Privacy Policy

Who Are We?

We are Showbie Inc., the provider of Socrative. Our head office is located at #1400, 10117 Jasper Avenue NW, Edmonton, Alberta, Canada T5J 1W8.

Socrative is a web-based and tablet app that can be used by teachers to assess student understanding in real-time through activities such as quizzes and polls. There are free and paid versions.

Showbie is a Data Controller with respect to Personal Data which we collect and process for our own purposes in order to provide our products and services to customers. Showbie is a Data Processor when processing Personal Data on behalf of our customers, for example, schools, teachers etc.

Our Privacy Pledge

Showbie Inc. (“Showbie”, “we” or “us”) provides certain services including the Socrative application (the “Application”) and related software services as more particularly described in our Terms of Use (“Services”). Your trust is key to the success of our business. We take privacy and confidentiality very seriously and safeguard the Personal Data of our users in accordance with this Privacy Policy.

This Privacy Policy discusses the high degree of importance that we place on your privacy, including how we collect, use, and disclose Personal Data as well as the rules and conditions related to privacy of information while using our Services.

This Privacy Policy does not apply to the practices of companies that we do not own or control. Our customers are responsible for maintaining their own privacy policies governing their collection, use, and disclosure of Personal Data and are responsible for ensuring that they have obtained the necessary authorizations and consents for any Personal Data made available to us for use in accordance with this Privacy Policy.

This Policy sets out the basis on which any Personal Data we collect from you, or from others, will be processed by us. Please read the following carefully to understand our practices regarding your Personal Data and how we will treat it.

Details of Personal Data Processing

In the course of our business, we collect and process the Personal Data as set out in this Policy. This may include data we receive directly from a Data Subject (for example, by completing forms or by corresponding with us by mail, phone, email, or otherwise) and data we receive from other sources (including, for example, business partners, sub-contractors in technical, payment and delivery services, credit reference agencies, government bodies, and others).

We will only process Personal Data for the specific purposes set out in this Policy or for any other purposes specifically permitted by the applicable law. We will notify those purposes to the Data Subject when we first collect the data or as soon as possible thereafter.

You may give us Personal Data where you are a user of our Services, a teacher, school or other third party interacting with us. We use your Personal Data for the following purposes:

  • To provide and maintain our Application and Services
  • To notify you about changes to our Application and Services
  • To allow you to participate in interactive features of our Application and Services when you choose to do so
  • To provide customer support
  • To gather analysis or information so that we can improve our Application and Services
  • To monitor the usage of our Application and Services to detect, prevent, and address security issues

Further details of the Personal Data we collect, details of the processing activity, and the lawful basis for each is as follows:

WWhen you become our customer the processing of your information, and/or that of your team who you nominate to liaise with us, will become a condition of the contract between us as we require certain information in order to be able to provide you with our services (e.g. contact information). In those circumstances, if you do not provide your information when requested, we may be unable to provide our Services to you.

Representiatives of customers (schools, districts, businesses, etc.):

We require the following information to set up your accounts: first name, last name, email address, phone number (optional), country, and school name. We use this data to set you up as a customer on our systems and to liaise with you and your teachers about projects that we are undertaking with you. We also process payment information to facilitate payment of our Services; for internal and external auditing and to make appropriate financial returns to revenue; to process payment of invoices etc. Our payment system also collects the IP address of users who pay online to facilitate credit card location verification.

We collect, use and disclose your Personal Data to provide the Services to you via the Application, and to administer your account in accordance with: (a) this Policy, (b) any other agreement you may have entered into with us, and (c) applicable laws and regulations. It is your responsibility to ensure that we are kept informed of the correct and current contact information for you.

The lawful basis for this processing is the agreement you have agreed to, or if you have not entered into an agreement with us, our legitimate interests in providing the Application and Services through our agreement with the customer.

When corresponding with us by phone, e-mail or otherwise, we ask you to disclose only as much information as is necessary to provide you with our Services or to submit a question/suggestion/comment in relation to our Services or products.

The lawful basis for this activity is our agreement with your or our legitimate interests in providing our Application and Services in addition to our legitimate interests in improving our Application and Services based on your question/suggestion/comment.

If you are a Teacher/Administrator:

We collect and process your first name, last name, email address, phone number (optional), country, school name, school type, user ID, password, activity within the service. We also process payment information to facilitate payment of our Services; for internal and external auditing and to make appropriate financial returns to revenue; to process payment of invoices etc. Our payment system also collects the IP address of users who pay online to facilitate credit card location verification.

When corresponding with us by phone, e-mail or otherwise, we ask you to disclose only as much information as is necessary to provide you with our Services or to submit a question/suggestion/comment in relation to our Services or products.Users can log in to our Services directly using the Socrative app/web page or by using certain specified third-party accounts such as Google and MasteryConnect. We may add other third-party sign-on functionality in the future. By signing on in using a third-party account, we use your name, profile picture (if available), and email address to authenticate your identity and to pre-populate your profile.

Some third-party services, such as Google, give you the option to post or share information about your use of the services to your third-party account. The settings for that kind of sharing are outside of our Services. It’s up to you to check the sharing and privacy settings on any third-party accounts.

The lawful basis for this processing is the Terms of Use you have agreed to, or our legitimate interest in facilitating the provision of the Applications and Services to our customers, including processing payment.

If you input the Personal Data of others into the application, you are responsible for ensuring that you have obtained any permissions or authorizations for any Personal Data of others that you input or send through the Application.

We will communicate with you regarding our Services and your account. We will do this via the internet and via the email address you have provided. You acknowledge that data and information transmitted over the internet is susceptible to error or security breaches.

The lawful basis for this activity is the agreement you have entered into or our legitimate interests in providing you with important information about the Services and your account.

If you are a Student:

Showbie collects limited Personal Data from minor students only as needed for the operation and management of the Services provided by Showbie, and only where that student’s school board, educational institution, or teacher has contracted with Showbie to do so.

Data collection varies depending on whether the teacher uses the free or paid/pro version of Socrative.

If teachers are using the paid/pro version of Socrative, Showbie collects first name, last name, user ID, password, school name, location, activity within the service, and IP address. The Teacher may upload a class roster which includes unique usernames and passwords for each student.

If teachers are using the free version of Socrative, they provide a code for students to access the app, and creating a student profile is not required. We will collect only the student’s activity within the service and IP address.

Teachers will have access to class rosters and students’ activities within the service, such as quiz results.

Teachers may share template quizzes, tests, etc. with other persons using Socrative, but these templates do not contain any Personal Data about students, only the name of the teacher author.

When corresponding with us by phone, e-mail or otherwise, we ask you to disclose only as much information as is necessary to provide you with our Services or to submit a question/suggestion/comment in relation to our Services or products.

(a) It is the responsibility of our customers, e.g. the school board, educational institution, or teacher to obtain the consent of parents/legal guardians prior to our collection of such student Personal Data. If you are a minor student, do not upload or send any Personal Data about yourself or other students to Showbie, other than what is requested upon signing up for the Services. If we discover we have the Personal Data of a student without consent of a parent/legal guardian, or information in excess of what we request upon sign-up, we will permanently destroy that information as quickly as possible. If you believe a student may have provided us Personal Data without consent of a parent/legal guardian, or information in excess of what we request upon sign-up, please contact us at [email protected].

(b) Students can sign up to our Services with a username and password. Your teacher may instead provide you with a code, in which case you will not be required to sign up to access Socrative. Students are unable to see the activities of other students, irrespective of whether or not they are members of the same course group on Socrative.

(c) The Application allows students and teachers to interact. This information will also form part of the Personal Data of students. However, we are a Data Processor of this Personal Data on behalf of the students’ school board, educational institution or teacher who has contracted with us, and that school board, educational institution, or teacher is the Data Controller.

When we act as a Data Controller for the purposes set out above, the lawful basis for the processing is the agreement entered into with us, or our legitimate interests in providing the Application and Services through our agreement with your school board, educational institution, teacher, or the like.

Information collected as part of our sales and marketing efforts:

We collect, use and disclose Personal Data of administrative users or teachers for marketing purposes provided it does not direct advertising to any student users, and provided that student Personal Data is not used or disclosed. We collect Personal Data relating to administrative users or teachers for relevant product or marketing communications. We will never direct advertising to students or disclose student Personal Data for this purpose. Users may unsubscribe from marketing notifications at any time.

We collect, aggregate, and anonymize data for system monitoring, quality control, marketing, and product improvement purposes, provided it does not entail processing of any Personal Data of users.

The lawful basis for this activity is legitimate interest in selling and marketing our services when advertising to existing customers and consent when advertising to new and potential customers.

Website data:

We use both session-based and persistent cookies to track information about your use of the Application and our Services which allow us to make it easier for you to navigate the Services, or allow us to track your activities related to your use of the Application and our Services. We may also use third party analytics tools and technologies, such as Google Analytics, to track and analyze data from the Application and our Services.

Access to and Transfer of Personal Data

If you are located outside Canada or the United States and choose to provide information to us, note that we transfer the data, including Personal Data, to countries such as Canada and the United States.

All Personal Data processed by Showbie related to the Application and Services provided to our customers is stored in secure data centres hosted by Amazon Web Services (AWS) in the United States, with backup servers in South America, Asia and Australia. The full list of approved sub-processors, used in our capacity as a Data Processor, is listed in the GDPR compliant Data Processing Addendum (based on the EU Commision standard contractual clauses (2021/914)) we execute with all customers residing in the EEA.

In our capacity as a Data Controller, we rely on trusted third-party service providers such as for internal business operations, account administration, billing, improvement of services, and marketing. In this respect, our trusted third-party service providers may have access to relevant Personal Data in order for them to provide their services to us.

Where the customer is located in the EEA and the service provider is located in a country outside the EEA (“third country”) this will involve transferring of Personal Data to such third country.

Transfers to Showbie Inc., located in Canada, are covered by the EU Commissions Adequacy Decision (2002/2 EC). Showbie will not transfer Personal Data to third countries that do not offer adequate protection unless appropriate safeguards are established, such as EU Standard Contractual Clauses.

In addition, we may disclose your Personal Data to third parties:

  • In the event that we sell or buy any business or assets, we may disclose your Personal Data to the prospective seller or buyer of such business or assets;
  • If we, or substantially all of our assets, are acquired by a third party, information held by us about our customers will be one of the transferred assets;
  • If we are under a duty to disclose or share your information in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect our rights, property, or safety, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
  • As part of a project with other companies in the Showbie Group.

We may also be required to disclose Personal Data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. When acting in the role as a Data Processor we are committed to using reasonable efforts in redirecting any access requests received from governmental authorities or to notify the relevant customer about the request, unless we are prevented by law from doing so. In any case, we will challenge any overbroad or inappropriate disclosure and disclose only the minimum amount of Personal Data necessary to satisfy an access request.

How Long Do We Keep Hold of Your Information?

In our capacity as a Data Controller, the time periods for which we retain your data depends on the type of personal data and the purposes for which we use it. We will retain and use your Personal Data to the extent necessary to provide the Services and to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.

Our Data Controller customers, on whose behalf we process Personal Data acting as a Data Processor, collect and keep Personal Data. For further information on this, please contact your teacher, your school’s Socrative Administrator or the like.

Security of Personal Data

The security of your data is important to us but no method of transmission over the Internet or method of electronic storage is 100% secure. We will use appropriate technical and organizational measures to maintain the confidentiality, integrity, and availability of your Personal Data.

“Do Not Track” Signals

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

What are Your Rights with Respect to Your Personal Data?

You have the following rights:

  • To request access to any Personal Data held by us relating to you (a “Data Subject Access Request”). To make a Data Subject Access Request, please email us at [email protected].
  • To request that data is rectified, corrected or erased (subject to certain statutory restrictions).
  • To restrict the processing of Personal Data in certain circumstances.
  • To object to processing of Personal Data based on public interest grounds or based on legitimate interest of the data controller (subject to certain statutory exceptions).
  • To data portability, that is, to receive Personal Data about you and have it transmitted to another data controller, subject to certain limitations.
  • Where your data is processed based on your consent, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of processing based on consent before your consent was withdrawn.

Whenever possible, you can update your Information directly within your account settings section. If you are unable to change your information, please contact us to make the required changes.

To avail of any of the rights set out above, you may make a request to [email protected]. For the protection of privacy, suitable proof of identification will be required before a request can be processed.

Where we act as Data Processor and not Data Controller, we will refer your request to the applicable Data Controller, which, if you are a student, may be your teacher, school district, your educational institution or the like.

You also have the right to make a complaint to a supervisory authority. For a list of Supervisory Authorities in Europe, please see this list on the European Commission’s website.

In Canada you can contact the Office of the Privacy Commissioner of Canada.

What Will Happen if We Change Our Privacy Policy?

This Policy may change from time to time, and any changes will be posted on our website and will be effective when posted. This Policy was last updated on August 26, 2021.

How can you contact us?

If You have questions about this Privacy Notice or wish to contact Socrative for any reason, please contact us at:

Privacy Officer
Socrative, Inc.
#1400, 10117 Jasper Avenue NW
Edmonton, AB
T5J 1W8
Email [email protected]

Definitions

Personal Data

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.

Usage Data

Usage Data is data collected automatically either generated by the use of the Services or from the Service’s infrastructure itself (for example, the duration of a page visit).

Cookies

Cookies are small pieces of data stored on a User’s device.

Data Controller

Data Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of the personal data.

For the purpose of this Privacy Policy, Showbie is both a Data Controller, but Showbie may in other situations act as a Data Processor of your data.

Data Processor (or Service Providers)

Data Processor (or Service Provider) means a natural or legal person, public authority, agency or other body (other than an employee of the Data Controller) which processes Personal Data on behalf of the Data Controller.

We may use the services of various Service Providers to process your data more effectively.

Data Subject

Data Subject is a living individual who is the subject of Personal Data.

User

The User is the individual using our Application or Services. The User is typically the Data Subject, who is the subject of Personal Data.