Understanding Data Privacy: The Role of DreamBox Learning Inc. in Data Processing

In today’s digital age, understanding how your personal information is handled is crucial, especially within educational platforms. At DreamBox Learning, Inc., we recognize the importance of data privacy and are committed to protecting the personal information of our users, including teachers, parents, and students. This article explains our role as a data controller and how we process data in compliance with global data protection regulations like the General Data Protection Regulation (GDPR), Regulation (EU) 2016/679, and the UK Data Protection Act 2018 (DPA).

DreamBox Learning, Inc. is the entity responsible for the collection and use of your personal information under these regulations. We act as the data controller, meaning we determine the purposes and means of processing personal data. We believe in transparency and want to make it easy for you to reach us with any questions or concerns regarding your privacy.

You can contact DreamBox Learning, Inc. through various channels:

For US inquiries:

• Email: [email protected]
• Telephone: 1-800-323-9084
• Mail: 4350 Congress Street, Suite 700, Charlotte, NC 28209, USA

For UK inquiries:

• Email: [email protected]
• Telephone: 0800 6 527 527
• Mail: Attn Marissa Jones, 9 Palace Yard Mews, Bath, BA1 2NH, UK

For EU inquiries:

• Email: [email protected]
• Mail: DataRep, St Johannesgatan 2, 4th Floor, Malmo, SE – 211 46, Sweden

Personal Information Collection: What, Why, and How Long at DreamBox Learning Inc.

At Dreambox Learning Inc., we collect personal information to provide and enhance our educational services. Personal information is any data that relates to an identified or identifiable individual. We collect this information when you interact with our services, tailored to different user roles.

Information Collected from Teacher Users

If you are a Teacher User, we collect information at different stages of your engagement with our Learning Apps:

• Account Sign-Up: When you register as a Teacher User, we collect identifiers such as your name, email address, and phone number (optional). We also gather professional details like your school name, address, district, and job title. For account security, we collect encrypted password details. If you choose to sign up using Google Single Sign-On (SSO), Google’s privacy policies will govern that process, and we won’t collect your password directly. Providing a phone number allows us to contact you if necessary. This data is essential for account setup, management, and responding to your inquiries. Under EU or UK data protection laws, the legal basis for this processing is contract performance. Without this information, we cannot create your account.

  Alt Text: Image depicting a teacher completing the sign-up form for DreamBox Learning, highlighting fields for name, email, school details, and password creation.

  We also use your information to send service-related emails and, if you opt-in, marketing emails to inform you about our services. The legal basis for marketing emails under EU or UK law is your consent, which you can withdraw anytime via the “unsubscribe” link in our emails. Please note that unsubscribing from marketing emails will not prevent service-related communications. Our emails may include tracking technologies to analyze email effectiveness, such as open rates, engagement metrics, and click-through rates, helping us improve our communications. Opting into marketing communications implies consent to these technologies. You can prevent pixel tracking by disabling image downloads in your email settings.

• Learning Apps Usage: As you use our Learning Apps, we automatically collect internet and electronic network activity information through cookies and similar technologies. This includes usage data (timestamps), online identifiers (IP address), and usage information (topics clicked, interaction patterns). We use this data to generate aggregated usage reports, understand teacher engagement, improve the Learning Apps, and send platform-specific messages. This information is retained as long as your account is active, unless stated otherwise.

• Student User Account Creation: Teachers, parents, or guardians create Student User accounts. When creating these accounts, we collect student identifiers like name, date of birth, classroom name, and class year, along with login credentials. For accounts linked to a Teacher Account, an optional student email address can be provided. This information is used to generate a Student User ID and manage the student account. The legal basis for this processing under EU or UK data protection laws is contract performance.

  Teachers have access to student data linked to their classrooms, including names, grade levels, avatars, background themes, demographic data (gender, date of birth, race), usage information, educational progress (lessons completed, assignment history), login credentials, student IDs, alerts, achievements, ongoing assignments, login frequency, time spent on Learning Apps, and detailed curriculum performance breakdowns.

Information Collected from Parent/Guardian Users

For Parent/Guardian Users, data collection occurs when you sign up for our Learning Apps:

• Parent User Sign-Up: When you register as a Parent User, we collect identifiers (name, email, postal code, phone number (optional)), child’s identifiers (name, class year, date of birth (optional)), protected classifications (race and gender if provided), and login details (password). This information helps us create and manage your account, place your child at the appropriate curriculum level, and personalize Family Dashboard reports. The legal basis under EU or UK data protection laws is contract performance or compliance with legal obligations. Processing sensitive information like race is based on safeguarding the child’s rights, as per Art. 9(2)(b) GDPR, depending on member state laws. We may also send informational materials to your mailing address.

  Alt Text: Screenshot of a DreamBox Learning Family Dashboard, showing student progress, assignments, and learning metrics for parents.

  Parents/guardians can view student information on the Family Dashboard, including student name and account details, ongoing assignments, recent achievements, lessons completed, login frequency, time spent on Learning Apps, and curriculum performance details. They also receive notifications upon lesson completion.

Information Collected from Student Users

For Student Users, especially those under 16, data collection and processing require parental consent.

• Student Profile Updates: When students update their profiles, we collect avatar preferences to personalize their visual experience. Avatar selections are visible to other students on the Classroom login page.

• Feedback to DreamBox: If a student sends feedback, we collect message content, screenshots, and session data to troubleshoot technical issues, address product concerns, and improve our offerings. We do not directly respond to student feedback messages.

• Learning Apps Usage: We automatically collect internet and electronic network activity information (usage data like time per problem, clicked items, answers), online identifiers (IP address), and education information (participation history, performance data). This data is crucial for providing and enhancing the Learning Apps by monitoring student progress, adapting question content, personalizing learning paths and difficulty levels in real-time, creating diagnostic reports for parents/guardians and teachers, diagnosing and fixing errors, and awarding earned prizes/rewards.

  We also receive educational information from schools, including diagnostic assessment records (test names, scores, dates). Schools may optionally provide sensitive demographic data (ethnicity, race), special education status, assisted lunch information, and English Language Learner (ELL) status. We use this to optimize the system for better test performance, support schools’ equity efforts, and ensure compliance with regulatory requirements. This information is only shared with relevant schools. We also receive personal information indirectly from schools via rostering and SSO service providers for easier Learning Apps access.

• Survey Completion: Student survey responses at lesson ends are collected to improve our product and educational content. The legal basis for this processing under EU or UK data protection laws is our legitimate interest in identifying product and content issues. Surveys are randomly presented to a subset of students after specific lessons.

• Teacher Messages: When students receive messages from teachers, they can respond with emojis to communicate reactions. These messages are retained for 90 days.

Information Collected from Website Visitors

If you are a website visitor, we collect information when you interact with our website:

• Customer Support Contact: When you contact customer support, we collect identifiers (name, email), your role (school administrator, teacher, parent/guardian), and any information you include in your message. We use this to address your inquiries and troubleshoot issues. The legal basis under EU or UK data protection laws is service performance at your request.

• Newsletter Sign-Up: For newsletter subscriptions, we collect your email address to send updates and editorial content. Consent is the legal basis under EU or UK data protection laws, and you can withdraw consent via the “unsubscribe” link. Our newsletters may use tracking technologies to analyze engagement, similar to marketing emails for teachers, to optimize content delivery.

  Alt Text: Image of a newsletter sign-up form on the DreamBox Learning website, prompting visitors to enter their email address to subscribe for updates.

• Social Media Interactions: We engage with users on platforms like Facebook, X, LinkedIn, Instagram, and YouTube. These Social Networks may process personal information in the USA, with potentially less protective laws than in your country.

  • Community Management: We collect contact information and interactions like “likes,” shares, and messages to analyze content perception and improve our public relations. The legal basis under EU and UK data protection laws is our legitimate interest in optimizing communication with users and the public. You can object to this processing by emailing [email protected].

  • Page Insights: When you visit our Social Media pages, the Social Network records your IP address and usage behavior via trackers or advertising IDs. This data helps us receive aggregated, anonymous statistics about user demographics, engagement metrics, and reach, allowing us to improve advertising campaigns. We are joint controllers with the Social Network for this processing under EU and UK data protection laws, based on our legitimate interest in statistical evaluation for advertising improvement. Objections can be sent to [email protected]. We do not independently retain this information; refer to the Social Network’s privacy policies for data protection and storage details.

  • Information Processed Solely by Social Networks: We do not control how Social Networks use personal information for their purposes, storage duration, or third-party sharing. If you are logged into a Social Network, they automatically collect your Social Network ID and link it to advertising IDs, tracking your visits to our Social Media Page and other online interactions. This enables tailored content and advertising. Refer to the Social Network’s privacy policies for details on their data collection and usage practices.

• Cookies and Tracking Technologies: We use essential, performance, marketing, and analytics cookies to collect usage, device, and location information (via IP address) on our Website. This helps enhance user experience, conduct website analytics, prevent fraud, detect unlawful activity, and diagnose/repair website errors. Analytics and advertising cookies may be considered “sale” or “sharing” under the California Privacy Rights Act. You can opt-out via Your Privacy Choices.

  • Adobe Marketo Engage: We use Adobe Marketo Engage to collect data on website interactions, browsing activity, device info, IP address, referring URLs, search queries, social media profiles, purchase history, and ad clicks via cookies and web beacons. This information manages online content, improves website performance, and targets advertising. Review Adobe’s Privacy Policy for more details and opt-out options here or via Your Privacy Choices.

  • Firebase Crashlytics SDK: We use Firebase Crashlytics SDK to collect crash reports, including logs, user interactions before crashes, crash counts, and user IDs, to enable crash reporting, management, and developer analysis for preventing future crashes. See Firebase’s Privacy and Security Terms for details and opt-out via Your Privacy Choices.

• Data Aggregation and Anonymization: We aggregate and anonymize collected data for benchmarking and internal analytics in de-identified form. We do not attempt re-identification unless necessary to verify compliance with data protection laws.

DreamBox Learning Inc. also uses collected personal information for legal compliance, business maintenance, and other limited circumstances as detailed in “HOW WE SHARE YOUR PERSONAL INFORMATION”.

Data Retention Policies at DreamBox Learning Inc.

DreamBox Learning Inc. retains your personal information as long as necessary for the purposes outlined in this Privacy Notice. Unless specified otherwise, we retain data:

• For the duration of your account existence.
• Until the information is no longer needed for its collected purpose.
• Until a valid deletion request is received, in which case we will delete or anonymize the data within 30 days.

For accounts associated with schools or districts, data is deleted 90 days after subscription expiration. However, we may retain personal information longer for:

• Legal Compliance: Meeting obligations like accounting, dispute resolution, and labor, tax, and financial regulations.
• Safety and Security: Securing our properties and preventing fraud.
• Legal Claims: Exercising or defending legal claims, responding to legal processes or governmental requests, enforcing contracts or Terms of Use, and investigating potential violations.

How DreamBox Learning Inc. Shares Your Personal Information

1. General Sharing Practices

DreamBox Learning Inc. shares personal information as described in the “PERSONAL INFORMATION WE COLLECT, WHY AND FOR HOW LONG” section and in the following general situations:

• Within DreamBox: We share data internally for efficient service provision, such as accounting and customer support, on a need-to-know basis, based on our legitimate business interests.
• With Teachers and Parents/Guardians: We share student diagnostic reports (educational progress data) with parents/guardians and teachers.
• Corporate Reorganization: In case of business restructuring like mergers, acquisitions, sales, or transfers, we may share personal information with involved third parties (buyers, targets, advisors) to facilitate transactions, including during bankruptcy or liquidation proceedings, based on legitimate business interests or consent where legally required.
• Legal Purposes: We disclose personal information when legally required, such as in response to court orders, subpoenas, or governmental requests, including for national security. We may share data with legal advisors or auditors to protect our legal rights, enforce terms of use, defend against claims, and prevent illegal activities, fraud, or threats to safety, based on legal compliance or legitimate interests in complying with non-EU data protection laws.
• With Your Consent: We may request your permission to share your personal information for specific purposes, notifying you and seeking consent before sharing. You can revoke consent anytime by emailing [email protected].

2. Sharing in the Last Twelve (12) Months

For Business Purposes: In the last 12 months, DreamBox Learning Inc. has disclosed categories of personal information for business purposes to the following third-party categories:

• Identifiers: To service providers for IT support, data hosting, analysis, CRM, mailing, email delivery, professional services, auto-rostering, payment processing, research, reporting, video/phone systems, web analytics, and similar services.
• Internet or Electronic Network Activity Information: Collected by cookies to IT support for security incident detection, fraud prevention, and service error identification and repair.
• Internet or Electronic Network Activity Information: Collected by cookies to our cookie management provider.

3. Sale of Personal Information

In the preceding 12 months, DreamBox Learning Inc. has shared internet or electronic network activity information collected via cookies and tracking technologies with data analytics/advertising providers as described in “PERSONAL INFORMATION WE COLLECT, WHY AND FOR HOW LONG”. You can revoke consent or adjust privacy preferences via Your Privacy Choices.

SERVICE PROVIDERS HANDLING STUDENT USER INFORMATION

For children and student privacy laws (COPPA and FERPA), here are service providers for Learning Apps that collect or maintain Student Users’ personal information:

| Service Provider | Contact Information