Thread Learning Commitment to Your Privacy

Thread Learning, Inc. (“Thread learning,” “we,” “our,” or “us”) understands that privacy is tremendously important to visitors to our website, to teachers, administrators and other representatives of schools who use our Sites, Apps and Services (collectively, “Schools”), and to students and parents whose information we store on behalf of their Schools. Thread Learning has prepared this Privacy Policy to describe our practices regarding personal information that may be collected from users (“you”) when you interact with any Thread Learning websites (“Sites”), applications (“Apps”) or other related educational services (“Services”) that post or link to this Privacy Policy, and you understand that:

  • “Sites” includes, without limitation, www.Threadlearning.com;
  • “Apps” includes, without limitation, Thread Learning’s iOS and Android applications; and
  • “Services” includes, without limitation, our APIs and other services.

We are committed to protecting your personal information and satisfying the spirit as well as the letter of all applicable legal requirements, including the Children’s Online Privacy Protection Act (“COPPA”) and the Family Educational Rights and Privacy Act (“FERPA”), through our compliance with this Privacy Policy.

By submitting personal information through our Sites, Apps or Services, you expressly consent to the processing of your personal information in accordance with this Privacy Policy. You represent that you have the appropriate permissions to provide the information you provide on our Sites, Apps or Services and that your provision of such information satisfies all legal requirements, including those of COPPA and FERPA. We promise to limit the use of personal information collected through our Services to the purposes described in this Privacy Policy.

If you are a student or parent, please contact your School if you have questions about the School’s use of technology service providers such as Thread Learning. If a student contacts Thread Learning with a question about our Services, 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.

TABLE OF CONTENTS

  1. How We Collect and Use Your Information
  2. How We Share Your Information
  3. How We Store and 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. Changes to Our Privacy Policy

We are dedicated to being transparent in our data collection and use practices.

1. HOW WE COLLECT AND USE YOUR INFORMATION

Information We May Collect:

  • Thread Learning may collect your name, School name, School district, email address, account name, password, phone number, avatar, message content and other information relating to your School’s information system(s), including, for example, student identification numbers and parent-child relationships. We may also collect your billing address and credit card information.
  • Once a School begins using Thread Learning, we track and retain related records of all activity within such School’s account.

How We Collect Information:

  • Student Data – Protecting children’s privacy is especially important to us. Students do not currently access the application themselves, but teachers, team administrators and parents may all input student information. When a new student profile is created by a School, we ask for the student’s name, age and parental email address, which we use to seek verifiable parental consent or provide parental notice (as applicable and as required under all applicable laws), as well as allow Schools to update parents on student progress. With parental consent, we may also use student age to compare students’ progress solely for the purpose of improving teaching methodologies. Both Schools and parents may input additional student data, which Thread Learning collects for the purposes of providing our Services and coordinating educational care. Schools and parents may be able to input Individualized Education Plan data, as well as academic data, behavior data, and avatars, which data may take the form of text, photos and/or video. Schools may also have the option to import information directly to Thread Learning Sites, Apps and Services. In some cases, Schools may choose to import data from another vendor, such as a third party student information system or other data source (e.g., Clever). All information collected by Thread Learning that is described in this paragraph may be referred to in this Privacy Policy as “Student Data”.
  • Customer and Parent Data – When a teacher, team administrator or parent creates a Thread Learning account in order to use our Sites, Apps and/or Services, we ask for such person’s name, individual password, School organization and email address and offer such person the option to provide a phone number and avatar. Team administrators may also be asked for team passwords and email addresses of other teachers on the team. All information collected by Thread Learning that is described in this paragraph may be referred to in this Privacy Policy as “Client Data”.
  • Information automatically collected through technology We automatically collect certain types of usage information when you view our Sites, Apps and/or Services. We may use cookies — a small text file containing a string of alphanumeric characters — to record current session information, but we do not use permanent cookies. You are required to log in to your Thread Learning account after a certain period of time has elapsed to protect you against others accidentally accessing your account contents. We also collect information about how you use the Services (e.g., the pages you view, the links you click and other actions you take on the Services) and your usage of the Services over time. We may collect log file information from your browser or mobile device each time you access the Services. Log file information may include anonymous information such as your web request, IP address, browser type, information about your mobile device, number of clicks, how you interact with links on the Services, pages viewed and other such information. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Services. We do not allow any third party advertising networks to collect information about the users of our Sites, Apps or Services.

What We Do with This Information:

  • Student Data Thread Learning has access to personally identifiable information about students, only as determined by Schools and consented to by parents for purposes of providing our Services. We strictly maintain the confidentiality of Student Data and do not use Student Data for any purpose other providing Services. A School may allow students, teachers and parents to log into our Sites and Apps to access Student Data and/or third party applications that have been authorized by such School. Each School is solely responsible for obtaining appropriate parental consents, as needed, before the student is permitted to access the Services.
  • Information collected automatically through technology – We use automatically collected information to operate, maintain and provide the features and functionality of our Services, to analyze our Services offerings and functionality, and to communicate with Schools and website visitors. We use or may use data collected through cookies, log files and device identifiers 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) provide and monitor the effectiveness of our Services; (d) monitor aggregate metrics such as total number of visitors, traffic and usage on our website and our Services; (e) diagnose or fix technology problems; and (f) help users efficiently access information after signing in.
  • Billing information – Your billing information is only used for billing purposes and is kept confidential.

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.

2. HOW WE SHARE YOUR INFORMATION

Thread Learning only shares your personal information in a few limited circumstances, described below. We do not rent or sell information for marketing purposes.

Parties With Whom We May Share Information:

  • We may share information with third parties that provide us with technology services (“Service Providers”), strictly for the purpose of carrying out their work for us (e.g., web hosting and analytics services) and which are bound by contractual obligations to keep personal information confidential. See the Thread Learning Service Providers list below.
  • We may be required to share information with law enforcement or other third parties when compelled to do so by court order or other legal process, to comply with statutes or regulations, to enforce our Terms of Service, or if we believe in good faith that the disclosure is necessary to protect the rights, property or personal safety of our users.

If we sell, divest or transfer our business, or any other change in control of our business occurs, we will not transfer personal information of our customers (including any Client Data or Student Data) unless the new owner agrees in a contract with us to maintain and provide the Services as a going concern and in accordance with data privacy standards no less stringent than our own. In such event, we will provide you with notice and an opportunity to opt out of the transfer of Client Data or Student Data to the new owner of our business.

Thread Learning Service Providers

Below is a list of Service Providers that provide us with technology services and with which data is shared. This list provides an illustration of the types of Service Providers utilized by Thread Learning, but may not be comprehensive and is subject to change at any time. If you have questions about Thread Learning Service Providers, please contact us at privacy@threadlearning.com.

Client Data Storage:

The Thread Learning Sites, Apps and Services have industry standard security measures in place to protect the loss, misuse and alteration of the information under our control. While there is no such thing as “perfect security” on the Internet, we will take all reasonable steps to ensure the safety of your information. Although Thread Learning owns the data storage, databases and all intellectual property rights of its Sites and Apps, you retain all rights to your data and applicable Student Data (in accordance with FERPA), and we will never sell or share Student Data or Client Data with any third parties. We respect the privacy of our customers and students, as well as the privacy of their data.

List of Service Providers:

  • Microsoft Azure – Data collected by Thread Learning, including any personal information contained in the data, may be stored via our private server hosted by Microsoft Azure. No other personal information is provided to Microsoft Azure.
  • Realm – Realm is used as part of Thread Learning’s backend syncing technology. Thread Learning may at times provide Realm access to Student Data and Client Data, including personal information contained in the data, for the sole purpose of technical support.
  • Amazon Web Services – Data collected by Thread Learning, including any personal information contained in the data, is backed up on a regular basis to an encrypted Amazon S3 drive. No other personal information is provided to Amazon Web Services.
  • Intercom – We use Intercom as our help center tool. Requests sent to us via our support channels are collected and stored in Intercom. This may include limited Student Data and/or Client Data (i.e., name and email address), as well as the requestor’s device information.
  • Slack – We use Slack in coordination with Intercom as our help center tool. Requests sent to us via our support channels are also collected and stored in Slack so that we can provide the fastest possible support. This may include limited Student Data and/or Client Data (i.e., name and email address), as well as the requestor’s device information.
  • Crashlytics (owned by Google) – We use Crashlytics as a crash reporting service tool to optimize our technology and our support. Crashlytics does not have access to Student Data or Client Data, although it may include a user’s location and device information.
  • Google Analytics – We use Google Analytics as an analytics tool to measure how the application is used in order to optimize our technology and our products. Google Analytics does not have access to personal information, although it may include location and device information.
  • Apple – We use Apple App Store and their analytics tool, Testflight, as an analytics tool. Apple does not have access to personal information, although it may include location and device information.

 

 

Please note that the Thread Learning Privacy Policy applies to Thread Learning and not any services or applications of Service Providers or any other third parties, which may have their own privacy policies.

3. HOW WE STORE AND PROTECT YOUR INFORMATION

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 building and files. All information you provide to us is backed up on at least an hourly basis.

Under Thread Learning’s incident response plan, in the event of a security breach, Thread Learning will report any confirmed or suspected breach to designated leadership of all affected Schools as soon as possible after the discovery of the breach, both orally and in writing, but in any event within two (2) business days after Thread Learning security personnel confirm that a breach has or may have occurred.

Thread Learning also maintains a data loss prevention strategy, which further outlines how we prevent the loss or theft of Student Data.

The safety and security of your information also depends on you. We urge you to be careful about sharing your account information or giving out information in any public areas of the Services such as the message boards or forums. The information you share in public areas may be viewed by other authorized users of the Services.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. We are not responsible for circumvention of any privacy settings or security measures contained within the Services.

If you have any questions about data storage and protection, contact us directly at founders@threadlearning.com.

4. YOUR CHOICES ABOUT YOUR INFORMATION

Account Information and Settings: Schools may update account information and modify Services by signing into the account of a team administrator. All users can opt out of receiving promotional email from us by clicking on the “unsubscribe” feature at the bottom of each email. Users can also update their individual notification preferences within relevant Sites, Apps and Services to control certain related messaging. However, certain messaging (such as password reset communications) cannot be disabled.

If you are the parent or legal guardian of a student whose data is stored by Thread Learning, you can email us at founders@threadlearning.com to have the applicable Student Data, and/or the applicable student’s account, deleted.

If you would like a copy of your child’s Student Data that we may have stored, you can contact us by sending an email to founders@threadlearning.com. At any time, parents can refuse to permit us to collect further Student Data from their children. Please keep in mind that deleting Student Data or other records we are asked to delete may require us to terminate one or more user accounts. Before we can share with you or delete the requested Student Data or other information, as applicable, we will need to verify your identity and may require you to provide acceptable forms of personal identification.

You may be able to disallow cookies to be set on your browser. Please look for instructions on how to delete or disable cookies and other tracking/recording tools on your browser’s technical settings. You may not be able to delete or disable cookies on certain mobile devices and/or certain browsers. For more information on cookies, visit www.allaboutcookies.org. Remember, disabling cookies may disable many of the features available on the Services, so we recommend you leave cookies enabled.

Following termination or deactivation of a School’s account with us, Thread Learning may retain Student Data, Client Data and other related information for a commercially reasonable time, for backup, archival or audit purposes; provided, however, that any and all Student Data associated with such School will be deleted within thirty (30) days of termination in accordance with FERPA. We may maintain anonymized or aggregated data, including usage data, for analytics purposes only.

5. CHILDREN’S PRIVACY

Schools using Thread Learning for children under 13 years of age are required by our Terms of Service to obtain appropriate parental consent to use Thread Learning.

6. LINKS TO OTHER WEBSITES AND SERVICES

Thread Learning reviews our Service Providers and their privacy policies carefully. However, Thread Learning is not responsible for the practices employed by websites, applications or services linked to or from our Services. We recommend that Schools review the privacy policies of other applications before authorizing any third party to access Student Data and/or Client Data through our Sites, Apps and/or Services.

7. HOW TO CONTACT US

If you have any questions about this Privacy Policy or Thread Learning, please contact us at founders@threadlearning.com.

8. CHANGES TO THIS PRIVACY POLICY

Thread Learning may modify or update this Privacy Policy from time to time, so you should review this page periodically. The date that this Privacy Policy was last updated is identified at the bottom of this page. If we make a material change to this Privacy Policy with respect to how we collect and use your personal information, we will provide at least thirty (30) days’ prior written notice to you by email to the email address specified in your account, if you have one, so that you have sufficient time to evaluate the change, and you can choose to opt out by deleting your Thread Learning account before the change takes effect. You are responsible for ensuring that we have an up-to-date, active and deliverable email address for you and for periodically visiting this Privacy Policy to check for any changes.

This Privacy Policy was last modified on October 8, 2018.