Spaces by myBlueprint 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 the Spaces product safe.
• We maintain a comprehensive security program reasonably designed to protect the privacy, security and confidentiality of your personal 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.
• We do not use your personal information to build a personal profile of you other than for supporting authorized educational or school purposes or as authorized by you or your parent or guardians

This Privacy Policy is effective as of February 20, 2020.

Doublethink Inc. o/a myBlueprint and Spaces (“Spaces”, “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.

This Privacy Policy explains how we collect, use, disclose and protect your personal information when you use our website (the “Site”), our mobile application (the “App”) and our services, including but not limited to our portfolio and career education services, or any, electronic publications, newsletters and/or announcements (collectively, the “Services”). This Privacy Policy is incorporated into and forms part of our Terms of Use, which outline the terms and conditions you agree to when using our Site, App and Services. We will only collect, use and disclose your personal information in accordance with this Privacy Policy.

By using our Site, App or Services, you represent that you, or your parent or guardian, has provided all necessary consents to use the Site, App and Services as required under any applicable privacy laws and that you, or your parent or guardian, consents to the collection, use and disclosure of your personal information as outlined in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use our Site, App or Services or supply your personal information to us. 

Parent/Guardian Consent Requirement

Spaces requires parent or guardian consent as a condition of use of our Site, App or Services for certain users when required by applicable law. Most schools have policies that govern the use of third-party educational services and products like Spaces, and that address compliance with parental consent and annual notice requirements under laws such as the Children’s Online Privacy Protection Act (“COPPA”) and the Family Educational Rights and Privacy Act (“FERPA”). As such, school districts, administrators, and teachers are in the best position to provide required annual notices and obtain parental consent required as a condition of using our Site, App or Services in compliance with applicable law and school policies. When parent or guardian consent is required under applicable law, Spaces requires that school districts or teachers obtain written consent from the parents or guardians of students when school districts or teachers set up accounts on behalf of their students, invite students to use our Site, App or Services, and allow students to access student accounts in the classroom. To help facilitate this process, we have provided a model consent form that school districts and teachers may use to obtain parent/guardian consent to our Privacy Policy and Terms of Use in our Knowledge Base. 

If you are a school administrator or teacher, by inviting students to use our Site, App or Services, or setting up accounts on behalf of students in your school or classroom, you represent that you or the school district by which you are employed have obtained necessary consent from the parents or guardians of students in your classroom to whom you have invited, or will invite, to use our Site, App or Services.  You further represent that each student’s parent or guardian consents: (1) to the collection, use, and disclosure of personal information as outlined in this Privacy Policy, and (2) the terms specified in our Terms of Use on behalf of his or her child.

We provide schools, school administrators and teachers with notices required under applicable law. Additionally, upon request from a school, school administrator or teacher that has established an account with Spaces for use in the classroom, we provide the school 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.

Personal information means any information about an identified or identifiable individual. Anonymous Data means data that is not associated with or linked to any individual’s personal information or will not easily permit the identification of individuals. This includes data about how users interact with the Services. Spaces does not consider personal information to include Anonymous Data. The types of personal information that we may collect when using our Site and 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;

When you use our Services, we will also know what school you attend and the city and state or province in which you go to school, and we may combine that information with information we have from your account.

We collect, use and disclose your personal information in order to provide you with our Services. We also collect, use and 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 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 Spaces, 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 and App and help us develop new services, apps, tools and Site 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/school purposes, or for the purposes listed above as authorized by you or your parent or guardian.

We may collect your personal information when you voluntarily provide it to us by using our Services. For example, we may ask you to provide personal information if you:

• use our Site, App and our 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 our Services that ask for or require personal information.

Any personal information posted, used or disclosed on a Facebook page, YouTube page or other social networking page or site is subject to that website’s privacy policy, and is not subject to this Privacy Policy.

We securely store your personal information in the United States or Canada, depending on where you reside..  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 Spaces 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, however, you are solely responsible for maintaining the secrecy of your username, password and any other account information. We also take reasonable steps to ensure that our employees are 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 limit the collection of personal information to that which is necessary to fulfill the purposes identified in this Privacy Policy and we collect, use and disclose your personal information in accordance with this Privacy Policy.

Your personal information will not be used without your consent for purposes other than those for which it was collected or in accordance with applicable laws. From time to time, we may wish to use personal information for new or additional purposes, in which case we will amend the Privacy Policy to include these new or additional purposes and will obtain your consent through your continued use of our Site, App and Services.

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 such that individual records cannot be linked back to an original student record system or to other individual records from the Spaces database. We may use this Anonymous Data and aggregated data for any purpose and disclose such data to third parties in our sole discretion.

When we contract with a school district to provide access to our Site, App, or Services to you, we will work with the school district to determine whether we are a “school official” under FERPA.  In cases where we are designated as a “school official,” we will be under the direct control of the school district or educational institution with respect to the use and disclosure of your personal information.

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. 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 18 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 by running a script that will permanently delete the account and all associated personally identifying information from our database. We also delete your personal information upon termination of your account, and 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 or school purposes, or purposes authorized by you or your parent or guardian.

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 activity, and operating and maintaining the Site and App. These service providers and partner companies may only use your personal information for the purposes described in this Privacy Policy, and we require that our vendors and third parties with whom your personal information is shared in order to deliver our Services, if any, are obligated to implement the same commitments identified in this Privacy Policy for the given personal information;
• 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;
• if we sell or transfer all or a portion of our business or assets to a related company or a third party. Your personal information will remain subject to any pre-existing Privacy Policy unless you agree to the privacy policy of the company or third party that acquires your personal information;
• with your consent; or
• when otherwise required or permitted 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.

If you are a student, your parent or guardian, as well as your teacher and an administrator from your school and/or school district, may view and access all of your personal information, content and activity associated with your account. If you are a teacher, you will be able to access and edit all information, including personal information, about the students in your classroom.

If the context in which we collect or use your personal information changes, we will obtain your consent in accordance with applicable law prior to such changes becoming effective. In the event that we experience a data breach that results in the release of your unencrypted personal information to an unauthorized third party, we will provide notification to you and to relevant legal authorities without unreasonable delay in accordance with applicable law. We will also take reasonable steps to conduct a threat assessment and remedy the impact of any data breach on you.

Our Site may contain links to other sites that are independently owned and operated by third parties. These other sites may have their own privacy policies and are not governed by this Privacy Policy. We are not responsible for the privacy practices or the content of any sites owned and operated by any third parties. Other sites may collect and treat information collected differently, so we encourage you to carefully read and review the privacy policy of each site you visit.

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.

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.

How Do We Use Cookies and Web Beacons?

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 and for use by third parties that serve advertisements about Spaces on other sites you may visit.
• use third party service providers, such as Google AdSense or AdWords, to serve advertisements on our behalf across the Internet. These advertising service providers may collect information about your visits to our Site, and your interactions with our Services.
• use the information about your visits to other sites to allow third party service providers to target advertisements for services available from Spaces.

You can set your internet browser up 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.

As described above, you may be able to set your browser to refuse cookies. If you refuse cookies you may still receive online advertising, but it may be less personalized.

Web Analytics

Our Site also uses third party analytics services to track telemetry concerned with load, performance and usage metrics, exception reports, and other diagnostic data. Some of the analytics services we use may place cookies in the browser of the visitor of the web pages which allows for an analysis of your use of the site. The only user data visible in the diagnostic reports are URLs; and as a best practice our Service does not put any personal data in plain text in a URL.  Analytics services we use may also use “cookies” to analyze how you use our Site.  We may also use cookies to carry out frequency assessments, page usage assessments, and marketing assessments.  For these assessments, we utilize cookie information without a link to your personal information, so the assessment is completely anonymous.

You 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.

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 of your data protection rights.  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 school, school district 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.

We comply with the United States CAN-SPAM Act, a law 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 privacy@spacesedu.com or by calling us at 1-416-901-5555.

If you decide to unsubscribe, we will only contact you (i) for the purposes allowed under applicable law; (ii) to send you notices of changes to our Privacy Policy; or (iii) to receive Service related messages.

We are committed to protecting the privacy of children.  Our Site, App and Services are primarily intended to be used by school administrators, teachers, parents, other adults, and students for K-12 school and educational purposes. As set forth in the “Parent/Guardian Consent Requirements” section of this Privacy Policy, we require schools and/or teachers that establish accounts through our Site, App or Services and invite students to use our Site, App or Services to obtain parent or guardian consent when required under applicable law. We also provide required notices in accordance with applicable privacy laws. Please do not send us more information than is required to use the Services and App.

We reserve the right to change or replace this Privacy Policy at our sole discretion at any time.  Please check back from time to time to ensure that you are aware of any updates or changes in this Privacy Policy. If we propose to make any material changes, we will notify you by means of a prominent notice on this page at least thirty (30) calendar days prior to the change becoming effective, and will allow you choices before your personal information is used in any manner inconsistent with the terms that you were initially provided. We will not make any material changes to other policies or practices governing the use of your personal information that are inconsistent with contractual requirements.  We will post the most current version of our Privacy Policy on our Site and we will indicate at the top of this page the date this Privacy Policy was last revised. Your continued access or use of this Site, App or Services after any such changes constitutes your acceptance of the Privacy Policy as revised. 

This privacy policy was last updated on February 20, 2020.  You may access an archive of our previous Privacy Policies by contacting us at privacy@spacesedu.com.

By using our Services and providing us with your personal information, you agree that Spaces may collect your personal information and you voluntarily consent to the collection, use, disclosure and transfer of your personal information in accordance with this Privacy Policy. If you do not agree with any terms of this Privacy Policy, please do not use our Site, App or our Services or provide us with any personal information. If you do not understand the nature, purpose and consequences of us collecting, using and disclosing your personal information, please do not use our Site, App or our Services or provide us with any personal information, and contact us at the contact information set forth below so that we can address your questions or concerns.

Subject to legal and contractual requirements, you may refuse or withdraw your consent for certain purposes identified in this Privacy Policy at any time by contacting us at the contact information below. If you refuse or withdraw your consent, you acknowledge that we may not be able to provide you or continue to provide you with certain services or information, which may be of value to you.

Any dispute arising between you and Spaces with respect to privacy is subject to the terms and conditions of use and this Privacy Policy, including limitations on damages, arbitration and application of the laws of the Province of Ontario. We reserve the right to change this Privacy Policy at any time by posting the policy changes on our website. Site visitors are advised to periodically check this website for such changes.

We welcome your feedback. If you have questions, comments or concerns about this Privacy Policy, or would like to do any of the following:

• 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;
• request a copy of our Privacy Policy in another language; or
• report any complaint or violation of this Privacy Policy

Contact Spaces at privacy@spacesedu.com or call 1-416-901-5555. You can also mail us at the address below:

How to Contact the Appropriate Authority

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office