This is the privacy policy of Elementari, LLC (we, us, our) and details what information we collect through our website (www.elementari.io) (the "Site"), how we use, process, and share it, and what we're doing to keep it safe. It also tells you about your rights and choices with respect to your information, and how you can contact us if you have any questions or concerns.. This policy applies to anyone who uses Elementari, whether by submitting illustrations or sounds, creating and using an account, or writing your story. Please read it carefully and if you are under 13, please ask a parent or guardian to read it for you.

Elementari is committed to protecting the privacy of our users and providing a safe, online environment for young writers, students, educators, and parents / legal guardians. In our commitment to protect the privacy of children, Elementari has taken the Student Privacy Pledge which commits us to policies and practices surrounding the collection, use, maintenance and disclosure of personal information from Students.

This Privacy Policy is written in compliance with important laws such as Children’s Online Privacy Protection Act (COPPA), Family Education Rights and Privacy Act (FERPA) and General Data Protection Regulation (GDPR).

Who do we collect information from?

We may collect information from teachers, parents, family members, guardians and students who create an account with Elementari, upload content, or write content in the form of stories. We might also collect anonymous information about users before accounts are created or content is uploaded.

What personal information is collected about me?

Personal identifiable information (PII), as used in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context.

Information you provide

Registering for an account

  • In order to create and share stories, you need to make an account. During account creation, we ask you for a username and your email address (or your parent or guardian's email address if you are under 18 years old). We ask that you select a username that does not disclose your real name or other information that could identify you.

Profile Information

Accounts on Elementari have a public profile page and is visible to anyone who visits their profile page. The profile can contain the following information:

  • Display name, location (country), bio, custom avatar image, custom banner image, and links to personal website/social media.
  • Student accounts are limited in how they can edit their profile and can only put up location (country) and choose from a list of avatars. Custom avatar/banner upload, editable display name, bio, external links are not available.

Purchasing Membership

  • When purchasing a subscription, we securely ask for (but do not store on our servers) your credit card information - all of our credit card transactions are processed by our payment provider, Stripe.

Educator Accounts

  • When creating classroom, we ask for educators to provide a class name and grade level.
  • Educators can create or change Student usernames and passwords.
  • Educators have the option of adding Student first names and last name first initial.

User Generated Content

  • Information in stories: We collect any information that you provide to us when you create Elementari stories (including unpublished stories). This data may include text or audio files which includes information about you. We do not allow using illustrations that are not approved by Elementari in stories.
  • Profile information: When creating an account, you may opt to add information to your profile including a bio, country location, profile picture, banner image, and 3rd party links.
  • Student accounts have additional privacy measures in place. Student accounts do not have the ability to upload their own images (for profile picture/banner image) or edit their profile information. Furthermore, all stories need teacher approval before they can be published to the public.

Communications

  • If you contact us directly, we may receive additional information about you. For example, we may receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide.

We will only collect the minimum data necessary to run and manage Elementari.

Personal Information We Collect Automatically From Your Use of the Site

When you use Elementari, we and our third-party service providers collect information about you and your device through automated means, such as cookies and web server logs. By using Elementari, you consent to the placement of cookies and similar technologies in your browser in accordance with this Privacy Policy. The information collected in this manner includes your IP address, network location, what browser you are using, device IDs and characteristics, operating system version, language preferences, referring URLs, and information about the usage of our site.We use this information, for example, to ensure that the site functions properly, to determine how many users have visited certain pages, or to prevent fraud. We use IP address information to derive your approximate location. We also work with analytics providers, see our list of 3rd party service providers here, which use cookies and similar technologies to collect and analyze information about use of the site and report on activities and trends. These services may also collect information about the use of other websites, apps, and online resources.

If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer tohttp://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of Elementari.

Children

Generally

In the event that the Site or Service is used by individuals under the age of 13, Elementari will comply with the Children’s Online Privacy Protection Act.

  • We do not collect personal information from children under the age of 13 without prior consent of their parent or legal guardian .
  • In order to become a Member, a child under 13 must provide a username, password and parent or legal guardian email address. We use that parent or legal guardian email address to request consent from the parent or legal guardian before allowing the child to register
  • When a child under 13 registers for a student account, we rely on the school to provide consent on behalf of the parents or legal guardians.
  • We limit PII as much as possible to still participate in our service (no email necessary for student accounts - just a username).
  • We allow teachers and parents to review, delete, and manage their students' information through account settings or by emailing [email protected]
  • Student accounts will need their published stories to be moderated and approved by their teacher in order for their story to be read by the general public.
  • We employ filters to prevent the communication of personal information and age-inappropriate words and phrases. In addition, we may employ live moderation and encourage other users to flag inappropriate communications.

Below is how we comply with different privacy laws.


COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under 13, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation's consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.

We adhere to the following COPPA tenets:

  • We will not require a child to disclose more information than is reasonably necessary to participate in our service.
  • Teachers and parents can agree to the collection and use of their students' information, but still not allow disclosure to third parties.
  • Teachers and parents can review, delete, and manage their students' information through account settings on our website or by emailing [email protected]
  • We notify teachers and parents directly before collecting PII from their children. This includes what specific information will be collected and how it might be disclosed, a link to our online privacy policy, and how teachers and parents can give their consent.
  • Parents can give consent by creating accounts for their children and providing the minimum necessary personal information needed during that account creation.
  • Student accounts for use in school settings can only be created with consent of a teacher.

FERPA

Our collection, use, and disclosure of student data is governed by this privacy policy, any other agreement with an educational agency, the provisions of the Family Educational Rights and Privacy Act (FERPA), COPPA, and applicable state laws which relate to the collection of student data. See the rest of this privacy policy for other details on the limited ways in which we handle student data.

SOPIPA

Elementari is compliant with SOPIPA, meeting, among others, these requirements. We:

  1. do not use any data collected via the service to target ads to students;
  2. do not create advertising profiles on students;
  3. do not sell student information;
  4. do not disclose personal information, unless required by law or as part of the maintenance and development of the service;
  5. do use sound information security, including encryption of data and other industry-standard practices;
  6. will delete data that we have collected from students in a school when the school or district requests it;
  7. share information only with educational researchers or with educational agencies performing a function for the school;
  8. innovate safely without compromising student privacy by only using de-identified and aggregated data to develop and improve the service.

How does the Elementari Team use my personal information?

Internal and Service-Related Usage

We use Personal Information for internal and Site-related purposes, including to operate, provide, and maintain the Site. We may use your personal information, such as email, with 3rd party services to make this possible. See our list of 3rd party services here.

Analytics and Improving the Site

We and our service providers use Personal Information that we collect on the Site, such as your location and your activities on the Site, to monitor and analyze usage of the Site and to improve and enhance the Site. You can see our list of 3rd party services we use here.

Communications

We may send emails to an email address you provide to us for customer-service or technical-support purposes, to send you information about topics or content that we think may interest you, or updates about the latest developments or features on the Site. We may also send a newsletter to the email address you provide to us if you subscribe to receive the newsletter.

Aggregate Data

We may de-identify and aggregate information collected through the Site for statistical analysis and other lawful purpose, including in research studies intended to improve our understanding of how people learn with Elementari.

Legal

We may use your Personal Information to enforce our Terms of Use, to defend our legal rights, and to comply with our legal obligations and internal policies. We moderate all content posted to Elementari, including unpublished stories. If you are located in the European Economic Area, we only process your Personal Information based on a valid legal ground, including when:

  • You have consented to the use of your Personal Information, for example, to receive electronic marketing communications;
  • We need your Personal Information to provide our services, including for account registration, to respond to your inquiries, or for customer support;
  • We have a legal obligation to use your Personal Information; or
  • We or a third party have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information to personalize our services and provide you with tailored content, conduct business analytics, and otherwise improve the safety, security, and performance of our Site. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

How Does Elementari Share my Personal Information?

We do not sell or trade your information, and do not otherwise transfer it except as described in this privacy notice. We disclose information that we collect through the Site to third parties in the following circumstances:

With Your Consent

With your consent. We will share personal information with companies, organizations or individuals outside of Elementari when we have your consent to do so. We require opt-in consent for the sharing of any sensitive personal information.

With our Partners

We may share aggregated information and non-identifying information that we collect with our partners – like publishers, research institutions, advertisers or connected sites. For example, we may share information publicly to show trends about the general use of our services.

With the Public Through the Services

By default content (stories, illustrations, sounds) published through the Site and many actions (likes and comments) are shared with the public. Because this kind of information can be seen by anyone and may be indexed by search engines, you should be careful about what you choose to disclose publicly and make sure it’s information you want to share with everyone.

Legal Exception

If required to do so by law or in the good faith belief that such action is appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, such as school, school districts, and law enforcement, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Business Transfers

If Elementari is involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of any personal information and give affected users notice before personal information is transferred or becomes subject to a different privacy policy. We will contact you to let you know if we plan to do this. If you are unhappy with the transfer you may contact us to end your contract with us within 30 days and if you do so, we will not transfer your data to that company.

Your Rights and Choices

Updating and Your Information

You can update your password and email address through the Account Settings page. Regular users can optionally update their profile information including display name, profile picture, cover image, bio, and external links. Student accounts do not have these features to ensure privacy. You cannot change your username, but you can make a new account and manually remix your stories to the new account.

Deleting Your Information

We don’t keep your information for longer than we need to for the purposes listed in this policy.

We will only keep your information for as long as your account is open and you can delete your account from your account settings page or by emailing us at [email protected] Deleting your account will permanently remove your information, stories, and activity from our servers. If you are a contributing composer or illustrator, see our Terms of Use for how your assets will be processed upon account deletion.

Marketing Communications

If you decide at any time that you no longer wish to receive marketing communications from us, please follow the unsubscribe instructions provided in any of the communications. You may also opt out from receiving email from us by sending your request to us by email at [email protected] Please be aware that, even after you opt out from receiving marketing communications from us, you may continue to receive administrative messages from us regarding the Site.

Your Data Protection Rights (EEA)

In certain jurisdictions, you have the right to request access and receive information about the Personal Information we maintain about you, to update and correct inaccuracies in your Personal Information, to restrict or object to the processing of your Personal Information, to have the information blocked, anonymized, or deleted, as appropriate, or to exercise your right to data portability to easily transfer your Personal Information to another company. Those rights may be limited in some circumstances by local law requirements. In addition to the above-mentioned rights, you also have the right to lodge a complaint with a competent supervisory authority subject to applicable law.Where required by law, we obtain your consent for the processing of certain Personal Information collected by cookies or similar technologies, or used to send you direct marketing communications, or when we carry out other processing activities for which consent may be required. If we rely on consent for the processing of your Personal Information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.To update your preferences, ask us to remove your information from our mailing lists, or submit a request to exercise your rights under applicable law, please contact us as specified in the “How to Contact Us” section below.

Third Party Services

The Services may contain links to other websites and services, including payment services. We are not responsible for the privacy practices or the content of those websites, and you should review the privacy statements of each third party website you visit. This Policy applies solely to information collected by the Services.

Data retention

We do not typically delete or expire Stories as the Member maintains an active account with Elementari. There are some exceptions for education accounts:

Educators:

  • You may remove Student(s) from a class at any time with the options available through the Class Dashboard. Removing a students does not delete the student account. Students removed from a class will still be able to use the Service if there is a parent or guardian email associated with the account.
  • For educational usage it is the teacher’s responsibility to make a student's published story public.
  • We will delete or de-identify Student accounts with no log-in activity over a three-year period. If you would like for this to happen at a specific date or time, please contact us.

We may retain aggregated, anonymized information.

Security

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. All financial transactions are processed through a secure gateway provider (Stripe), with no sensitive financial information stored or processed on our servers.

Your data is transmitted securely over SSL and stored in Amazon Web Services. Amazon Web Services participates in the EU-US Privacy Shield arrangement.

This mean that Google protects your information in the US as it would be protected in the EU. Additionally, Google Cloud offers world class data security which you can read about at https://cloud.google.com/security Additionally, we conduct regular security audits on these services and access to this data is restricted to only authorized employees of Red Jumper with suitable training and background checks.

The Elementari Team has in place physical and technical procedures that are intended to protect the information we collect on the Elementari website against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. However, no Internet transmission is completely secure, and we cannot guarantee that security breaches will not occur. Without limitation of the foregoing, we are not responsible for the actions of hackers and other unauthorized third parties that breach our reasonable security procedures.

Please notify us of any unauthorized use of your account or any suspected breach of security. Elementari will comply with all applicable laws in the event of an unauthorized disclosure of personal information.

Notifications of changes to the Privacy Policy

We review our security measures and Privacy Policy on a periodic basis, and we may modify our policies as appropriate. We will not reduce your rights under this policy, use your data for purposes not covered by it, or lessen the security of your data without your consent. If we make material changes, we will notify you through the Site or by sending you an email or other communication. We encourage you to review our Privacy Policy on a regular basis. The “Last Updated” date at the top of this page indicates when this Privacy Policy was last revised. Your continued use of the Site following these changes means that you accept the revised Privacy Policy. The most current version of the Policy will always be located at elementari.io/policy.

International Cross-Border Data Transfer

Elementari is based in the United States. Personal Information that we collect may be transferred to, and stored at, any of our affiliates, partners, or service providers which may be inside or outside the European Economic Area, including the United States. By submitting your personal data, you agree to such transfers.

What can I do to help protect my privacy?

Please do not share personal contact information (such as your name, physical address, email address, or phone number) in stories, comments, and your profile. Please let us know if you see this kind of information by using the “Report” link which appears on the page. It is also important that you maintain the security and control of your account credentials, and not share your password with anyone.

Contact Us

It is our goal to make our privacy practices easy to understand. Please contact us if you have questions, concerns or if you would like more detailed information.


Elementari, LLC
805 S Stapley Dr
Mesa, Arizona 85204
USA
[email protected]