For California Residents
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit CCPA Privacy notice for California Residents
Effective Date: July 13th, 2020
StudyPad, Inc. ("Company","we","us","our") knows that you care about how your and your child's personal information is used and shared, and we take your privacy seriously.
By visiting the SplashLearn
If you are accessing the Service from within the European Union (EU) or you are an EU citizen, please review the Lawful Bases for Processing Personal Data
and Individual Rights
sections below for more information on how your personal data will be processed and the rights you have regarding this processing.
Data Controller and Data processor:
For individuals in European Union, the following definitions hold:
Data Controller: When we are collecting or receiving any personal information directly from individuals (data subjects) during the usage of our services, we will act as Data Controllers. For example: Child’s personal information from Parent, Parent’s personal information form themselves, teacher’s personal information while accessing our services etc.
Data Processor: When we are collecting, receiving or obtaining any personal data of students/ children from any educational institutions or from teachers then we will act as data controllers and we may act as a data processor. When we act as data processors, it is the responsibility of data controllers (teachers and educational institutions) to take the explicit consent from a child's parent or comply as per privacy guidelines before sharing the details with us. Once we receive the details, as a data processor we will adhere to all the privacy guidelines.
How is children's personal information treated?
If you are a minor, you may not disclose Personal Information to us. Company only collects limited Personal Information about children ("Children's Personal Information") directly from the parent or guardian who has downloaded our mobile applications or registered on our website. If you are a minor, please do not send any Children's Personal Information about yourself to us, other than what we request from your parent or guardian who registers for the Services.
In the event that we learn that we have collected Children's Personal Information directly from a minor, we will delete that information as quickly as possible. If you believe that a minor may have provided us Children's Personal Information without parental involvement, please contact us at [email protected]
In this document "Personal Information" shall apply to personal information of individual Service users who are not student registrants. References to "Children's Personal Information" shall only apply to personal information of student users of the Services. General references to "information" shall apply to all users.
If you are a minor and your parent has signed up for the Service, you understand that your parent may be able to view all information within or associated with the account, including without limitation progress reports and usage data that tracks your performance on games, assessments and other tests available through the Services.
What Personal Information Does Company Collect?
The information we gather from customers enables us to personalize and improve our services. We collect the following types of information from our customers:
Information You Provide to Us:
Information about you
We collect your email address, account password, zip code, credit card and/or other payment information and any other information necessary for us to provide our services. If you are a teacher or a school administrator we also collect your school name from you in order to provide you school level features and prevent misuse of our services meant for teachers and schools.
We also offer parents and teachers the ability to sign up for the services using their existing Facebook or Google account. If you choose to sign up for the Services using one of these accounts, we will receive your full name from the service provider managing that account.
Information about Children
Children's Personal Information provided by parents is limited to a screen name and gender. As a teacher or a school administrator, you also provide a full name to be able to track progress and distinguish students, you may choose to provide a different identifier instead of name for this purpose. You may also provide us with a username and a password for each of the student accounts.
A child (or parent) can record their voice while reading a digital book and play it back to help them learn to read. This recording stays on your device and is not sent to our servers. The recording is automatically deleted as soon as the child moves to the next page of the book. The record voice feature is optional, and parents can deny microphone access without affecting the child's access to the books.
Additionally you may also provide us with additional personal information when you contact us for product or technical support like an alternate communication method which we will use to answer your queries and process your requests. If you are using the service as an Educational Institution, Student information may be visible during Customer Support and/or Troubleshooting. Personally identifiable information such as Student Name, Teacher Email Address, login dates and times could be viewed on our service by Product Support Staff.
You can choose not to provide us with certain information, but then you may not be able to take advantage of many of our special features. The Personal Information you provide is used for such purposes as answering questions, sending product updates, and communicating with you about Company's products and services, including specials and new features. The Children's Personal Information you provide shall only be used for creating your individual account (which will allow you to receive progress reports that include tracking your child's performance and progress). You may modify or remove your Personal Information or Children's Personal Information identified below at any time by logging into your account and accessing features to edit your profile and/or account information.
) on the Services at your own risk. We attempt to limit access to blogs, forums, and other mechanisms of sharing content by requiring your user profile and password to upload and share Content. We cannot, however, control the actions of you or others. If someone chooses to share their username and password, it is possible a minor might gain access to such forums and view or share Content.
By sharing Student Data or other information to SplashLearn, you expressly grant, and you represent and warrant that you have all rights necessary to grant, to SplashLearn a non-exclusive, royalty-free, worldwide license during the term of the Agreement to use, transmit, distribute, modify, reproduce, display, and store the Student Data solely for the purposes of (i) providing the Services as contemplated by the Agreement, and as otherwise described herein, (ii) maintaining, supporting, evaluating, improving and developing our products, applications, and Service, and (iii) enforcing our rights under the Agreement.
Personal Information Collected Automatically
We receive and store certain types of information whenever you interact with our Services or use our services. Company automatically receives and records information on our server logs from your browser including your IP address, cookie information, and the page you requested. Generally, our service automatically collects usage information, such as the numbers and frequency of visitors to our Services and its components, similar to TV ratings that indicate how many people watched a particular show. Company only uses this data in aggregate form, that is, as a statistical measure, and not in a manner that would identify you personally.
This type of aggregate data enables us to figure out how often customers use parts of the Services so that we can make the Services appealing to as many customers as possible, and improve those Services. As part of this use of information, we may provide aggregate information to our partners about how our customers, collectively, use our Services. We share this type of statistical data so that our partners also understand how often people use the Services, so that they, too, may provide you with an optimal online experience. Again, Company does not disclose aggregate information to a partner in a manner that would identify you personally.
We often receive a confirmation when you open an email from Company if your computer supports this type of program. Company uses this confirmation to help us make emails more interesting and helpful. When you receive email from Company, you can opt out of receiving further emails by following the included instructions to unsubscribe.
We may also send parents and teachers practice reminders through our mobile apps. These notifications are intended for grownups only and can only be requested through the parent/grownup sections of our mobile apps. You can opt-out from these notifications or modify the frequency of these notifications at any time through the app or device settings.
users for advertising purposes.
How does the Company Use the Information it Collects
The following is a summary of the purposes for which we may use the information that we collect
To provide you the services: The information we collect is used to provide the service to you. This includes maintaining your account, enabling payments, sending reports to parents and teachers, responding to your requests and providing you support.
To communicate with you: We use your information to send communications related to our businesses such as product or service updates, and to communicate with you about our products and services, including special and new features and promotional offers. You may unsubscribe from any of these communications at any time using our email preferences page. We only send communications to adult users of the service
To improve our products and services: We use the information we collect to personalize the service, including the learning content, to help you quickly find information regarding products, services or content and so on, to customize your experience based on your platform. We also collect statistics to analyze the effectiveness of our service in order to make it better, understand usage patterns and identify defects and technical problems, as well as statistics to improve our advertising campaigns and reach out to users more effectively.
To ensure security of our services and data: We use information to secure accounts and prevent unauthorized access and fraud, secure payment transactions, comply with laws and regulations
Will Company Share Any of the Personal Information it Receives?
Your Personal Information and Children's Personal Information is an integral part of our business. We neither rent nor sell your Personal Information or Children's Personal Information to anyone. We share your Personal Information and Children's only as described below. As explained below, we only share Children's Personal Information associated with your account directly with you to report on your child's performance using our Services. We never share that Children's Personal Information with any third party. A child's usage data (i.e. performance on tests, games, etc. available on the Services) is shared through aggregated, anonymous comparisons, but never in a way that could personally identify the child. In addition, we do not offer students chat rooms or community features that allow the sharing or posting of Children's Personal Information in a public forum. Here
is the list of third-party service providers we work with.
Again, please note that references to "Personal Information" only apply to personal information of individuals who are not students.
Sharing with Affiliated Businesses:
In the event that SplashLearn is involved in a merger, reorganization, dissolution, sale of business or assets or similar event, information disclosed to or collected by may be transferred to SplashLearn’ successor, or to the purchaser of such assets, as applicable. You will be notified via email and a prominent notice on our Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
We employ APIs of other companies and people to perform tasks on our behalf and may need to share your information with them, including Personal Information or Children's Personal Information, to provide products or services to you. Examples include sending billing receipts and weekly progress reports and providing user services. Unless we tell you differently, these companies do not have any right to use Personal Information or Children's Personal Information we share with them beyond what is necessary to execute tasks at hand. We will also require that these companies agree to protect the security of the information we share with them. You hereby consent to our sharing of Personal Information and Children's Personal Information for the above purposes. For any privacy inquiries related to how these companies may handle your information on our behalf, please use the contact information of StudyPad at the bottom of this page, and we will respond to all such inquiries.
Minors are not allowed to enter or upload User Submissions. If the registration process is completed correctly, no Children's Personal Information will ever be displayed to any third party through a User Profile. Email addresses are used to add new User Submissions to user profiles and to communicate through User Submissions. Users' email addresses will not be directly revealed to other users by Company, except, when the user is "connected" to another user via a shared group membership, or an invitation, or if the user has chosen to include their email address in their User Profile.
Communication about the Services or in response to User Submissions:
As part of the Services, you will receive from Company email and other communication relating to your child's progress and use of the Services or User Submissions. You acknowledge and agree that by allowing your child to use the Services, and by posting such User Submissions, Company may send you email and other communication that it determines in its sole discretion relate to such activity and your User Submissions.
We may send offers to you on behalf of other businesses. However, when we do so, we do not give the other business your name and address. If you do not wish to receive these offers, please unsubscribe using the instructions provided in the email, the account management tools on the website, or by sending an email with your request to [email protected]
Protection of Company and Others:
We may release Personal Information when we believe in good faith that release is necessary to comply with the law; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of Company, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
With Your Consent:
Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and you will be able to prevent the sharing of this information.
Is Personal Information About Me Secure?
The security of your personal information is important to us. To prevent unauthorized access, disclosure, or improper use of your information, and to maintain data accuracy, we've established physical, technical, and administrative safeguards to protect the personal information we collect. In particular:
We periodically review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
We perform application security testing; penetration testing; conduct risk assessments; and monitor compliance with security policies.
When you enter any information anywhere on the Service, we encrypt the transmission of that information using secure socket layer technology (SSL) by default.
SplashLearn's database where we store your personal information is encrypted at rest, which converts all personal information stored in the database to an unintelligible form.
We ensure passwords are stored and transferred securely using encryption and salted hashing.
SplashLearn's Website and the Service is hosted by third-party service providers at separate facilities, with whom we have a contract providing for enhanced security measures.
We restrict access to personal information to authorized SplashLearn employees, agents or independent contractors who need to know that information in order to process it for us, and who are subject to strict confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
Company endeavors to protect user information to ensure that user account information is kept private, however, Company cannot guarantee the security of user account information. Your Personal Information or Children's Personal Information is protected by a password for your privacy and security. You need to ensure that there is no unauthorized access to your account and Personal Information or Children's Personal Information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your account.
If SplashLearn becomes aware of a systems security breach by an unauthorized party or that any user data was used for an unauthorized purpose, we will comply with relevant state and other data breach laws. We will notify users of any breach resulting in unauthorized release of data electronically, at minimum, and without unreasonable delay so that you can take appropriate steps. The notification will include: date of the breach, the types of information that were subject to the breach, general description of what occurred and steps SplashLearn is taking to address the breach.
StudyPad makes certain choices available to you when it comes to your personal data. Please review the below information outlining your choices and how to exercise them. We will respond to all requests within a reasonable timeframe. If our full response will ever take more than a month due to complexity or scope, we will notify you of this and keep you updated.
Review and update your data:
You have the right to access and update any personal data that we have collected. Some personal data, such as the account holder's name and email address can be found and updated using the account management tools on our website at https://www.splashlearn.com/profile
. For any personal data beyond this, please submit a request using the contact information at the end of this section. We may request more information to confirm your identity before modifying any personal data.
Delete your data: You also have the right to get your personal data deleted. This is sometimes known as the ‘right to be forgotten’. To request that we delete all personal data about you, please submit a request using the contact information at the end of this section. We may request more information to confirm your identity before deleting any personal data.
Please note that some content will not be deleted given various compliance and recordkeeping obligations schools have. Please contact your (or your child's ) school if you would like this content deleted. If the school determines that the request should be implemented, they may submit a request to us.
For more information on our data deletion and retention practice from the section below.
Restrict Processing: You have the right to restrict how we process your personal data in certain circumstances. This is an alternative to requesting the deletion of your data. Rather than requesting we delete all of your personal data, you may request that we limit our uses of your personal data to specific purposes. You may wish to request we restrict our processing if you contest the accuracy of your personal data and we are working to verify this information, or if you want us to retain your personal data in connection to a legal claim but cease processing it.
Data Portability: You have the right to obtain copies of your information in a structured, commonly used format so that you can move your data between our service and the services of others. We may request more information to confirm your identity before providing any personal data.
Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or when our processing of your data is based on legitimate interests. You may request that we stop processing your personal data for direct marketing purposes. This is an absolute right and we cannot refuse this request. Beyond direct marketing, if you wish to exercise this right, you must give specific reasons as to why you object to our processing of your data, based on your particular situation. Even after receiving such a request, we may continue processing if it is necessary for the exercise/defense of a legal claim or if we can demonstrate a compelling legitimate ground for the processing.
If any request made under this section is clearly unfounded or excessive, we may reject the request or require a reasonable fee to honor the request. If we decide to reject your request, we will inform you of the reasons for not taking action and provide information on other possible remedies. If we decide that a reasonable fee is necessary, we will promptly inform you and will comply with the request upon receipt of this fee.
Individuals in European Union have an option to lodge a complaint with their local supervisory authority. A list of Supervisory Authorities is available here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
. In addition, the controller is obliged to inform all recipients to whom it discloses data of any such corrections, deletions, or restrictions placed on processing the same per Art. 16, 17 Para. 1, 18 GDPR. However, this obligation does not apply if such notification is impossible or involves a disproportionate effort. Nevertheless, users have a right to information about these recipients.
Lawful Bases for Processing Personal Data:
If you are an individual in the European Union (EU) or an EU citizen, we collect and process data about you only where we have legal bases for doing so under applicable EU laws. This means we collect and process your data only when:
It is necessary for a legitimate interest (which is not overridden by your individual privacy interests), such as preventing fraud, improving the Services, and increasing the security of the Services and network infrastructure;
You have consented to this collection and processing for a specific purpose;
It is necessary to fulfil our contractual obligations; or
It is necessary to comply with a legal obligation.
Some examples of our legitimate interests and the data being processed include:
Network and information security (password, IP address, Device ID)
Customer Support and fraud prevention (name, email address)
Improving our products and services (hardware information, activity logs)
Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time. If you wish to withdraw your consent, please contact us using the information in the Contact for Individual Rights Requests
Where we rely on our legitimate interests to process your personal data, you have the right to object. More information on exercising this right can be found in the Individual Rights
If you have any questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us at [email protected]
Contact for Individual Rights Requests
Please use the below information when submitting a request to exercise any of the above rights. Please do not submit requests across multiple communication channels. We will make all efforts to respond to your request within a reasonable timeframe.
Email: [email protected]
Attn: Joy Deep Nath
548 Market, St #64304
San Francisco CA - 94104
For Data Subjects in the EU:
We have appointed GDPR-Rep.eu as representative according to Art 27 GDPR and to provide you with an easy way to submit us privacy related request. If you want to make use of your data subject rights, please visit: https://gdpr-rep.eu/q/17025404
Maetzler Rechtsanwalts GmbH & Co KG
Attorneys at Law
c/o StudyPad, Inc
Schellinggasse 3/10, 1010 Vienna, Austria
Please add the following subject to all correspondence:
GDPR-REP ID: 17025404
International/ Cross Border Data Transfers
For individuals in the European Union(EU), Switzerland and UK, data transfers to the United States where SplashLearn is based is on the basis of compliance with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework.
Pursuant to the Privacy Shield Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to [email protected]
. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to [email protected]
SplashLearn’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, SplashLearn remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless SplashLearn proves that it is not responsible for the event giving rise to the damage.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, SplashLearn is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, SplashLearn may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the Privacy Shield Principles, SplashLearn commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union, United Kingdom, and Swiss individuals with Privacy Shield inquiries or complaints should first contact SplashLearn at: [email protected]
SplashLearn has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints/
for more information and to file a complaint. This service is provided free of charge to you.
Cross-Border Transfers other than to the United States
Personal data may be accessed by our personnel in India for the purpose of providing services. In such instances, we use Standard Contract Clauses approved by the European Commission to protect personal data. If you have queries, please contact us using the contact information mentioned at the end of the document.
Data Deletion & Retention
We store your personal information for as long as it is necessary to provide products and Services to you and others, including those described above. Personal information associated with your account will be kept until your account is deleted unless we no longer need the data to provide products and services.
Please note that we may have to retain some information after your account is closed, to comply with legal obligations, to protect the safety and security of our community or our Service, or to prevent abuse of our Terms. You can, of course, delete your account at any time, as per the Deleting Your Account section.
Student Data Protection Policy: We will not retain a student's personal information for any longer than is necessary for educational purposes, legal or contractual obligations, or to provide the Service for which we receive or collect the child's personal information. Additionally, we only keep a child's personal information for as long as his or her student account is active, unless we are required by law or the child's school to retain it, need it to ensure the security of our community or our Service or to enforce our Terms.
Please see the following section on information about data deletion due to account inactivity:
Home Accounts: For accounts created by parents, if neither the student, nor the student's parent(s) or any of the other student accounts associated with the parents' accounts have logged into their account in 2 years, SplashLearn will automatically delete or de-identify the personal information tied to the student account that is not necessary for educational purposes or legal obligations, including device tokens, device identifiers and IP addresses. In effect, the student account will be anonymized and de-linked from the parent account and the data will be non-recoverable. We will make reasonable attempts to inform parents about the account modification a few days in advance. We may retain some personal information about the parents for reasons outlined earlier, but these will not be tied to any personal information about the student. Parents can always request deletion of their accounts as outlined in the "Deleting your account" section.
Classroom Account: If neither the teacher, nor any of the students associated with the teacher account have logged into their account in 2 years or performed any activity, SplashLearn automatically deletes or de-identifies any personal information tied to the student accounts that is not necessary for educational purposes or legal obligations, including device tokens, device identifiers and IP addresses.
What happens when an account is deleted: SplashLearn de-identified or deletes any personal information tied to the accounts, including emails, usernames. device token, device identifiers, IP addresses. This information may persist in backups that we maintain, for a reasonable amount of time. SplashLearn retains de-identified usage information about the accounts unless we contractually obligated to delete such information.
When a teacher or school administrator delete an account from within their SplashLearn dashboard, the deleted accounts are kept in a recoverable state for 14 days before the deletion actually takes place. This is done so that any erroneous deletions on the user's part can be recovered and accounts may be restored.
Please note that after an account is deleted from our systems, it is not possible for us to restore the account or any personal information associated with it.
After registration, if you receive emails from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving emails from us by using the account management tools on our website or sending your request to us by email on [email protected]
Schools signed up for a membership will be notified in advance of any material changes to privacy policies, including practices around new or additional data collection, or new ways of using the data that may lessen your privacy and rights.
Questions or Concerns
If you have any questions or concerns regarding privacy on our Services, please send us a detailed email at [email protected]. We will make every effort to resolve your concerns.
StudyPad, Inc. 548 Market, St #64304
San Francisco CA - 94104
Phone: +1 855 979 8948
For data subjects in the EU, GDPR-Rep.eu has been nominated as our representative in the European Union. If you want to make use of your data privacy rights, please visit: Our GDPR-Rep.eu landing page