Last Updated: August 1, 2024
The Sprout Labs website(s), application(s), and software platform(s), including Sprout Labs Game, that operate in connection with The Sprout Labs Solution, an early literacy assessment and intervention platform (collectively, the “Services”) are owned and operated by Sprout Labs, Inc hereafter referred to as “Sprout Labs.” Sprout Labs is committed to protecting your privacy. By using the Services and visiting any websites owned and operated by Sprout Labs, you accept and consent to this Privacy Policy. Your use of Sprout Labs products or services is, at all times, subject to the Sprout Labs Terms of Service, which include this Privacy Policy and the Data Privacy Agreement (“DPA”) between you and Sprout Labs. Please read this Privacy Policy carefully. Capitalized terms that are not otherwise defined herein have the meaning provided in the Terms of Service.
As used in this Privacy Policy, “we,” “our” or “us” refers to Sprout Labs. “You,” “yours” or other similar designation refers to an individual or entity that visits our website as well as an entity or institution or individual that accesses or uses the Services, including but not limited to local educational agencies (“LEAs”), state educational agencies, (“SEAs”), other educational institutions, providers of preschool and other early childhood education programs, parents, or guardians.
Please see our Children’s Privacy section for information on our data collection, use, and disclosure practices for childs under 13.
Information We May Collect
You may provide us with information about you when you correspond with us via our website, or via phone, e-mail, postal mail, or in another manner. You may also provide us with information about you if you are an authorized user of the Services. The information you give us may include your name, relationship to child, address, e-mail address, phone number, job title, and description. Sprout Labs Game users are required to provide us with an email and password to use those services (no information from the child is required to be provided as part of the Sprout Labs Game offering).
Information We Collect About You via Our Website.
When you visit our websites, we or our third-party service providers may automatically collect the following information for analytics purposes: Internet Protocol (“IP”) addresses, preferences, web pages that you visited prior to visiting our website, information about your browser, network, or device (such as browser type and version, operating system, Internet service provider, preference settings, unique device IDs, and language and other regional settings), and information about how you interact with our website (such as timestamps, clicks, scrolling, browsing times, searches, transactions, referral page, load times, and problems you may encounter, such as loading errors).
Cookies and other tracking technology:
Cookies. We or our third-party service providers may also use “cookies” to help personalize your online experience. A cookie is a text file placed on your hard disk by a web page server. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie. We and our third-party service providers use some necessary cookies because they allow visitors to navigate and use key features of our website, as well as analytics and performance cookies to collect information about how visitors interact with our website.
Page tags and web beacons. These technologies are used to track visitors as they navigate our Websites to understand Website performance better and to measure the performance of online advertising. Recipients of emails we send are also tracked using this technology. For example, web beacons track whether an email was opened and whether links within the email were clicked. This information is collected for measuring the performance of email messages and is processed according to our Privacy Notice.
Local and session storage. Our website uses local and session storage to temporarily store information to improve user experience while interacting with the website.
Information We Collect About Students Through the Sprout Labs Solution.
The Sprout Labs Solution allows an authorized user, such as a Sprout Labs employee to run early literacy assessments. When this occurs, we generate and maintain a participant code that is associated with the child. We also collect the following information in order to generate a risk assessment related to early literacy:
Your child’s name and grade level
Your child’s response to assessment questions
The response time associated with your child’s response to assessment questions
Your child’s voice data for portions of the assessment that require your child to repeat words
Whether your child has a family history of reading struggles, has an individualized education program (IEP), or is an English language learner (ELL)
Educational records that may be protected under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g; 34 C.F.R. Part 99; “FERPA”).
We also collect a username and password of a parent or guardian when logging into the reading intervention instructional app. This username includes the email address chosen by the parent or guardian to use. While using the intervention instructional app, we collect voice data for portions of the exercises that require your child to repeat words, phrases or sounds.
Information We Receive from Others.
We may receive information about you if you use any of the websites we operate or become an authorized user of the Services. If this occurs, we will inform you when we collect that data that it may be shared internally and/or in combination with data collected on our website.
How We Use and Share the Information We Collect
We use the information we collect to establish and maintain your account in order to provide you with access to the Services, and to provide you with the results of assessments that you conduct for your children. We also use this information to conduct research and analysis to operate, evaluate, and improve the Services, for educational purposes, or as required by law.
With respect to child users of the Services, we do not require children to provide more personal information than is reasonably necessary to utilize the Services. In fact, The Sprout Labs Solution does not allow authorized users to provide any more personally identifiable data than is reasonably necessary to utilize the Services.
How We Share the Information We Collect.
We do not sell you or your child’s personal information. We will not share you or your child’s personal information or user data except as described herein and in the Terms of Service, or unless we otherwise obtain your authorization to do so.
We share a very limited amount of de-identified information of child users of The Sprout Labs Solution with our service provider, Soapbox Labs, to help them understand the customers we serve, and to deliver the Services to you.
Specifically, we share de-identified voice recordings of children that have utilized the Solution with our service provider; however, before sharing this data, we take steps to ensure that the data does not contain any personally identifiable information and that de-identified information cannot be re-identified by unauthorized third parties. We also take steps to ensure that our service provider maintains appropriate confidentiality, security, and other requirements we have deemed necessary to protect your data from unauthorized disclosure. Our service provider takes steps to protect de-identified user data that we share with it in a manner consistent with the practices addressed in this Privacy Policy.
We may also share personally identifiable or de-identified information with authorized individuals who perform tasks on our behalf, such as employees and contractors who need information in order to deliver the Services to you. We employ safeguards to ensure that these authorized individuals do not: (1) use the information for any purpose other than to deliver the Services to you or as otherwise authorized by the Terms of Service or this Privacy Policy, or (2) disclose the information to unauthorized parties.
In some cases, we may be required to share your information pursuant to a lawful request such as a court order or subpoena, or when otherwise required by law. We may also share your information under the following circumstances:
In connection with an investigation of suspected unlawful activity;
When we determine that disclosure is necessary to protect the rights, property, or safety of Sprout Labs, our customers, or other third parties; and
In the event of a corporate sale, merger, acquisition, dissolution, or other similar event.
Third Party Links.
When visiting our website or using the Services, you may encounter links to web pages and sites that are not owned or controlled by Sprout Labs. Sprout Labs makes no warranties or claims regarding services from these sites, and no such warranties or claims should be implied or assumed. Sprout Labs encourages you to review the privacy statements and policies of websites you choose to link to from Sprout Labs so that you can understand how those websites collect, use, and share your information. Sprout Labs is not responsible for the privacy policies, statements, or other content on websites not owned or controlled by Sprout Labs .
How We Store and Protect Your Personal Information.
Sprout Labs uses various security measures, including physical, administrative, and technical measures, to help protect your information and to help prevent unauthorized access to, or disclosure of, your information. We require our employees to comply with information security safeguards, and our systems are protected by technological measures to help prevent unauthorized individuals from gaining access. For example, among other measures, we ensure that all data is encrypted using a Transport Layer Security (“TLS”) certificates during transmission. All data that is stored is encrypted at rest, and no production or customer data is stored outside of the underlying infrastructure, which uses Virtual Private Clouds (“VPCs”) for all environments.
Notwithstanding these precautions, no system can be completely secure and there remains a risk that unauthorized access or use, hardware or software failure, or a number of other factors may compromise the security of your information. Upon discovery of any unauthorized acquisition of user personal information, Sprout Labs will take immediate measures to safeguard and prevent further dissemination of any such personal information. When reasonably able to do so, Sprout Labs will notify the impacted parties via contact information on record, and such notifications will include information required by applicable data breach notification laws.
How We Protect Child Privacy.
Protecting the privacy of childs who use the Services is especially important to us, and we take our obligation to protect child data seriously. We maintain compliance with the Children’s Online Privacy Protection Act (“COPPA”) with respect to personal information we collect from children under the age of 13 (see our Children’s Privacy section, below, for more information). \
Student records obtained by Sprout Labs from a parent or guardian continue to be the property of and under the control of the parent or guardian. Theparent or guardian retains full ownership rights to the personal information and records it provides to Sprout Labs .
Sprout Labs will not use any information in a child education record for any purpose other than those required or specifically permitted by this Agreement.
Parents, legal guardians, or eligible children may review personally identifiable information in the child’s records and correct erroneous information by contacting Sprout Labs
Sprout Labs is committed to maintaining the security and confidentiality of child records. In the event of a data breach, Sprout Labs will adhere to the applicable Federal and/or State data breach notification requirements. For purposes of this policy, a breach is any unauthorized acquisition of computerized data that compromises the security, confidentiality, or integrity of personal information that we maintain.
Sprout Labs will delete or de-identify personal information under the following circumstances: (1) upon expiration or termination of our agreement with an educational institution, or (2) within sixty (60) days of receiving a written deletion request from the educational institution.
Sprout Labs prohibits using personally identifiable information in child records to engage in targeted advertising. Notwithstanding the foregoing, nothing in this Privacy Policy will prohibit Sprout Labs from utilizing de-identified user information for product development or improvement services.
Children’s Privacy
This section of the Privacy Policy provides information for parents and legal guardians about our practices with respect to information that we collect from childs under 13 who use our Services. We do not knowingly collect, use, or disclose personal information from childs under 13 years of age without a parent or legal guardian’s consent. In this section, we use the term “personal information” as such term is defined in the Children’s Online Privacy Protection Act (“COPPA”) and the Federal Trade Commission’s rules implementing COPPA.
Parent/Legal Guardian Consent Form. When purchased directly from Sprout Labs by a family (parent/legal guardian) such as the Sprout Labs Game, Sprout Labs understands that the parent’s or legal guardian’s consent is required for the collection, use, or disclosure of such information, and Sprout Labs will not collect, use, or disclose any personal information from the child if the parent does not provide such consent.
We obtain explicit consent from the parent or the legal guardian of the child before administering the assessment and only a parent or guardian may download and provide access to our instructional app for the child’s benefit.
We keep a record of consent obtained for the purposes of the instructional games.
The parent or legal guardian can provide verifiable consent to the collection, use, and disclosure of the information via an online form that is administered via email prior to collecting or using the personal information.
Personal Information We Collect from Children Under 13
Voice data for portions of the games that require the child to repeat sounds or words. We may also collect information about the child’s activities on our Services, including information about the child’s device used to play the games, the child’s responses to questions or activities and the response time associated with the child’s response to questions or activities.
Information Uses
We use the information we collect from childs under 13 only for educational purposes, including to operate, maintain, and improve the Services.
Information Disclosures
We disclose the information we collect from childs under 13 in the following circumstances:
Sprout Labs Game users will have access to their child’s personal information.
To third party service providers that assist us in providing the Services.
Requests to Access and Delete a Child’s Information
Parents and legal guardians of children under 13 may request to review the personal information collected from their child, direct us to delete the personal information we have collected from their child, and refuse to permit our further collection or use of the personal information collected from their child. To make such a request, please contact us at info@sproutlabs.com
International Data Transfers
All information processed by us or our service providers may be transferred, processed, or stored anywhere in the world, including in countries that may have data protection laws that are different from the laws where you live. Your information may be accessible to the courts, law enforcement, and national security authorities of the United States. We endeavor to safeguard your information consistent with the requirements of applicable laws. If your personal information is transferred to a country other than your home country, we will take measures to protect your personal information with appropriate contract clauses. To obtain more information about our policies and practices with respect to service providers outside your country, please reach out to us as in the ‘Contacting Us’ section below.
Operator of this Online Service / Contact Information
The operator collecting or maintaining personal information from children through this online service is Sprout Labs, located at 163 Highland Ave, #1067, Needham, MA 02494 and info@sproutlabs.com.
Your Choices Regarding the Information We Collect
You can correct, update, or remove your personal information if it changes or if you no longer want to receive information from us beyond information related to our Services. To submit a request:
If Services were provided as a result of purchasing Services directly from Sprout Labs for your child (such as Sprout Labs Game), submit your request directly to Sprout Labs using contact information in the “Contact Us” section.
Changes to Our Privacy Policy
We may revise our Privacy Policy from time to time. Any changes we may make to our Privacy Policy in the future will be posted on this page. You can see when we last updated our policy by looking at the “Last Updated” date at the top of this page. If we make material changes to our Privacy Policy, we’ll provide a prominent notice by posting a notice via the Services, by posting a notice on our website, and/or by notifying you via email using the email address you provided, so you can review the updates.
We encourage you to review this Privacy Policy from time to time. Your continued use of the Services after the revised Privacy Policy has become effective constitutes your acknowledgment and agreement to the terms included in the then current version of our Privacy Policy. If you don’t agree with any changes we make to our Privacy Policy, you may terminate your account pursuant to the terms and conditions included in our Terms of Service and any applicable Statement of Work that we have entered into with you.
Contacting Us
We welcome your questions and comments regarding our Privacy Policy. You may submit questions, comments, requests, and concerns regarding this Privacy Policy by sending an email to: info@sproutlabs.com. We will use commercially reasonable efforts to promptly respond to your inquiry, and/or to identify and resolve your concern.
