privacy policy

Last updated July 25, 2019

Governing Principles

Data security and user privacy is important to us. We are committed to the following principles with respect to your personal information: 

  • Spinndle does not own the content or data collected from a district, School board, School, teacher, parent or Student. Users own their content and data.

  • We do not use personal information to market or advertise to you or Students, nor do we permit third parties to do so. 

  • Spinndle does not use Student data for targeted advertising purposes.

  • Spinndle collects, stores, processes and shares Student personal information only for the purposes of providing the Service (as defined herein), or as authorized by a School, parent or guardian.

  • Spinndle will maintain a comprehensive data security program designed to protect the types of Student data maintained by Spinndle.

  • Spinndle will delete or de-identify Student personal information at the direction or request of the School, parent or guardian.

  • Spinndle will clearly and transparently disclose our data policies and practices.

  • We will not make any material changes to our Privacy Policy that relate to the collection or use of Student personal information without first giving notice to the School, parent or guardian and providing a choice before the Student personal information is used in a materially different manner than was disclosed when the information was collected.

If you have any questions about your privacy, please contact us at support@spinndle.com.

Spinndle Privacy Policy

Spinndle is provided by Spinndle Inc. This Privacy Policy outlines our practices regarding the collection, use, disclosure, and protection of personal information that is collected through our website and our mobile application(s) and associated services (collectively, the “Service”), as well as your choices regarding the collection and use of information. Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms of Service (the “Terms”). Please be sure to read this entire Privacy Policy before using or submitting information to Spinndle.

This Privacy Policy is incorporated into the Terms by reference. In addition to reviewing our Privacy Policy, you should also read and understand the Terms. Your use of the Service constitutes your agreement to be bound by the Terms and this Privacy Policy.

“You” or “your” means a User of the Service. An “Individual User” as used in this Privacy Policy may be a teacher or School administrator using the Service. Where applicable, “you” or “your” also means a School or School district/board or other educational institution otherwise known as an “Enterprise User” using the subscription Service, with whom the User is associated either as a Student, teacher, School or district/board administrator, or parent of a Student and is authorized by the Enterprise User to use the Service (an “Authorized User”). The term “User” as used herein refers to any user of the Service being an Individual User, Authorized User or Enterprise User. In this Privacy Policy, we use the term “School” to refer to the educational institution, teachers, principals, School districts/boards, School administrators and any other User acting on behalf of an educational institution, regardless of whether the User is an Individual User or an Enterprise User.

 

1. How Spinndle Collects Information

Spinndle may collect personal information from Users as described below.

A. INFORMATION ABOUT SCHOOLS

We ask for certain information when a School registers for a Spinndle account or corresponds with us online, which may include, but is not limited to, first and last name, email address, user name and password, and any additional personal information you voluntarily provide in your Spinndle profile, which could include, but is not limited to, your School name and location, what grade level and subject matter you teach, your position within the School, country, and the type of devices your Students use (collectively, “School Data”). Once the School has an account, we collect content and information provided by the School through the School’s use of the Service, which could include class rosters, parent contact information, photos, images, video and any other content the teacher or Authorized User posts to the Service. 

When a School posts content (text, messages, comments, or any other kind of content) on the Service, the information contained in the posting, including first name, last name, email address will be stored in the Service for purposes of providing the Service.

When a School logs into an existing account through their third party (e.g. Microsoft or Google) account, we may collect first and last name, email address and other information specific to that third party account to authenticate the School.

When a School provides feedback to a Student, such as replying to a post, assessing skills, or prompting learning, we store the feedback in the Service for purposes of providing the Service.

If a School provides us feedback or contacts us via email, we will collect the School’s name and email address, as well as any other content included in the email for purposes of replying to the School and improving the Service. We use this information to operate, maintain and provide the features and functionality of the Service, to analyze and improve the Service offerings and functionality, and to communicate with our Users.

B. INFORMATION ABOUT PARENTS & GUARDIANS

We ask for certain information when a parent or guardian (referred to herein as a “parent”) registers for a Spinndle account, which may include information such as first and last name, email address, profile picture, user name and password, and any additional information the parent voluntarily provides, which could include, but is not limited to the name and location of your child’s School and what your relationship is with the child (parent, grandparent, guardian, etc.). We may collect other personal information you provide to the Service, such as your email address and your child’s teacher’s name and email address if you request that we invite the teacher to access the Service. We use this information to operate, maintain and provide the features and functionality of the Service, to analyze and improve the Service, and to communicate with you.

C. INFORMATION ABOUT STUDENTS

Spinndle provides the Service to Schools to properly document and assess 21st century learning. Through the provision of the Service to a School or parent, we may collect or have access to personal information about Students (“Student Data”) that is provided by the School, parent or by the Student. The type of information we collect will depend on how the School, parent or Student uses the Service, but could include the Student’s first and last name, email address, class assignment data, and other classroom content. When a Student posts content (text, images, photographs, videos, messages, comments, links, or any other kind of content) using the Service, the information contained in the posting, including first name, last name, email address, and any audio and image included within any video will be stored in the Service as per the consent provided by the respective Quest Owner(s). Other Users may view Student content. If a Student provides us with feedback or contacts us via email, we will collect the Student's name and email address, as well as any other content included in the email, for purposes of replying to the Student and improving the Service.

We consider Student Data to be highly confidential and use this data solely to provide the Services to the School and to the parent, and in limited ways, for our internal purposes in accordance with the Terms or specific agreements with Schools. Our collection, use, and disclosure of Student Data is governed by the Terms, any other agreement with the School, and by applicable Canadian, U.S. and international laws relating to the collection and use of personal information of Students. If you have any questions about our collection and use of Student Data, please contact us at support@spinndle.com. If you have any questions about reviewing, modifying, or deleting the personal information of a Student, please contact your School directly.

 

D. INFORMATION WE COLLECT FROM THIRD PARTY SERVICES AND SOCIAL MEDIA SITES

We may collect information about you from third party services that you connect to the Service. For example, if you use a single-sign on like Google Apps for Education, to access your Spinndle account, we may receive certain information from that third party application. We may also receive information about you if you interact with us through various social media, for example, by following us on Twitter or liking us on Facebook. The data we receive is dependent upon your privacy settings with the social network. You should always review and, if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the Service.

E. AUTOMATICALLY COLLECTED INFORMATION

When a User uses the Service, some information may be automatically collected to help us understand how the Service is being used and how to improve the Service. For example, device type, the device identifier (UDID), the Open Device Identification Number (ODIN), date/time stamps for each visit, browser type, operating system, Internet Protocol address, Internet service provider (ISP), referring/exit pages, clickstream data, and domain name are all collected for purposes of administering, tracking usage of, and improving the Service. We may store this information.

Spinndle uses cookies (small text files placed on your device) and similar technologies to provide the Service, to help collect data, and to market to Schools. These cookies help us provide the Service. These cookies collect information about how you use the Service (e.g., the pages you view, the links you click, and other actions you take on the Service), information about your browser and online usage patterns (e.g., Internet Protocol address, browser type, browser language, referring / exit pages and URLs, pages viewed, whether you opened an email, links clicked), and information about the device(s) you use to access the Service (e.g., mobile device identifier, mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, and, depending on your mobile device settings, your geographical location data at the city, state, or country level). We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service. Although we do our best to honor the privacy preferences of our Users, we are not able to respond to “Do Not Track” signals from your browser at this time.

Cookies allow us to provide you with a better user experience. For example, we use or may use the data collected through cookies to: (i) remember information so that you will not have to re-enter it during your visit or the next time you visit the site, and (ii) provide custom, personalized content and information. Cookies also allow us to analyze, improve and protect the Service and our Users. For example, we may also use Cookies to: (a) provide and monitor the effectiveness of the Service; (b) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website and the Service; (c) diagnose or fix technology problems; (d) investigate fraud or misuse of the Service and (e) otherwise to plan for and enhance the Service. Most browsers automatically accept cookies as the default setting. Each User has a variety of tools to control cookies, web beacons, and similar technologies, including browser controls to block and delete cookies and controls from some third-party analytics service providers to opt out of data collection through web beacons and similar technologies. User browser settings and other choices may impact the functionality of the Service.

 

F. THIRD PARTY TRACKING AND ONLINE ADVERTISING: 

We may permit third-party online advertising networks to collect information from visitors to www.spinndle.com to provide customized content, advertising and commercial messaging to you from time to time on other websites or services. Typically, the information is collected through cookies or similar tracking technologies. You may be able to set your browser to reject cookies or other tracking technology by actively managing the settings on your browser or mobile device. (To learn more about cookies, clear gifs/web beacons and related technologies and how you may opt-out of some of this tracking, you may wish to visit http://youradchoices.ca/, http://www.aboutads.info/choices/ and/or the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org). Please note that although we may permit third party advertising partners to collect information on our Spinndle website for the purpose of sending targeted advertisements, we do not allow third party advertising networks to collect information about Students or parents who are logged into the Service, or to collect information from our mobile apps.

2. Use of Personal Information

Spinndle stores and processes User personal information in Canada, and we use this information as follows:

  • To provide the Service, including updating, securing, troubleshooting, and providing support.

  • To improve and develop the Service.

  • To respond to User comments and questions and provide customer service.

  • To send the User information, including confirmations, technical notices, updates, security alerts, and support and administrative messages.

  • To identify specific Users in our system.

  • To facilitate the creation and management of accounts on the Service.

  • To process and deliver orders.

  • To comply with applicable laws, including website accessibility laws that may require transcription of audio or other methods to make User content available on the Service.

  • To aggregate or anonymized data to study and improve the Service, user functionality, and product offerings.

  • For other purposes with your consent.

INFORMATION WE SHARE.

Spinndle does not sell User personal information. We share personal information we collect on Users (including Students and Schools) when Users create accounts, request support, post work, or otherwise use the Service. We may also share User personal information with vendors, consultants, and other third party service providers who need access to such information to carry out work on our behalf and at our direction. For example, we rely on data center operators and communications vendors to operate the Service or send you notifications.

We may also share User personal information for legal, protection, and safety purposes. For example,

  1. We may share information to comply with applicable laws.

  2. We may share information to respond to lawful requests and legal processes.

  3. We may share information in an emergency, such as protecting the safety of our employees and agents, our Users, or any person.

  4. We may share information to protect the rights and property of Spinndle, our agents, employees, customers, and others, including by enforcing our agreements, policies, and the Terms.

  5. We may disclose or transfer your personal information in connection with the sale, merger, bankruptcy, sale of assets or reorganization, in whole or in part, of Spinndle.

Spinndle reserves the right to share Users’ personal information to respond to duly authorized information requests of governmental authorities or where required by law. Spinndle reserves the right to use or disclose personal information provided to Spinndle  in response to a lawful request by public authorities, including to meet national security or law enforcement requirements, or if Spinndle reasonably believes that use or disclosure is necessary to protect Spinndle’s rights and/or to comply with a judicial proceeding, court order, or legal process. In exceptionally rare circumstances where national, provincial, state, or company security is at issue, Spinndle reserves the right to share our entire database of visitors and clients with appropriate government authorities. If we are going to share User personal information, we strive to provide the User with advance notice by e-mail unless prohibited by law from doing so.

 

3. Communications

As part of the Service, we may use your information to communicate with you about your account or transactions with us, or send you information about Service updates, newsletters, or promotional materials. You acknowledge that by using the Service, Spinndle and our trusted third party business partners working on our behalf may send you email or engage in other communications with you. You can unsubscribe from these emails by clicking on the “unsubscribe” button within the body of the email. Please note that you are not permitted to unsubscribe or opt-out of non-promotional messages regarding your account, such as account verification, changes or updates to features of the Service, or technical or security notices.

When you provide an email address to invite a School, Student, parent or other contact to join the Service, we will use this information to send the invitation, and we may send 1-2 reminder emails if we have not received a response. From time to time, we may also send these individuals email communications letting them know more about Spinndle and the Service. The recipients may unsubscribe from these emails by clicking on the “unsubscribe” button within the body of the email at any time or by contacting us at support@spinndle.com.

COMMUNICATIONS WITH STUDENTS

We use Student Data to facilitate the sending of communications via the Service from the School, Student, and parent. We send these communications only on behalf of, and at the direction of the School or parent. In limited circumstances, we may also send the Student notifications from Spinndle regarding the Student’s account and use of the Service, but Spinndle will never use Student Data for advertising or marketing purposes without consent. Please note that all Users who have been authorized to have access to a Student’s account, which could include a parent, School administrator, teacher and/or other User, may be able to view activity and content associated with such Student account, including the content of communications.

4. Links to Other Websites

The Service and our email communications may contain links to other websites or services. Any personal information you provide on the linked pages is provided directly to that third party and is subject to that third party’s privacy policy. Except as described above, we are not responsible for the content or privacy and security practices and policies of websites to which we link. Links from the Service to third parties or to other sites are provided for your convenience. We encourage you to learn about their privacy and security practices and policies before providing them with personal information.

5. Information Security and Data Storage Practices

Spinndle cares about the security of your personal information and uses commercially reasonable physical, administrative and technological safeguards to preserve the integrity and security of all information we collect and that we share with the service providers. Our employees and contractors are bound to uphold the provisions in this Privacy Policy, and violators will be subject to disciplinary action, up to and including termination and further legal action. We maintain physical, electronic, and procedural safeguards that are designed to protect our Users’ personal information. We use internet security best practices to transfer personal information. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to buildings and files. You can help protect against unauthorized access to your account limiting access to your computer and browser by signing off after you have finished accessing your account.  In the event of an unauthorized release, disclosure, or acquisition of User information, Spinndle will notify affected individuals (either directly or through Schools), as required by applicable law. While we use reasonable efforts to protect your personal information, we cannot guarantee its absolute security.

By using the Service, you consent to the transfer of your personal information to Canada in accordance with this Privacy Policy. You understand that your personal information will be subject to the laws of Canada, which may be different from those of your country of residence.

We store and process your personal information in compliance with applicable laws and regulations.

NOTICE TO PARENTS AND SCHOOLS

Under applicable laws and regulations in certain jurisdictions, verifiable parental consent is needed to collect, use, or disclose personal information (e.g., full name and email address) from each User under 13 years old. In accordance with such applicable laws and regulations, a School or Quest Owner may act as the agent of the parent or legal guardian of a Student and provide consent on behalf of the parent for Spinndle’s collection, use, and disclosure of the Student’s personal information. By enrolling a Student under 13 to use the Service, the School provides such consent to us and agrees that the Students’ activities while on the Service are subject to the Terms. Please see Spinndle’s Parent Consent Form for guidelines on how teachers and students should provide consent on behalf of parents. 

This Privacy Policy does not govern any School's collection, use, or disclosure of a Student User’s personal information through the Service, and we are not responsible for any such collection, use, or disclosure. Parents should contact the School or Quest Owner directly to understand the Quest Owner’s privacy practices or to request to access, change or delete information collected by the Quest Owner in connection with the Service that cannot otherwise be accessed, changed or deleted as described in this Privacy Policy.

As required under applicable laws and regulations in certain jurisdictions, parents may make certain choices regarding how their child’s information is used. (For more information, see “Parent’s Choices Regarding Information on Students Under 13” below). Parents should submit these requests to the School or Quest Owners, and the teacher or School Quest Owners, as the parent’s agent, must pass those requests to us by emailing support@spinndl.com.

PARENT’S CHOICES REGARDING INFORMATION ON STUDENTS UNDER 13

Under applicable laws and regulations in certain jurisdictions, parents of Students under the age of 13 years have certain rights with respect to our collection, use, retention, and disclosure of their Student’s information. This includes the right to review, update, or delete Student information, as well as prohibit our sharing Student information with third parties. Parents can exercise these rights by contacting the respective Quest Owner, and the Quest Owner should submit these requests, on the parent’s behalf, to Spinndle by emailing support@spinndle.com. Notwithstanding any such requests, we may continue to share the Student information for non-Service purposes as described in the section titled “Information We Share.”

A parent should request deletion of the Student’s information (such as videos submitted) through the Quest Owner. Upon receiving such requests, the Quest Owner can request deletion of the Student’s information by emailing support@spinndle.com. This will delete the Student information from our live databases. We will not have any liability whatsoever for any termination of the account or related deletion of the Student information. When we delete personal information, it will be deleted from our active databases but may remain in our archives for up to 30 days.

Schools and Quest Owners should always obtain parental consent for a Student under 13 to use the Service. Please see Spinndle’s Parent Consent Form for tips to obtain proper consent from parents. 

 

6. Control, Access, and Deletion of Personal Information

You may access, update or correct your personal information at any time by logging into your account. If you are a School, you may access, update and correct the personal information contained in any account under your control by logging into your account, and/or by logging into your School Student Information Management System. Parents may request to access, correct and update a Student’s personal information, but these requests may require the School’s authorization to update or delete information contained in active School accounts.

We retain your personal information, including Spinndle content, for as long as the account is covered by an active subscription or license as described in the Terms, or until we receive a request to delete such information.

When a Spinndle profile is no longer in active use by a School, the profile will be archived in “read-only” format. Archived profiles are maintained to provide parents indefinite access to the Student’s work, and parents and Students can access such data at any time. Spinndle maintains this information only for the benefit of the parent and Student. Spinndle may continue to send email communications to the parent and Student until we receive an unsubscribe request or until the account has been deleted. If the account is no longer covered by a School license, Spinndle will delete archived accounts, including the personal information and User Content associated with such accounts, after a period of dormancy.

To delete an archived account, please contact us at support@spinndle.com. Spinndle will promptly delete or de-identify account data within thirty (30) days of such request or instruction, though we may retain and use certain information if necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, and all information stored in our backup data repository will be deleted pursuant to our standard deletion policy. We may maintain aggregate or de-identified data in a form that does not reasonably identify a particular individual, for our internal use or analytic purposes.

7. Users from the European Union

The European Union’s General Data Protection Regulation (GDPR) and other data protection laws grant you certain rights in relation to your personal information. Where applicable to you, you can:

  1. request access to your personal information and how we process it;

  2. request correction of the personal information that we hold about you;

  3. ask us to delete your personal information;

  4. object to us processing your personal information;

  5. request the restriction (temporarily or permanently) of processing of your personal information;

  6. request the transfer of your personal information to you or to a third party; and

  7. withdraw consent at any time where we are relying on consent to process your personal information.

Note that withdrawing your consent to our processing of your information will not affect the lawfulness of any processing carried out before you withdraw your consent. You should also be aware that if you do withdraw your consent, we may not be able to provide certain services to you. Where this is the case, we will let you know at the time you withdraw your consent. Please note that even after you have withdrawn your consent we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.

8. Children’s Privacy

Spinndle does not knowingly collect personal information through the Service from a child under the age of 13 unless and until a School has appropriate consent and authorization from a parent for a Student under the age of 13 to use the Service and for Spinndle to collect information from such Student. Please contact us at support@spinndle.com if you believe we have inadvertently collected personal information from a child under the age of 13 without proper consent so that we may delete such information as soon as possible.

9. Service Development

The Service is under continuous development and testing. The Service may contain bugs and other errors that could adversely affect the use or performance of the Service. Issues or errors of this nature may impact our ability to comply with this Privacy Policy.

10. Our Privacy Policy Will Change Over Time

Because we continue to develop the Service, take advantage of technologies to improve the services we provide, and monitor changes to applicable laws and regulations in respect of privacy and the collection, use and storage of personal information, this Privacy Policy will change over time. We will note the effective date of this Privacy Policy at the top of this page, and you should review this page periodically for any changes. If we make any material changes in the way we use personal information, we will attempt to notify registered Users by sending an email to the User’s registered email address and posting a notice on our website homepage and login page. It is your responsibility to check for updates to this Privacy Policy and to delete your account if you do not agree to such changes, as any such update shall be effective even if you do not receive notice of such update. Your continued access and use of the Service will constitute your acceptance of any changes or revisions to this Privacy Policy.

 

PRIVACY POLICY CHANGES WITH RESPECT TO STUDENT DATA

We will use commercially reasonable best efforts to provide at least 30 days-notice of a Privacy Policy change that may involve collecting, using, storing, or sharing Student Data in a materially different way than was disclosed in a previous version of this Privacy Policy, so that you have sufficient time to evaluate the change in practice. If you do not choose to accept the changes, you may opt-out by deleting your account before the changes take effect. You may request previous versions of this Privacy Policy by contacting us at support@spinndle.com.

11. Your Comments or Concerns

We welcome your feedback. If you have any comments or concerns about this Privacy Policy or would like to contact us for any reason, you may reach us at support@spinndle.com.