Drafted: May 9, 2017
FERPA and other regulatory obligations
What information we collect and why we collect it.
We collect information to provide better services to all of our users. We collect information in two ways:
Information you give us
For example, some of our services may require you to sign up for a Sparkler account. When you do, we’ll ask for personal information, like your name, email address, and a password.
Information we get from your use of our services
We may collect information about the learning services that you use and how you use them. This information includes:
We may obtain and compare your provided login credentials with known credentials associated with your account in order to provide you access to your account. We may store and issue temporary credentials on your behalf for purposes such as password resets.
We may collect device specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). Sparkler may associate your device identifiers or phone number with your Sparkler account.
Log and application information
When you use our services or view content provided by Sparkler, we may automatically collect and store certain information in server logs. This may include: details of how you used our service, such as your activities on authorized learning websites, Internet protocol address, device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL, cookies that may uniquely identify your browser or your Sparkler account.
When you use a Sparkler service, we may collect and process information about your network, such as your IP address, your Internet Service Provider, your domain name, your bandwidth, your network route to the Internet and to our services.
When you use a location-enabled Sparkler service, we may collect and process information about your actual location. When you do not use a location enabled service, we may infer your approximate location by examining your Network information.
We may collect and store information (including personal information) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.
Cookies and anonymous identifiers
How we use information we collect.
We use the information we collect from all of our services first and foremost to provide information to our customers and partners to help them provide services based on the information. We also use the information to provide, maintain, protect and improve the services we offer as well as to develop new services, to keep our system running effectively and to protect Sparkler and our users.
We will never sell information provided by, or about, our customers or partners to anyone.
We may use the name you provide for your Sparkler profile across all of the services we offer that require a Sparkler account. In addition, we may replace past names associated with your Sparkler account so that you are represented consistently across all our services. If other users already have your email, or other information that identifies you, we may show them your publicly visible Sparkler profile information, such as your name and photo. When you contact Sparkler, we may keep a record of your communication to help solve any issues you might be facing. We may use your email address to inform you about our services, such as letting you know about upcoming changes or improvements, or in the case of urgent updates.
We use information collected from cookies and other technologies, like pixel tags and web page events, to improve your user experience and the overall quality of our services. For example, we may track a website you visit and some information about what you do on that website, with your permission or the permission of your school or the organization providing Sparkler to you. We may combine personal information from one service with information, including personal information, from other Sparkler services – for example to improve our ability to provide relevant services to you.
Transparency and choice
People have different privacy concerns. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. In some cases your information may be managed by a third party such as a school, healthcare provider, or community organization. In those cases, your control over the use of your data at Sparkler may be the responsibility of that third party. We will always do our best to help you work with that third party to manage your information. In all cases where it applies, we will follow FERPA and other privacy and data use regulations.
Information we share
We do not share personal information with companies, organizations and individuals outside of Sparkler unless one of the following circumstances applies:
With your consent
We will share personal information with companies, organizations or individuals outside of Sparkler when we have your consent to do so. We require opt-in consent for the sharing of any sensitive personal information.
With partner administrators
With partner administrator authorized recipients
In some cases, partner administrators will authorize other parties to view or interact with your information, usually to improve the services you receive related to the information. For example, a partner administrator may make your data available to your teacher, so they can help you learn, or they may ask us to make your data available within an authorized Learning Management System.
For external processing
For legal reasons
We will share personal information with companies, organizations or individuals outside of Sparkler if we have a good faith belief that access, use, preservation or disclosure of the information is reasonably necessary to: meet any applicable law, regulation, legal process or enforceable governmental request, enforce applicable Terms of Service, including investigation of potential violations, detect, prevent, or otherwise address fraud, security or technical issues, protect against harm to the rights, property or safety of Sparkler, our users, employees or the public as required or permitted by law.
We work hard to protect Sparkler and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. In particular, we encrypt many of our services using SSL. We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. We restrict access to personal information to Sparkler employees, contractors and agents who need to know that information in order to process or manage it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
Compliance and cooperation with regulatory authorities