Privacy Policy

For the purpose of this section, Personal Information is defined as information that identifies, relates to or could reasonably be linked with or describes an individual or household, either directly or indirectly. We may combine, augment, or extend the data we collect with additional data from third-party sources.

• Data you provide to us: We collect information created or uploaded to the product by users through their use of our Products and Services. This may include student records uploaded by teachers or administrators and any information entered into the product by users. For example, teacher's names and email addresses used when registering accounts, and the content of interviews and interactions when students use Polaris Education. Please note, we require student users to opt-in to entering their personal information directly into the service.
• Data from third party sources: We allow teachers and administrators to add information about students and classes directly into the product manually or via third party tools used by schools. The data collected from these tools, including information provided by teachers, administrators, and all student records, is used solely for the purpose of delivering and supporting the service.
• Data collected automatically: When you use our services, we may use cookies and similar technologies that collect certain technical and usage information to deliver the services and better understand how you use the product. For more information on cookies and similar technologies, please see the Cookies and Similar Technologies section below.

We limit the data we process and collect from users of the product and students to only what is required to deliver the services. We use the collected data for the following purposes:

• Service delivery and App Functionality (such as provide, operate and improve the service and our business, review, screen and monitor user created content)
• Account Management
• Product Personalization
• Research and product improvement
• Security and Compliance with applicable laws
• Send communications and help you use the service better
• Marketing our services to teachers and administrators

Polaris Education is an empathy interview tool that enables teachers and school leaders to collect, record, and understand student feedback on curriculum, extracurricular activities, and other resources and materials. The Polaris Education app collects feedback from students through written and audio recording submissions and allows teachers and school administrators to view individual and aggregated responses.

When students use Polaris Education through their school, their accounts are established and managed by the school. Teachers may create or choose question sets for students and assign those questions directly to students via the service. Beyond the assignment of survey questions from teachers to students, the service does not facilitate social interactions between users.

All platform users are registered through their school accounts. Furthermore, the service does not allow interactions between non-authorized users, nor does it enable external sharing or posting of information. We take steps to anonymize and aggregate student submissions where possible. To support the safety of student users, we review and monitor chat content within our platform in compliance with applicable school mandatory reporting requirements. When harm is detected, we may de-anonymize student submissions in order to follow reporting requirements.

Our service is free of advertising, including contextual and personalized ads. Additionally, we do not solicit user participation in third-party sweepstakes, contests, or promotional activities. We may, with your consent, send teachers and school leaders first-party marketing communications about our services, from which you can opt out at any time.

As part of providing our services, we may share data with third party sub processors who process information to help us provide our services. This includes product functionality, analytics, onboarding, research, and product improvement.

We establish contractual limitations with third party sub processors that restrict the extent and purposes for which they may process any personal information we disclose to them. These third parties are permitted to process personal information solely on our behalf and in accordance with our instructions. They are also required to implement and maintain security measures that provide a level of protection equivalent to those we uphold. You can view the vendors we use to process data, and the purposes for which they are used to provide our product, below.

Below is a list of our data sharing partners along with links to their privacy policies for your information.

For the avoidance of doubt, we never sell personal data from our service and we do not share data with third parties for their own marketing, advertising purposes, or creating advertising profiles.

We do not display your personal information that you have submitted to us or that we have collected in the product. This does not prevent users from posting their own personal information through social features or otherwise.

We may disclose information, including personal information, if we have a good faith belief that doing so is necessary to comply with the law, such as complying with a subpoena or other legal obligation.

To use our Products and Services, users are required to create an account. During the account creation process, we will collect certain information to establish and manage your account effectively. Our platform is equipped with access control mechanisms, allowing you to define, manage permissions for your data, and control any information you provide to us. Certain account controls may be accessible only to account administrators.

We may contact teachers or administrators for our own direct marketing or to provide guidance on how to better utilize the product and to inform them about our services. You can stop receiving email communications from us by clicking "unsubscribe" in such communications or contacting us directly. We make every effort to promptly process all unsubscribe requests.

The Service may contain links to websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or other online services that are not associated with us. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions.

Third-party login through Google is supported for authentication into our Product or Services. When you choose to log in to our services using third-party authentication, such as through social media accounts or other external identity providers, we collect certain information from your chosen third-party platform. This may include basic profile details, such as your name, email address, and profile picture. By opting for third-party login, you grant us permission to access and use this information for the purpose of creating and managing your account, as well as enhancing your overall experience with our services. We may also request additional permissions during the authentication process, depending on the requirements of the third-party provider.

Our Product may use cookies to help you personalize your online experience. A cookie is a text file that is placed on your device browser that stores preferences to facilitate and enhance your experience. For example, if you register with our Product or Services, a cookie helps our product to recall your specific information on subsequent visits.

For clarity, we do not use third-party cookies on our service for personalized advertising or to track users and display personalized advertisements on other third-party websites or services. You can find a list of the types of first and third party cookies we use below:

Functional cookies: Enable the core operation of our Products and Services and cannot be switched off in our systems. They include cookies that we use to help control secure areas of our site and to make sure it is accessible to you. You can set your browser to block or alert you about these cookies, but some parts of the site will not work as a result.

Analytics cookies: These cookies allow us to collect information about patterns of behavior among people using the site. Analytics cookies allow us to count site visits and understand traffic sources so we can measure and improve the performance of our site. We never collect any information from analytics cookies that could be used to personally identify you.

We are dedicated to safeguarding the security of information obtained through the services, including personal information. When we collect information from you, we implement reasonable and appropriate administrative and technical safeguards to help protect it from unauthorized access, use, or disclosure. For example, all data is encrypted during transmission and at rest.

While we implement robust security measures, please be aware that no system is completely secure, and we cannot guarantee absolute security of your information. In the event of a data breach, we will make reasonable efforts to notify affected users in accordance with applicable laws and regulations.

We retain personal information only as long as necessary for the purposes for which it was collected. If a school cancels or terminates their account, user data associated with that account will be deleted. In some cases, we may retain personal data beyond the length of time that you have an account with us in order to resolve disputes, comply with legal and compliance obligations, or otherwise.

Except as otherwise provided, this section applies to residents of states where they have privacy laws applicable to us that grant their residents the rights described below.

For purposes of this section, "personal information" has the meaning given to "personal data", "personal information" or similar terms under the applicable privacy laws of the state in which you reside. Please note that not all rights listed below may be afforded to all users and that if you are not a resident of the relevant states, you may not be able to exercise these rights. In addition, we may not be able to process your request if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to it.

In some cases, we may provide a different privacy notice to certain categories of residents of these states, such as job applicants, in which case that notice will apply with respect to the activities it describes instead of this section.

Verification: Upon receipt of your request, we will initiate the identity verification process to confirm that you are the individual for whom we hold information in our system. This verification procedure necessitates your cooperation in supplying relevant information, allowing us to compare it with the details you previously furnished. Depending on the nature of your request, we may request specific information to align with our existing records, or we may reach out to you using a previously provided communication method (such as phone or email). In certain situations, alternative verification methods may be employed based on the circumstances.

Any personal information disclosed in your request will solely be utilized for the purpose of confirming your identity or validating your authority to make the request. We will make every effort to minimize the need for additional information for verification purposes. However, should it be impossible to verify your identity with the existing information in our records, we may request additional details to ensure security and prevent fraud. Any supplementary information you provide for verification will be promptly deleted upon the completion of the verification process.

Authorized Agents: Your authorized agent may be able to make a request on your behalf. However, we may need to verify your authorized agent's identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.

• Access: You can request access to the personal information that we have collected about you.
• Correction: You can request that we correct inaccurate personal information that we have collected about you.
• Deletion: You can request that we delete your personal information. Please note that once we process a deletion request, we may be unable to provide access or support to any past products or services.
• You have the option to opt-out of specific tracking activities related to targeted advertising, also referred to as interest-based advertising. According to the CCPA, this involves the 'sharing' of your personal information with advertising partners.
• End users have the option to opt-out of their personal information being sold or shared with third parties. You have the right to request details on the personal information that we sold, shared, or disclosed to a third-party for a business purpose.

Please note that Polaris Education does not track users for interest based advertising, share user information with advertising companies, or sell user information.

Users can exercise their privacy rights with Polaris Education by contacting their school or district to access, correct, or delete their conversation data, or by opting out of audio recording and advocacy use during the consent process.

We comply with the U.S. Children's Online Privacy Protection Act and Family Educational Rights and Privacy Act, and describe our practices regarding the processing of personal information for users under the age of 13 below. Our service is designed to be used by teachers, administrators, and students in an educational context. As part of our services, we may process student records and data from children 13 years of age and under, as provided to us by schools, teachers, and directly from students.

When we provide services on behalf of a school, the school provides consent for Polaris Education to collect and process information from students under the age of 13 as permitted by the Children's Online Privacy Protection Act. As described in the notice we provide to schools, we collect, maintain, use and share student records only for authorized educational purposes.

We are committed to protecting the privacy and data of students and children and do not require more information about students or children than is reasonably necessary to provide the service. In addition:

• We collect, maintain, use and share student records only for an authorized educational purpose.
• We do not use or disclose student records for targeted advertising or any other commercial purposes unrelated to education.
• We do not build a personal profile of a student other than to deliver our service.

Student records that we process on behalf of schools and educators remain under the control of the respective school. To request access to, modification of, or deletion of student records, please contact the school that maintains those records directly.