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Privacy Notice (Archived)
Privacy Notice
This is an archived version of our Privacy Notice dated June 20, 2023. View the current version here. Key changes from this Privacy Notice to the updated Privacy Notice include:
- The addition of short summaries at the start of each section to make it easier for our users to understand our privacy practices. You should still read the full Privacy Notice for additional details.
- Updated disclosures relating to marketing and advertising to address some common questions. To be clear, we don’t use Student Data for targeted advertising.
- New disclosures relating to children’s data in connection with the launch of Brisk Boost for Students.
Last Updated: June 20, 2023
This Privacy Notice applies to the products and services of Brisk Labs Corp. ("Brisk," "we," "our," or "us") that link to this page, such as Brisk’s websites, online platforms and web browser extensions (collectively, our "Service").
Through our Service, we provide productivity tools that speed up tasks like lesson planning, grading, and more. This Privacy Notice describes how we collect, use and disclose your personal data when you visit our Service or otherwise engage with us.
A note about Student Records: Our Service is intended for providers of educational services, such as schools and school districts (collectively, "Schools"), as well as teachers and authorized school users and administrators (collectively, "Educators"). When the Service is used as part of a School’s educational curriculum, the personal data related to students ("Students") that is (i) provided to Brisk by a School, or (ii) collected by Brisk during the provision of the Service to a School, may include information defined as "educational records" by the Family Educational Rights and Privacy Act ("FERPA") or "covered information" under California’s Student Online Personal Data Protection Act ("SOPIPA"), or other information protected by similar student data privacy laws. We call this information "Student Records." Please see the "Student Records" section below to understand the principles which guide our collection, use and disclosure of Student Records.
Our Service's use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.
If you are an Educator and are interested in using our Service, please ask your School to contact us about entering into a student data processing agreement with us under applicable student data privacy laws.
When we use the term “personal data” in this Privacy Notice, we mean any data or information that identifies, relates to, describes, is capable of being associated with or could reasonably be linked, directly or indirectly, with a particular natural person or household.
We collect personal data in a variety of ways. For example, we may collect personal data when you register for an account on our Service, send us messages, subscribe to our mailing lists, newsletters or other forms of communications, participate in a survey, or integrate our Service with a third-party site or service. In addition, we may collect personal data automatically when you interact with our Service. At times, we may also collect personal data about you from other sources and third parties.
Information You Provide
We collect the following information you provide in connection with our Service:
- Account Information, including full name, email address, School name, and other account information that you choose to provide to us.
- Inquiry and Communication Information, including information in customer messages sent through forms, in emails, or via phone. For example, if you join our waitlist, then we may ask you to provide your name and state of residence. We use this information to investigate and respond to your inquiries, communicate with you, and enhance the services we offer to our users and to manage and grow our Service.
- Information Collected Through the Use of the Service, including any files, documents, videos, images, data, or information you choose to upload or transmit through your communications with us or your use of the Service.
- Information from Educators, such as School name, district, teacher or authorized administrator title, organizational units associated with the School, course information and topics, grade levels taught, course work and assignments, course sections, and Student-related information such as topics of study, assignments and content (e.g., homework), and grades. Information from Educators may include Student Records as further described in the "Student Records" section below.
We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages. We may also send you Service-related emails or messages (e.g., user account verification, change or updates to features of the Service, technical and security notices) and communications from or about Brisk.
Personal Data Automatically Collected
As is true of many digital properties, we and our third-party partners may automatically collect certain information from or in connection with your device when visiting or interacting with our Service, such as the list below and in the sub-sections here:
- Information We Receive from Third-Party Sites You Connect to/Integrate with Our Service, including personal data we may receive about you from third-party platforms, networks, services and/or sites that you integrate with our Service and combine that with information we collect through our Service. For example, if you register through or otherwise grant access to a third-party site or service, such as Google (e.g., Google Classroom, G-Suite including Google Docs, Google Chrome, and Google Drive), we may collect personal data that is associated with your third-party site account. This information we collect may include, for example, your name, email address, courses, Student rosters, course materials, information about Google Doc views, version history, comments, and authentication action information, and Student submissions, including some Student Records. If you create or upload assessments or other academic or educational resources or materials, we collect the content of these materials and metadata you provide about them. The information we receive from these third-party sites is dependent upon that third party’s policies and your privacy settings on that third-party site. You should always review and, if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our Service.
- Log Data, including internet protocol (IP) address, operating system, device type and version, browser type and version, browser ID, the URL entered and the referring page/campaign, date/time of visit, other user agent string data, the time spent on our Service, and any errors that may occur during the visit to our Service). Log data may overlap with the other categories of data below.
- Analytics data, including the electronic path you take to our services, through our services and when exiting our services, UTM source, as well as your usage and activity on our services, such as the time zone, activity information (first and last active date and time), usage history (flows created, campaigns scheduled, emails opened, total log-ins) as well as the pages, links, objects, products and benefits you view, click or otherwise interact with. We may also analyze the interaction between you and your customer using our Service.
- Location data, such as general geographic location that we or our third-party providers may derive from your IP address, or more precise geolocation with your permission when accessing our online services through a mobile device.
We and our third-party providers may use (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect this personal data. We may also use this information to distinguish you from other users of our Service. This helps us monitor and analyze how you use and interact with our Service. It also helps us and our partners to determine products and services that may be of interest to you. For more information about these practices and your choices regarding cookies, please see the Control Over Your Information and Third Party Tracking and Online Advertising sections below.
Personal Data from Third Parties
We also obtain personal data from third parties. We often combine with personal data we collect either automatically or directly from an individual. We may receive the same categories of personal data as described above from the following third parties:
- Other Users or Individuals who Interact with our Service. We may receive your information from other users or other individuals who interact with our Service. For example, if an Educator uses our browser extension to detect AI-generated content in an online document, our Service will process any personal data included in the document.
- Information we receive from authentication services you connect to our Service: Some parts of our Service may allow you to login through a third-party social network or authentication service such as Google. These services will authenticate your identity and provide you the option to share certain personal data with us, which could include your [your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties]. The data we receive is dependent on that third party’s policies and your privacy settings on that third-party site. We use this information to operate, maintain, and provide to you the features and functionality of the Service. We may also send you service-related emails or messages (e.g., account verification, purchase confirmation, customer support, changes, or updates to features of the Service, technical and security notices).
- Other Sources: We may also collect personal data about individuals that we do not otherwise have from, for example, publicly available sources, third-party data providers, or through transactions such as mergers and acquisitions. We use this information to operate, maintain, and provide to you the features and functionality of the Service, generate leads, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.
We may use personal data to:
- Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Service you have requested.
- Manage our organization and its day-to-day operations.
- Verify your identity and entitlement to products or Service, when you contact us or access our Service.
- Communicate with individuals, including via email and newsletters.
- For marketing and advertising purposes, including to market to you or offer you through email, phone or text message information and updates on products or services we think that you may be interested in. Please note that we do not use Student Records for these marketing and advertising purposes.
- Administer, improve and personalize our Service, including by recognizing an individual and remembering their information when they return to our Service.
- Identify and analyze how individuals use our Service.
- Conduct research and analytics on our customer and user base and our Service. For example, as part of our AI writing detection service, Brisk uses version history data to assess the effort that Students put into their assignments. This can be used to flag suspicious work and support learners.
- Improve and customize our Service to address the needs and interests of our user base and other individuals we interact with.
- Test, enhance, update and monitor the Service, or diagnose or fix technology problems.
- Help maintain the safety, security and integrity of our property and Service, technology assets and business.
- To enforce our contractual rights, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties.
- Prevent, investigate or provide notice of fraud or unlawful or criminal activity.
- Comply with contractual and legal obligations and requirements.
- To fulfill any other purpose for which you provide personal data.
- For any other lawful purpose, or other purpose that you consent to..
Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the inquiry/request and/or personal data we require fall outside the scope of this Privacy Notice. In that case, the additional privacy notice will govern how we may process the information provided at that time.
We may also share, transmit, disclose, grant access to, make available, and provide personal data with and to third parties, as follows. For more information on how we share Student Records that we collect from Schools, please see the section on "Student Records" below.
- Brisk Entities: We may share personal data with other companies owned or controlled by Brisk, and other companies owned by or under common ownership as Brisk, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Service.
- AI Service Providers: We share personal data with service providers who perform AI-powered functions or services on our behalf. For example, this may include service providers who assist us in providing the AI-powered tools that form a part of our Service, including generative content creation and AI-writing detection.
- Your School: If you interact with our Service through your School, we may disclose your information to your School.
- Other Users: If you participate in any of our online communities, we may disclose your public profile information to other online community members, as well as any other information you choose to provide or make public.
- Customer Service and Communication Providers: We share personal data with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries.
- Marketing Providers: We coordinate and share personal data with our marketing providers in order to communicate with individuals about the Service we make available.
- Other Service Providers: We also share personal data with our other service providers, such as vendors who help us with data analysis, fraud prevention, infrastructure provisioning, analytics services, IT services, product fulfillment, and web hosting.
- Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal data to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal data may also be disclosed in the event of insolvency, bankruptcy, or receivership.
- Legal Obligations and Rights: We may disclose personal data to third parties, such as legal advisors and law enforcement:
- in connection with the establishment, exercise, or defense of legal claims.
- to comply with laws or to respond to lawful requests and legal process.
- to protect the rights and property of Brisk, our agents, customers, and others, including to enforce our agreements, policies, and terms of service.
- to detect, suppress, or prevent fraud.
- to reduce credit risk and collect debts owed to us.
- to protect the health and safety of us, our customers, or any person.
- as otherwise required by applicable law.
- in connection with the establishment, exercise, or defense of legal claims.
- With Your Consent or At Your Direction: In addition to the sharing described in this Privacy Notice, we may share information about you with third parties whenever you consent to or direct such sharing.
We consider Student Records to be confidential and do not use Student Records for any purpose other than to provide the Service on the School’s behalf, in accordance with contractual agreements with the School. To help Schools address their obligations to protect their students’ data privacy, we have implemented additional controls and procedures for Schools when they enter into a contract with Brisk to use the Service as part of a School’s educational curriculum. When the Service is used as part of a School’s educational curriculum, the personal data related to Students that is (i) provided to Brisk by a School, or (ii) collected by Brisk during the provision of the Service to a School, may include information defined as “educational records” by the Family Educational Rights and Privacy Act (“FERPA”) or “covered information” under California’s Student Online Personal Data Protection Act (“SOPIPA”), or other information protected by similar student data privacy laws. We call this information “Student Records.”
As between us and the School, Student Records are owned and controlled by the School. Our collection and use of Student Records is governed by our contracts with the Schools and by applicable privacy laws. For example, we provide the Service to Schools as a “School Official” under FERPA and we work with Schools to help protect personal data from the Student’s educational record, as required by the FERPA.
- We collect, maintain, use and share Student Records only for an authorized educational purpose and as described in our Agreement with the School, or as directed by the School or by the Student’s parent or legal guardian (each, a “Parent”).
- We do not use or disclose Student Records for targeted advertising purposes.
- We do not build a personal profile of a Student other than in furtherance of an educational purpose.
- We maintain a comprehensive data security program designed to protect the types of Student Records maintained by the Service.
- We will clearly and transparently disclose our data policies and practices to our users.
- We will never sell Student Records unless the sale is part of a corporate transaction, such as a merger, acquisition, bankruptcy, or other sale of assets, in which case we will require the new owner to continue to honor the terms provided in this Privacy Notice or we will provide the School with notice and an opportunity to opt-out of the transfer of Student Records by deleting the Student Records before the transfer occurs.
- We will not make any material changes to our Privacy Notice or contractual agreements that relate to the collection or use of Student Records without first giving notice to the School and providing a choice before the Student Records are used in a materially different manner than was disclosed when the information was collected.
How We Share and Disclose Student Records
We disclose Student Records solely as needed to provide the Service on behalf of specific Schools in accordance with our contractual agreements with those Schools or with the consent of the School or Parent. For example, Student Records and account usage data may be disclosed to or accessible by users who are authorized to use the Service on behalf of the School. In addition, depending on the manner in which Brisk is used by the School and the terms of the agreement between the School and Brisk, we may provide access to certain Student Records to the Student and/or to the Parent of the Student about whom the records relate, for the purpose of monitoring Student usage and activity and evaluating the effectiveness of the School’s use of the Service. We also disclose Student Records to our trusted service providers who have a legitimate need to access such information on our behalf, subject to appropriate contractual terms to protect such data.
Furthermore, we may disclose Student Records in connection with a business transaction or to support our legal rights and obligations, as described in our Our Our Disclosure of Personal Data section of this Privacy Notice.
How We Use De-Identified Data
We may also generate, use, and disclose de-identified information for adaptive learning purposes or customized student learning purposes, to recommend content or services relating to School purposes or other educational or employment purposes, as well as for development, research and improvement of our Service. In addition, we may use de-identified information for the development and improvement of other educational sites, services and applications or technologies more generally to the extent permitted under applicable law. “De-identified information” means data from which all personally identifiable information has been removed or obscured so that the remaining information does not reasonably identify an individual and there is no reasonable basis to believe that the information can be used to identify an individual.
How We Retain Student Data
We will not knowingly retain Student Records beyond the time period required to support an educational purpose, unless authorized by the School.
Please note: Schools are responsible for maintaining current class rosters, and for managing Student Records which they no longer need for an educational purpose by submitting a deletion request.
If you are using the Service on behalf of a School and wish to access Student Records, delete Student Records or close your account, please contact us (privacy@briskteaching.com). If you are a Parent or Student and wish to access Student Records, delete Student Records or close your account, please direct your request to your School.
Questions About Student Data
If you are a Parent or Student and have questions about specific practices relating to Student Records provided to Brisk by a School, please direct your questions to your School.
You may control your information in the following ways:
- Profile, controls and data sharing settings. You may update your account information and may change some of your account controls and data sharing preferences by visiting your “Account” page, removing our browser extension via the “settings” or “tools” menu for on your web browser, or emailing us at privacy@briskteaching.com.
- Disconnecting your Brisk account from third party sites. As discussed above, you may be able to connect your Brisk account to accounts you have on third party sites such as Google. You may disconnect your account from a third-party site at any time by visiting the “Account” page to remove authenticated sites and services or removing the Google Chrome Extension under the “Tools” page.
- How to control your communications preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).
- Modifying or deleting your information. If you have any questions about modifying your information, or if you want to remove your name or comments from our Service or publicly displayed content, you can contact us directly at privacy@briskteaching.com. We may not be able to modify your information in all circumstances.
Please note: As indicated above, we do not disclose Student Records for targeted advertising purposes. For more information about our third-party tracking in other contexts, please see below.
We participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on your online browsing history and your interests. We permit third-party online advertising networks, social media companies, and other third-party services to collect information about your use of our Service over time so that they may play or display ads on our Service, on other websites, apps, or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. We may share a common account identifier (such as an email address or user ID) or hashed data with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.
To learn more about interest-based advertising and how you may be able to opt out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at www.aboutads.info/choices. Please note that some advertising opt outs may not be effective unless your browser is set to accept cookies. Furthermore, if you use a different device, change browsers, or delete the opt-out cookies, you may need to perform the opt-out task again.
Google Analytics and Advertising
We use third party tracking technologies including Google Analytics to recognize you and link the devices you use when you visit our website or Service on your browser, log in to your account on our Service, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Service and to tailor our content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout.
We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Google Ads and Google Beacon conversions. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.
Brisk collects and uses Student Records at the direction of and under the control of a School. As such, we rely on each School to provide appropriate notice to Parents of the School’s use of third-party service providers such as Brisk, and for the Schools to provide consent, if necessary, and authorization for Brisk to collect Student Records, as permitted under applicable laws.
Our Service is not directed to, and we do not intend to, or knowingly, collect or solicit personal data from children under the age of 13. If you are under the age of 13, please do not use our websites or online services or otherwise provide us with any personal data either directly or by other means. If a child under the age of 13 has provided personal data to us, we encourage the child’s parent or guardian to contact us at privacy@briskteaching.com to request that we remove the personal data from our systems. If we learn that any personal data we collect has been provided by a child under the age of 13, we will promptly delete that personal data.
Our Service may include links to third-party websites, plug-ins, and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to any personal data practices of third-party websites and online services or the practices of other third parties.
We are not responsible for such third-party privacy practices. To learn about the personal data practices of third parties, please visit their respective privacy notices.
If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to privacy@briskteaching.com.
11. UPDATES TO THIS PRIVACY POLICY
We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the “Last Updated” date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will provide reasonable notice to you, such as by email to your registered email address, by prominent posting on this website or our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.
As noted above, we will not make any material changes to this Privacy Notice that relate to the collection or use of Student Records without first giving notice to the School and providing a choice before the Student Records are used in a materially different manner than was disclosed when the information was collected.