Privacy Policy

Last updated: May 22, 2024.

This Privacy Policy explains how Transparent Classroom, INC, is committed to protecting your privacy and ensuring that you feel comfortable using our Transparent Classroom software (our “Service”). This Privacy Policy covers the Transparent Classroom website (www.transparentclassroom.com), mobile applications, web applications, and is applicable worldwide.

This policy describes our data handling practices and how we collect and use the Personal Information and other information you provide during your interactions with us and our Service. “Personal Information” means any information that can be used to individually identify a person, and may include, but is not limited to name, email address, postal or other physical address, credit or debit card number, title, and other personally identifiable information including student data, metadata, and user content. Personal Information does not include information that cannot be used to identify you, such as internet protocol (“IP”) address, browser type, internet service provider, operating system, or device type, or information that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person (collectively “De-Identified Data’’).

This Privacy Policy is a binding contract and by using our Service you agree to it. This Privacy Policy may be updated from time to time for reasons such as operational practices or regulatory changes, so we recommend that you review our Privacy Policy when returning to our website.

Consistent with the collection and uses of Personal Information described in this Privacy Policy, please know:

  1. We are deeply committed to creating a safe and secure online environment for you & your children.
  2. We do not sell your Personal Information to advertisers. Ever.
  3. We make it easy for: - Teachers to choose to share information & progress with a child’s parents; - Schools may choose to share structure (lessons, forms, etc.) with other schools; and - Teachers & staff may access the information they need to do their job.
  4. We make it hard for anyone to unknowingly share any Personal Information with anyone else.
  5. We have proudly signed and committed to the Student Privacy Pledge 2020.

1. Family Educational Rights and Privacy Act

Our Service is a compliant third-party education service provider under FERPA regulations. Any use of any Personally Identifiable Information follows all use and re-disclosure requirements under FERPA. Transparent Classroom takes reasonable precautions to safeguard student data against loss, misuse, and unauthorized access or disclosure. All student information is used solely for the purpose of which the educational institution has requested. Use of our Service does not require the waiver of any FERPA rights. Although our service is a FERPA compliant education service provider, ultimately the responsibility for protecting student data is your child’s school.

2. Collection and Use of Personal Information

In order for you to register with our Services, your child’s school must provide us with your name and email at a minimum. You may also have chosen to provide other Personal Information like a profile photo or address. If you are a school, we may also collect your payment information, mailing address, telephone number and other information about your school.

Overall we collect the following categories of Personal Information about you when you use or otherwise interact with our Services:

  • Name
  • Title
  • Email address
  • Home/work/mobile telephone number
  • Postal or other physical address
  • IP addresses and other information collected passively, as further detailed in the “Passive Collection” section below
  • Device identifiers, as further described in the “Mobile Application” section below
  • Your children’s information including names, ages, genders, schools attended, interests, their emergency contacts, pick-up contacts, information how the children should be picked up from schools or classes or camps, medical information and insurance information in the face of medical emergencies.
  • Information required by enrichment providers who provide enrichment classes or by schools which host enrichment classes
  • If you are a school, we may also collect your payment information, mailing address, telephone number and other information about your school.

3. Processing of your Personal Information

We will use your Personal Information only in accordance with our Privacy Policy. If you do not wish us to continue using your Personal Information in this manner, you can request that your account be deactivated by contacting us as at privacy@transparentclassroom.com.

We will only process your Personal Information if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity (i.e. processing that is necessary for the performance of a contract with you, such as your user agreement with us that allows us to provide you with the Services) and our “legitimate interests” or the legitimate interest of others (e.g. our users) such as:

  • Administering, personalizing, improving or operating our Services and business
  • Better understanding your needs and interests
  • Fulfilling requests you make related to the Services
  • Complying with our legal obligations, resolving disputes with users, enforcing our agreements
  • Protecting, investigating and deterring against fraudulent, harmful, unauthorized or illegal activity
  • Responding to inquiries from you or our third-party service providers

We collect and/or process your Personal Information in connection with the following activities related to our Services:

  • Account registration
  • Use and testing of certain Services features, features in development
  • Generating reports based on information collected from use of our Services
  • Requesting service and support for our Services and providing such support
  • Placing transactions or orders
  • Conducting surveys and processing information
  • Conducting research relating to our Services
  • Billing and collecting payments for our Services
  • Participating in discussion groups or forums
  • Registering for newsletter subscriptions
  • Customizing and personalizing the content and features you see
  • To keep you up to date on the latest Service announcements, updates, upgrades, system enhancements, special offers, and other information
  • To conduct audits and provide support for our Services
  • To provide the ability to create personal profile areas and view protected content
  • To meet contract or legal obligations
  • Communicating with you by email, telephone or regular mail regarding news updates, special promotional offers, our products and services, or other information which may be of interest to you. If you later wish to opt out of receiving such promotional communications from us at any time, simply follow the “Opt-Out” instructions.

If you no longer wish to receive certain communications from us, you may opt-out of receiving them by following the unsubscribe instructions included in each communication or by emailing us at info@transparentclassroom.com. However, you will not be able to opt-out of all communications, such as those legally required notices or required Service notices.

4. Sharing your Personal Information with Parents, Teachers and Administrators

Administrators within Transparent Classroom can see all the information published to and by Transparent Classroom within their school. This includes all student records across the school, parent information, and even parent browsing history within our Service. Teachers within Transparent Classroom are allowed to see all information associated with their classrooms.

The directory shows you which staff members are Administrators, and which are Teachers. It also shows you which classrooms a teacher has access to.

As a Parent, you have the right to access all Personal Information included in the items described in the following list.

Parents can see:

  • Any non-private teacher observation made about their child
  • Any non-private photo their child was tagged in
  • Their child’s progress through lessons (unless the school disables this feature)
  • All published conference reports, forms, and attendance records we keep about their child

Parents may also access theirs and their child’s Personal Information through the Transparent Classroom website. Further, you may edit and delete some of your and your child’s Personal Information we collect through the Transparent Classroom website.

Parents with children in the same classroom can see:

  • Other parents’ names and profile photos (unless school removes their children from directory)
  • Other parents’ children’s names and profile photos (unless school removes children from directory)
  • Contact information those parents have not marked private including phone, email, and address
  • Non-private observations and photos of another child IF AND ONLY IF both their child and the other child were mentioned in the same observation or tagged in the same photo.

Parents with children in the same school but different classrooms don’t have access to any of this information.

Parents and staff are not allowed to see any information associated with any parent or child from a different school.

The information one school is allowed to share with other schools is:

  • Lessons (names, descriptions, ordering and grouping)
  • Conference Report templates
  • Form templates

In order to provide excellent and timely customer support, Transparent Classroom staff have the ability to look at all the information in the system.

Generally, if you would like to further limit the use or disclosure of your Personal Information as set forth in this Section 6, or if you would like to request a copy of your accessible Personal Information, please contact privacy@transparentclassroom.com.

5. Sharing your Personal Information With Third Party Service Providers

Transparent Classroom does not sell or rent your (or your child’s) Personal Information to any third party for any purpose - including for advertising or marketing purposes. Third-party advertising is not permitted on Transparent Classroom. Furthermore, we do not share Personal Information with any third parties except in the limited circumstances described in this Privacy Policy.

We work with vendors, service providers, and other partners to help us provide our Service by performing tasks on our behalf. We may need to share or provide information (including Personal Information) to them to help them perform these business functions, for example sending emails on our behalf, database management services, database hosting, providing customer support software, and security. These service providers do not have the right to use your Personal Information we share with them beyond what is necessary to assist us. These service providers must adhere to confidentiality and security obligations in a way that is consistent with applicable law and their own terms and policies.

Transparent Classroom is responsible for the processing of Personal Information it receives in accordance with the DPA, which incorporates European Commission’s Standard Contractual Clauses, and subsequent transfers to a third party acting as an agent on our behalf. We comply with the DPA, including the Standard Contractual Clauses, for all onward transfers of Personal Information from the EU or Switzerland, including onward transfer liability provisions.

The third parties we work with to provide our Service are:

  • Amazon Web Services (AWS) for hosting Transparent Classroom’s servers and data
  • Facebook for single sign on
  • GitHub stores our source code
  • Google for single sign on, using forms with prospective schools, and sending texts to devices
  • Google Analytics for analytics on our websites
  • Heroku the platform that hosts our applications
  • Help Scout for providing customer support
  • Logentries for logging and understanding errors
  • Sentry for reporting errors
  • Rollbar for reporting errors
  • ScoutAPM for monitoring usage of our servers
  • Paypal for processing school payments
  • SendGrid for sending email updates to teachers and parents
  • Shortcut for internal communication and project management
  • Slack for internal communication
  • Stripe for storing payment information and processing payments

If you would like to opt out of third-party tracking via Google Analytics, please do so here.

This Privacy Policy only applies to information collected during your use and access of the Service or any other interactions you may have with Transparent Classroom. Our Service contains links to other locations on the internet that are not owned or controlled by us. We are not responsible for the privacy practices of other websites or services. We encourage you to read the privacy statements of each website that collects your Personal Information.

We may also disclose your Personal Information to effect a merger or acquisition or to support the sale or transfer of business assets. If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or prominent notice via the Services of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

We may disclose your information to a third party where we believe, in good faith, that it is desirable to do so for the purposes of investigating, preventing, or taking action regarding suspected or actual illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Use, to comply with subpoenas, or as otherwise required by law. In the event that we receive a subpoena affecting your privacy, we are not required to notify you or quash the subpoena ourselves.

6. Automatic Collection

Transparent Classroom and our third-party service providers automatically collect some information about you when you use our Services, using methods such as cookies and tracking technologies (further described below). Information automatically collected includes IP address, Internet service provider, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, sections of the Services visited, number of links you click while on the Services, search terms, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, website traffic and related statistics, keywords and/or other data.

7. De-Identified Data

We may use De-Identified Data to test features in development, and analyze the information we have to evaluate and improve products and services, develop new services or features, and conduct audits and troubleshooting activities. De-identified Data will have all direct and indirect personal identifiers removed. This includes, but is not limited to, name, ID numbers, date of birth, demographic information, location information, and school ID. Furthermore, we agree not to attempt to re-identify De-Identified Data and not to transfer De-Identified Data to any party unless that party agrees not to attempt to re-identify any Personal Information from such data. We may share this De-Identified Data with our affiliates, agents, advertisers, manufacturers, and business partners. We may also disclose De-Identified Data in order to describe our Services to current and prospective business partners and to other third parties for other lawful purposes.

8. Choice

We provide you with the opportunity to opt out of having your Personal Information used for certain purposes when we ask for this information; however, this may limit your ability to fully use our Service. You may also update your personal and security preferences by signing in to the Service. You may also opt out of email and promotional communications by following the instructions included in each such communication or by emailing us at privacy@transparentclassroom.com.

9. Security

Transparent Classroom uses reasonable administrative, technical, and physical security measures to protect data about Transparent Classroom customers. Transparent Classroom stores your Personal Information and other data on servers located in the United States. If you would like to know more, please email privacy@transparentclassroom.com.

You are responsible for maintaining the strict confidentiality of your account login credentials, and for any activity that occurs under your account credentials. Notify us if you suspect any unauthorized use of your account or other breach of security.

10. Cookies and Tracking Technologies

When you use the Service, we may collect certain information by automated or electronic means, using technologies such as cookies, browser analysis tools, and web server logs. As you use the Service, your browser and devices communicate with servers managed by our business partners, our service providers or us to record the interactivity and to fulfill your requests for services and information.

In many cases the information we collect using cookies and other tools is used in non-identifiable ways and without any reference to Personal Information. For example, we use information we collect about users to optimize the Services and understand its traffic and usage patterns. In other cases, we associate the information we collect using cookies and related technologies with Personal Information. In that case, this Privacy Policy governs how we use that information.

11. Data Retention

We retain Personal Information only for as long as necessary to provide the Services you have requested and thereafter for a variety of legitimate legal or business purposes. These might include retention periods:

  • mandated by law, contract or similar obligations applicable to our business operations;
  • for preserving, resolving, defending or enforcing our legal/contractual rights; or
  • as needed to maintain adequate and accurate business and financial records.

If you have any questions about the security or retention of your Personal Information, please contact us at privacy@transparentclassroom.com.

12. Governing Law

This Privacy Policy and the privacy practices of Transparent Classroom is governed by the internal laws of the State of Washington, United States.

Important Notices to Non-U.S. Residents

The Services are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By providing us with any information through the Site, or the Services, you consent to this transfer.

We may transfer your Personal Information to third parties acting on our behalf for the purposes of processing or storage. By using any of our Services or providing any Personal Information for any of the purposes stated above, you consent to the transfer and storage of your Personal Information, whether provided by you or obtained through a third party, to the U.S. as set forth herein, including the hosting of such Personal Information on U.S. servers.

13. California Consumer Privacy Act

We permit residents of California to use our service, and fully comply with California’s privacy laws. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/ccpa. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Service that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@transparentclassroom.com.

14. Data Subject Rights

You have certain rights with respect to your Personal Information as set forth below. Please note that in some circumstances, we may not be able to fully comply with your requests (such as if the request to delete or export information must come from your child’s school), or we may ask you to provide us with additional information in connection with your request. For example, if we need to verify your identity or the nature of your request. In such situations, however, we will still respond to let you know of our decision.

To make any of the following requests, contact us at privacy@transparentclassroom.com.

  • Access: You can request more information about the Personal Information we hold about you. You can also request a copy of the Personal Information.
  • Rectification: If you believe that any Personal Information we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging into your account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
  • Objection: You can contact us to let us know that you object to the collection or use of your Personal Information for certain purposes.
  • Erasure: You can request that we erase some or all of your Personal Information from our systems.
  • Restriction of Processing: You can ask us to restrict further processing of your Personal Information.
  • Portability: You have the right to ask for a copy of your Personal Information in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
  • Withdrawal of Consent: If we are processing your Personal Information based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Information, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
  • Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Information with a supervisory authority.

15. Data Privacy Frameworks, Data Protection Addendum, and EC Standard Contractual Clauses

If you are a resident of the EEA, the UK or Switzerland, we will protect your personal data when it is transferred outside of the EEA, the UK or Switzerland by processing it in a territory which the European Commission has determined provides an adequate level of protection for personal data; or otherwise ensuring appropriate safeguards are in place to protect your personal data.

For transfers of your personal data to Transparent Classroom’s operations based in the US, we rely on the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF (“UK-U.S. DPF”), and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce. To learn more about the Data Privacy Framework (“DPF”) program, and to view our certification, please visit https://www.dataprivacyframework.gov/. Transparent Classroom complies with the EU-U.S. DPF, the UK-U.S. DPF, and the Swiss-U.S. DPF as set forth by the U.S. Department of Commerce. Transparent Classroom has certified to the U.S. Department of Commerce that it adheres to (i) the EU-U.S. DPF Principles with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK-U.S. DPF and (ii) the Swiss-U.S. DPF Principles with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (“DPF”) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Transparent Classroom commits to resolve DPF Principles-related complaints about our collection and use of your Personal Information. EU, UK and Swiss individuals with inquiries or complaints regarding our handling of Personal Information received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF or the Swiss-U.S. DPF should first contact Transparent Classroom at privacy@transparentclassroom.com.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Transparent Classroom commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities, the UK Information Commissioner’s Office (ICO), the Gibraltar Regulatory Authority (“GRA“) and the Swiss Federal Data Protection and Information Commissioner (“FDPIC“) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF. Under certain conditions, it may be possible to invoke binding arbitration for complaints regarding DPF compliance not resolved by any of the other DPF mechanisms.

Transparent Classroom remains responsible if its service provider, when acting on its behalf, processes personal data in a manner inconsistent with the DPF Principles, unless it is not responsible for the event giving rise to the damage.

The Federal Trade Commission has jurisdiction over Transparent Classroom’s compliance with the EU-U.S. Data Privacy Framework EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.

For transfers of Personal Data outside of the EEA, the UK or Switzerland to recipients outside of the U.S, Transparent Classroom’s Terms of Service also include a Data Protection Addendum (DPA), which incorporates The European Commission’s Standard Contractual Clauses (or “SCCs”). The SCCs incorporated into the DPA are standardized contractual terms, recognized and adopted by the European Commission, with the primary purpose of ensuring that any Personal Information leaving the European Economic Area (“EEA”) to recipients outside of the U.S. will be transferred in compliance with EU data-protection law. In certain cases, Transparent Classroom will transfer Personal Information in accordance with the European Commission-approved Standard Contractual Clauses, a copy of which can be obtained here.

Transparent Classroom, additionally complies with the SCCs as set forth by the European Commission regarding the collection, use, and retention of personal information transferred from the EEA, UK, and Switzerland to recipients outside of the United States. If there is any conflict between the terms in this Privacy Policy and the DPA, including the SCCs, the DPA shall govern.

The European Commission’s SCCs incorporate the principal EU General Data Protection Regulation (GDPR) requirements covering access, disclosure, security and transparency of Personal Information, and sets forth a framework for U.S. companies, and EU entities working with U.S. companies, to meet the requirements of the GDPR. Both you and Transparent Classroom will comply with the DPA, including the SCCs, so that Transparent Classroom’s EU-based users can share Personal Information with us and remain compliant with the GDPR.

We are committed to protecting your privacy in compliance with the European Commission’s SCCs. EU and Swiss Individuals with inquiries or complaints regarding our Privacy Policy can contact us at privacy@transparentclassroom.com.

Please review the full text of our DPA here.

We work hard to promptly respond to any requests we receive regarding privacy and data protection. If you do not receive a timely acknowledgement of your request from us, or if we have not addressed your request to your satisfaction, you agree to refer the matter to the International Center for Dispute Resolution / American Arbitration Association (ICDR/AAA). ICDR/AAA is an independent recourse mechanism chosen by Transparent Classroom. You may get more information or contact ICDR/AAA at https://www.icdr.org/about_icdr. The services of ICDR/AAA are provided at no cost to you. Under certain conditions, individuals may invoke binding arbitration when the dispute resolution procedures of ICDR/AAA have been exhausted.

16. Notice to Schools - Australia Privacy Principles

Prior to use of Transparent Classroom in Australia, informed consent must be provided by the parents of each child in your school that their child’s data will be transferred beyond the borders of Australia through the Service. Parents must be notified prior to providing consent that if consent is given to the overseas disclosure, the schools will not be required to take reasonable steps to ensure that Transparent Classroom complies with Australian Privacy Laws. To learn more about Australian Privacy Principles visit https://www.oaic.gov.au/privacy/australian-privacy-principles.

17. Amendments

We may modify the terms of this Privacy Policy from time to time. In the event of any material change to our Privacy Policy, in Transparent Classroom’s sole discretion, you may be notified by email of such change, if you are registered user of the Service. If any change is unacceptable to you, you should immediately cease use of the Service. Your continued use of the Service following a notice of a change in the Agreement via the Service will constitute your binding acceptance of the changes.

18. Comments and Questions

If you have any comments or questions, you may address them to Transparent Classroom, 4730 University Way NE. Ste 104 PMB 5234 Seattle, Washington 98105, or by email at info@transparentclassroom.com.