Effective Date: October 27, 2022
Updated Date: September 18, 2023
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:
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 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.”
(c) Information Third Parties Provide About You
(d) Interactions with Third-Party Platforms
2. How Do We Use the Information Collected?
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?
(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.
(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.
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?
7. What About Transfer of Information to the United States?
8. What Should Parents Know About Children?
9. Who owns Student Data when Structal is used at a Local Education Agency?
Student Data is Property of LEA
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.