Social Learning Platform Application Privacy Policy

Last Updated: July 12, 2024

This Privacy Policy applies only to the Everyday Speech Social Learning Platform Application offered at https://slp.everydayspeech.com (the “Platform” or the “Everyday Speech Platform”). This Privacy Policy does not apply to our website at https://everydayspeech.com (the “Website”). The Privacy Policy for the website may be found at https://everydayspeech.com/privacy.

The Platform is a web and mobile-based platform designed to provide educators and students with a comprehensive, online social learning curriculum. The Platform is owned and operated by Everyday Speech, LLC, a Massachusetts limited liability company (“everydayspeech.com”, “Everyday Speech”, “Company”, “we”, “us” or “our”). Everyday Speech is committed to protecting your (collectively, “you,” “your”) personal information. We provide this Privacy Policy to inform you, the administrators, educators, and students who may interact with our Platform, of the types of information we collect, how we may use that information, and how we share it.

Capitalized terms are defined throughout this Privacy Policy. Some provisions of this Privacy Policy might only apply to these specific types of users, people or entities:

  • “Customer” refers to the employer, organizational or educational institution that has signed up for the Platform. If you have directly signed up for the Platform or otherwise purchased Platform services then you are the Customer. If you are an employee, contractor or any other type of authorized representative of the Customer and are accessing the platform in that capacity, then the provisions of the Privacy Policy for the customer’s data will also be for your data.
  • “Student” refers to any children, students, or anyone else who has a student account or student information administered by the Customer in the Platform.

Our use of your personal information may also be governed by a separate written agreement between us and the Customer regarding their right to use the Platform (a “Customer Agreement”). To the extent that the terms and conditions contained in the applicable Customer Agreement conflict with the terms and conditions contained in this Privacy Policy, the terms and conditions contained in the applicable Customer Agreement shall govern our collection, use, and sharing of your personal information.

By using or accessing the Platform, you agree to the terms of this Privacy Policy.

Information We Collect and How We Collect It

Information You Provide

We collect and store information that you voluntarily provide to us, as well as data related to your use of the Platform. When you use the Platform, you may choose to provide us with:

  • User Account Information including first name, last name, email address, username, and password.
  • Payment and Transactional Data including the financial information required to process payments, collected by our payment processor, such as name, payment card information, bank account number, and billing information.
  • Student Information. including the optional information that you or the Customer provide about students such as first name, last name, email, session group information, assignments, session information, performance, observational notes, the Platform username and password, and student-generated content, such as student responses to open-ended questions in an interactive activity.
  • Information or Support Requests including the information you provide when you contact us for support or to request information such as your name, username, address, telephone number, email address and other information from which your identity is or may be discernible.
  • Customer Information including contact information for administrators or finance personnel as part of the setup and provision of services.
  • Platform User Communication including any information shared between users of the same Customer, which could include sensitive information, personally identifiable information, education records, or protected health information.
  • Surveys and User Research including any responses that you elect to share that answer questions provided by us as feedback on the Platform and its services. 

Information We Collect Automatically

When you use the Platform, our system automatically captures certain information. The information collected from your browser may include your Internet Protocol (IP) address, which browser type and version you are using, the name of the domain and host you are using to access the internet, the type of device you are using, and your device’s unique device ID. Additionally, we may collect the pages of the Everyday Speech Platform you visit, the time spent on each page, the activities on each page you engage with, and the access times and dates for each visit. We collect this data automatically to monitor and improve the Platform. We collect this data with features such as:

  • Cookies. We may use cookies, persistent data files provided by the application to your computer or mobile device, to help us better understand your usage of the application and aggregate performance and activity data over time.  
  • Analytics. We may use third-party service providers to help us better understand and use automatically collected information.

Our use of cookies and analytics technologies allows us to better service your usage of the application.

Information Provided About You

We may receive information about you from the Customer such as when they share user account information to connect you to the Platform. Additionally, we may supplement the information we collect with records from third parties, such as a single-sign-on provider, for purposes, including to help us correct our records, to enhance our ability to serve you, or to help detect and prevent fraud. We may also supplement Customer information from third parties to tailor the Platform and other communications to you.

To the extent we combine information we receive from those sources with your personal information, the combined information will be treated as personal information under this Privacy Policy, unless we have disclosed otherwise.

Using the Information We Collect

We collect personal information to provide the Platform to our customers. We may use personal information as follows:

  • Provision of the Platform. We may use your personal information and usage information to support the delivery of our services on the Platform.
  • Support the Platform. We may use the information you provide us to service any customer support you request, including troubleshooting problems and monitoring such requests.
  • Improve the Platform. We may use the information you provide us to customize, measure, and improve the Platform through various analytical methods and user research.
  • Announce updates to the Platform. We may occasionally share information with Customers about new products and features. You may remove your name from our product announcement list to stop receiving these feature and product improvement notifications.
  • Protect the Platform. We may need to use the information to protect our rights, prevent fraud, and keep the security of Everyday Speech, our employees, our customers, and your data.

Can We Use De-Identified Information?

In addition to the uses of personal information above, we may remove the identifiable parts of your information to create de-identified forms (“De-identified Information”). This process involves removing or masking details such as names, geographic location, student-generated content and any other data that can be used to trace back to a specific student or school, with or without additional context about that student. De-identified Information may be compiled with other data in aggregated forms. We use this De-identified Information in the following ways:

  • Improving Our Services: We may use De-identified Information for improving our product and services including to the Platform as well as sharing it with our third-party service providers to help us better deliver and improve our services to you.
  • Compliance and Reporting: We may use aggregated De-identified Information to compile reports that demonstrate compliance with educational standards, regulations and the Platform’s effectiveness. These reports may be shared with interested parties, potential or current customers, or published online to showcase the impact and efficacy of our services.
  • Research: We may aggregate De-identified Information to conduct research aimed at developing new educational tools and resources or describing trends and patterns. This research may be used internally, published online, or presented at industry conferences and other educational research seminars.

How Do We Share The Information We Collect?

We do not sell, rent or trade your personally identifiable information to third parties.We use third-party service providers to provide you with the Platform, and will share personally identifiable information with them as reasonably necessary to provide you the service requested. We may be required to share personal information with law enforcement as required to do so by court order or other legal process to comply with statutes or regulations, to enforce our Terms of Use, or if we believe in good faith that disclosure is necessary or appropriate to protect the rights, property, or safety of our users, our customers, and Everyday Speech.

As a part of business transfers, such as mergers or acquisitions, it is possible that our assets are merged with or acquired by a third party. Your personal information will likely be one of the transferred assets for uses, such as continuing to provide Platform services.

Information collected by or sent to us is stored and processed in the continental United States. If you access the Platform outside of the United States, we reserve the right to transfer your personal information outside of the country where you reside and/or from which you use the Platform to the United States. By using the Platform, you consent to any such transfer of information to the United States.

Children’s Privacy

We value and strive to follow additional privacy protections with respect to personal information we may collect from children under the age of 13. When we intend to collect personal information from children, we take additional steps to protect children’s privacy as more specifically set forth in this section. This section of the Privacy Policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”) and outlines our practices in the United States regarding our collection, use, and disclosure of children’s personal information.

The Information We Collect From Children

In addition to the personal information we collect as provided in this Privacy Policy, with respect to children under the age of 13 we may collect certain personal information of a child using the Platform, such as learning, tutoring, or support activities. See the “Student Information” under the “Information we collect and how it is collected” section for information on the data we collect. All of the children’s personal information (“Children’s Information”) is considered Student Information, because we collect the information as authorized by an educational institution and we limit the use of the information to an educational context.

The Children’s Information will then be associated with other personal information about the child that we maintain in the account created by the child’s educational institution to which the child belongs. We will retain Children’s Information only for as long as is reasonably necessary to fulfill the purpose(s) for which the information was collected. We will not require a child to provide more information than is reasonably necessary to provide the services, and their personal information will only be used for the purposes set forth in this policy and any additional agreements with the Customer and not for other commercial purposes.

How We Use and Disclose Children’s Information

We use and disclose the Children’s Information to provide the Platform and as described in the section of this Privacy Policy entitled “How We Use and Disclose Information.” Generally, we may disclose and share Children’s Information with our service providers that enable us to provide the Platform and the teacher or educational institution to which the child belongs. We do not sell Children’s Information, use it for targeted advertising, or advertise to children on our platform.

Consent for the Collection, Use, and Disclosure of Children’s Information

We collect personal information about Students under the age of 13 solely through the authorization of the Customer. When a school or district partners with us, they act as the primary custodian of Children’s Information, providing consent on behalf of parents or guardians. This delegated consent process allows schools to manage and control the sharing of Children’s Information with our services. We expect that the Customer will provide parents with a notice of this arrangement.

Compliance with U.S. Student Privacy Laws

Everyday Speech is committed to complying with applicable U.S. federal and state laws governing students’ privacy, including the Family Educational Rights and Privacy Act (“FERPA”)( 20 U.S.C. § 1232g; 34 CFR Part 99 ), the Pupil Privacy Protection Amendment (PPRA) and COPPA. The Customer is responsible for consent or notification in instances where parental or guardian consent or notification is required.

Customers subject to FERPA agree that Everyday Speech is under their direct control with respect to use and control of applicable education records and that they shall maintain this relationship as required by FERPA. Everyday Speech agrees to be bound by the relevant provisions of FERPA, including that we will remain under the “direct control” of the Customer, with respect to the use and handling of “education records” as the term is used in FERPA and will use education records only for authorized purposes.

Retention of Your Information

We will retain your personal information for as long as necessary to fulfill any of the legal, contractual, or business purposes for which we collected the personal information as listed in this Privacy Policy.

You can choose to cancel or delete your entire account at any time. If you choose to cancel, we will retain your data in case of reactivation for no longer than 120 days. We may retain Customer profile information for a commercially reasonable time for backup, archival, or audit purposes, but any and all identifiable Student Information associated with the Customer will be deleted.

Security

We have a multi-tiered approach to protecting your personal data that includes organizational and technical safeguards. Our security program aligns with the National Institute of Standards and Technology Cybersecurity Framework (NIST CSF). We rely on this industry standard to guide us on protecting the personal information submitted to or collected by us, both during transmission and once we receive it. We aim to protect personal data against known and anticipated threats through policies and controls. Our security controls include industry-standard data encryption in transit and at rest, role-based access controls, and web application firewalls. Everyday Speech restricts access to personal data to a need-to-know basis and maintains a disciplinary process for any violations.

Jurisdiction Specific Disclosures

Some jurisdictions may require additional disclosures. To view disclosures specific to U.S. jurisdictions and determine whether they apply to you, visit https://everydayspeech.com/state-specific-disclosures/.

Updates of this Privacy Policy

Each time you use or access the Platform, the current version of the Privacy Policy will apply. We will occasionally update this Privacy Policy to reflect changes in our Platform and/or business practices. Unless otherwise stated, our current Privacy Policy applies to all information that we have about you. You will be notified at least 30 days in advance of any material changes to our Privacy Policy coming into effect. Customers with concerns on any changes should reach out to their account representative to have them addressed within those 30 days. The “last updated” date at the top of this policy indicates when it was last revised.

Governing Law

This Privacy Policy is governed by the laws of the Commonwealth of Massachusetts, without giving effect to any principles of conflict of law.

Contact Us

To contact us with your questions or comments regarding this Privacy Policy or our information collection and dissemination practices, please contact us at: [email protected] or 617-564-3143.