Structal Privacy Policy
Effective Date: October 27, 2022
Updated Date: September 18, 2023
The Structal platform and the Structal web browser extension software is owned and operated by Structal, LLC (“Structal”). Structal takes your privacy seriously and this document represents its commitment to transparency about its collection of, use of, disclosure of and efforts to safeguard your personally identifiable information and software usage information. Our collection, use, and sharing of student Personal Information (defined below) is governed by the provisions of the Family Educational Rights and Privacy Act (“FERPA”), the Children’s Online Privacy Protection Act (“COPPA”), and other applicable laws that relate to the collection and use of Personal Information of students. This Privacy Policy, taken together with our Children’s Privacy Policy is compliant with both COPPA and FERPA.
Throughout this Privacy Policy the words “we”, “us” and “our” refer to Structal, and the words “you” and “your” refer to the user (such as a student that you are responsible for as a teacher or your child or a minor under your guardianship) visiting the Structal platform or using the web browser extension software (the platform, the web browser extension software and any associated mobile application collectively are referred to in this Policy as the “Application”). This Privacy Policy applies to information that we collect at or through the Application and our handling of such information. Please review the Application’s User Agreement terms, which govern your use of the Application.
By accessing and using the Application, you consent to our collection, use and sharing of your and your child’s information and data, and other activities, as described below.
1. What Information Does the Application Collect?
(a) Information You Provide to Us
Personal Information.We may ask you, your child or a minor under your guardianship to provide us with, or you might submit via the Application, personally identifiable information, which is information that identifies an individual personally, such as one’s first and last name and e-mail address (“Personal Information”). We may collect this Personal Information through various forms and in various places on the Application, including account registration forms, “contact us forms”, or when you otherwise upload data to and interact with the Application. Structal will only collect Personal Information necessary to fulfill its duties as outlined in its agreement with the student’s teacher or school district.
(b) Information Collected or Stored As You Access and Use the Application
In addition to any Personal Information or other information that you choose to submit to us via the Application, we use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Application (“Usage Information”). Our third-party service providers may also collect Usage Information via automated means. This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Application. That primarily, but not exclusively, entails Usage Information collected via Structal’s web browser extension software to enable [the artificial intelligence learning features that support learning]. While the web browser extension software downloaded and associated with your web browser is activated, we have direct visibility into all of the content that you access via your web browser that you give us access to, which all falls under the category of Usage Information. Another example are cookies to support login. To the extent we associate Usage Information with Personal Information that we collect directly from you on the Application, we will treat it as Personal Information.
Usage Information may include:
- your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Platform, and our servers identify your Device by its Device Identifier;
- your Device functionality (including browser, operating system, hardware, mobile network information);
- the URL that referred you to our Application;
- the areas within our Application that you visit and your activities there, including remembering you and your preferences. Another example are cookies to support login;
- your Device location;
- your Device characteristics; and
- certain other Device data, including the time of day, among other information.
Tracking Technologies. We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):
Cookies. A cookie is a data file placed on a Device when it is used to visit the Application. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our Application’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Platform, to monitor how users navigate the Application, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Application, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third-party service provider, is active only while you are connected to the Application, and is deactivated or deleted thereafter.
Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
ETag, or Entity Tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.
Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices in the same user).
Tracking Technologies Usage. We may use Tracking Technologies for a variety of purposes, including:
Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Application, including cookies required to prevent fraudulent activity and improve security.
Performance Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Application, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Application.
Functionality Related. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Application, including identifying you when you signin to our Application or keeping track of our specified preferences, including in terms of the presentation of content on our Application.
Targeting Related. We may use Tracking Technologies to deliver content relevant to your interests on our Application based on how you interact with our content. This includes using Tracking Technologies to understand the usefulness to you of the content that has been delivered to you.
Tracking Technologies Choices and Consent.
We obtain your consent to our information storage or collection Tracking Technologies by providing you with transparent information in our Privacy Policy and providing you with the opportunity to make a choice to disable cookies as set forth above. Please note that we are not required to obtain your consent to the information collection Tracking Technologies identified above that are strictly necessary.
We are giving you detailed notice of the Tracking Technologies and your limited choices regarding them so that your consent is meaningfully informed.
Third Party Tracking and “Do Not Track.”
There may be other Tracking Technologies now and later devised and used by us in connection with the Application. Further, third parties may use Tracking Technologies in connection with our Application, which may include the collection of information about your online activities over time and across third-party websites or online services. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third-party Tracking Technologies in connection with use of our Application and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties. Also, various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.
(c) Information Third Parties Provide About You
We may, from time to time, supplement the information we collect directly from you on the Application with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you. To the extent we combine information we receive from those sources with your Personal Information we collect on the Application, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information, unless we have disclosed otherwise. In no other circumstances do our statements under this Privacy Policy apply to information we receive about you from third parties, even if they have used our technology to collect it and share it with us.
(d) Interactions with Third-Party Platforms
The Application may include functionality that allows certain kinds of interactions between the Application and a third-party website or application. The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us. For example, when you register with the Platform, you may have an option to use your Facebook, Google or other account provided by a third-party site or application to facilitate the registration and log-in or transaction process on the Application, or otherwise link accounts. If we offer and you choose to use this functionality to access or use our Application, the third-party site or application may send Personal Information about you to us. If so, we will then treat it as Personal Information under this Privacy Policy, since we are collecting it as a result of your accessing of and interaction on our Application. In addition, we may provide third-party sites’ interfaces or links on the Application to facilitate your sending a communication from the Application. For example, we may use third parties to facilitate emails, tweets or Facebook postings. These third parties may retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy. Structal may not control or have access to your communications through these third parties. Further, when you use third-party websites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party tools on our Application.]
2. How Do We Use the Information Collected?
Generally. We may use your Personal Information or Usage Information that we collect about you: (1) to provide the literacy support services that are core to Structal’s product and mission; (2) to provide you with information or services or to process transactions that you have requested or agreed to receive; (3) to provide you with information via email about new Structal product or service offerings on an ongoing basis, unless you opt out of receiving such emails; (4) to enable you to participate in a variety of the Application’s features; (5) to process your account inquiry, including verifying your information is active and valid; (6) to improve the Application, to create new service offerings, to customize your experience on the Application, or to serve you specific content that is most relevant to you; (7) to contact you with regard to your use of any of the Application and, in our discretion, changes to the Application and/or any of the Application’s policies; (8) for internal business purposes; and (9) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.
Contact Us. Please note that information submitted to the Application via a “contact us” or other similar customer inquiry function may not receive a response.
3. How and When Do We Share Information with Third Parties?
We will not share Personal Information with third parties for direct marketing purposes. We may, however, share non-Personal Information, such as aggregated user statistics and browsing behavior information, with third parties. We may share the information we have collected, including Personal Information, as disclosed at the time you provide the information and as described below or otherwise in this Privacy Policy. Structal may also disclose Personal Information as follows:
(a) Third Parties Providing Services on Our Behalf. We may use third-party vendors to perform certain services on behalf of us or the Application, such as hosting the Application, designing and/or operating the Application’s features, tracking the Application’s activities and analytics, and enabling us to send you special offers or performing other administrative services. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to Personal Information. We are not responsible for those third-party technologies or activities arising out of them, nor are we responsible for the effectiveness of or compliance with any third parties’ opt-out options.
(b) To Protect the Rights of Structal and Others. To the fullest extent permitted by applicable law, we may also disclose Personal Information if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of Structal or third parties (including through the enforcement of this Privacy Policy, our Terms of Use, the User Agreement or other applicable agreements and policies); or (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders). To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, all without notice to you.
(c) Affiliates and Business Transfer. We may share Personal Information with our parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Application or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.
4. What About Information I Disclose Publicly or to Others?
User-Generated Content and Public Information. The Application also permits you to submit various types of content that might include Personal Information (collectively, “User Content”). We may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed) and may or may not attribute it to you.
Others may have access to this User Content and may have the ability to share it with third parties. For example, if you upload images to the Application, you should consider avoiding uploading images with embedded location data (EXIF GPS) included. Other users of the Application can download and extract any location data from images posted on the Application. Please think carefully before deciding what information you share, including Personal Information, in connection with your User Content. Please note that Structal does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available via the Application or what others do with information you share with them on the Application. We are not responsible for the accuracy, use or misuse of any User Content that you disclose or receive from third parties through the Application.
Your User Content is posted and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Content. Therefore, we cannot and do not guarantee that your User Content will not be viewed by unauthorized persons.
For full terms and conditions regarding User Content you submit to the App, please review the Terms of Use.
5. Does Third-Party Content or Links To Third-Party Platforms Appear on the Application?
The Application may contain content that is supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Application are served to you. In addition, when you are on the Application you may be directed to other services that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. For example, if you “click” on a link, the “click” may take you off the Application onto a different site. These other sites may associate their Tracking Technologies with you, independently collect data about you or others, including Personal Information, and may or may not have their own published privacy policies. We encourage you to note when you leave our Application and to review the third-party privacy policies of all third-party websites and exercise caution in connection with them.
6. How Do I Change My Information and Communications Preferences?
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. The Application may allow you to review, correct or update Personal Information you have provided through the Application’s registration forms or otherwise, and you may provide registration updates and changes by contacting us. If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Under the Children’s Online Privacy Protection Act, parents have a right to review or have deleted the child’s personal information. Structal shall take all commercially reasonable steps to comply with such requests (including from teachers). Please note, however, that it is not always possible to completely remove or delete all student information from our databases and that residual data may remain on backup media or for other reasons. When you edit your Personal Information or change your preferences on the Application, information that you remove may persist internally for Structal’s administrative purposes. Teachers or school districts may cancel or modify our e-mail marketing communications they receive from us by following the instructions contained within our promotional e-mails or in some cases by logging into your Application account and changing your communication preferences. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of e-mails the opt-out will be so limited. Please note that we reserve the right to send you certain communications relating to your account or use of our Application, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications. If you have any questions about the Privacy Policy or practices described in it, you should contact us in the following ways: Postal Mail: Attention: Privacy Officer, Structal, LLC, 155 Seaport Blvd., Boston, MA 02210.; By e-mail: admin@structal.ai.
7. What About Transfer of Information to the United States?
Our Application is operated in the United States. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Application or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.
8. What Should Parents Know About Children?
We understand the importance of protecting children’s privacy in the interactive world. Please see our Children’s Privacy Policy for more details.
9. Who owns Student Data when Structal is used at a Local Education Agency?
Student Data
Student Data includes any data, whether gathered by Structal or provided by Local Education Agency ("LEA") or its users, students, or students’ parents/guardians, that is descriptive of the student including, but not limited to, the student’s first and last name, grade level, test results, special education data, grades, evaluations, socioeconomic information, student identifiers, search activity, or any other information or identification number that would provide information about a specific student. Student Data includes Meta Data and Usage Information. Student Data further includes “personally identifiable information (PII),” as defined in 34 C.F.R. § 99.3 and as defined under any applicable state law. Student Data shall constitute Education Records for the purposes of this privacy policy, and for the purposes of federal, state, and local laws and regulations. Student Data shall not constitute that information that has been anonymized or de-identified, or anonymous usage data regarding a student’s use of Structal’s services.
Student Data is Property of LEA
All Student Data transmitted to Structal is and will continue to be the property of and under the control of the LEA. Structal further acknowledges and agrees that all copies of such Student Data transmitted to Structal, including any modifications or additions or any portion thereof from any source, are subject to the provisions of this privacy policy in the same manner as the original Student Data. Structal and LEA agree that as between them, all rights, including all intellectual property rights in and to Student Data contemplated per the Privacy Policy, shall remain the exclusive property of the LEA. For the purposes of FERPA, Structal shall be considered a School Official, under the control and direction of the LEA as it pertains to the use of Student Data, notwithstanding the above.
Parent Access
To the extent required by law the LEA shall establish reasonable procedures by which a parent, legal guardian, or eligible student may review Student Data, correct erroneous information, and procedures for the transfer of student-generated content to a personal account, consistent with the functionality of services. Structal shall respond in a reasonably timely manner (and no later than forty five (45) days from the date of the request or pursuant to the time frame required under state law for an LEA to respond to a parent or student, whichever is sooner) to the LEA’s request for Student Data in a student’s records held by Structal to view or correct as necessary. In the event that a parent of a student or other individual contacts Structal to review any of the Student Data accessed pursuant to the Services, Structal shall refer the parent or individual to the LEA, who will follow the necessary and proper procedures regarding the requested information.
10. What About Security?
We endeavor to incorporate commercially reasonable safeguards to help protect and secure Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Application and provide us with your information at your own risk.
We align with the internationally recognized ISO 27001 security standard.
We use security technologies like HTTPS to protect Personal Information in transit.
11. What About Changes to the Privacy Policy?
We reserve the right to change this Privacy Policy at any time. If we make material changes to the policy, we will notify your primary email or the primary email of authorized account administrators in the case of minors. Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of our Application indicates your consent to the privacy policy posted at the time of use. However, we will not use your previously collected Personal Information in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.