Last updated: April 2, 2024.
This Privacy Policy explains how Lightsmith Consulting LLC, dba Transparent Classroom is committed to protecting your privacy and ensuring that you feel comfortable using our Transparent Classroom software (our âServiceâ). 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. âPersonal Informationâ 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 (âIPâ) 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 âDe-Identified Dataââ).
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:
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 childâs school.
In order for you to register with our Services, your childâs 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:
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 âlegitimate interestsâ or the legitimate interest of others (e.g. our users) such as:
We collect and/or process your Personal Information in connection with the following activities related to our Services:
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.
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:
Parents may also access theirs and their childâs Personal Information through the Transparent Classroom website. Further, you may edit and delete some of your and your childâs Personal Information we collect through the Transparent Classroom website.
Parents with children in the same classroom can see:
Parents with children in the same school but different classrooms donât 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:
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.
Transparent Classroom does not sell or rent your (or your childâs) 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 Commissionâs 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:
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.
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.
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.
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.
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.
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.
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:
If you have any questions about the security or retention of your Personal Information, please contact us at privacy@transparentclassroom.com.
This Privacy Policy and the privacy practices of Transparent Classroom is governed by the internal laws of the State of Washington, United States.
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.
We permit residents of California to use our service, and fully comply with Californiaâs privacy laws. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/ccpa. Californiaâs âShine the Lightâ 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.
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 childâs 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.
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 Classroomâs operations based in the US, we rely on the EU-U.S. Data Privacy Framework (âEU-U.S. DPFâ), the UK Extension to the EU-U.S. DPF (âUK-U.S. DPFâ), and the Swiss-U.S. Data Privacy Framework (âSwiss-U.S. DPFâ) as set forth by the U.S. Department of Commerce. To learn more about the Data Privacy Framework (âDPFâ) 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 (âDPFâ) 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 Commissionerâs Office (ICO), the Gibraltar Regulatory Authority (âGRAâ) and the Swiss Federal Data Protection and Information Commissioner (âFDPICâ) 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 Classroomâs 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 Classroomâs Terms of Service also include a Data Protection Addendum (DPA), which incorporates The European Commissionâs Standard Contractual Clauses (or âSCCsâ). 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 (âEEAâ) 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 Commissionâs 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 Classroomâs 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 Commissionâs 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.
Prior to use of Transparent Classroom in Australia, informed consent must be provided by the parents of each child in your school that their childâs 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.
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 Classroomâs 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.
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.