EFFECTIVE JULY 1, 2021 (see archived version)

This document is a supplement to our General Privacy Notice and is available for Educators to distribute to families and students.



Guiding Principles


• We want all kids to achieve at their highest possible level.

• We expect kids to make mistakes.

• We believe kids are entitled to leave their mistakes behind. 

• We believe kids have a right to veto their presence online.

• We believe in transparency and feedback.  


TABLE OF CONTENTS

Our purpose is to enable

  • Students to develop skills through instant feedback and repeated practice.
  • Educators to personalize learning journeys for students.

Your educator is your point of contact

We are a data processor/service provider for Educators, which include teachers, tutors, home educators, therapists, schools, medical providers, and other entities (an "Educator"). Educators create accounts for students under their charge. Educators can share students with each other so your student can have a single student dashboard.


Your Educator is responsible for

  • Having a legal right under applicable law to collect data from you.
  • Obtaining consent to collect data from you if the law requires your explicit consent.
  • Setting and resetting your password, nickname, and username.
  • Permitting you to review any data collected from you.
  • Deleting data collected from you that is erroneous or that is no longer required to be maintained.

Students have rights regarding their data under a variety of laws. Contact your Educator to exercise your rights, including:

  • Revoking consent.
  • Reviewing your data (most data is available for self-review in the Student dashboard). 
  • Deleting or correcting data.

We can't talk to you directly

Our agreements require that you direct questions or concerns to your Educator. We are responsive to their requests. Things you can raise with them that we will support them in addressing include, but are not limited to

  1. Resetting your password,
  2. Login challenges,
  3. Correcting errors in materials, and
  4. Correcting or removing inappropriate materials.

If you contact us directly, we will redirect you to your Educator. We will not release information to a person other than an Educator. We will respond to any request from your Educator authorizing us to make disclosures to you.


Safety and security

Security is a shared responsibility. Students are expected to follow their Educator's acceptable use policy and keep their passwords safe and secure. Students should use the most secure password appropriate to their age. Students must not attempt to log in as or impersonate another student.


DO NOT SEND YOUR PASSWORD IN EMAIL

We do not require your password at any time to provide customer support to your Educator or to you. We store your password salted and hashed (encrypted) for your protection. Keep it secret. If you forgot your password, ask your Educator to reset it.


    Authenticators

Your Educator may create an account for you that requires an authenticated login. Educators can choose the authentication method: (a) username and password or (b) a third-party authentication service. The third-party authenticator may collect information about your use of our service. Contact your Educator if you have questions about the third-party authentication service they have selected or if you need your third-party login credentials reset. Your school may choose from Google, Microsoft, Clever, and more authenticators. If you are having difficulty getting your third-party authenticator to work, your Educator can add a Boom login to your account.

Our Information Security Plan

See our Information Security Plan for details on how we protect Student Data.


Data collection is determined by your Educator

Students may interact with Boom Cards using our no data collection method — called Fastplay — or they can interact using "assigned" Boom Cards decks (direct login or Hyperplay links). Assigned Boom Cards decks collect student performance data that is linked to the student login. Contact your educator to discuss the manner in which you are assigned decks and to request a change.


Data we collect

For all authenticated users, we record the account-created timestamp, last-login timestamp, the type of device being played (i.e., iOS or Android, but not the device ID), the app version (if playing a Boom Cards app), the OS version of the device, the browser type and version. We use this information for security and integrity purposes.


If you are assigned a Boom Cards deck, we will collect the data listed in our Data Elements disclosure. Student personal information other than the user nickname for a classroom roster is deemed confidential. Educators may optionally enable or disable the visibility of a classroom roster to students.


Who we share your student data with

We share data with all Educators associated with your student login. Your parent can become an Educator associated with you by creating a free Educator account and asking your primary Educator to share you with your parent.


Student Data is stored in the Boom Learning database. The Boom Learning database is encrypted in motion and at rest. This database is hosted by (and thus disclosed to) the subprocessors MongoDB and Amazon Web Services under obligations of confidentiality and with no right to use personal data. Information stored in the Boom Learning database is used and disclosed for the following business purposes: audit, detection, debugging, business operations, and R&D. In the rare event that a technical difficulty requires sharing of student data with subcontracted technical support personnel, we share that data on a need-to-know and least-information-necessary basis with those subcontractors. See our Subcontractor and Subprocessor disclosure for the list of Subcontractors and Subprocessors we use.


What we do with your data

These are the things we do with Student Data:

  • record your performance;
  • report your performance to your teacher;
  • audit access to our system for security and integrity purposes;
  • improve Boom Cards and Boom learning for a better Educator and Student experience; 
  • use student data to build personalized learning engines for students;
  • disclose your data to a parent or guardian, or to you if you are an eligible student, if you, your parent or guardian requests a service or product from us directly and consents to the use or disclosure to provide the service or product; and
  • allow a successor entity to maintain Student Data, in the case of a merger or acquisition, but only if the successor entity agrees to these same commitments to you.


No advertising, marketing or commercial use of Student Data

These are the things we do NOT do with Student Data. Again these are our DON'T DOs:

  • use or disclose it for advertising to students, their families or guardians;
  • build a personal profile of a student, family member or guardian for advertising or marketing purposes;
  • use it to inform, influence, or enable marketing, advertising, or for other commercial efforts unrelated to our educational service; OR
  • use it to develop unrelated commercial products or services.


Videos— especially YouTube

Some Boom Cards decks contain video. Most video requires at least a session cookie to play (see our Cookie Notice) and may place tracking cookies used for other purposes, including potentially targeted advertising. Your Educator is required to ensure that any video embedded in a privately published deck created for you conforms to your entities' and state's requirements regarding advertisements to students. If you don't trust your Educator, skip the play button on the video and ask for a link you can play in a browser in Incognito mode. 


We actively remove Boom Cards decks from our Public Store if we discover them to be delivering advertisements. Parents and Educators please go to https://wow.boomlearning.com/store and click Review and then Report to report any video with ads that slipped through our systems.


Due to recent changes in its terms, YouTube will no longer ensure a method of playback that is advertisement free. As a result, we are discontinuing allowing YouTube embedding in new Boom Cards decks published to the Store. Materials created before July 1, 2021 may contain YouTube videos. We are working with authors to transition their embedded video to alternative video services. If you are assigned a Boom Cards deck that contains a YouTube video, clicking play on that deck will cause YouTube to place a variety of cookies that will track your student for YouTube's advertising, marketing or commercial purposes. Skip the card with the video to opt out of YouTube tracking. Educators can Hide the Card for you. An Educator who owns the video and has YouTube Partner account may be able to set the video to deliver to you advertisement-free. Contact your Educator if you have concerns about YouTube videos in assigned decks.


We Do Not Sell Student Data

We do not claim ownership of the student performance data. Ownership of that data lies with either the Educator or the student, depending on the terms of the relationship between the Educator and student. If we ever sell our company outright, our successor must agree not to claim ownership of your student performance data, either. We do not sell student data to third parties.


    Deleting Student Data

At any time, your Educators may use self-help tools we provide to delete selected performance logs. They may also use these tools to delete a student outright. Deletion cannot be undone. If your Educator fails to renew an account and fails to delete student records, we perform scheduled deletion of stale accounts as follows to minimize privacy risk: 

  • student accounts 90 days after the associated paid Educator membership expires – we assume these students will have a new teacher in the next session; renew early to avoid. 
  • student accounts 180 days after the last Educator login for free accounts – we assume these are homeschool or small tutor accounts; login in at least once every 179 days to avoid. 

To retain your data you will need to 

  • Have a parent create a free account
  • Have your Educator "share" you as a student to your parent
  • Purchase the Boom Cards decks in the parent account for which you wish to see the Student Data


Legal authority data requests

We are required to disclose Personal Information in response to lawful requests by legal authorities. If a legal authority is asking for information about a student, we will inform the Educator who is responsible for passing the notification to the student’s legal guardian.


Breach notifications

If it has been determined that there is a breach that requires notification, the legal guardian will receive the notification directly from the Educator unless we have been provided direct contact information and have been given consent for direct contact by the Educator.