IQClub School Privacy Policy

Student privacy is integral to our core mission and operations. We adhere to these principles in managing Student Data:

• Student Data is used solely for the authorized purposes as stipulated by the school or consented by the parent/student.

• Our School Privacy Policy and the IQClub School product are structured to comply with COPPA, FERPA, and individual state student privacy laws including SOPIPA.

• Student Data is never utilized or disclosed for targeted advertising or any marketing aims.

• IQClub does not display third-party advertisements to students.

• We avoid creating personal profiles of students unless needed for educational support or expressly permitted by the parent.

• We maintain that schools should manage the Student Data under their control.

• Student Data is not retained beyond the necessary duration required to fulfill educational objectives, unless retention beyond this period is parentally authorized.

• Student Data is never sold or leased to external parties, barring instances of business transfers like mergers, acquisitions, bankruptcy, or asset sales.

• We implement top-tier security measures and encryption to safeguard Student Data.

• Our data policies and practices are communicated clearly and transparently.

• Material changes to our School Privacy Policy concerning the use or collection of Student Data will be disclosed prior to implementation, allowing schools to opt-out before any new practices take effect.

1. EPIC SCHOOL AND STUDENT DATA

When used by a School for educational reasons, the IQClub School product may access, gather, or receive Student Data supplied by the School, the student, or the student's parent or legal guardian, hereafter referred to as a “Parent.” The ownership and control of Student Data reside with the School and the student (or the student’s Parent).

The School Privacy Policy and the IQClub School product aim to safeguard Student Data pursuant to the requirements of relevant student data privacy laws. For instance:

The Family Educational Rights and Privacy Act (“FERPA”). Student Data that IQClub gathers may include personally identifiable information protected under FERPA. IQClub may process Student Data as a "School Official" as defined in FERPA and its accompanying regulations, under the direct supervision of the school. We commit to collaborating with our School partners to uphold compliance with the FERPA regulations, and the Protection of Pupil Rights Amendment (“PPRA”).

The Children’s Online Privacy Protection Act (“COPPA”). We do not deliberately collect personal data from children under 13 without authorization from the School to do so on behalf of the School. When IQClub School is utilized in classrooms or school settings, we depend on the School to provide the necessary consent allowing us to collect personal information from students under 13 exclusively for the benefit of the School and strictly for non-commercial purposes, as COPPA allows. Upon request, we will allow the School to review and delete any personal information gathered from their students. If you are a Parent with queries regarding your child’s interaction with IQClub School or the information gathered, please contact your child’s School.

Student Online Personal Information Privacy Act (“SOPIPA”) and similar state laws. The School owns and controls the Student Data. We do not engage in or disclose Student Data for targeted advertising nor do we compile a student profile except for educational purposes. We never sell Student Data except as part of a corporate event such as a merger, acquisition, bankruptcy, or asset sale, in which scenarios we strive to ensure the successor entity maintains the commitments of this privacy policy or we will inform you of such a sale, providing an option to delete your account before the data transfer. Parents can review and amend incorrect Student Data by reaching out to their School directly. Should an unauthorized release of Student Data occur, IQClub will immediately inform the School’s account administrator.

2. INFORMATION WE COLLECT

Our collection of data is strictly limited to what is necessary to provide the IQClub School service. There have been inquiries about whether we collect data on other topics of interest to schools. For clarity, we do not gather biometric, free or reduced lunch eligibility, health, or financial data concerning students. In delivering the IQClub School Services, we may collect the following types of information:

• Information about educators and Schools: When an educator registers an account, we collect personal information including their first and last name, email address and password, profession, country of residence, school name, and school zip code. Additionally, we collect content and information that an educator submits, such as lesson plans and notes.

• Information about students: Students cannot independently create accounts on IQClub School; they must be added to a classroom by an educator or school administrator. Educators provide details about students in their classroom, such as first and last names and learning levels. Educators may choose to submit non-identifiable usernames or identifiers instead of student names at their discretion. The educator can enable students to add their first name and last initial to their profiles. Schools may set up class rosters via Google Classroom integration and/or employ a single-sign on (SSO) system like Google Classroom for student logins instead of traditional usernames and passwords to facilitate access. Depending on the educator’s usage of the IQClub School Service, we may also gather content and information provided by the student, such as quiz responses, which might be accessible by others in the same class.

• Information about Parents: We might collect information about a student’s parent or guardian, such as names or email addresses, provided by the teacher or the parent/guardian. This data might be linked with the student’s information. Further information may be gathered if a parent sets up a Parent account (which is covered by the general IQClub Privacy Policy, not this specific policy).

• Third-Party Authentication Services: If registration occurs through an integrated platform or authentication service (like Google Accounts), IQClub receives personal information linked with the authentication service, potentially including additional data not essential for service use (like a student's full name or student ID). Such data will be considered Student Data. By utilizing an authentication service and/or allowing your students to use one to create IQClub accounts, you authorize IQ MOD to collect and store information provided by those services. You can change the information shared with us by these services or revoke access anytime through your settings with the authentication service.

• Use of Service: We collect details about how and when our Services are accessed, including usage durations, viewed content, and user activities. We track data such as the number of books a student reads, the time taken to finish each book, and insights into the student’s reading skills and interests.

• Device Information: Our third-party service providers and we capture specific information automatically from and about your device when you use our Services through mechanisms like cookies, pixel tags, or similar technologies. We gather details such as your device type, the type and version of your browser, the operating system's name and version, IP address, referral URL, and may also record a persistent identifier or unique ID that helps identify your browser, mobile device, or account. Additionally, we may collect your device’s location data, or estimate your location based on information such as your IP address. This information is collected to enhance our understanding of how our Services are used, support diagnostic and support activities, manage the Services, improve navigation, better display content, personalize your interaction with our Services, identify your computer to facilitate and secure your use of the Services, and to accumulate statistical data to continuously refine and understand the functionality of the Services, helping us address any related questions.

We do not allow third-party advertising networks to gather information about students' interactions with the IQClub School Services for the purpose of targeted advertising.

3. HOW WE USE STUDENT DATA AND PERSONAL INFORMATION

We utilize Student Data solely to deliver our Services to educational institutions and to aid in refining and advancing our offerings. More specifically, we employ the information gathered in the following ways:

• To enable educators to evaluate students' assignments, track their performance and progress, plan educational activities, and provide instructional support.

• To allow parents and guardians to access and monitor their children's assignments, and their academic performance and progress.

• To provide students with assessments and support, enable them to retrieve educational materials shared by their teachers, and facilitate the creation of their own libraries of work.

• For adaptive or customized education, which includes generating tailored learning suggestions, recommending additional educational materials or activities, and helping students track their progress and organize their completed works.

• To tailor the user experience, such as by displaying students' names on their individual profile pages or on teacher dashboards.

• For analytical purposes, in order to comprehend how our Services are utilized and their performance, thereby enabling us to enhance design and functionality. Our analysis includes aggregated data that does not single out any specific individual.

• To supply educators with various report types, like those focusing on the performance and progress of specific classes or students, and to offer recommendations for the product.

• To identify and resolve issues, troubleshoot problems, and provide ongoing maintenance and support.

• We may communicate with teachers or parents using their information, including sending them marketing communications in line with their preferences. We do not direct marketing communications at students.

4. HOW WE DISCLOSE OR SHARE STUDENT DATA AND PERSONAL INFORMATION

We share or disclose personal information when necessary to offer our Service or with the consent of the educator, School or Parent. Additionally, we disclose personal information under these scenarios:

• Within the Service, information is shared according to the Service’s features. For instance, a student's profile name (first name, last initial) may be visible to other students in the same class, along with their avatars and details about their participation in class reading activities. Educators have the option to use pseudonyms for profile names to further protect student identity.

• Student Data can be shared with authorized School users like teachers and administrators, based on the settings chosen by the School.

• Student Data may be shared with a student's Parent who links their account to the student’s account. We offer a mechanism through which a Parent can transfer or save Student Data to a personal Parent account when no longer required for educational purposes. The Service may also facilitate limited communication between users, such as messages from educators to students in their class or communications from parents to their children. However, students are restricted from contacting individuals outside of their class other than their Parent.

• We do not use, disclose, sell, or rent Student Data to third parties for targeted advertising, marketing or any commercial purposes.

• We share information with reliable third-party service providers who perform services on our behalf, such as website hosting and customer support services.

• We may disclose information in case of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of our business, assets or stock, including bankruptcy or similar situations. If our business undergoes a change in ownership, Student Data will only be transferred if the new owner adheres to equivalent or stricter data privacy standards as ours, or if Schools are notified and given the chance to opt-out by deleting the Student Data before its transfer.

• We may use and disclose information when we deem it necessary or appropriate: (a) under applicable law, even those outside your country of residence; (b) to comply with legal proceedings; (c) to respond to requests from public and government officials, including those outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of our affiliates; (f) to safeguard our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to pursue available remedies or limit damages we may sustain.

We are permitted to use and disclose information that does not directly identify an individual for any purpose, unless restricted by law.

5. THIRD-PARTY SERVICES

This Privacy Policy does not cover, nor are we liable for, the privacy, information, or other practices of third parties, including any third party that operates a website or service linked to from the Services. The presence of a link within the Services does not constitute an endorsement of the linked site or service.

6. SECURITY

We implement suitable organizational, physical, technical, and administrative safeguards to protect and maintain the integrity and security of the personal information we obtain. To secure the registration and sign-up procedure, we utilize the industry-standard Secure Socket Layer (SSL) encryption. Access to Student Data is confined to IQClub employees who need this data to fulfill their job duties. Employees who do not adhere to our privacy and confidentiality policies may face disciplinary measures, including termination. Despite these efforts, no security system is completely foolproof; thus, we cannot ensure the absolute security of your personal information or Student Data. Should there be any compromise of personal information under our control due to a security breach, we will take appropriate measures to assess the situation and comply with all relevant legal requirements. In the event of a security incident that significantly affects the security or privacy of Student Data, we will promptly inform the affected educator or School.

7. USER ACCESS

You may be entitled to access, amend, download for transfer to a comparable service, or erase any of your personal data collected by IQClub. If you wish to exercise these rights, please contact us here.

If you are a parent seeking to access, correct, alter, download, or update information pertaining to a student, please coordinate directly with the student's teacher or school.

8. RETENTION PERIOD

We do not retain Student Data longer than necessary to fulfill the educational purposes of the School unless the retention is approved by the School or a Parent. Active student user accounts linked with a School will not have their Student Data deleted or made anonymous without a directive from the School. It is the responsibility of the educator and the School to keep updated student rosters and to mark any Student Data that is no longer required for educational purposes by submitting a request for deletion. Educators and School users may submit deletion requests by contacting us at [email protected].

Upon receipt of a deletion request from a School, we will delete or anonymize Student Data within 60 days. If we do not receive such a request, we may still delete or anonymize Student Data following a period of inactivity as per our typical data retention policy.

Note: Immediate or complete data deletion may not always be possible, for instance in cases where data is held in technical support files, customer service records, backups, and other related business documents. We are not obligated to remove data that has been sufficiently de-identified or separated from personal identifiers, rendering it unable to be linked back to any specific individual. We also do not delete Student Data transferred to or stored in a personal account without a Parent's request.

9. YOUR CALIFORNIA CONSUMER PRIVACY RIGHTS

As a "School Official," when IQClub supplies the IQClub School product to Schools, we act as a service provider under the definitions of the California Consumer Privacy Act. We gather, keep, utilize, and disclose Student Data solely to assist our School clients in providing the Services, and not for any other commercial uses. If you have questions or wish to exercise your rights under California law, please contact your School directly.

10. UPDATES TO THIS PRIVACY POLICY

We may modify this Privacy Policy as necessary to align with updates to our Service and our usual procedures. The "Last Updated" date at the top of this page shows when this Privacy Policy was most recently updated. By continuing to use the Services after these modifications, you agree to the revised Privacy Policy.

We will not implement any significant changes to this Policy concerning the collection or use of Student Data without first providing notice to the school and offering an option before the Student Data is utilized in a way that significantly differs from the manner described at the time of collection.

11. CONTACT US

If you have inquiries concerning this Privacy Policy, please click here to contact us.