International Privacy Policy

1. INTRODUCTION

Seesaw Learning, Inc’s (“Seesaw“, “we“, “us” or “our“) mission is to create an environment where students can be their best. Protecting your and your child(ren)’s privacy is fundamental to our mission and business. We operate a learning experience platform that brings together premium instructional tools and curriculum, inclusive two-way communication, deep learning insights and progress monitoring (the “Seesaw Service“).

This International Privacy Policy (this “Privacy Policy”) sets out how we collect, store, process, transfer, share and use data that identifies, can reasonably identify or is associated with you or, if a parent, your child(ren) (your “Personal Information”) when you access or use the Seesaw Service outside the United States.

The terms of this Privacy Policy are generally applicable to your access and use of the Seesaw Service. However, we indicate where additional parts of this policy apply ONLY if you access and use the Seesaw Service from Australia, Brazil, the EEA, New Zealand, Canada, or the UK. This privacy policy is designed to comply with the requirements of the right to be informed under the UK General Data Protection Regulation (UK GDPR) and the EU General Data Protection Regulation (GDPR), the Brazilian General Data Protection Law (LGPD) as well as the notification obligations set out in Australian Privacy Principle 5 and New Zealand’s Information Privacy Principle 3.

Please ensure that you have read and understood this Privacy Policy before accessing and using, or, if you are a parent, allowing your child(ren) to access or use the Seesaw Service. If you have any questions, comments or requests regarding this Privacy Policy, please contact us using the details set out in the “How to contact us” section below.

2. WHO IS RESPONSIBLE FOR YOUR PERSONAL INFORMATION?

We work with schools to make the Seesaw Service available to school administrators, teachers, students (i.e. parent’s child(ren)) and parents. How we share responsibility for using your Personal Information between us and the school, or, where applicable, the local authority or education board responsible for managing suppliers and service providers for the school (the “school administration”) will vary depending on where the school or school administration is located.

Information for schools and users in the UK or EEA

“Controller” means the entity that determines how and why your Personal Information is collected and used.

“Processor” means the entity that processes your Personal Information at the instruction of the controller. The controller remains responsible for your Personal Information at all times.

Where we act as a “processor”

We mostly use Personal Information as a processor on behalf of the relevant school or school administration. This means that the school or school administration determines and is responsible for how we process Personal Information.

For further information about how we process Personal Information on behalf of schools and school administrations, you can view the descriptions in our Data Processing Agreement. However, if your school uses the Seesaw Service and has uploaded your Personal Information to the Seesaw Service, you should consult that school’s privacy notice for information about how that Personal Information is used.

If you sign up as a teacher to the Seesaw Service with a free account, you must make sure that you have the relevant school’s authorisation to do so. When you sign up with your school’s authorisation, we will process Personal Information uploaded to the Seesaw Service as a processor on behalf of your school; however, if you sign up independently or without the school’s authority you will be the controller of, and responsible for the processing of Personal Information relating to students and parents that you or they upload to the Seesaw Service. We will use such Personal Information as a processor on your behalf as set out in our Data Processing Agreement.

Where we act as a “controller”

We also may process some Personal Information as a controller as described in this Privacy Policy, meaning that we determine and are responsible for how your and, if you are a parent, your child(ren)’s Personal Information is used.

Where we act as “joint controllers”

For certain processing described in the section headed “Information collected automatically about all users of the Seesaw Service”, we act as a joint controller with the relevant school or school administration, meaning that we jointly determine and are responsible for how your Personal Information is used.

We and the school have allocated responsibility for complying with our obligations under applicable data protection law as follows:

Information about how we use your Personal Information: we will provide you, on behalf of both us and the school, with information in this Privacy Policy about how your Personal Information is used by us as joint controllers.
Your rights: we will serve as the primary contact point for exercising your rights in respect of the Personal Information we process as joint controllers (as further described in the “Your Privacy Rights” section below). If you would like to exercise your rights in respect of your Personal Information, you can do so by contacting us using the details in the “How to contact us” section below.
Security: we will store and maintain safeguards to ensure that the Personal Information we process as joint controllers is kept secure.
Lawfulness: we have determined the lawful basis relied on for processing your Personal Information as joint controllers, as set out in the section headed “Information collected automatically about all users of the Seesaw Service” below.
Transfers: we have implemented safeguards for the transfers of your Personal Information we undertake, including transfers outside of the jurisdiction you are in, as set out in the “International Transfers” section below.

Information for schools and users in Canada, Australia and New Zealand

Apart from as expressly stated in this Privacy Policy (or as directed by your school administration), Seesaw does not access, collect, use or disclose any Personal Information of teachers, parents or the child(ren) of parents which, at all times, remains under the control of your school or school administration. Please refer to your school’s privacy policy as to how your information is collected, used and/or disclosed by your school administration.

Before allowing a student to use the Seesaw Service you, as a teacher or school administrator (as determined in accordance with your school’s policies) must obtain parental or guardian approval for that student (i.e. their child) to use the Seesaw Service. In doing so, you must provide a copy or a link to this Privacy Policy to the student’s parent/guardian and explain that Seesaw will collect, use and disclose their and their child(ren)’s Personal Information in accordance with this Privacy Policy.

Without limiting the above, school administration, teachers and parents that upload any Personal Information into the Seesaw Service must obtain the approval of all third parties (other than a parent’s child(ren)) whose Personal Information is uploaded to or used in the Seesaw Service by you, including referring them to this Privacy Policy.

3. HOW TO CONTACT US

You can contact us anytime with questions about this policy at https://help.seesaw.me/hc/en-us/requests/new or by email at privacy@seesaw.me.

If you are in Canada, you can contact our privacy officer at privacy@seesaw.me.

If you are in the EEA / UK, you can contact our data protection officer directly by email to dpo@seesaw.me.

You can also contact our EU and UK Representative, VeraSafe by completing the form at https://www.verasafe.com/privacy-services/contact-article-27-representative or by post to the following address:

EU Representative	UK Representative
VeraSafe Ireland Unit 3D North Point House North Point Business Park New Mallow Road Cork T23AT2P Ireland	VeraSafe UK 37 Albert Embankment London SE1 7TL United Kingdom

Data Protection Officer

We have appointed VeraSafe as our Data Protection Officer (DPO) in the EU and UK. While you may contact us directly, VeraSafe can also be contacted on matters related to the processing of Personal Information.

VeraSafe LLC
100 M Street S.E., Suite 600
Washington, D.C.
20003
USA
Email: experts@verasafe.com
Web: https://www.verasafe.com/about-verasafe/contact-us

4. PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT

The Personal Information we collect and how we use it depends on your role and how you use the Seesaw Service. Please select from the following to jump to the appropriate section, which sets out what information we collect, how we use it and (for individuals in Brazil, the EEA or UK) the lawful basis we rely on for processing with. For individuals in Canada, notwithstanding any lawful basis identified below, when we control and are accountable for your personal information (which we refer to throughout as acting as an “accountable organization”), we will obtain your consent (which may be express or implied) except as otherwise permitted or required by law:

Information for schools and users in Australia and New Zealand

The information contained in this section constitutes our notification to you of our collection, use and disclosure of your Personal Information in accordance with Australian Privacy Principle 5 and New Zealand’s Information Privacy Principle 3.

If you are in Australia, by using the Seesaw Service you (and, if a parent, on behalf of your child(ren)) consent to the Seesaw’s collection of any of your sensitive information (as defined in the Privacy Act 1988), including in the following information types listed in Section 6 of this Privacy Policy:

Content and posts uploaded to online classrooms by teachers
Activities designed using the Seesaw service hosted on the ‘Community Library’
Messages sent between teachers and students/your child(ren)through the Seesaw service
Activities assigned to the student/your child(ren) by their teacher and completed by the student including their responses
Content (images, text, audio) uploaded by the student as part of their journal on the Seesaw Service
Profile photo used on a teacher’s/student’s account

Information for individuals in Brazil

The purposes for which we process Personal Information are described in the tables below. Seesaw does not process Personal Information for unlawful, abusive or discriminatory practices.

Prospective customers

If you, as a school administrator or teacher, contact us as a prospective customer to express an interest in the Seesaw Service, we will collect and process the following Personal Information. If you are in Brazil, the EEA or UK, we process this Personal Information as a controller with, and if you are in Canada, we process this Personal Information as an accountable organization:

Your contact information, such as your name, email address and the name of the school board, district or administration you work for.

How we use it	Lawful basis we rely on (EEA / UK / Brazil)
We use this information to communicate with you, including responding to your queries, comments or requests for further information about the Seesaw Service.	The processing is necessary for our legitimate interests, namely communicating with prospective customers.
We use this information to send you promotional emails in accordance with your preferences.	The processing is necessary for our legitimate interests, namely promoting the Seesaw Service.

The content of any queries or comments that you submit to us.

How we use it	Lawful basis we rely on (EEA / UK / Brazil)
We use this information to respond to and address your questions, issues and concerns.	The processing is necessary for our legitimate interests, namely communicating with prospective customers.

We may occasionally receive the contact information described above from third party sources and use that information to reach out to you about the Seesaw Service. For further information about how we collect and use this information in this way, please see our Indirect Collection Notice.

Visitors to our website

We automatically collect certain Personal Information about how you access and use our website at www.seesaw.com (our “Website”), and information about the device you use to access and use the Website. We collect and process the following information in this way and, if you are in Brazil, the EEA or UK, we do so as a controller, and if you are in Canada we do so as an accountable organization:

Information about the device you use to access the Website, such as IP address, unique device identifying numbers, type of device used, operating system, screen size, browser type, browser window size and device model and your approximate location derived from your IP address.

How we use it	Lawful basis we rely on (EEA / UK / Brazil)
We use information about how you use and connect to the Website to present the Website to you on your device.	The processing is necessary for our legitimate interests, namely to provide the Website to the user.
We use this information to monitor and detect fraud or suspicious activity on our Website.	The processing is necessary for our legitimate interests, namely monitoring fraud and suspicious activity on our Website.
We aggregate this information to monitor the performance of the Website, to identify errors and ways in which we can improve the Website, including developing new features of the Website.	We will only use your Personal Information in this way to the extent you have given us your consent to do so.
We use this information alongside our advertising partners, as described in the section headed “Online advertising” below to serve you targeted advertising on other websites that you visit, and to identify how effective those advertisements are.	We will only use your Personal Information in this way to the extent you have given us your consent to do so.

Information about how you interact with the Website, such as the pages you view and features you use on the Website, and any errors that occur on our Website while you are using it.

How we use it	Lawful basis we rely on (EEA / UK / Brazil)
We use information about how you use and connect to the Website to present the Website to you on your device.	The processing is necessary for our legitimate interests, namely to provide the Website to the user.
We use this information to monitor and detect fraud or suspicious activity on our Website.	The processing is necessary for our legitimate interests, namely monitoring fraud and suspicious activity on our Website.
We aggregate this information to monitor the performance of the Website, to identify errors and ways in which we can improve the Website, including developing new features of the Website.	We will only use your Personal Information in this way to the extent you have given us your consent to do so.
We use this information alongside our advertising partners, as described in the section headed “Online advertising” below to serve you targeted advertising on other websites that you visit, and to identify how effective those advertisements are.	We will only use your Personal Information in this way to the extent you have given us your consent to do so.

School administrators

If you are responsible for procuring and managing relationships with vendors and suppliers at your school or at the relevant school administration, or are otherwise the primary contact for a school or school administration’s use of the Seesaw Service, we will collect the following Personal Information about you:

The classes you create on the Seesaw Service (including the grade / year, the names of the students and their parents), the schoolwork and activities you set for these classes, content and posts you upload to online classrooms as on the Seesaw Service, your feedback on student activities on the Seesaw Service and the messages you send through the Seesaw Service. We use this information to provide the features and functionalities of the Seesaw Service. If you are in Brazil, the EEA or UK, we use this information only as a processor for the relevant school or school administration. If you are in Canada, we use this information only as a service provider for the relevant school or school administration. If you are in Canada, we use this information in this way primarily as a service provider for the relevant school or school administration.

Your contact information, such as your name, email address, phone number, and the school or school board or other administrative body that you work for. We use this information to create and authenticate your account on the Seesaw Service, send you service-related communications in accordance with your preferences and to respond to support requests. If you are in Brazil, the EEA and UK, we use this information in this way primarily as a processor for the relevant school or school administration. We also use your contact information as a controller/accountable organization as follows:

How we use it	Lawful basis we rely on (EEA / UK / Brazil)
Communicate with you in relation to the administration of our relationship with the relevant school or school administration.	The processing is necessary for our legitimate interests, namely administering our contracts and relationships with our customers.
We use this information to send you promotional emails in accordance with your preferences.	The processing is necessary for our legitimate interests, namely promoting the Seesaw Service.

Third party account information. If you choose to link a third-party account with the Seesaw Service, such as a Google or Clever account, we will link that third-party account with your Seesaw account and, subject to the data sharing preferences you have set with respect to that third-party account, receive the above account information from that third-party account provider. We use this information to create and authenticate your account on the Seesaw Service, send you service-related communications in accordance with your preferences and to respond to support requests.

If you are in Brazil, the EEA or UK, we use this information in this way primarily as a processor for the relevant school or school administration. If you are in Canada, we use this information in this way primarily as a service provider for the relevant school or school administration.

We also use the contact information we receive from the third-party account provider as a controller/accountable organization as follows:

How we use it	Lawful basis we rely on (EEA / UK / Brazil)
We use this information to send you promotional emails in accordance with your preferences.	The processing is necessary for our legitimate interests, namely promoting the Seesaw Service.

Questions, comments and other correspondence that you send us through our helpdesk, such as support requests or queries relating to the Seesaw Service. We use this information to respond to support requests.

If you are in Brazil, the EEA or UK, we use this information primarily as a processor for the relevant school or school administration. If you are in Canada, we use this information primarily as a service provider for the relevant school or school administration.

We also use the questions, comments and other correspondence you send to us and process it as a controller as follows:

How we use it	Lawful basis we rely on (EEA / UK / Brazil)
We use this information to identify ways in which we can improve the Seesaw Service, including fixing errors in the Seesaw Service or developing new features and functionalities on the Seesaw Service.	The processing is necessary for our legitimate interests, namely informing our product development and improvement.
If you submit support questions to Ada, our AI in-product support chatbot, we will use the transcript of your interaction with the chatbot to train and improve the chatbot.	The processing is necessary for our legitimate interests, namely informing our product development and improvement.

Communication preferences, such as your preferences for service-related communications and promotional emails. We process your preferences for service-related communications to ensure that we only send you communications in accordance with your preferences.

If you are in Brazil, the EEA or UK, we use this information primarily as a processor for the relevant school or school administration. If you are in Canada, we process your information in this way as a service provider for the relevant school or school administration.

We also use the questions, comments and other correspondence you send to us and process it as a controller/accountable organization as follows:

How we use it	Lawful basis we rely on (EEA / UK / Brazil)
We use this information to comply with our obligations to send you promotional messages only in accordance with your preferences.	The processing is necessary for our compliance with a legal obligation to which we are subject.

Community activities. If you design activities on the Seesaw Service and contribute them to our Community Library, or if you post publicly available comments and reviews to our Teacher Scrapbook we will use your screen name and the content you post and process as a controller/accountable organization as follows:

How we use it

Lawful basis we rely on (EEA / UK / Brazil)

We use this information to display the activities you contribute to our Community Library and feedback you contribute to our Teacher Scrapbook to other users of the Seesaw Service and visitors to the Website in order to:

provide community-driven resources to other teachers;
promote the Seesaw Service and community engagement between teachers using the Seesaw Service.

The processing is necessary for our legitimate interests, namely providing community features of the Seesaw Service and promoting the Seesaw Service.

Teachers (school accounts)

If you are a teacher and your school has given you access to the Seesaw Service, we will collect the following Personal Information about you:

The classes you create on the Seesaw Service (including the grade / year, the names of the students and their parents), the schoolwork and activities you set for these classes, content and posts you upload to online classrooms on the Seesaw Service, your feedback on student activities on the Seesaw Service and the messages you send through the Seesaw Service. We use this information to provide the features and functionalities of the Seesaw Service.

If you are in Brazil, the EEA or UK, we use this information only as a processor for the relevant school or school administration. If you are in Canada, we use this information only as a service provider for the relevant school or school administration.

If you switch to a free account on the Seesaw Service after your school account on the Seesaw Service is closed, you will no longer have access to this information.
Your contact information, such as your name, email address, phone number and the school that you work for. We use this information to create and authenticate your account on the Seesaw Service, send you service-related communications in accordance with your preferences and to respond to support requests.

If you are in Brazil, the EEA or UK, we use this information in this way primarily as a processor for the relevant school or school administration. If you are in Canada, we use this information in this way primarily as a service provider for the relevant school or school administration.

We also use your contact information and process as a controller/accountable organization as follows:

How we use it	Lawful basis we rely on (EEA / UK / Brazil)
We use this information to send you promotional emails in accordance with your preferences.	The processing is necessary for our legitimate interests, namely promoting the Seesaw Service.

Third party account information. If you choose to link a third-party account with the Seesaw Service, such as a Google or Clever account, we will link that third-party account with your Seesaw account and, subject to the data sharing preferences you have set with respect to that third-party account, receive the above account information from that third-party account provider. We use this information to create and authenticate your account on the Seesaw Service, send you service-related communications in accordance with your preferences and to respond to support requests.

If you are in Brazil, the EEA or UK, we process your information in this way as a processor for the relevant school or school administration. If you are in Canada, we use this information in this way primarily as a service provider for the relevant school or school administration.

We also use your contact information and process as a controller/accountable organization as follows:

How we use it	Lawful basis we rely on (EEA / UK / Brazil)
We use this information to send you promotional emails in accordance with your preferences.	The processing is necessary for our legitimate interests, namely promoting the Seesaw Service.

Questions, comments and other correspondence that you send us through our helpdesk, such as support requests or queries relating to the Seesaw Service. We use this information to respond to support requests.

If you are in Brazil, the EEA or UK, we use this information in this way primarily as a processor for the relevant school or school administration. If you are in Canada, we use this information primarily as a service provider for the relevant school or school administration.

We also use your contact information and process as a controller/accountable organization as follows:

How we use it	Lawful basis we rely on (EEA / UK / Brazil)
We use this information to identify ways in which we can improve the Seesaw Service, including fixing errors in the Seesaw Service or developing new features and functionalities on the Seesaw Service.	The processing is necessary for our legitimate interests, namely informing our product development and improvement.
If you submit support questions to Ada, our AI in-product support chatbot, we will use the transcript of your interaction with the chatbot to train and improve the chatbot.	The processing is necessary for our legitimate interests, namely informing our product development and improvement.

Communication preferences, such as your preferences for service-related communications and promotional emails. We process your preferences for service-related communications to ensure that we only send you communications in accordance with your preferences.

If you are in Brazil, the EEA or UK, we process your information in this way as a processor for the relevant school or school administration. If you are in Canada, we process your information in this way as a service provider for the relevant school or school administration.

We also use your contact information and process as a controller/accountable organization as follows:

How we use it	Lawful basis we rely on (EEA / UK / Brazil)
We use this information to comply with our obligations to send you promotional messages only in accordance with your preferences.	The processing is necessary for our compliance with a legal obligation to which we are subject.

Community activities. If you design activities on the Seesaw Service and contribute them to our Community Library, or if you post publicly available comments and reviews to our Teacher Scrapbook we will use your screen name and the content you post and process as a controller/accountable organization as follows:

How we use it

Lawful basis we rely on (EEA / UK / Brazil)

provide community-driven resources to other teachers;
promote the Seesaw Service and community engagement between teachers using the Seesaw Service.

The processing is necessary for our legitimate interests, namely providing community features of the Seesaw Service and promoting the Seesaw Service.

Teachers (free accounts)

If you sign up to the Seesaw Service with a free account, you should ensure that you have your school’s authorisation to use the Seesaw Service. If you do, we will process your Personal Information in the same way as described under Teachers (school accounts).

Your contact information, such as your name, email address, phone number and the school that you work for:

How we use it	Lawful basis we rely on (EEA / UK / Brazil)
We use this information to set up and authenticate your account on the Seesaw Service.	We will share your Personal Information with companies that provide services to us, such as
The processing is necessary for the performance of a contract between you and us, namely our Terms of Service.	We use this information to send you service-related communications relating to your account on the Seesaw Service.
The processing is necessary for the performance of a contract between you and us, namely our End User License Agreement.	We use this information to send you promotional emails in accordance with your preferences.

Third party account information. If you choose to link a third-party account with the Seesaw Service, such as a Google or Clever account, we will link that third-party account with your Seesaw account and, subject to the data sharing preferences you have set with respect to that third-party account, receive the above account information from that third-party account provider.

How we use it	Lawful basis we rely on (EEA / UK / Brazil)
We use this information to set up and authenticate a separate account for you on the Seesaw Service.	The processing is necessary for the performance of a contract between you and us, namely our Terms of Service.
We use this information to send you service-related communications relating to your account on the Seesaw Service.	The processing is necessary for the performance of a contract between you and us, namely our Terms of Service.
We use this information to send you promotional emails in accordance with your preferences.	The processing is necessary for our legitimate interests, namely providing community features of the Seesaw Service and promoting the Seesaw Service.

Information about the classes you teach (including the grade / year, the names of the students and their parents), the schoolwork and activities you set for these classes, content and posts you upload to online classrooms on the Seesaw Service, your feedback on student activities on the Seesaw Service and the messages you send through the Seesaw Service.

How we use it	Lawful basis we rely on (EEA / UK / Brazil)
We use this information to provide you with access to the learning resources, activities and teaching resources on the Seesaw Service (including feedback functionalities and features that allow you to message parents and students)	The processing is necessary for the performance of a contract between you and us, namely our Terms of Service.

Questions, comments and other correspondence that you send us through our helpdesk, such as support requests or queries relating to the Seesaw Service.

How we use it	Lawful basis we rely on (EEA / UK / Brazil)
We use this information to respond to your questions and support requests in relation to your account on the Seesaw Service.	The processing is necessary for the performance of a contract between you and us, namely our Terms of Service.
We use this information to identify ways in which we can improve the Seesaw Service, including fixing errors in the Seesaw Service or developing new features and functionalities on the Seesaw Service.	The processing is necessary for our legitimate interests, namely informing our product development and improvement.
If you submit support questions to Ada, our AI in-product support chatbot, we will use the transcript of your interaction with the chatbot to train and improve the chatbot.	The processing is necessary for our legitimate interests, namely informing our product development and improvement.

Communication preferences, such as your preferences for service-related communications and promotional emails.

How we use it	Lawful basis we rely on (EEA / UK / Brazil)
We use this information to send you service-related communications relating to your account on the Seesaw Service in accordance with your preferences.	The processing is necessary for the performance of a contract between you and us, namely our Terms of Service.
We use this information to send you promotional emails in accordance with your preferences.	The processing is necessary for our compliance with a legal obligation to which we are subject.

Community activities. If you design activities on the Seesaw Service and contribute them to our Community Library, or if you post publicly available comments and reviews to our Teacher Scrapbook we will use your screen name and the content you post as follows:

How we use it

Lawful basis we rely on (EEA / UK / Brazil)

provide community-driven resources to other teachers;
promote the Seesaw Service and community engagement between teachers using the Seesaw Service.

The processing is necessary for our legitimate interests, namely providing community features of the Seesaw Service and promoting the Seesaw Service.

Family Members

If your child’s school has signed up to use the Seesaw Service, you will be invited to access the Seesaw Service by your child’s teacher or the school administrator. When you sign up to the Seesaw Service, we will collect the following Personal Information about you:

Your contact information, such as your name, email address and phone number. We use this information to create and authenticate your account on the Seesaw Service, send you service-related communications in accordance with your preferences and to respond to support requests.
Third party account information. If you choose to link a third-party account with the Seesaw Service, such as a Google or Clever account, we will link that third-party account with your Seesaw account and, subject to the data sharing preferences you have set with respect to that third-party account, receive the above account information from that third-party account provider. We use this information to create and authenticate your account on the Seesaw Service, send you service-related communications in accordance with your preferences and to respond to support requests.
Information about linked student accounts. We use this information to link your account to your child’s account, send you relevant service-related communications relating to your child’s activity on the Seesaw Service.
Messages and comments that you send to the teacher or school administrator through the Seesaw Service. We use this information to facilitate communication between family members, teachers and schools in accordance with the functionalities of the Seesaw Service.
Questions, comments and other correspondence that you send us through our helpdesk, such as support requests or queries relating to the Seesaw Service. We use this information to respond to support requests.

If you are in Brazil, the EEA or UK, we use the information as described above as a processor for the relevant school or school administration. If you are in Canada, we use the information as described above as a service provider for the relevant school or school administration.

However, we also use your questions, comments and other correspondence and process as a controller/accountable organization as follows:

How we use it	Lawful basis we rely on (EEA / UK / Brazil)
We use this information to identify ways in which we can improve the Seesaw Service, including fixing errors in the Seesaw Service or developing new features and functionalities on the Seesaw Service.	The processing is necessary for our legitimate interests, namely informing our product development and improvement.

Students or, if you are a parent, your child(ren)

When providing the Seesaw Service to schools, we will collect and use the following Personal Information about students/your child(ren) to provide the relevant features and functionalities of the Seesaw Service:

Account information, such as name, email address and verification code provided by the teacher to allow students to access their account;
Third party account information. If a student chooses to link a third-party account with the Seesaw Service, such as a Google or Clever account, we will link that third-party account with the student’s or, as a parent, your child(ren)’s Seesaw account and receive the above account and profile information from that third-party account provider;
Profile photo to allow Students, or as a parent, your child(ren) to customise and personalise their account on the Seesaw Service;
Information about the student’s teacher and class;
Activities assigned to the student/your child(ren) by their teacher and completed by the student through the Seesaw Service;
Content uploaded by the student/your child(ren) as part of their journal on the Seesaw Service, including images, text and audio;
Feedback from teachers on student/your child(ren) work uploaded to the Seesaw Service;
Messages sent between the student/your child(ren) and their teacher on the Seesaw Service, and between the teacher and family members relating to the student/your child(ren); and
Information about linked family member accounts.

If you are in Brazil, the EEA or UK, we use information about students/your child(ren) as described above only as a processor on behalf of the relevant school or school administration. If you are in Canada, we use the information about students/your child(ren) as described above only as a service provider on behalf of the relevant school or school administration

Information collected automatically through the Seesaw Service

When you access the Seesaw Service as a school administrator, teacher or family member, we automatically collect the following Personal Information about how you access and use the Seesaw Service, and information about the device you use to access and use the Seesaw Service:

Information about the device you use to access the Seesaw Service, such as IP address, unique device identifying numbers, type of device used, operating system, screen size, browser type, browser window size and device model and your approximate location derived from your IP address.
Information about how you interact with the Seesaw Service such as the pages you view and features you use on the Seesaw Service, and any errors that occur on the Seesaw Service while you are using it.
We use information about how you use and connect to the Seesaw Service to:
present the Seesaw Service to you on your device; and
monitor and detect fraud or suspicious activity on our Seesaw Service.

If you are in Brazil, the EEA or UK, we use information about how you use and connect to the Seesaw Service:

as a processor on behalf of the relevant school or school administration to present the Seesaw Service to you on your device;
as a controller if you sign up to or retain a free account as a teacher without your school’s authorisation. The lawful basis we rely on for processing your personal information in this way is that the processing is necessary for our legitimate interests, namely to provide the Seesaw Service to the user; and
for the following purposes as a joint controller with the relevant school or school administration, or as an independent controller if you sign up to or retain a free account as a teacher without your school’s authorisation:

How we use it	Lawful basis we rely on (EEA / UK / Brazil)
We use this information to monitor and detect fraud or suspicious activity on our Seesaw Service.	The processing is necessary for our legitimate interests, namely monitoring fraud.

5. COOKIES AND SIMILAR TECHNOLOGIES

Our Website uses cookies and similar technologies such as pixels and Local Storage Objects (LSOs) like HTML5 (together, “cookies“) to distinguish you from other users of our Website. Please see our Cookie Policy for information about the cookies and similar technologies we use on our Website.

6. HOW LONG WILL WE STORE YOUR PERSONAL INFORMATION

We will store your Personal Information for the following periods, unless we are required to retain it for longer under applicable law, court order or to bring or defend a legal claim.

If you are in the Canada, EEA or UK, the information we process as a processor/service provider on behalf of the relevant school or school administration, including all student data and most family member data, is retained in accordance with the retention periods set by the relevant school or school administration.

Our default data retention periods are set out below; however, please consult your school or school administration’s privacy policy for more information about how long we may retain Personal Information on their behalf.

Please select from the following to jump to the appropriate section:

Prospective customers

Category of Personal Information	How long we keep it
Your contact information, such as your name, email address and the name of the school board, district or administration you work for.	1 year, unless you become a customer of the Seesaw Service, in which case we will retain it for the periods set out below for the category of School administrators, Teachers, Family Members and Students.
The content of any queries or comments that you submit to us.	1 year, unless you become a customer of the Seesaw Service, in which case we will retain it for the periods set out below.

Visitors to our website

Category of Personal Information	How long we keep it
Information about the device you use to access the Website, such as IP address, unique device identifying numbers, type of device used, operating system, screen size, browser type, browser window size and device model and your approximate location derived from your IP address.	14 days
Information about how you interact with the Website, such as the pages you view and features you use on the Website, and any errors that occur on our Website while you are using it.	14 days

School administrators, Teachers, Family Members and Students

Category of Personal Information	How long we keep it
All information associated with the account on the Seesaw Service, except for activities designed on the Seesaw Service and added to our Community Library, or content you posted publicly (including usernames, comments and reviews) on the Teacher Scrapbook.	Until the closure of the account on the Seesaw Service. An account may be closed and deleted by you, the relevant school or school administration, or by us if the account is inactive for 18 months.
Activities designed on the Seesaw Service and added to our Community Library, and data and content associated with publicly available comments and reviews on our Teacher Scrapbook.	For as long as we maintain the Community Library and Teacher Scrapbook on the Services.

Information collected automatically through the Seesaw Service

Category of Personal Information	How long we keep it
Information about the device you use to access the Seesaw Service, such as IP address, unique device identifying numbers, type of device used, operating system, screen size, browser type, browser window size and device model and your approximate location derived from your IP address.	1 year from when it was collected.
Information about how you interact with the Seesaw Service such as the pages you view and features you use on the Seesaw Service, and any errors that occur on the Seesaw Service while you are using it.	1 year from when it was collected.

7. SECURITY

We implement appropriate physical, technical, and organizational measures to protect your Personal Information against accidental or unlawful destruction, loss, change or damage. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.

We have internal procedures and policies regarding our handling of Personal Information to facilitate our compliance with this Privacy Policy and applicable laws, including with respect to retention of Personal Information, access to Personal Information by personnel (which is limited on a need-to-know basis), and the handling of complaints. If you would like additional information about these procedures and policies, please contact us as described below.

8. RECIPIENTS OF YOUR PERSONAL INFORMATION

We may share your Personal Information:

Recipients	Why we share your Personal Information with these recipients	How these recipients will use your Personal Information
Service providers	We will share your Personal Information with companies that provide services to us, such as: Analytics service providers; Communications service providers, such as email distribution and optimisation platforms; Data hosting, storage and security providers.	These recipients will use your Personal Information as processors/service providers on our instructions
Advertising partners	Where we collect Personal Information automatically about visitors to our Website, we may share that Personal Information with our advertising partners as further described in the “Online Advertising” section below.	These recipients will process Personal Information to serve advertising about Seesaw on other websites that you visit, optimise our online advertising campaigns and measure the effectiveness of such advertising. We will only share your Personal Information in this way to the extent you have given us your consent to do so.
Buyers of our business	We may share Personal Information with other parties in connection with a transaction or potential transaction where we merge with another organisation, file for bankruptcy, or sell some or all of our assets or stock. For instance, if we sell the Seesaw Service to a third party, we will share the Personal Information we have collected through the Seesaw Service with that buyer.	These recipients will use your Personal Information to complete a transaction to buy all or the part of our business that includes the Website, App or Services. If you are in Brazil, the EEA / UK, the lawful basis we rely on for sharing Personal Information with these recipients is that it is necessary for our and the recipient’s legitimate interests, namely completing a transaction to buy all or part of our business.
Law enforcement, regulators and other parties for legal reasons	We may share your Personal Information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and/or (iii) exercise or protect the rights, property, or personal safety of Seesaw, its users or others.	These recipients will use your Personal Information in the performance of their regulatory or law enforcement role. If you are in Brazil, the EEA / UK, the lawful basis we rely on for sharing Personal Information with these recipients is that the processing is either necessary to comply with a legal obligation to which we are subject, or is necessary for our legitimate interests, namely enforcing our rights or complying with requests from regulatory authorities.

9. ADVERTISING

Promotional emails

From time to time, we may contact school administrators and teachers with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services.

For some marketing messages, we may use Personal Information we collect about you to help us determine the most relevant marketing information to share with you.

You can withdraw your consent at a later date by clicking on the “unsubscribe” link at the bottom of our marketing emails or by updating your preferences through your “Account Settings” on the Seesaw Service.

Online advertising

We work with online advertising networks and advertising partners to tailor the ads played or displayed to you on other websites, apps, or services. We do not use personal information to advertise third-party products or services on the Seesaw Service.

The ads you see online are tailored to your interests based on information collected about you, including information about your age, demographic, location, as well information about your internet usage over time, such as the websites you visit, the products and pages you view and the links you click on (including links in ads played or displayed to you).

Typically, this information is collected through cookies or similar tracking technologies. When you visit our Website we will, if you give us your consent to do so, place cookies and similar tracking technologies on your device to:

identify you and your device, and share this information with the relevant advertising networks, so that they can serve you advertising based on the information those advertising networks (or the partners they work with) have about your internet usage history;
collect information about how you use our Website, so that when you visit another website that works with the same advertising network as us, we can play you adverts for the Seesaw Service which are tailored to the pages and features of our Website that you accessed.

We may use certain forms of display advertising and other advanced features through third party service providers like Google Universal Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Site. You can opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences. You may learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy at http://www.google.com/policies/privacy/partners. You can also view Google’s currently available opt-out options at https://tools.google.com/dlpage/gaoptout.

Controlling the ads you see online

Please see our Cookie Policy for details of the third parties that collect information about your use of our Website for advertising purposes.

We will only collect and share information about your use of our Website for advertising purposes to the extent you have given us your consent to do so. You can customise your preferences at any time by accessing the cookie preferences centre through the cookie widget on the Website.

Withholding or withdrawing consent, or opting out of the use of advertising cookies, will mean that information about your use of our Website will not be shared with advertising networks to allow us to target advertising on other websites.

If you opt-out of advertising by opting out of the use of, or withholding or withdrawing your consent to advertising cookies, you will still get ads when you browse the internet, and those ads may still be relevant to your interests. However, this advertising may be based on the content of the site you visit or, for advertising on social media, your approximate location or demographic information associated with your social media profile, rather than your recent browsing activity. As a result, you may still see advertising relevant to your location, demographic or other information on the websites you visit even if you reject cookies on our Website.

10. INTERNATIONAL TRANSFERS

The Personal Information we collect may be transferred to and stored by us or our service providers in countries outside of the jurisdiction you are in where we and our third-party service providers have operations, including in the United States and in any province in Canada. In accordance with the notification requirement of Quebec Law 25, Personal Information collected through our services will be transferred to the United States.

Information for schools and users in the EEA or UK

In the event of a transfer outside of the EEA / UK, we ensure that: (i) the Personal Information is transferred to countries recognised as offering an equivalent level of protection (“Adequacy”); or (ii) the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission or approved under the UK Data Protection Act 2018 (“Standard Contractual Clauses”).

Where we transfer your Personal Information to recipients in Canada, we ensure that the recipient is subject to Adequacy, as determined by the European Commission and under the UK Data Protection Act 2018.

When we transfer your Personal Information to recipients in the United States, we ensure that such transfers are:

to a recipient certified under the EU-U.S. Data Privacy Framework and (where applicable) the UK-U.S. Data Bridge; or
subject to agreements incorporating the Standard Contractual Clauses.

If you wish to enquire further about these safeguards used, please contact us using the details set out in the “How to Contact Us” section above.

Information for schools and users in Australia or New Zealand

We will take reasonable steps to ensure that overseas recipients do not breach the Australian Privacy Principles 2-13 (inclusive) or New Zealand’s Information Privacy Principles 1-13 (inclusive).

Information for schools and users in Brazil

In the event of a transfer of your Personal Information outside of Brazil, we ensure that: (i) the Personal Information is transferred to countries recognized as offering an equivalent level of protection; or (ii) the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the Brazilian ANPD. If you wish to enquire further about these safeguards used, please contact us using the details set out in the “How to Contact Us” section above.

11. DATA PRIVACY FRAMEWORK

This section applies to schools and users in Switzerland, the EEA or UK.

Seesaw has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of Personal Information received from the European Union or European Economic Area (“EU/EEA”) in reliance on the EU-U.S. DPF, and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Seesaw has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles”) with regard to the processing of Personal Information 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 program, and to view our certification, please visit www.dataprivacyframework.gov.

Seesaw is responsible for the processing of Personal Information it receives, under each Data Privacy Framework and subsequently onward transfers to third parties to perform processing functions or to provide services on our behalf.

Seesaw commits to resolve Data Privacy Framework-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, and the Swiss-U.S. DPF should first contact our Privacy Team at: privacy@seesaw.me.

Seesaw has further committed to refer unresolved DPF Principles-related complaints to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.
Additionally, Seesaw is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission for compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. As further explained on the Data Privacy Framework program website at www.dataprivacyframework.gov, you may also invoke binding arbitration when other dispute resolution procedures have been exhausted.

12. YOUR PRIVACY RIGHTS

In accordance with applicable privacy law, you have some or all of the following rights in respect of your Personal Information that we hold.

If you are in Brazil, the EEA or UK:

Right of access. You have the right to obtain.

confirmation of whether, and where, we are processing your Personal Information;
information about the categories of Personal Information we are processing, the purposes for which we process your Personal Information and information as to how we determine applicable retention periods;
information about the categories of recipients with whom we may share your Personal Information; and
a copy of the Personal Information we hold about you.

Right of portability. You have the right, in certain circumstances, to receive a copy of the Personal Information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your Personal Information to another person.

Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete Personal Information we hold about you without undue delay.

Right to erasure. You have the right, in some circumstances, to require us to erase your Personal Information without undue delay if the continued processing of that Personal Information is not justified.

Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your Personal Information if the continued processing of the Personal Information in this way is not justified, such as where the accuracy of the Personal Information is contested by you.

Right to withdraw consent. If you have provided consent for the processing of your Personal Information, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your Personal Information before your withdrawal.

You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your Personal Information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

If you are in the EEA, UK or Switzerland:

If we received your Personal Information in reliance on the Data Privacy Framework, you may also have the choice (‘right to opt out’) of having your Personal Information shared with third parties and to revoke your consent for us to share your Personal Information with third parties. You may also have the right to opt out if your Personal Information is used for any purpose that is materially different from the purpose(s) for which it was originally collected or which you originally authorized.

If you are in Brazil:

In addition to the rights stated above, you also have the right to request anonymization, blocking, or deletion of your personal information that is unnecessary or excessive for the original purpose for which it was collected, or which is processed in violation of the LGPD. We may not be able to fulfil this request if Seesaw or your school administration is required to retain your Personal Information for legal or regulatory obligations, to defend against legal claims, or for other legally permitted reasons.

If you are in Australia:

Right of access. You have the right to request access to Personal Information we hold about you.

If you wish to access any of your personal information that you have provided to us, please contact us using the details set out above in Section 5 ‘How to contact us’.

Right to rectification or correction and notification to third parties. You have the right to request the correction of personal information we hold about you. You also have the right to have any correction notified to third parties to whom we have provided your personal information.

Right to opt out: You have the right to opt out of receiving marketing and to the disclosure or use of your personal information for marketing.

Seesaw will take reasonable steps to ensure that your personal information is accurate, up to date, complete and not misleading. However, to assist us to do this, we request that you keep your personal information up to date on the Seesaw Service or inform us of any changes to your Personal Information to ensure our records remain accurate and current.

If you believe that any of your Personal Information held by us is incorrect and you cannot amend such in the Seesaw Service, then please request us to amend that Personal Information via the details in the section headed “How to contact us” above.

If you are in New Zealand:

Right of access. You have the right to request access to Personal Information we hold about you.

If you wish to access any of your personal information that you have provided to us, please contact us using the details set out above in Section 5 ‘How to contact us’.

Right to rectification or correction. You have the right to request the correction of personal information we hold about you.

Right to opt-out. You have the right to opt-out of marketing. You can contact us to do so or use the unsubscribe mechanism included in each electronic direct marketing message we send to you.

If you are in Canada:

Rights of access: You have the right to request:

– Request a copy of your Personal Information that we hold about you.

– Information about the types of Personal Information we hold about you and the purposes for which the Personal Information has been used.

– The names of the third parties to whom we have disclosed or may have disclosed personal information and in what circumstances.

Right of correction. You have the right to request that inaccurate or incomplete Personal Information be corrected or updated.

Right of deletion. You may have the right, in certain circumstances, to request that we delete the Personal Information we hold about you.

Right of portability. You may have the right, in certain circumstances, to receive a copy of the Personal Information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your Personal Information to another person.

Right to withdraw consent. You have the right to withdraw consent to our processing of Personal Information.

These rights are subject to applicable legal restrictions.

How to exercise any of the above rights

If you wish to exercise one of the rights, please contact us using the contact details set out in the “How to contact us” section above. Due to the confidential nature of data processing, we may ask you to confirm your identity when exercising the above rights.

If you contact us to exercise rights on behalf of your child, we will assess whether your child is competent to exercise those rights themselves based on their age. In accordance with guidance from the Information Commissioner’s Office, we will normally assume that children aged 12 or over (or 13 or over in the province of Quebec) are able to exercise the rights mentioned above. Where that is the case, we may ask you to provide authorisation from your child to exercise their rights on their behalf.

We will respond to your requests to exercise your or your child’s privacy rights within the timelines prescribed by applicable data protection laws.

Complaints

Information for schools and users in the EEA or UK

If you are in the UK or EEA, you also have the right to lodge a complaint to your local data protection authority. If you are in the UK, information about how to contact your local data protection authority is available here. If you are in the European Economic Area, information about how to contact your local data protection authority is available here and here (if you are in Switzerland).

Information for schools and users in Australia

If you are in Australia, if you have any concerns about how we handle your personal information, believe we have breached the Privacy Act 1988 or any Australian Privacy Principles, if you wish to make a compliant or need further information, please contact us via the details noted in Section 5 “How to contact us”. You will need to provide us with sufficient detail regarding your complaint and any supporting evidence.

We will investigate the issue and determine the steps to be taken to resolve the complaint and will notify you in writing if we require any additional information and also of the outcome of our investigation.

If you are not happy with the outcome of our investigation, you may complain to the Office of the Australian Information Commissioner by way of their website www.oaic.gov.au or by phone to their hotline 1300 363 992.

If you are using the Seesaw Service through a school, for complaints about how your Personal Information is being handled by your school we recommend that you first refer your compliant to the relevant school and note their contact details should be included in that school’s privacy policy.

Information for schools and users in New Zealand

If you have any concerns about how we handle your personal information, believe we have breached the Privacy Act 2020 or any of the New Zealand Information Privacy Principles, if you wish to make a compliant or if you need further information, please contact us via the details noted above in Section 5 “How to contact us”. You will need to provide us with sufficient detail regarding your complaint and any supporting evidence.

We will investigate the issue and determine the steps to be taken to resolve the complaint. We will notify you in writing if we require any additional information and also of the outcome of our investigation.

If you are not happy with the outcome of our investigation, you may complain to the Office of the Privacy Commissioner by way of their website www.privacy.org.nz/your-rights/making-a-complaint-to-the-privacy-commissioner/.

If you are using the Seesaw Service through a school, for complaints about how your Personal Information is being handled by your school, we recommend you first refer to the relevant school’s privacy policy.

Information for schools and users in Canada and Brazil

If you have any questions about this Privacy Policy or how we process Personal Information, or if you would like to make a complaint, please contact our legal counsel at legal@seesaw.me.

13. UPDATES

We may update this Privacy Policy from time to time and so you should review this page periodically. When we change this Privacy Policy, we will update the “Effective Date” above. We will notify you of any material changes using the contact details you have provided to us. Changes to this Privacy Policy are effective when they are posted on this page.

If you are in Canada, Australia or New Zealand, your continued use of the Seesaw Service after the effective date of the modified Privacy Policy is deemed to be your acceptance of those amendments.

Last Update:	Description:
July 30, 2026	Included further detail on Seesaw’s data retention policies. Included provisions applicable to data processing pursuant to the Brazil LGPD. Updated information on the Data Privacy Framework recourse mechanisms.

International Privacy Policy

August 18 – September 30