ask you to provide personal information if you:
- use our Site, App, and Services;
- register, update or create an account on our Site, App or through a third-party service;
- sign into your account;
- send us a question or comment by email, message, or phone;
- register to receive newsletters, articles, and updates about our services; and
- otherwise participate in features of our Site, App and Services that ask for or require personal information.
How Do We Safely Store Your Personal Information?
We securely store your personal information in the United States if you reside in the United States. We securely store your personal information in Canada if your reside in Canada or outside of the United States. We maintain technical, physical, and administrative security safeguards to protect your personal information against loss, theft, and unauthorized access. Any personal information that you provide to us is exchanged on a secure server. We store data in a highly secure Microsoft Azure datacenter. Microsoft Azure provides industry-leading compliance and privacy certifications to keep student data in SpacesEDU safe.
Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us.
We take reasonable steps to verify your identity before granting you access to your account on our Site. This may include verifying your identity with personal information or multi-factor authentication as the Educational Institution elects. The manner in which you access SpacesEDU is controlled by your Educational Institution through the use of settings. For example, the Educational Institution may allow you to access SpacesEDU with your Google account and password. To assist us in maintaining product you asked to maintain the secrecy of your username, password, and any other account information. We train our employees to be aware of the importance of maintaining the confidentiality of personal information and that unauthorized persons do not gain access to personal information that we have disposed of or destroyed.
We provide further protections for your stored data, which is discussed further in the section, “Data Security", below.
Limiting Collection of Personal Information
Use, Disclosure and Retention of Personal Information
We may generate Anonymous Data from personal information collected through the Site, App and Services by removing information that makes the data personally identifiable to an individual. This includes information about how users interact with certain areas of the Services. We anonymize personal information collected through the Site, App or Services by de-identifying records or aggregating data such that individual records cannot be linked back to an original student record system or to other individual records from the SpacesEDU database. We use Anonymous Data within the system to improve our Products. We may also use it to demonstrate the effectiveness of our Products and for the development and improvement of our Products.
Retention Of Records
We retain your personal information only for as long as we need it to fulfill the purposes for which it was collected, to ensure your compliance with our Terms of Service, and to comply with our legal obligations. Our retention policies will vary slightly, depending on whether or not you are an Individual Free User or whether your Educational Institution has a contract with SpacesEDU.
- Individual Free Users - Dormant Account: Prior to the start of each academic year, we review user account activity to confirm that each user has accessed their account in the preceding 24 months. If a user has not accessed their account during this period, subject to legal or contractual requirements, we will delete the personally identifying information associated with that account.
- Individual Free Users - Deletion Request: An individual user may request that their personally identifying information be deleted. In such a case, and subject to any applicable legal or contractual requirements, the data will be deleted in a commercially reasonable time, and in no event, exceeding 90 days.
- Educational Institution Contract - Deletion Request: Educational institutions in a contract with SpacesEDU (or once a contract expires) may request us to delete the personally identifying information of its users. Unless otherwise specified under the contract, and subject to applicable legal authority, the data will be deleted in a commercially reasonable time, and in no event, exceeding 90 days.
- Educational Institution Contract - No Deletion Request: In the event that an Educational Institution contract expires without renewal, and there is no Deletion Request, we will delete the personally identifying information of its users following the policy outlined under the point “Individual Free Users - Dormant Account”.
Students that leave or graduate from an Educational Institution will continue to have free access to their account during the retention period.
We do not knowingly retain your personal information beyond the time period required to support the provision of our Services to you, and/or to support authorized educational purposes, or purposes authorized by you or your parent or guardian.
Third parties do not have direct access to your data. We may also use and disclose your personal information to service providers, data processors and other third parties (“Third Parties”) under the following limited circumstances:
- to service providers that help with our operations and Site, App and Services including, without limitation, for monitoring and analyzing Site and App data, operating and maintaining the Site and App, and for the purposes of product improvement. Examples of such third-party service providers include Microsoft, which stores our data, and Datadog, which monitors and analyzes user activity to help us resolve issues. We periodically use other third-parties to perform other core functions. The current list of third-party providers will be supplied to Educational Institutions upon request.
- when necessary to protect our safety, property or other rights, our representatives, customers and users of the Site, App and Services, including to detect and prevent fraud;
- with your consent; or
- when otherwise required by law. When permitted under applicable law, we will provide you with notice if we receive a government or legal request for your personal information;
- Third parties will be prohibited from reidentifying anonymous data or combining anonymous data with personally identifiable data.
- You have the right to notify SpacesEDU that you do not wish to have your data transferred to third parties. In such an event, your use of SpacesEDU may be compromised or rendered impractical.
- We do not sell or transfer your data to third parties, save to fulfill the purposes of this Agreement. Data will not be shared with third parties for the purposes of advertising, to create automated profiles, or for data enhancements. Neither SpacesEDU or third parties within its controls will engage in social or targeted advertising. In short, our products and services are not designed to either deliver advertising or to permit the delivery of advertising, either from SpacesEDU or third parties within its controls. Users who receive advertising are strongly urged to contact SpacesEDU for rectification.
- Users do not currently have direct access to third parties who perform services for SpacesEDU. In the event they do, SpacesEDU will require the third party to verify the identity of the user before permitting access.
Access To Data
If you are a student, your parent or guardian, as well as your teacher and an administrator from your Educational Institution, may view and access all your personal information, content and activity associated with your account. In certain cases, access may be granted to a decedent's fiduciary or personal representative. SpacesEDU strives to create an environment where data stored is accurate and accessible. If you are a teacher, you will be able to access and edit all information, including personal information, about the students in your classroom. Students or guardians of students who wish to confirm the accuracy of data modify or delete data should direct their requests to their Educational Institution. SpacesEDU will delete or modify data found to be inaccurate by the Educational Institution.
Commitment to Data Security
We will use administrative, physical, and technical safeguards designed to protect student data from unauthorized access, disclosure, acquisition, destruction, use or modification. These efforts will include:
- The appropriate training of employees who have access to the data.
- Access to data stored on SpacesEDU’s servers will be restricted to senior managers.
- All employees with access to data will have background checks.
- Data in transit will be encrypted.
- Data in storage will be encrypted.
- Any user who has access to appropriate data must create an account.
- Periodic security audits to identify any needed improvements in SpacesEDU security technology and practices.
Data Breach Process
If we experience an unauthorized access to your data, we will provide notification to you by email and to any relevant legal authorities without unreasonable delay in accordance with applicable law. Our notification will provide details about the unauthorized access. We will also take reasonable steps to conduct a threat assessment and remedy the impact of any data breach on you, and take other steps as required by law.
Links to Other Sites and Privacy Policies of Other Sites
Cookies, Web Beacons, and Other Similar Technology
As you interact with this Site, we may use automatic data collection technology and services that record and collect information that identifies your computer, tracks your use of this Site, and collects certain other information about you and your surfing habits. This data collection technology may include cookies, web beacons and other similar technologies on this Site to enhance functionality and navigation for our visitors. These cookies and beacons will be used only for the purpose of supporting and enhancing the Services we provide, as more detailed below.
What Are Cookies and Web Beacons?
A cookie is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store settings in the browser. Web beacons are an invisible image file used for tracking purposes. Web beacon type functions allow us to count the number of users who have visited a particular web page or to access certain cookies.
We may use web beacons on this Site to:
- count users and to recognize users by accessing our cookies. Being able to access our cookies allows us to personalize this Site and improve your experience at our Site.
- include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened. Information tracked through these mechanisms includes but is not limited to: (i) your IP address; (ii) the type of web browser and operating system being used; (iii) the pages of the Site a user visits; and (iv) other sites a user visited before visiting our Site.
- We may also employ cookies and action tags (also known as single pixel gifs or web beacons) to collect information about your use of, and activities on, our Site for our use.
You can modify your privacy controls so that you are notified when cookies are stored, you can decide in each individual case whether you want to accept cookies, or you can refuse to accept any cookies. However, if you do not accept cookies, you may be restricted in how you are able to use our Site. You can delete cookies which are already stored on your browser at any time. You will find more details on how to do this in the operating guide for your Internet browser program.
You or your Educational Institution can set your internet browser to prohibit the installation of cookies that are utilized by the analytics services that we use. However, if you do not accept cookies, you may be restricted in how you are able to use our Site.
Personal Information and Data Protection Rights
Your personal information is subject to international data transfer or jurisdiction laws. Compliance with International data transfer laws will be handled by a Data Protection Officer (“DPO”) or other contact.
We would like to make sure you are fully aware of all your data protection rights. These rights may be coordinated, with and subject to the processes of your Educational Institution. Every user is entitled to the following:
The right to access – You may request access to or copies of your personal information which we may hold by contacting us at the contact information set forth below, and we will respond within the time periods provided for under applicable laws. We will need to verify your identity before providing you with the personal information we hold about you. There is no cost for these access requests unless you require copies of records. We may not be able to provide you with access to your personal information if the information cannot be separated from the personal information of others, cannot be disclosed for reasons of security or commercial confidentiality, or is protected by legal privilege. If we cannot provide you with access to your personal information, we will advise you of the reasons access is being denied, unless we are prohibited by law from doing so.
- The right to rectification – You may request to update, change, or correct your personal information at the contact information set forth below. You have the right to request that we correct or complete any personal information which you advise us is inaccurate or incomplete. Where appropriate, the amended information shall be transmitted to third parties having access to such information. If you have any concerns about your information that was provided by your Educational Institution and/or teacher, please contact these parties directly.
- The right to erasure – You have the right to request that we erase your personal information, under certain conditions.
- The right to restrict processing – You have the right to request that we restrict the processing of your personal information, under certain conditions.
- The right to object to processing – You have the right to object to our processing of your personal information, under certain conditions.
- The right to data portability – You have the right to request that we transfer the information we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights or have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us at email@example.com.
We comply with the United States CAN-SPAM Act and Canada's Anti-Spam Legislation (CASL), laws that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients of such messages the right to opt-out. We will not send you electronic communications in contravention of this law. As part of signing up to receive the Services, you may have also opted in to receive email communications from us. If you opted-in to receive such communications, we may use the information to communicate with you regarding our products, Services, and promotions; provide you with other information that you request; and/or improve our product and service offerings.
You will always have the opportunity to “unsubscribe” from receiving any of our e-mail or other communications at any time and we will ensure that our e-mails include instructions on how to unsubscribe if you no longer wish to receive future e-mails from us. We provide an on-going opportunity to unsubscribe or opt-out of contact by us by accessing our Site or by e-mail to firstname.lastname@example.org or by calling us at 1-416-901-5555.
Personal Information of Children
How to Contact Us
- see your personal information that you have already sent us so that you can correct, update, or delete it from our files;
- ask that we not send you electronic communications or otherwise contact you;
Contact SpacesEDU at email@example.com or call 1-416-901-5555. You can also mail us at the address below:
168 Bedford Road, Second Floor
Toronto, Ontario M5R 2K9