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Clever’s Commitment to Your Privacy

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Effective Date: December 8, 2023

Clever is a proud signatory of the Student Data Privacy Pledge.

Clever (“Clever,” “we,” or “us”) understands that privacy is tremendously important to our online visitors to our website (“Website Visitors”), to schools who use our Service (“Schools”), and to students whose information we may access on behalf of a School (“Students”). Clever provides a platform that enables Schools to securely provision the accounts with the third-party applications that they use. As we describe below, Schools decide which data is integrated with Clever, and Schools are responsible for determining whether data is ever shared with applications through Clever. This privacy policy applies to our website https://clever.com/ and to the Clever platform (our “Service”) and describes the steps we take to protect your data.

Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms of Use.

Click on the links below to jump to each section:

  1. How We Collect and Use Information
  2. Sharing of Your Information
  3. How We Protect Your Information
  4. Your Choices About Your Information
  5. Children’s Privacy
  6. Links to Other Websites and Services
  7. How to Contact Us
  8. Jurisdiction-Specific Disclosures
  9. Changes to Our Privacy Policy

In certain jurisdictions, we are required by applicable data protection laws to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions or states. If you are a resident of the states of California, Colorado, Connecticut, Nevada, Virginia or Utah, or if you are located in the European Economic Area, Switzerland or the United Kingdom, Canada or Australia, please click on Jurisdiction-Specific Disclosures for additional disclosures that may be applicable to you.

We strive to be transparent in our data collection and use practices. This is the type of personal information we may collect. Student Data is used only for educational purposes at the direction of the School.

1. HOW WE COLLECT AND USE INFORMATION

We collect the following types of information:

Information about Schools:  We ask for certain information when a School administrator registers a School with Clever, or if the administrator corresponds with us online, including a name, school name, school district, school email address and/or account name and password, phone number, message content, and information relating to the School’s information systems. We may also retain information provided by a School if the School sends us a message via email, online chat, telephone, teleconference or in person, posts content to our website or through our Service, or responds to emails or surveys. Once a School begins using the Clever Service, we will collect content and information provided by the School through the School’s use of the Service and we will keep records of activities related to the Service. We use this information to operate, maintain, and provide the features and functionality of the Service, to analyze and improve our Service offerings and functionality, and to communicate with our Schools and Website Visitors.

If a School uses Clever IDM, Clever will also access user data from the School’s identity provider to create, update, and archive user accounts in selected identity providers. This may include updates to account fields and an account’s membership in organizational units and groups. If the School sets up Google Workspace as a destination in Clever IDM, Clever’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Student Data: Through the course of providing its Service to a School, Clever may have access to personally identifiable information about students (“Student Data“) that is provided by the School, by the parent or guardian, or by the Student. Depending on the features and functionality of the Service selected by the School, a School may authorize Clever to receive Student Data from the learning application(s) provided by third-party developers that are used by the School. Clever has access to Student Data only as requested by the School and only for the purposes of performing Services on the School’s behalf. The type of Student Data we collect will depend on how the School uses the Service and the learning applications which the School connects through the Service. In many instances, Clever receives Student Data only from the School or its designated third parties and never interacts with the Student directly. In some instances, depending on the level of Clever’s Service selected by the School, the Schools may allow Students to log into the Clever Service to access third party applications that have been authorized by the School. In that instance, the School provides each student with login credentials and provides consent for Clever to collect personal information directly from a student who is permitted to access the Service.

Badges: As an alternative to a user name and password login, a School may choose to use the Clever Badge to authenticate Student users. The Clever Badge is a QR code provided by the School to the Student (usually in the form of a laminated card or paper print-out) which recognizes a user’s Clever account when the Badge is read by the camera on a Chromebook, laptop or other device. Clever does not collect or store any image collected by the device camera. The camera content is processed on the users’ device and Clever only receives the tokens used for authentication. You can learn more about Clever Badges here.

Student Data is used only for educational purposes at the direction of the School. 

Clever does not own or control Student Data, and collects Student Data only subject to the direction and control of the School.  We consider Student Data to be confidential and do not use such data for any purpose other than to provide the services on the School’s behalf and to maintain, support, evaluate, diagnose and develop our Services, in accordance with contractual agreements with the School. Our collection, use, and disclosure of Student Data is governed by our General Terms of Use, our Additional Terms of Use for Schools, and/or any other agreement with the School, by the provisions of the Family Educational Rights and Privacy Act (FERPA), the Children’s Online Privacy Protection Act (COPPA), and applicable state laws which relate to the collection of Student Data. If you are a Student or parent, please contact your School if you have questions about the School’s use of technology service providers like Clever.

See “How We Share Your Information“ below for more information on the limited ways in which we share School and Student Data. See “Children’s Privacy“ below for more information on how we collect and use the personal information of children under 13.

Information about Parents: 

Depending on the features and functionality selected by the School, we may collect personal information about a student’s parent or legal guardian (a “Parent”) that is provided by the School or by the Parent if the Parent creates an account to access the School’s Clever Service. Please refer to the Additional Terms of Use for Parents to learn more about how we treat Parent personal information and accounts. 

Information about Others: 

We also collect personal information from Developers and other individuals who create an account, correspond with us online or otherwise use or interact with the Clever Service, including a name, contact information and information relating to the Developer business or service. We may also retain information if the Developer sends us a message via email or online chat, posts content to our website or through our Service, or responds to emails or surveys. Once a Developer begins using the Clever Service, we will collect content and information about the Developer’s use of and interaction with the Service and we will keep records of activities related to the Service. We use this information to operate, maintain, and provide to the features and functionality of the Service, to analyze and improve our Service offerings and functionality, and to communicate with our Developers and others.

Information collected through use of the Service: 

We may collect information you provide or upload to the Service as well as activity and actions within our Service. For example, we collect information from files that you upload or content you post to the Service (such as in a classroom dashboard), messages you send or receive through the Service, and content you post such as in product reviews or comments. If you are a Developer, we will also collect information you make available to us when developing an Application via the Service.

Information collected through technology: 

Like most websites and online services, we and our third-party partners automatically collect information you provide to us and information about how you access and use the Services and information about the device you use to access the Services. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, file information and similar technology (collectively, “tracking technologies”) and we may use third-party partners or technologies to collect this information. For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device, or your account, and other such information. We also collect information about the way you use our Service, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, the information you enter when you interact with the Service or engage in chat features through our Service, how frequently you access the Service, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, and other actions you take on the Service. When you access our Service from a mobile device, we may collect unique identification numbers associated with your device or our mobile application, mobile carrier, device type, model, and manufacturer, and mobile device operating system. We may be able to determine your approximate location by analyzing other information, like an IP address to associate a user with their School. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service.

All of the information collected automatically through these tools allows us to improve your user experience, monitor and improve the Service and improve the effectiveness of our Service, communications features and customer service functionality. For example, we may use the data collected through cookies to: (a) remember information so that a user will not have to re-enter it during subsequent visits; (b) provide custom, personalized content and information; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our Service; (e) monitor aggregate metrics such as total number of visitors, traffic, and usage on our website and our Service; (f) diagnose or fix technology problems; (g) help users efficiently access information after signing in; and (h) otherwise to plan for and enhance our Service. On certain portions of our website, we and our third party partners may also collect device and usage data for purposes of tracking adult visitors to our websites and for other targeted advertising, attribution, research and analytics purposes. While we may permit third party advertising partners to collect information from visitors to adult-directed pages of our site (such as the support pages), we do not permit third party advertising networks to collect information about authenticated users our Service for the purpose of serving targeted advertising and we will never use Student Data for targeted advertising. 

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it. 

For more information about the types of tracking technologies we use and how you can control them, please see our Cookie Notice.

Student privacy is very important to us. Student Data is only shared in limited circumstances – and never shared with or sold to third parties for marketing purposes.

2. HOW WE SHARE YOUR INFORMATION

Clever only shares personal information in a few limited circumstances, described below. We do not rent or sell information for marketing purposes and we will never share or sell Student Data with third parties for marketing purposes

Who we may share information with:

In the event of a change of control: If we sell, divest or transfer our business, we will not transfer personal information of our customers unless the new owner intends to maintain and provide the Service as a going concern, and provided that the new owner has agreed to data privacy standards no less stringent than our own. In such case we will provide you with notice and an opportunity to opt-out of the transfer of personally identifiable Student Data.

How Student Data is shared: Other than the disclosures described above, Clever does not disclose Student Data other than as authorized and permitted by the School. The Clever Service may facilitate the School’s sharing of Student Data with third parties. For example, some elements of our Service enable Schools to interact or communicate with parents, students, teachers and to share Student Data with designated third-party applications for the benefit of the student’s education. Clever does not facilitate the sharing of any Student Data with third parties on the Service except on behalf of the School after the School has authorized a third party or application to access Student Data through the Service. Please remember that this Privacy Policy applies to the Clever Services, and not to other services or third-party applications, which have their own privacy policies. Schools should carefully read the privacy practices of each third-party application before agreeing to share Student Data with the third-party application through the Service.

We take strong measures to keep data safe and secure.

3. HOW WE PROTECT YOUR INFORMATION

Storage and processing: Any information collected through the Service from US residents is stored in the United States. Clever maintains strict administrative, technical, and physical procedures to protect information stored in our servers, which are located in the United States. Access to information is limited (through user/password credentials and two factor authentication) to those employees who require it to perform their job functions. We use industry-standard Secure Socket Layer (SSL) encryption technology to safeguard the account registration process and sign-up information. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to buildings and files. You can learn more about our comprehensive security program by reviewing the Clever Security Practices.

Unauthorized disclosure: If there is any disclosure or access to any personally identifiable Student Data by an unauthorized party that compromises the security, confidentiality, or integrity of the Student Data, we will promptly notify the affected School(s) and will use reasonable efforts to cooperate with their investigation of the incident.

Questions about data? Here are your options.

4. YOUR CHOICES ABOUT YOUR INFORMATION

Account information and settings: Schools may update account information and modify Services by signing into the administrator account. Schools and other Website Visitors can opt-out of receiving promotional email from us by clicking on the “unsubscribe” feature at the bottom of each email. Sorry, you cannot unsubscribe from Service-related messaging.

If you have any questions about reviewing or modifying account information, contact us directly by visiting our Help Center.

Access to Student Data: Student Data is provided and controlled by the Schools. If you have any questions about reviewing, modifying, or deleting personal information of a student, please contact your School directly.

How long we keep User Content: Following termination or deactivation of a School account, Clever may retain School profile information and content for a commercially reasonable time for backup, archival, or audit purposes, but any and all Student Data associated with the School will be deleted promptly. We may maintain de-identified or aggregated data, including usage data, for analytics purposes. We also may not be able to delete information that was previously shared with other users (such as through messages) or information previously shared with third-party applications. If you have any questions about data retention or deletion, please contact us by visiting our Help Center.

We do not collect any information from students without consent.

5. CHILDREN’S PRIVACY

Clever does not knowingly collect any information from children under the age of 13 (or the applicable age of consent in local jurisdictions) unless and until the School has authorized us to collect such information through the provision of the Service to Students on the School’s behalf. Because Clever collects and uses Student Data at the direction of and under the control of a School, Clever relies on each School to provide appropriate notice to parents of the School’s use of third party service providers such as Clever, and for the Schools to provide consent and authorization for Clever to collect personal information from children under 13, as permitted by the Children’s Online Privacy Protection Act (COPPA) and other applicable data protection laws. All personal information collected from or about a child under 13 is “Student Data” because when Clever collects personal information from a child on behalf of a School, the information is considered part of that child’s educational record and is under the direct control of the School.

Personal information collected from children

We intentionally limit the collection of personal information from children to only what is needed to provide the Service. Most of the children’s personal information collected by Clever is provided by the authorized School adult users, either manually or through an integration with School information systems, and is not collected directly from the children themselves. The type of personal information Clever collects from children depends on how the School uses the Service and the learning application the School connects through the Service. When the School allows its Students to log into the Clever Service to access third party applications that have been authorized by the School, Clever may collect: login credentials, authentication events, usage information about the child’s use of the Service and activities, such as login timestamps, logs of third-party application access, content or messages sent or received through the Service, information about the child’s interaction with third party Developers authorized by the School, and similar information. We also collect information about the browser or device used by the child to access the Service, including an IP address or other unique identifier. We may link or combine this information with personal information we receive about the Student from the School.

How we use and disclose personal information collected from children

We collect, use and disclose personal information from a Student under 13 for the use and benefit of the School and for no other commercial purpose. 

Clever only shares personal information collected from or about a Student under 13 in a few limited circumstances, described below. We do not rent or sell information for marketing purposes and we will never share or sell a child’s personal information with third parties for marketing purposes.

Accessing or Deleting a Child’s Personal Information 

Upon written request, we will provide the School the opportunity to access and review the personal information collected from their students. At any time, a School can refuse to permit any further collection of a child’s personal information and/or request to delete a child’s personal information. If you are a Parent and you have questions about the personal information collected by Clever, please discuss your questions with your child’s School. 

Please contact us at trust@clever.com if you believe we have inadvertently collected personal information of a child without proper consent so that we may delete such data as soon as possible. 

6. LINKS TO OTHER WEB SITES AND SERVICES

We are not responsible for the practices employed by websites, applications or services linked to or from our Service. We recommend that the School review the privacy policies of other applications before authorizing a third party to access data through the Service.

7. HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Service, we recommend contacting us by visiting our Help Center.

Additionally, Clever can be reached:

If you are not satisfied with our response, you can contact the iKeepSafe Safe Harbor Program’s dedicated consumer complaint department at: coppaprivacy@ikeepsafe.org

If a Student contacts Clever with a question about our Service, we will collect personal information from that Student only as necessary to respond to the Student’s request and direct the Student to contact the Student’s School, and we will then delete or anonymize the personal data of the Student after providing our response.

8. JURISDICTION-SPECIFIC DISCLOSURES

We may be required by law to provide additional privacy disclosures, depending on the jurisdiction in which you reside. Please refer below for disclosures that may be applicable to you:

9. CHANGES TO OUR PRIVACY POLICY

Clever may modify or update this Privacy Policy from time to time so you should review this page periodically. Click here to see all changes to this Privacy Policy. If we change the policy in a material manner, for example, if we seek to use personal information in a materially different way than we had previously, we will provide at least 30 days’ notice. Of course, you can always opt-out by deleting your account before the changes take effect.