Student Privacy Policy
For Students, Guardians, and Schools
Last Updated February 10, 2022
Clayful, Inc. (“Clayful”, “we”, “our”, or “us”) provides coaching services for students (the “Service”). The Service is provided through schools or other educational institutions (“Schools”) as a way to connect students with the support they need to deal with life’s challenges as they grow. We recognize the sensitivity of students’ information. We take the responsibility to protect that information seriously.
This Student Privacy Policy applies to students’, teachers’ and guardians’ information we receive from Schools, students, or guardians in the course of providing the Service. For information about how we handle personal information collected through our website and other activities, please review our Website Privacy Policy.
Compliance with U.S. student privacy laws
The Service is subject to the Family Educational Rights and Privacy Act (FERPA) and the Children’s Online Privacy Protection Act (COPPA). Clayful is a “school official” under FERPA and receives student information pursuant to agreements with Schools. Schools and/or guardians consent to our collection, use, and disclosure of students’ information as described in this policy as required by COPPA. Clayful does not sell, license, or rent any student’s personal information, it does not engage in, inform, influence or enable advertising to students, and does not use students’ personal information other than to provide the Service or comply with legal obligations as described below.
1. Collection of information
Student information. With Schools and/or guardians consent, we collect student information as needed to provide and evaluate its Service from both Schools and students. From Schools, we collect a student ID, attendance data, grade level, grades, and demographic information like gender, date of birth, ethnicity, income level, living situation, and languages spoken. From students, we collect names, usernames/passwords, email addresses, phone numbers, information contained in their chats with our coaches, and survey/emotional assessment responses.
School user information. Clayful may collect teachers, staff members and other authorized users’ personal information such as name and email address to create and differentiate such user accounts.
Guardians’ information. We may collect names, emails, phone numbers, and addresses from guardians.
Automatically generated information. We gather certain information automatically when Students use the Service, such as IP address, browser type, information about how, how often and when a user engages with a page or feature of the Service. Clayful may gather this information using cookies (small data files on a computer’s browser), web beacons (invisible electronic images embedded on web pages) and similar technologies. In some cases, third parties may deliver cookies to the user’s browser on Clayful’s behalf. For example, Clayful uses Google Analytics to help measure the performance of the Service.
Clayful does not use or sell automatically generated information to market or advertise to students.
2. Use of information
Clayful may use personal information for:
Coaching. We use students’ information to connect them with a coach and facilitate the coaching sessions.
Creating aggregated/anonymized information. We may aggregate or anonymize the personal information we collect such that the resulting information (“Resulting Information”) cannot reasonably be linked to an individual or School. We may use the Resulting Information for our legitimate business purposes, such as creating reports about students’ experiences and issues (for example, we may tell a School that 40% of its students experience anxiety about standardized tests) or sharing anonymized conversations in marketing materials and investor communications. We do not share identifiable student information with Schools or other third parties unless required to do so by law.
Improving the Service. We use students’ information and automatically generated information to assess the effectiveness of coaching sessions and to improve our Service.
Research and development. We may use aggregated and/or anonymized student information for educational research and development purposes.
Providing customer support for Schools. We use personal information in the course of providing customer support.
Legal compliance. We use personal information to comply with applicable laws and lawful requests, protect the rights and safety of Clayful, students, and others, and to protect students and the Service from unauthorized, fraudulent, or illegal activity.
We will not use students’ information for marketing or other commercial purposes.
3. Sharing of information
Clayful shares personal information as follows:
With service providers. Clayful may disclose information to third parties as necessary for them to help us provide the Service, including hosting, chat, and analytics services.
With professional advisors. Clayful may disclose information to professional advisors like lawyers and accountants where doing so is necessary to facilitate the services those advisors provide to us.
As required by law or to ensure safety. Clayful may be required to disclose or grant access to personal information to law enforcement, government authorities, and other parties in order to comply with law enforcement requests and legal processes. In particular, we may be a mandatory reporter in certain circumstances. This may require us to disclose personal information to authorities if we fear that a student is at risk of harming herself or others. We may also share personal information to protect students’, our, or others’ rights, property, or safety. Clayful may also report any law enforcement and other incident reports made by Clayful to Schools.
In a business transition. In the event Clayful goes through a business transition, such as a merger, acquisition, asset sale, bankruptcy, restructuring, or other corporate change, personal information maintained by Clayful may be disclosed or transferred to the other company and other parties assisting with the transaction.
4. Privacy Rights
COPPA permits guardians to request access to or deletion of children’s information and to instruct companies to stop collecting or using children’s information. Since Clayful provides the Service to students on behalf of Schools, guardians should contact Schools with such requests. Clayful will forward any requests it receives to the appropriate School, unless Clayful’s contract with the School or applicable law requires otherwise.
5. Information security safeguards
Clayful treats personal information received from Schools as confidential. Clayful implements administrative, technical, and physical security procedures reasonably designed to protect the personal information stored on its servers, which are located in the United States. Even with these safeguards, however, we cannot guarantee the security of personal information.
6. Changes to this Policy
Clayful may modify this Student Privacy Policy to reflect new legal requirements or as its information practices evolve. We will post any adjustments to this Student Privacy Policy on this web page, and the revised version will be effective when it is posted (or as otherwise indicated at the time of posting).
7. Questions and Contact information
Please contact us at privacy@clayfulhealth.com with any questions about this Student Privacy Policy.