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Privacy Policy

Version 1.0 | Last Updated: 2024-01-01

1. Introduction

SwiftASL ("we," "our," or "us") is committed to protecting the privacy of all users, especially children. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you use our web application and services designed to help Deaf children learn to read through ASL video flashcards.

We comply with the Children's Online Privacy Protection Act (COPPA) and the Family Educational Rights and Privacy Act (FERPA) to ensure the protection of children's personal information and educational records.

2. COPPA Compliance

SwiftASL is designed for use by children under 13 years of age. We are fully committed to complying with the Children's Online Privacy Protection Act (COPPA). Key points of our COPPA compliance include:

2.1 Educational Purpose

SwiftASL collects and uses children's personal information solely for educational purposes.

  • No Marketing: We do not use children's data for marketing or advertising purposes
  • No Selling: We never sell, rent, or trade children's personal information to third parties
  • No Repurposing: Data is not used for any purpose other than providing and improving the educational service
  • Limited Retention: Data is not retained longer than necessary for educational purposes
  • Security: All data is protected by reasonable security measures appropriate for children's information

2.2 Parental Consent Requirements

When a child under 13 creates an account through self-registration:

  • We require a parent/guardian email address during registration
  • We send a consent request email to the parent/guardian
  • The child's account is placed in "restricted mode" until consent is received
  • In restricted mode, the child cannot record videos or practice - only view their dashboard and settings
  • If consent is not received within 7 days, the consent request expires
  • Accounts without consent are automatically deleted after 30 days

2.3 Teacher-Created Accounts (FERPA Exception)

When a teacher creates a student account through our platform:

  • The teacher acts as a "school official" under FERPA (Family Educational Rights and Privacy Act)
  • Separate parental consent is not required as the school has authorized the use of SwiftASL for educational purposes
  • These accounts have immediate full access to the educational features
  • Parents retain all rights to access, review, and request deletion of their child's educational records

2.4 General COPPA Commitments

  • Parents can review, request deletion of, and refuse further collection of their child's information
  • We collect only the minimum information necessary for the educational purpose of our service
  • We do not condition participation on disclosure of more information than reasonably necessary
  • We maintain reasonable security procedures to protect children's information

3. FERPA Compliance

When SwiftASL is used by schools, we act as a "school official" under FERPA and agree to the following:

  • We use education records only for the purposes for which disclosure was made
  • We do not disclose education records to third parties without proper consent
  • We maintain appropriate security measures to protect education records
  • Parents have the right to inspect and review their child's education records
  • Parents may request correction of records they believe are inaccurate

4. Information We Collect

4.1 Student Information

  • Account Information: Username and 6-digit PIN (email is optional)
  • Educational Content: Video recordings of ASL signs created by the student
  • Practice Data: Flashcard practice results, word mastery progress, and learning statistics
  • Usage Data: Time spent practicing, session frequency, and streak information

4.2 Parent/Teacher Information

  • Account Information: Username, email address, and password
  • Contact Information: Email for notifications and password recovery
  • Authentication Data: Two-factor authentication information if enabled

4.3 Automatically Collected Information

  • Device type and browser information
  • IP address (for security and audit purposes only)
  • Access logs for security monitoring

5. How We Use Information

We use collected information solely for:

  • Providing the educational flashcard learning experience
  • Tracking student progress and generating reports for parents and teachers
  • Personalizing the learning experience based on performance
  • Communicating important service updates to parents and teachers
  • Maintaining security and preventing unauthorized access
  • Complying with legal obligations

6. Information Sharing

We do not sell, trade, or rent personal information. We may share information only in these circumstances:

  • With Parents: Parents can view their child's complete learning data
  • With Teachers: Teachers can view student progress for educational purposes
  • Service Providers: Trusted partners who assist in operating our service (bound by confidentiality)
  • Legal Requirements: When required by law or to protect rights and safety

7. Data Security

We implement comprehensive security measures including:

  • Encryption of data in transit (HTTPS/TLS)
  • Secure password storage using industry-standard hashing
  • Role-based access controls
  • Regular security audits and monitoring
  • Complete audit logging of all data access
  • Video content accessible only to authorized users (student, parents, teachers)

8. Data Retention and Deletion

  • Active accounts: Data is retained as long as the account is active
  • Deleted accounts: Data is soft-deleted and retained for 6 months for recovery purposes
  • After 6 months: Data is permanently and irreversibly deleted
  • Parents may request immediate data deletion (subject to legal retention requirements)

9. Parental Rights

Parents have the right to:

  • Review all personal information collected about their child
  • Request deletion of their child's personal information
  • Refuse further collection of their child's information
  • Export their child's data in a portable format
  • Withdraw consent at any time

To exercise these rights, please contact us at privacy@swiftasl.com or use the data export feature in your account settings.

10. No Social Features

SwiftASL does not include any social features. Students cannot communicate with other students, share content publicly, or interact with users outside their authorized circle (teachers and parents). All video content is private and only accessible to the student who created it and their authorized adults.

11. Third-Party Services

We may use the following types of third-party services, all bound by strict data protection agreements:

  • Cloud hosting providers for secure data storage
  • Email service providers for parent/teacher communications
  • Video processing services for optimizing recorded content

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify parents and teachers of any material changes via email and will require re-consent if changes affect children's data collection. The "Last Updated" date at the top indicates when this policy was last revised.

13. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact us:

SwiftASL Privacy Team

Email: privacy@swiftasl.com