Last updated: June 23, 2020
Applicability of Spirit of Truth Digital Learning Platform.
“Authorized Users” means the students, administrators, teachers, catechists, staff and any other persons who are authorized by the School to access and use the Service.
“School”, “you”, or “your” means the Catholic school or parish that purchases the Service.
Sophia’s Privacy Principles
- We do not disclose Authorized Users’ information for targeted advertising purposes.
- We do not build a personal profile of any Authorized User of the Service other than in furtherance of an educational purpose as authorized by the School.
- We maintain a data security program designed to protect Authorized Users’ information maintained by the Service.
- We will clearly and transparently disclose our information policies and practices to the School and to Authorized Users.
Questions regarding the review, modification, or deletion of an Authorized User’s information must be directed to the School.
Collection and Use of Authorized Users' Information.
We may collect information from and about Authorized Users in a variety of ways, which may vary according to an Authorized User’s use of the Service. The categories of information we collect may include:
- Account Information: When an account for an Authorized User is created or updated, we may receive information about the Authorized User from the School, including the Authorized User’s name, phone number, address, email address, and, in the case of a student Authorized User, birthdate and grade level (“Account Information”). We use this information for the purpose of providing the Service to you.
- User-Generated Content: We may receive and use information or “content” provided directly by Authorized Users who are (1) students responding to activities or assessment questions within the Service; (2) teachers, catechists, and other school administrators using the notifications feature within the Service to communicate with students; and (3) teachers, catechists, and other school administrators seeking technological or pedagogical support by using the Service’s chat feature (collectively, “User-Generated Content” or “UGC”). We use UGC for the purpose of providing the Service to you, and to improve and maintain the Service. As part of providing the Service to you, the Service may process certain student UGC in its facilitation of a “pre-scoring” feature. The Service’s pre-scoring feature is only available in connection with certain student activities and assessments (e.g., multiple choice, word-search, and matching activities), and teachers, catechists, or school administrators are provided an opportunity to either accept or reject these Service-generated pre-scores.
- Navigational and Device Information: When an Authorized User accesses the Service, the computer, phone, or other device being used provides navigational information, such as browser type and version, service-provider identification, IP address, the site or online service from which the Authorized User came, and the site or online service to which the Authorized User navigates, which is stored in the Service’s service logs. We may also collect device-specific information when you install and use the Service’s mobile application including your device model, operating system information, and mobile application version and usage information. (Collectively, “Navigational and Device Information”, and collectively with Account Information and UGC, “Personal Information”.) Navigational and Device Information is used to present, improve, and maintain the Service.
- Metrics data: We may collect anonymized metrics concerning Authorized Users’ usage, of the Service (“Metrics”) to present, improve, and maintain the Service, and to gather aggregate information about the Service user base.
We may “de-identify” Authorized Users’ Personal Information so that the information can no longer reasonably be used to identify a person and therefore becomes non-personal information. When such de-identified or non-personal information of multiple individuals is bundled together, it is called “aggregated” information.
Sharing of Authorized Users’ Information with Third Parties.
In addition to sharing the above information with the School, we may share Personal Information with our Service Providers (defined below), provided, however, that in such a case, we will require the Service Providers not to use such Personal Information for any reason except to provide services to us. We may also share Metrics with our Service Providers for data analytic purposes. We may also share aggregated and de-identified information that cannot reasonably be used to identify any Authorized User with Service Providers and other third parties. “Service Providers” means third parties who perform services (such as data storage and email or in-Service chat providers) on our behalf.
We may share Personal Information: (i) with any successor to all or part of our business; (ii) in order to comply with a subpoena, court order, or applicable law; (iii) in order to protect the rights, property, or personal safety of users, us, or the public; and (iv) with other third parties with the consent of, and at the direction of, the School.
Retention and Deletion of Authorized User Information.
We will retain Personal Information for as long as the School remains a client of Sophia, and will delete such information, or return it to the School, upon termination of our agreement with the School. We may retain an archival copy of such Personal Information in accordance with our record retention policies.