Privacy Policy
S​​quare Panda Privacy Policy
Updated and Effective [2023]
Square Panda Education Private Limited ("Square Panda") owns and operates the Square Panda mobile games and applications including websites, programs, and applications utilized by parents and education professionals (the "Teaching Services") and applications that students can use to aid the development of literacy skills (the "Student Services"); the Teaching Services and Student Services, collectively, the ("Services") that support early literacy skills in the classroom. This Privacy Policy explains how we collect, share, and use personal information about its users (“you†or “Usersâ€) that we collect through the Services, and how you can exercise your privacy rights.
This privacy policy (“Privacy Policyâ€) is incorporated into and is part of our Terms of Service. By using our Services, you agree to our Privacy Policy and Terms of Service.
If you have any questions or concerns about our use of your personal information, please contact us using the contact details provided at the bottom of this Privacy Policy.
The Services are available to education institutions ("Customers"): administrators, teachers and other education professionals ("Teachers", "Administrators") to use with their students, whom they are responsible for overseeing in the Services. The Customer must designate a single administrator ("Customer Administrator") to facilitate license distribution among schools and/or classrooms.
The Teaching Services and the Student Services are available to Home Users: Parents to use with their children, for whom they are responsible for overseeing in their use of the Student Services.
Square Panda may function in the capacity of a "processor" when we process certain personal data such as names, e-mail addresses, and other contact information on behalf of our Users to create your account (the "Account") and provide the Services. We function in the capacity of a "controller" when we send marketing materials that Users may choose to receive in accordance with applicable law, and in relation to Home Users.
PERSONAL DATA WE COLLECT
We collect personal data through the Services. "Personal Data" means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, online identifier or a combination of otherwise non-identifiable factors that would reveal the identity of that natural person.
In some cases, we will ask for your permission so that we may process your Personal Data. For example, we will ask for your permission to send you our marketing newsletters. For Home Use, we will also obtain permission from the parent or guardian identified in the Account before creating an account for a child, in accordance with the applicable law.
However, in certain circumstances, applicable data protection laws allow us to process your Personal Data without needing to obtain your consent. Those situations might include:
We are legally prohibited from fulfilling such interests when they are overridden by your interests or fundamental rights and freedoms which require protection of Personal Data.
INFORMATION YOU PROVIDE
Education Institutions:
When your educational institution agrees to use the Services, the Customer Administrator provides us with their first and last name, e-mail address, username and password, as well as the school/district name and address, including city, region or state, and country. We use that information to create your school or district Account. Through that Account, the Customer Administrator is able to provide a link for other Administrators and Teachers to access the Services.
Teachers and other Administrators provide us with the information necessary to create their Accounts. This includes your first and last name, username and password, e-mail address and school name. We may also request your gender, grade and employee ID. We use this information to create your Account, allow you to access your user profile, allow you to see your students' activity in the Services, and to respond to your requests to receive support, respond to questions, or to receive marketing and other communications from us.
At your option, you may also provide us with your gender, grade, country and phone number. With your permission, we may also use your phone number to contact you to provide you with information related to resolving an issue with the Services that you report to us.
Teachers also provide us with the first and last names of the students who will use the Services. They may also choose to provide a nickname, date of birth, gender, IEP, e-mail address for a legal guardian, languages, and a photo. Teachers may provide this information directly, or we may collect it via connection to the User's student information system, as authorized and configured by the User.
We use this information to permit students to access the Student Services and to provide the Services under the direction of their Teachers, and to allow Teachers to maintain a record of their students' work in the Services for their educational purposes.
Home use:
Parents create an Account in the Services by providing a first and last name, country, e-mail address, password, language preference, and in certain regions of the world, phone number, and, optionally, gender, and an age range.
To connect an Account to the child, we ask parents to provide their child's first name and date of birth. At the parent's option, they may also upload a photo of the child, which is used to personalize their experience, or an avatar may be selected from one we provide. They may also, optionally, provide the child's gender.
Special Note About Children's Data
Users and Parents may optionally provide their child's gender and photo, but we do not collect those directly from the child.
Prior to collecting any personally identifiable information about or from a child, we will provide Users and Parents with notice explaining what information we may collect and requesting their consent prior to collecting it.
Parents may work directly with their school or district to review or modify information in their child's education record that may be stored by us. We will then work with parents and schools together to facilitate these requests, which should be sent to support@squarepanda.com.
Doing so will delete the selected child's data from the Account. Square Panda will be unable to restore that portion of the Account, at a later date.
INFORMATION WE COLLECT AUTOMATICALLY
When you use our Services, we may collect certain information automatically from your device. This information may be considered Personal Data under applicable data protection laws.
Specifically, the information we collect automatically may include your device's IP address, device type, hardware model, unique device identification numbers, operating system, IMEI number, browser-type, browser version, the pages or features of our Service that you visit and/or use, broad geographic location (e.g., country or city-level location), default language, phone number, mobile operator or ISP, timezone, the time and date of your visit, the time spent on certain pages, other technical information, and other statistics. We may also collect information about how you use the Service and how your device has interacted with our Service.
Collecting this information enables us to better understand the Users of our Service, where they come from, what content or features on our Services is of interest to them, and to provide useful features to simplify your experience when you return to the Services, such as remembering your login id, Personal Data and third-party information, and to deliver relevant content based on your preferences, usage patterns and location. We use this information for our internal analytics purposes, to prevent fraudulent behavior in our Service, and to improve the quality and relevance of our Service to our players and visitors.
To collect this information, we use one or more of the following technologies:
Cookies: A cookie is a small data file sent from a website or application and stored on your computer or device. Cookies allow us to recognize your browser when you return to our App, and to remember your login information. Cookies also allow us to authenticate you as a User, serve certain features, better understand how you interact with the Services, and to monitor aggregated usage. You can set your browser to detect some cookies, to stop accepting cookies or to prompt you before accepting a cookie. Some functions may not work correctly if cookies are blocked. To learn more about browser cookies, including how to manage or delete them, look in the Tools, Help or similar section of your web browser, or visit allaboutcookies.org.
Local Storage: We may use, collect, and store information locally on your device using a web storage mechanism known as local storage. We use this technology to keep you logged in to the Services, administer the Services, and to remember your account preferences and status. This information persists until applications are uninstalled or the storage is explicitly cleared.
Session Storage: We may use, collect, and store information locally on your device using a web storage mechanism known as session storage. We use this technology to keep you logged in to the Services, administer the Services, and to remember your account preferences. This information is deleted once the browser tab is closed.
By using our Services, you agree to our use of these tracking technologies.
Through certain Services, we may collect Personal Data about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online features and services. We may use third-party analytics services on the Services, such as those of Google Analytics. The service providers that administer these analytics services help us to analyse your use of the Services and improve the Services. The information we obtain may be disclosed to, or collected directly, by these providers and other relevant third parties who use the information, for example, to evaluate use of the Services, help administer the Services and diagnose technical issues.
HOW WE USE YOUR INFORMATION
a) We may use information that we receive to help you efficiently access your information after you access our Services, remember information so you will not have to re-verify it during your access and to respond to your inquiries about our offerings, and to offer you other products, programs, or services that we believe may be of interest to you.
b) We may use your information to provide promotional offers by way of direct marketing communications, only where you have given us your separate consent.
c) We may use your information to provide customised learning videos and audio based on our artificial intelligence-based multisensory phonics learning system to develop Users into learners for life.
d) We may use your information to send in mobile application push notifications, reminders and SMS notifications.
e) We may develop and test new products and features and automatically update the website platform on your devices and provide, improve, test, and monitor the effectiveness of our Services.
f) We may diagnose or fix technology problems and use the collected information to respond to you when you contact us.
g) We may use the collected information to comply with applicable laws and to protect and defend the rights or safety of Square Panda, its Users or any other person and verify provided User profile information with third party providers and ensure technical service functionality and data accuracy, perform trouble-shooting and prevent or detect fraud, security breaches or illegal activities.
We are not responsible in the event that the application does not work as a result of failure to update the application or when the hardware does not support the application.
WHO DO WE SHARE YOUR PERSONAL DATA WITH?
We may disclose your Personal Data to the following recipients or categories of recipients:
Our service providers and subcontractors who process your Personal Data only on our behalf and according to our instructions. These partners provide data processing services to us, for example, to provide (i) data hosting, (ii) marketing and advertising services, (iii) user support, as well as (iv) analytics for Services;
Any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person; and
A potential or actual buyer (and its agents and advisers) in connection with any proposed or actual purchase, merger or acquisition of any part of our business, provided, however, that your information will remain subject to this Privacy Policy.
OTHER WEBSITES AND SERVICES
Square Panda may engage third party vendors and/or contractors to perform certain support services for Square Panda, including, without limitation, software maintenance services, advertising and marketing services, web hosting services and such other related services which are required by Square Panda to provide its Services efficiently.
These third parties may have limited access to your Personal Data. If they do, this limited access is provided so that they may perform these tasks for Square Panda and they are not authorized by Square Panda to otherwise use or disclose your Personal Data, except to the extent required by law.
Our Services may contain links to other sites that are not operated by us. We are not responsible for the practices employed by any websites or services linked to or from our Services, including the information or content contained within them. If you click on a third-party link, you will be directed to that third party's site. Your interactions with these features are governed by the privacy policy of the third party company providing it, our Privacy Policy does not apply to those third-party websites or services. We strongly advise you to review the Privacy Policy of every site you visit.
Square Panda does not make any representations concerning the privacy practices or policies or terms of use of such third party websites, nor does it control or guarantee the accuracy, integrity, or quality of the information, data, text, software, music, sound, photographs, graphics, videos, messages, or other materials available on such websites. The inclusion or exclusion of references to third party websites does not imply any endorsement by Square Panda of the website, the website's provider, or the information on such website.
The Services may contain content served by third parties, including videos and advertisements, and we work with third party service providers to serve our advertisements elsewhere online. In connection with serving content and providing analytics and advertising services, third parties may collect certain information about your visits to this or other websites and we may receive information regarding the use of the Services and the effectiveness of our advertisements. We do not share Personal Data with these third parties, but the advertising networks, advertisers, ad agencies, analytics service providers and other vendors may set and access their own tracking devices (including cookies and web beacons) and they may otherwise collect or have access to information about you (such as your general interest in certain book genres).
HOW YOU CAN ACCESS AND MODIFY YOUR INFORMATION
If you wish to access, correct, update, or request deletion of your Personal Data or, in the case of parents, the Personal Data of your children, you may do so at any time through the settings in the Services or by e-mailing us at support@squarepanda.com. Users in India may choose to contact us at support@squarepanda.in. You hereby understand that any such modification or deletion may affect your ability to use the Services. Further, it may affect Square Panda’s ability to provide its Services to you.
If you have signed up to receive e-mail updates about our products, you may opt out of receiving e-mails from us by clicking on the "unsubscribe" link found at the bottom of each e-mail. If you have opted out of receiving e-mails from us, we may still send essential communications, such as legal notices or password change information to you as needed.
Education Institutions: At any time, you may access, amend, correct or delete information about your students through your Teacher Portal dashboard available in the Services or by e-mailing us at support@squarepanda.com. Users in India may choose to contact us at support@squarepanda.in.
SECURITY
The security of your Personal Data is important to us, and we strive to implement and maintain reasonable, commercially-acceptable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure.
Specific measures we use include the use of firewalls, encryption, access keys, and rule/role-based access procedures to ensure that only those of our employees, who on behalf of their work are entitled to process Personal Data, are entitled to use a system containing Personal Data. The information is collected into databases that are protected by firewalls, and passwords.
However, please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the Personal Data we have collected from you.
INTERNATIONAL DATA TRANSFERS
We process and store personal information we may collect in accordance with the region where you are located. For example, if you are located in the United States, we will store your data in North America. If you are located in China, we will store your data in China.
The information will be treated in accordance with this Privacy Policy and applicable privacy laws in North America, the EEA and other regions in which we operate. These laws may be different from the privacy laws in your country, and we note that an adequacy decision by the European Commission does not exist. However, this does not change our commitments to safeguard your privacy and we will comply with all applicable laws relating to the cross-border data disclosure of your Personal Data. Where required, we implement Standard Contractual Clauses with our third parties (pursuant to Article 46 (2) of the GDPR), and you may request a copy of the Standard Contractual Clauses by e-mailing us at support@squarepanda.com.
DATA RETENTION
We retain your Personal Data for as long as you retain an active Account with us. We will delete your Personal Data within sixty (60) days after expiration of a User contract. However, if at any time you would like to request deletion of Personal Data associated with your Account, you may send us a written request to support@squarepanda.com and we will delete the requested information within forty-five (45) days. Users in India may choose to contact us at support@squarepanda.in.
We may also retain and use aggregated, deidentified information to develop and improve our educational products, to demonstrate the efficacy of our products, including in the marketing of our products, for customized and adaptive learning and for other legally permissible purposes.
YOUR DATA RIGHTS
At any time, you may access, amend, correct or delete information about your Students through the Teacher Portal or Parent Portal, by e-mailing us at support@squarepanda.com. Users in India may choose to contact us at support@squarepanda.in.
If you wish to access, correct, update, request deletion, restrict processing of, or object to processing of your Personal Data, you can do so at any time by contacting us at support@squarepanda.com. Users in India may choose to contact us at support@squarepanda.in. The same applies to portability requests.
If you have declared your consent for any processing of your Personal Data, you can withdraw this consent at any time. Such a withdrawal will not affect the lawfulness of the processing prior to your withdrawal of consent.
You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
UPDATES TO THIS PRIVACY POLICY
We reserve the right to update or change our Privacy Policy at any time. We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we do, we will provide prominent notice in the Services, and your continued use of the Service after we post such notice will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy. If we make any material changes to this Privacy Policy, we will notify you either through the e-mail address you have provided us or by other means as required by law and obtain your consent.
You can see when this Privacy Policy was last updated by checking the date displayed at the top of this Privacy Policy.
LIMITATION OF LIABILITY
Square Panda is not responsible for any breach of security or for any actions or inactions of any third parties that receive your Personal Data. Notwithstanding anything contained in this Privacy Policy or elsewhere, Square Panda shall not be held responsible for any loss, damage or misuse of your Personal Data, if such loss, damage or misuse is attributable to any event that is beyond the reasonable control of Square Panda and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes, lockouts or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, civil disturbances, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, and any other similar events not within the control of Square Panda ("Force Majeure Event") and which Square Panda is not able to overcome such Force Majeure Event.
Square Panda is not responsible for any actions or inactions of any third parties that receive your Personal Data.
At any point of time, our liability for any loss arising from a particular transaction carried out by you on the Services shall not exceed the consideration paid by you for that particular transaction.
OPT-OUT
We provide all Users with the opportunity to opt-out of receiving non-essential (promotional, marketing-related) communications from us after setting up an Account on the Services. All Users are also given the option of cancelling their Accounts and bringing to our attention their desire to discontinue the use of our Services. If you want to remove your contact information from this website and our newsletters, please send us an email at support@squarepanda.com. Users in India may choose to contact us at support@squarepanda.in. Even if the User opts-out, we reserve the right to notify you about your existing Account.
SPECIAL NOTES FOR USERS IN INDIA
Scope:
This Privacy Policy is an electronic record in the form of an electronic contract formed under the Indian Contract Act, 1872 and this Privacy Policy is published in accordance with the provisions of the Indian Information Technology Act, 2000 and the rules made thereunder, specifically, The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal data or information) Rules, 2011 and Regulation 3(1) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021. This Privacy Policy does not require any physical, electronic or digital signature. This Policy is a legally binding document between you and Square Panda.
The engagements with all the private and public organizations in India will be governed by the respective agreements with these organizations
This Privacy Policy shall be governed by and interpreted and construed in accordance with the laws of India. The place of jurisdiction shall exclusively be in Mumbai. In the event of any dispute arising out of this Privacy Policy the same shall be settled by a binding arbitration conducted by a sole arbitrator, appointed jointly by both parties and governed by the Arbitration and Conciliation Act, 1996. The venue and seat of arbitration shall be Mumbai.
Grievance Officer:
In accordance with the Information Technology Act, 2000 and Rules made thereunder, the name and contact details of the Grievance Officer are provided below:
Name: Chirag Desai
Address: 605-606, A wing, 6th Floor, Kanakia Wall Street, Andheri-Kurla road, Andheri East, Mumbai City, Maharashtra, 400093
Contact No.: +91 98335 45522
Email ID: chirag@squarepanda.com
For registering your complaint, please write to the Grievance Officer at the above-mentioned email address in relation to any violation of this Policy or the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021. The Grievance Officer shall redress the complaint in accordance with the provisions of the Information Technology Act, 2000 and Rules made thereunder.
HOW TO CONTACT US?
The data controller is Square Panda Inc. 935 Benecia Ave, Sunnyvale, CA 94085, United States of America
If you have any questions about this Privacy Policy, please contact us at support@squarepanda.com. Users in India may choose to contact us at support@squarepanda.in.