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Privacy Policy

Effective Date: December 2024
Last Updated: December 2024

Introduction

CoGuide (“we,” “our,” or “us”) is committed to protecting the privacy and security of student data. This Privacy Policy explains how we collect, use, disclose, and protect information when you use our classroom participation monitoring service.

Information We Collect

Data We Collect

  • Participation Data: Hand raise detection, speaking patterns, response timing, and engagement metrics
  • Seat Mapping Data: Classroom seat positions and participation by location (A1, A2, B1, etc.)
  • Classroom Analytics: Aggregated participation patterns, engagement trends, and teaching insights
  • Technical Data: Device information, app usage statistics, and system performance data

Data We Do NOT Collect

  • Personal Identifiable Information (PII): No student names, addresses, or personal details
  • Facial Recognition Data: No facial images or biometric information
  • Audio Recordings: No voice recordings or stored audio content
  • Biometric Data: No fingerprint, face, or other biometric information
  • Location Data: No GPS or location tracking beyond classroom seat positions

How We Use Information

Educational Purposes Only

  • Classroom Insights: Provide teachers with participation analytics to improve teaching effectiveness
  • Engagement Analysis: Help teachers understand student engagement patterns
  • Teaching Support: Assist teachers in creating more inclusive and effective learning environments
  • Professional Development: Enable teachers to reflect on and improve their teaching practices

Data Processing

  • Real-time Analysis: Process participation data in real-time during classroom sessions
  • Local Processing: All analysis occurs on school-owned devices or school cloud infrastructure
  • Aggregated Reporting: Generate anonymous, aggregated reports for classroom insights
  • No Commercial Use: Data is never used for commercial purposes or sold to third parties

Data Storage and Security

Storage Location

  • School-Controlled: All data is stored in school-controlled cloud infrastructure or local devices
  • No Third-Party Storage: Data is never stored on CoGuide’s servers
  • Geographic Control: Schools control where their data is geographically stored

Security Measures

  • Encryption: All data encrypted in transit and at rest using industry-standard encryption
  • Access Controls: Strict access controls with role-based permissions
  • Audit Logging: Complete audit trails of all data access and modifications
  • Regular Security Updates: Continuous security monitoring and updates

Data Sharing and Disclosure

We Do NOT Share Data With

  • Third-Party Advertisers: No data shared for advertising purposes
  • Commercial Partners: No data sold or shared for commercial use
  • Government Agencies: No data shared unless legally required
  • Other Schools: No data shared between different educational institutions

Limited Sharing

  • School Personnel: Only authorized school staff can access classroom data
  • Legal Requirements: Data may be disclosed if required by law or legal process
  • Service Providers: Limited sharing with trusted service providers under strict agreements

Student Privacy Rights

FERPA Compliance

  • No Educational Records: CoGuide does not create or maintain educational records as defined by FERPA
  • No PII Collection: No personally identifiable information is collected from students
  • School Control: Schools maintain complete control over all student data
  • Parental Rights: Parents retain all rights under FERPA regarding their children’s data

COPPA Compliance

  • No Direct Collection: CoGuide does not directly collect personal information from children
  • School-Controlled: All data collection is controlled by schools, not by CoGuide
  • Educational Purpose: Data collection serves legitimate educational purposes only
  • Parental Consent: Schools obtain necessary parental consent for data collection

Data Retention and Deletion

Retention Periods

  • Configurable Retention: Schools can set their own data retention periods (7-90 days recommended)
  • Automatic Deletion: Data automatically deleted when retention periods expire
  • Manual Deletion: Schools can delete data immediately if needed
  • Complete Removal: Deleted data is permanently removed from all systems

Data Portability

  • Export Capabilities: Schools can export all data in standard formats
  • Data Migration: Schools can move data to other systems if needed
  • No Vendor Lock-in: Data is not tied to CoGuide platform
  • Open Formats: Data stored in open, accessible formats

International Data Transfers

Data Location

  • School Control: Schools control where their data is stored geographically
  • Local Processing: Data processing occurs in school-controlled environments
  • No International Transfers: Data is not transferred internationally without school consent
  • Compliance: All data transfers comply with applicable privacy laws

Changes to This Privacy Policy

Policy Updates

  • Regular Reviews: This policy is reviewed and updated regularly
  • Notification: Schools will be notified of significant changes
  • Effective Date: Updated policies will include a new effective date
  • Continued Use: Continued use of CoGuide constitutes acceptance of updated policies

Contact Information

Privacy Questions

Data Protection Officer

  • Email: [email protected]
  • Responsibilities: Data protection compliance, privacy inquiries, incident response

Legitimate Educational Interest

  • Educational Purpose: Data processing serves legitimate educational interests
  • Student Benefit: Processing benefits students by improving teaching effectiveness
  • Minimal Impact: Processing has minimal impact on student privacy
  • Proportionality: Data collection is proportional to educational benefits
  • School Consent: Schools provide consent for data processing on behalf of students
  • Parental Consent: Schools obtain necessary parental consent where required
  • Withdrawal: Consent can be withdrawn at any time
  • Informed Consent: Consent is based on clear information about data use

Your Rights

School Rights

  • Access: Right to access all data collected about your school
  • Correction: Right to correct inaccurate data
  • Deletion: Right to delete data
  • Portability: Right to export data in standard formats
  • Restriction: Right to restrict data processing
  • Objection: Right to object to data processing

Student Rights

  • No Direct Collection: Students are not directly subject to data collection
  • School Protection: Student privacy is protected through school policies
  • Parental Rights: Parents retain all rights regarding their children’s data
  • Transparency: Clear information about data practices

Compliance and Certifications

Regulatory Compliance

  • FERPA: Full compliance with Family Educational Rights and Privacy Act
  • COPPA: Compliance with Children’s Online Privacy Protection Act
  • State Laws: Compliance with applicable state student privacy laws
  • International Laws: Compliance with applicable international privacy laws

Security Certifications

  • SOC 2: Security and availability controls
  • ISO 27001: Information security management
  • Regular Audits: Third-party security audits
  • Penetration Testing: Regular security testing

Incident Response

Security Incidents

  • Detection: Continuous monitoring for security incidents
  • Response: Immediate response to security incidents
  • Notification: Prompt notification of affected schools
  • Recovery: Rapid recovery and security improvements

Data Breaches

  • Immediate Action: Immediate containment of any data breach
  • Assessment: Thorough assessment of breach impact
  • Notification: Notification of affected parties as required by law
  • Prevention: Implementation of additional security measures

Children’s Privacy

Special Protections

  • Enhanced Security: Additional security measures for children’s data
  • Minimal Collection: Minimal data collection from children
  • Parental Control: Parents maintain control over children’s data
  • Educational Focus: Data use limited to educational purposes only

Third-Party Services

Limited Integration

  • School-Controlled: All integrations are controlled by schools
  • Privacy Protection: Third-party services must meet privacy standards
  • Data Minimization: Only necessary data shared with third parties
  • Contractual Protection: Strong contractual protections for data sharing

Data Accuracy

Accuracy Measures

  • Regular Updates: Regular updates to ensure data accuracy
  • Correction Process: Easy process for correcting inaccurate data
  • Verification: Regular verification of data accuracy
  • Quality Control: Quality control measures for data collection

International Users

Global Compliance

  • Local Laws: Compliance with local privacy laws
  • Data Localization: Respect for data localization requirements
  • Cross-Border Transfers: Careful handling of cross-border data transfers
  • Cultural Sensitivity: Respect for cultural differences in privacy expectations

Questions and Concerns

Contact Us

If you have questions about this Privacy Policy or our data practices, please contact us:

Complaints

If you have concerns about our data practices, you can:
  • Contact our Privacy Team directly
  • File a complaint with your school’s data protection officer
  • Contact relevant privacy authorities
  • Seek legal advice if necessary

This Privacy Policy is effective as of the date listed above and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.