Pear Deck Learning Privacy Policy for Product Users

Last Updated Date: October 30, 2026

Introduction

Welcome! Liminex, Inc. doing business as GoGuardian and Pear Deck Learning and its family of company Affiliates, including Pear Deck, Inc. and Snapwiz Inc. (collectively, “Liminex”, “GoGuardian”, “we”, “us”, “our”) is an educational technology company that provides K-12 schools and school districts with digital learning tools designed to supercharge the learning potential of every student. The privacy of each and every user matters deeply to us, and we strive for transparency in all of our data privacy practices—especially when it comes to identifying the information that we collect, use, share, and disclose, as well as how we help keep your information safe. We take our responsibility to protect your information very seriously. Please remember that we are always here to answer any questions you have, and we look forward to working with you for years to come. Capitalized terms used herein that are not expressly defined are as defined in our Product Terms of Service and End User License Agreement (“EULA”).

This Product Privacy Policy (“Product Privacy Policy”) explains how we collect, use, share, disclose, and protect information collected from and about our School customers that are using our Offerings and such School’s Authorized School Personnel. Our Offerings include the following:

This Product Privacy Policy does not apply to:

visitors and users of our general audience Website and their information (please see our Privacy Policy for Website Visitors, "Website Privacy Policy");
information that we process on behalf of schools or other enterprise customers as a data processor while providing services to them (our use of information that we process on behalf of our enterprise customers is generally governed by our agreements with such customers; if you have questions regarding your personal information that we process on behalf of schools or our other enterprise customers, please direct your questions to the school or enterprise customer with whom you have a relationship);
organizations or third parties that we do not own or manage, or to individuals that we do not employ or manage. We encourage you to review the applicable third-party privacy policies and terms of use before submitting any information through those sites or services; or
Data submitted as a job applicant to Liminex and its Affiliates.

By using our Offerings, you, the school or school district (“School,” “you,” “your,” each as further defined in the EULA), are declaring that you have read and understand this Product Privacy Policy. If you are acting on behalf of a School, you represent and warrant that you are at least eighteen (18) years old and have the authority, right, and capacity to legally bind the School and have read and understand this Product Privacy Policy. Our EULA; any applicable Supplemental Terms; and, as applicable to the extent your School is in the European Economic Area ("EEA"), our Data Processing Addendum ("DPA") also apply to how we treat your information.

1. Information Provided Directly to Us through our Offerings

The information that we collect depends on the Offerings and features within those Offerings that a School uses and is generally limited to information that is specifically required for the use and functionality of such Offerings and features. We collect some business information directly from Schools (e.g., information collected when signing up to use our Offerings) about their students or other associated individuals (e.g., parents/guardians or visitors) or directly from the School’s students (e.g., browsing information) when we act as their service provider. We also collect some information automatically (e.g., Offerings usage information).

1.1 School Information

We collect the following information that we collectively label as “School Information”:

School Profile Information: When an official or other authorized representative of a School ("School Official") initiates contact through our Website for the Offerings on behalf of his/her School, we collect that School Official’s contact information as well as information about his/her School relevant to purchasing and setting up our Offerings. This information includes the School Official's name, email address, and phone number, as well as certain other information including the School’s name, address, billing address, number of devices, number of students, and network configuration. If the School Official creates an account for the Offerings, the School Official must also create a password.
Authorized School Personnel Information: In certain Offerings, following the establishment of an Account, Authorized School Personnel can use the Offerings to add additional Authorized School Personnel from their School and designate their appropriate permission levels in the Offerings. The Authorized School Personnel may provide such persons’ contact information such as email addresses and phone numbers. Certain Offerings require Authorized School Personnel to provide class enrollment information (e.g., class name and subject). Depending on the Offerings and features selected by a School, the Offerings can collect additional information about Authorized School Personnel, including chat messages and video conferencing between students and teachers (including if Authorized School Personnel participate in a chat function as part of a video conference), GoGuardian-generated unique account identifiers, and other relevant unique identifiers (e.g., Google Classroom identifiers if School integrates Google Classroom with GoGuardian Teacher). This information may change if a School and/or Authorized School Personnel utilize new features and/or Offerings. Students can only interact with Authorized School Personnel through the GoGuardian Offerings (via chats or video conferencing).
Support Requests: Authorized School Personnel can submit requests about the Offerings to our support center via our Help Center, through our Offerings themselves, and from our Website. When Authorized School Personnel submit support requests through these support centers, we receive these requests and associated contact information.
Application Usage and Business Information: Depending on the Offerings and features selected by a school, the Offerings can collect information regarding application usage and licenses.

1.2 Personal Student Information

We collect personal information about a current or former student enrolled in a K-12 School (“Personal Student Information” as further defined in our EULA) where Schools have provided consent as required by Applicable Law, including the Children’s Online Privacy Protection Act (“COPPA”). The Personal Student Information collected depends on the Offering(s) used and may change if a School utilizes new features or Offerings.

In connection with providing us with, or instructing us to collect, such Personal Student Information, each school in the United States (“U.S.”) must comply with any legal requirements applicable to it, which may include, providing appropriate notice and/or obtaining parental consent. Schools located in countries outside of the U.S. must also obtain and provide appropriate consent from parents and/or guardians of students or as otherwise required by Applicable Law.

1.2.1 GoGuardian Personal Student Information

This section applies to the GoGuardian Offerings. In providing our GoGuardian Offerings to Schools, we may collect Personal Student Information on behalf of a School. We only collect Personal Student Information on school-managed devices and/or Accounts where a School has already registered with GoGuardian and chosen to use GoGuardian Offerings and where such Schools have consented as set forth above. The Personal Student Information collected by our GoGuardian Offerings on behalf of a School depends on the particular GoGuardian Offering(s) and feature(s) selected by a School and the particular settings enabled or disabled by the School. Pursuant to such selections, the Personal Student Information that we collect may include:

Student’s School-Managed Account Information and Association Information: We may collect a student’s Google or Microsoft School-managed account information, including the student’s name, email address, Google Profile ID and Google Image URL (for school-managed Google accounts), Microsoft Profile ID (for school-managed Microsoft accounts), organizational unit, and device identifiers necessary to associate a student with a certain device and settings. Additionally, GoGuardian Offerings may also need to associate a student with a particular teacher’s classroom by using a Google classroom identifier or other identifier as well as one or more individuals (e.g., parents or guardians).
Activity Information: We may collect additional information from or about school-managed Accounts, devices, applications, and online activity. This may include chats (e.g., within GoGuardian Teacher), video conferencing recordings (including audio and video of participating students and chats from within a video conference), a student’s browsing history, IP address, online content, email content, screenshots, and key percentage variance (but not the actual inputs or sequence of inputs; e.g., to identify patterns like gaming). Students may use chat and video conferencing features only to communicate with Authorized School Personnel. Our Offerings do not permit interactions with individuals outside of those designated as Authorized School Personnel.
Grade, Attendance, and Assignment Information: We may collect grade, attendance, and assignment information.
General Location Information: For the purpose of allowing a school to locate and recover its devices (e.g., via GoGuardian Admin), we may collect the general geographic location of devices. While GoGuardian Offerings can collect IP addresses while active, no precise location data of mobile phones is collected by GoGuardian.
Integration Information: If your School chooses to integrate GoGuardian Offerings with other Integration Offerings (e.g., integrate with other School software with GoGuardian Offerings), then we may collect the information necessary to integrate and provide our Offerings, including unique identifiers (e.g., Google classroom identifier to connect a student to his/her classroom if your School integrates Google Classroom with GoGuardian Teacher) and other information (e.g., Parent/Guardian Information if your School integrates GoGuardian Offerings with the Parent/Guardian Information from Classlink or Clever).

1.2.2 Pear Deck Learning Personal Student Information

This section applies to the Pear Deck Learning Offerings. The Personal Student Information collected by our Pear Deck Learning Offerings on behalf of a School depends on the particular Pear Deck Learning Offering(s) and feature(s) selected by a School and the particular settings enabled or disabled by the School. Pursuant to such selections, the Personal Student Information that we collect may include:

School-Managed Account and Association Information: We may collect a student’s name, email address, and account identifiers (e.g., Google ID or Microsoft ID), as well as information needed to associate the student with a device, account, class, teacher, or school. In Pear Deck and Pear Practice, students may join sessions in anonymous mode, in which case we do not collect their name or email address. Pear Assessment may additionally collect a student ID and Pear Assessment username.
Activity Information: We may collect information about student activity within the Offerings, including responses to interactive features, assessment scores, and session URLs. If School uses Pear Assessment, we may collect audio recordings and images during assessments.
Device and Usage Information: We may collect device and usage details such as IP address, device identifier, operating system, browser type, non-precise geographic location (e.g., city or zip code), technical information about system and app software, peripherals, and timestamps associated with logins and usage. If School uses Pear Assessment, we may also collect time on task (the length of time a student spends on a question), browser lock events, and user interaction data.
Integration Information: Where your School chooses to integrate our Offerings with Integration Offerings (e.g., other School-selected software), we may collect the information necessary to support those integrations, including identifiers such as Google Classroom IDs or student information system data.
Demographic Information (Pear Assessment only): If School uses Pear Assessment, we may collect student demographic details, such as gender, date of birth, English language learner status, individualized education plan status, and free or reduced lunch status.

1.2.3 COPPA Safe Harbor

Protecting children’s and student’s privacy is especially important to us. We participate in the iKeepSafe Safe Harbor program. We have been granted the iKeepSafe COPPA Safe Harbor seal signifying that GoGuardian’s Website as well as the software that runs the Website and certain Offerings (GoGuardian Admin, GoGuardian Teacher, GoGuardian Beacon, GoGuardian Fleet, and GoGuardian DNS) and Pear Deck Learning Offerings (Pear Deck, Pear Assessment, and Pear Practice) have been reviewed and approved for having policies and practices surrounding the collection, use, maintenance and disclosure of personal information from children consistent with the iKeepSafe COPPA Safe Harbor program guidelines. COPPA is a federal law that regulates the online privacy of children under the age of 13. Below is an email for iKeepSafe Safe Harbor program: privacy@ikeepsafe.org.

1.3 Parent/Guardian Information

Depending on the Offering(s) utilized, feature(s) selected, and the particular settings enabled or disabled by the School (e.g., if a School chooses to utilize one of our Offerings with a guardian feature, such as to enable a School to send important automated notifications to a parent/guardian about his/her child, to view assessment results in Pear Assessment, etc.), we may receive Parent/Guardian Information, including the parent’s/guardian’s name, email address, phone number, and Association Information, from the School.

If you are a parent or guardian and utilize a guardian feature (including GoGuardian’s Parent App and/or guardian feature in Pear Assessment), we may collect Parent/Guardian Information directly from you including: (1) your email address to confirm your authorization from the School to use the app, to determine the student associated with you and, once verified, enable the app; and (2) certain automatically-collected information about your app activity as set forth below.

To learn whether your child’s School is using an Offering that collects and provides us Parent/Guardian Information or how to update a child’s legal parent/guardian contact information or other related Association Information, please contact your child’s School. For more information, please see the section below titled “Your Rights and Choices About Information Collected Through Our Offerings.”

1.4 Visitor Information

Depending on the Offering(s) utilized, feature(s) selected, and the particular settings enabled or disabled by the School, we may receive certain Visitor Information, including name, email address, phone number, photograph, government-issued identification, and Association Information about a person from the School. To learn whether a School is using an Offering that collects and provides us Third-Party Information or how to update it or any related Association Information, please contact such School directly.

2. Information We Automatically Collect through Our Offerings

Our Offerings may automatically collect the following additional information that we label collectively as “School Log and Cookie Information” (as defined in our EULA and supplemented below):

Analytics Information and Event Information: We may automatically collect certain information through analytics services providers, including IP address, internet service provider, date and time stamp, browser language, browser type, amount of time spent on particular features of our Offerings, and/or other general usage data. Similar to other software, we also collect event information regarding how users interact with our Offerings.
Log Information: We may collect log information such as service diagnostics and technical logging information, which may include IP address, login times to our Offerings, usage times of our Offerings, browser type, and browser configuration.
Device Information: We may collect information about the devices that log into our Offerings, including type of device, device settings, and operating system.
Cookies: We may use Cookies (defined below) in our Offerings for the purposes described in the section below titled “Cookies Notice.”

3. How We Use Information Collected Through Our Offerings

3.1 School Information and School Log and Cookie Information

We may use School Information and School Log and Cookie Information to:

set up and provide our Offerings;
analyze and improve our Offerings;
respond to a School’s and/or Authorized School Personnel’s requests and to provide related support;
administer and troubleshoot our Offerings;
send information to a School and Authorized School Personnel about how to use our Offerings and other important updates;
send email or text information or alerts as part of Offerings to a School and/or Authorized School Personnel;
notify a School and Authorized School Personnel about new features or Offerings that may be of interest to them, and, similarly notify other Authorized School Personnel of new features or Offerings that may be of interest to them when residents of the U.S. or otherwise as permitted by Applicable Law;
help prevent fraud and to enforce the legal terms that govern our Offerings;
to comply with Applicable Law and protect our and others’ rights, safety and property;
to determine general, non-identifying demographics such as location (down to the city level), age range (e.g., 25-35), and equipment profiles (e.g., Chromebook with medium-size screen); and
follow further instructions of a School.

We do not sell School Information and School Log and Cookie Information or share either for cross-context behavioral advertising (and have not done so in the past 12 months). No advertisements of any kind are shown in any Offerings. If School or Authorized School Personnel opt in to receive text messages for certain alerts or notifications (e.g., via GoGuardian Beacon), text messaging originator opt-in data and consent information will not be shared with any third parties other than third parties supporting our Offerings. School Information or Personal Student Information are not displayed publicly in any way.

3.2 Personal Information

In accordance with our contractual obligations, we may use Personal Student Information, Parent/Guardian Information, and Visitor Information (collectively, “Personal Information”) to:

provide, improve, and analyze our Offerings and for legitimate educational purposes of the School;
send individuals alerts and notifications (e.g., to parents and guardians in the Parent App) or otherwise provide information to such individuals consistent with our Offerings, including any guardian features thereof;
enforce the legal terms that govern our Offerings;
comply with Applicable Law and protect our and others’ rights, safety, and property; and
follow further instructions of a School.

At all times, Personal Student Information is the property of and under the control of a School or, as required by Applicable Law, the applicable eligible student, parent, or guardian. We will not use Personal Student Information for any purpose other than those required or specifically set forth in this Product Privacy Policy, our EULA, DPA, or any other agreement between a School and Liminex. We do not sell Personal Student Information. We do not share Personal Student Information with third-party service providers for training their artificial intelligence models for their own purposes. We do not use Personal Student Information to target advertisements (or share Personal Student Information for cross-context behavioral advertising purposes), market to students or anyone else, or amass a profile about a K-12 educational student for a non-educational purpose.

We do not use Personal Student Information for any purposes prohibited by the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g; 34 CFR Part 99.3) ("FERPA"), California Business & Professions Code section 22584 (“KOPIPA”), and California Education Code section 49073.1. We will use Personal Student Information in accordance with Applicable Law, including student privacy laws such as Connecticut's "Act Concerning Student Privacy" (Connecticut General Statutes § 10-234aa et seq.).

If you are located in the EEA or the United Kingdom ("UK"), please see the section below titled “Notice to EEA and Other Non-US Residents” for more information about how we use information and the legal bases for collecting information.

4. How We Disclose Information Collected Through Our Offerings

We may disclose information that we collect in the following ways:

Affiliates: We may provide access to or share your information with current or future Liminex companies, including our Affiliates such as Pear Deck, Inc. and Snapwiz Inc.
Authorized School Personnel Access: Each School determines which Authorized School Personnel have access to the School’s account with Offerings and their permission levels.
Third Parties Supporting Our Offerings: We may share information with our service providers that assist us in performing business-related functions that support our Offerings (e.g., we use hosting services and customer service tools to help support our Offerings). When we employ another company to perform a function of this nature, we provide them with the information that they need to perform their specific function and impose contractual limits on how such third parties can use such information. Regarding the Google Workspace API, we do not use this API to develop, improve, or train generalized artificial intelligence and/or machine learning models. We prohibit third parties from using Personal Student Information to create an automated profile, engage in data enhancement, conduct social advertising, or target advertising to students, parents, teachers, or the School. Information about third-party service providers with whom we share Personal Student Information that are utilized by GoGuardian Offerings is available here and Pear Deck Learning Offerings is available here.
With School Permission or at School Direction: We may disclose information, including Personal Student Information, to third parties pursuant to a School’s instruction or with a School’s permission. For example, if a School chooses to integrate our Offerings with another third-party company’s products or services, then we will share information as instructed. With your permission, we may also share or disclose your name and other content through a testimonial video or quotation.
Protection of Liminex and Others: We may disclose certain information if we believe in good faith that doing so is necessary or appropriate to (i) protect or defend the rights, safety, or property of Liminex or third parties, including to defend or enforce our Product Privacy Policy, EULA, or any other contractual arrangement; or (ii) to respond to claims that content violates the rights of third parties.
Legal Requirements: We may disclose certain information if we believe in good faith that doing so is necessary or appropriate to comply with any law enforcement, legal, or regulatory process, such as to respond to a warrant, subpoena, court order, or other Applicable Law.
Business Transfer: We may disclose certain information in connection with or during negotiations of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. If such transfer is subject to additional mandatory restrictions under Applicable Law, we will comply with such restrictions. The successor entity will be subject to all Applicable Law, including student privacy laws. In connection with such a transaction, we will also work to ensure that the successor entity has a commitment to student privacy.
De-Identified Information: We may use, share, or disclose De-Identified Information for various purposes such as product development, research, and marketing, in compliance with Applicable Law. For example, we may use aggregate, anonymous data to publish an e-book on Schools’ most utilized online educational resources.

If you are a School or other Authorized School Personnel in the EEA, Switzerland, or the UK, please see the section titled “Notice to EEA and Other Non-US Residents” below for additional information that may be relevant to you.

5. How Long We Keep Information

We retain Personal Student Information as directed by the School:

School’s Request for Deletion or Transfer of Personal Student Information: We act upon a School’s documented instructions to delete Personal Student Information during and after all School licenses to the Offerings have expired, unless we are required to retain such information to comply with our legal obligations with law enforcement, resolve disputes, or enforce our agreements. Upon instruction to delete Personal Student Information, we will take reasonable efforts to delete and/or de-identify such information in a commercially reasonable amount of time under Applicable Law. At the termination of all of the School’s licenses with us, we and the School may agree to transfer the School’s Personal Student Information back to the School. In that case, similar to deletion requests, we will act upon a School’s documented instruction to transfer the School’s Personal Student Information to the School and take reasonable efforts to transfer such information in a commercially reasonable amount of time under Applicable Law, unless we are required to retain such information to comply with our legal obligations, or with law enforcement, resolve disputes, or enforce our agreements. For Schools in the EEA, Switzerland, or the UK, Personal Student Information will be deleted and transferred/ported according to the terms of the DPA or other agreement between the School and us.
Video Conferencing Recordings: If a School enables the video conferencing feature in GoGuardian Teacher, audio and video recordings will be stored by GoGuardian for no more than 90 days.
Email Messages: If a School enables an email API feature in GoGuardian Beacon, email messages that do not generate a Beacon alert will be stored by GoGuardian for no more than 60 days.
Deactivated Accounts: We may consider a School’s account to be terminated 365 days after all of a School’s licenses expire without use, reactivation, or renewal by the School. At that time, if a School has not requested deletion of Personal Student Information, we will automatically de-identify and/or delete the School’s Personal Student Information within a commercially reasonable period of time as long as that information is not necessary to comply with our legal obligations, resolve disputes, or enforce our agreements. All Personal Student Information retained will remain subject to our Product Privacy Policy that was in effect at that time—even after the deactivation of an account or termination of a contract.

We generally retain information other than Personal Student Information for as long as it may be relevant to the purposes above or as required or permitted by Applicable Law. We consider the nature and sensitivity of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests in determining how long to retain such information. The purposes for which we use such information may dictate different retention periods for the same types of information. To dispose of any personal information, we may anonymize it, delete it or take other appropriate de-identifying steps. Please note that information may persist in copies made for backup and business continuity purposes for an additional period of time.

6. Your Rights and Choices About Information Collected Through Our Offerings

You have certain rights and choices with respect to your information as further described in this section.

6.1 School Profile Information and School Log and Cookie Information

Your choices about School Profile Information and School Log and Cookie Information:

Promotional Communications: In some circumstances, we may use School Profile Information for promotional communications. You can decline such promotional communications at the point information is requested for such purpose (e.g., by checking the relevant box) or, by following the unsubscribe instructions on communications sent to you. You can also contact us as described in the section titled “How to Contact Us” below.
Cookies and Analytics. You can opt out from certain cookie-related and analytics processing by following the instructions in the section titled “Cookie Notice” below.

Privacy rights related to School Profile Information and School Log and Cookie Information:

Residents of certain jurisdictions have rights with respect to personal information but, except as set forth below, these rights do not apply to business-to-business information (e.g., business contact, contract, and business communications) or personal information collected by Liminex when Liminex is acting as a service provider of a School (though we assist Schools in fulfilling requests that they receive). You can read more about any such applicable rights at our Website Privacy Policy.
If you are acting on behalf of your School and would like to submit a data request, please follow the instructions described in the section titled “School’s Request for Deletion or Transfer of Personal Student Information” above. Similarly, if you are a parent, guardian, eligible student, or Authorized Personnel and would like to submit a data request to us, please follow the instructions described later in this section.

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With respect to School Profile Information and School Log and Cookie Information, residents of the EEA, UK, and California may request that we:

(1) provide access to and/or a copy of such information; (2) prevent the processing of that individual’s information for direct-marketing purposes (including any direct marketing processing based on profiling); (3) update an individual’s information which is out of date or incorrect; (4) delete certain information that we are holding about an individual; and (5) restrict the way that we process and disclose certain of the individual’s information.
To exercise any of these rights, please contact us at privacy@goguardian.com. Authorized agents for California residents may submit requests here. In addition, you may have the right to lodge a complaint with the relevant supervisory authority in certain circumstances. However, we encourage you to contact us first, and we will do our very best to resolve your concern.
We will consider all requests and provide our response within the time period required by Applicable Law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to continue processing an individual’s information for our legitimate interests or to comply with a legal obligation. We may request that an individual and/or School provide us with information necessary to confirm the individual’s identity before responding to your request.
In addition, California residents may annually request a list of the third parties to which a company discloses “personal information” for such third parties’ marketing purposes and the types of information disclosed. However, we do not disclose personal information to third parties for such third parties’ direct marketing purposes.

6.2 School Information (other than School Profile Information) and Personal Student Information

Your choices about School Information (other than School Profile Information) and Personal Student Information:

Cooperation with Schools. We will assist the School in facilitating requests relating to Authorized School Personnel Information and Personal Student Information pursuant to the School’s instruction as explained further in the sections titled “How Long We Keep Information" or in the “Your Rights and Choices About Information Collected Through Our Offerings” above.
Review, Correction, and Deletion Requests.
- If a parent, legal guardian, eligible student, or Authorized School Personnel wishes to request a review, correction, or deletion of School Information (other than School Profile Information) or Personal Student Information related to themselves and/or their child, he/she should contact the appropriate School Official. We will cooperate with the School to fulfill requests pursuant to the School’s verification and instruction within a commercially reasonable amount of time and in compliance with Applicable Law. Where Applicable Law requires us to respond directly, we will do so.
- If you are a user of the Parent App, you can review information about the choices you may have with respect to the personal information you provide through the Parent App in the “Your Rights and Choices” section of our Website Privacy Policy.
- If you are Authorized School Personnel, please note that we may be required to maintain certain School Information if directed to do so by your School Official on behalf of your School employer or as needed by us to enforce our legal rights.
Transfer Requests. Our Offerings allow Authorized School Personnel to download certain information on behalf of a parent, legal guardian, eligible student, or Authorized School Personnel. If our Offerings do not cover the scope of the transfer request, we will, in compliance with Applicable Law and following documented instructions from the School, honor the requests from the parent, legal guardian, eligible student, or Authorized School Personnel for the transfer of Personal Student Information or personal data of the Authorized School Personnel by utilizing the same guidelines as described above in the section titled “Review, Correction, and Deletion Requests”.
Transfer Requests for Student-Generated Content. California law may require website operators to transfer student-generated content to the student’s personal account when requested by an eligible student, parent, or guardian. The Offerings are not used as the primary platform for students to submit their own content. To the extent that students in California, or in other states with similar transfer laws, submit their content on the Offerings, the appropriate parent, guardian, or eligible student may submit a request to privacy@goguardian.com to transfer this information to him/her. Following verification of the requestor’s authorization to receive the information (which may require verification by the requestor’s School), we will provide the student-generated content that we have in a commercially reasonable amount of time in either a CSV or other mutually-agreeable format. Please note that we cannot guarantee retention of student-generated content.

7. How We Protect Your Information

We take the security and privacy of your data very seriously. For these reasons, we have implemented various technical, administrative, and physical safeguards to protect your information, including, but not limited to, specific training of our personnel authorized to access Personal Student Information and other information and data encryption in transit and at rest. These safeguards vary depending on the sensitivity of the information at issue.

We are committed to preventing unauthorized access to our systems and data and will investigate any possible occurrence. In the event of a breach of Personal Student Information, we will comply with all relevant breach laws to assist the School or provide notification as required to you, a School, affected parents, legal guardians, eligible students, and regulators.

7.1 Additional Information for California Residents

If you are a California resident, California law requires us to provide you with some additional information.

We collect the following categories of personal information: identifiers (e.g., name and email address); internet or other network information (e.g., how users interact with our Offerings); and other information that identifies or can be reasonably associated with you (e.g., your correspondence with us). We also collect information at the direction of Schools including education information, location information (e.g., about devices), and audio and visual information.

We use such information to:

set up and provide our Offerings;
analyze and improve our Offerings;
respond to a School’s and/or Authorized School Personnel’s requests and to provide related support;
administer and troubleshoot our Offerings;
send information to a School and Authorized School Personnel about how to use our Offerings and other important updates;
notify a School and/or Authorized School Personnel about new features or Offerings that may be of interest to them as permitted by Applicable Law;
help prevent fraud and to enforce the legal terms that govern our Offerings;
comply with Applicable Law and protect our and others’ rights, safety and property; and
follow further instructions of a School

We retain such information as long as it is necessary to fulfill the purposes for which we collect it, unless a longer retention is required or permitted by Applicable Law. We consider the nature and sensitivity of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests in determining how long to retain information.

8. Notice to EEA and Other Non-U.S. Residents

European Union (“EU”) data protection laws make a distinction between organizations that process personal data for their own purposes (known as "data controllers") and organizations that process personal data on behalf of other organizations (known as "data processors"). Depending on the particular circumstance, we and your School may act either as a data controller or a data processor of your personal data. The laws in some jurisdictions like the EU also require data controllers to share the legal ground that they rely upon to use or disclose personal information.

8.1 Liminex as a Data Controller

We are considered the “controller” of School Profile Information and School Log and Cookie Information. As the data controller, we collect, use, share, and disclose this information as described in this Product Privacy Policy. We retain the personal data contained in this information for as long as necessary to provide you with the Offerings or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements.

Our legal grounds for using School Profile Information and School Log and Cookie Information are as follows:

Contractual Commitments: We use, share, and disclose information to honor our contractual commitments to a School.
Legal Compliance: We need to use, share, and disclose information in certain ways to comply with our legal obligations.
With Your Consent: Where required by Applicable Law, and in some other cases, we use, share, or disclose information on the basis of consent.
Legitimate Interests: In many cases, we use, share, or disclose information on the ground that it furthers our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as customer service, analyzing and improving our business, promotional activities, providing security for our Offerings, preventing fraud, and managing legal issues.

8.2 Information Transfer to the U.S.

If you are located outside of the U.S., please be aware that any information that you provide to us will be processed outside your jurisdiction. The recipients of information described in the relevant portions of the section titled “How We Disclose Information Collected Through Our Offerings” above may be located in the U.S. This information may be subject to U.S. law, including laws that may require disclosure of personal information to government authorities. Schools may export Personal Data (defined below) to jurisdictions outside the EEA on the basis of legal mechanisms approved by the European Commission and other relevant authorities for cross-border data transfers, such as standard contractual clauses.

The European Union-United States Data Privacy Framework, UK Extension to the European Union-United States Data Privacy Framework, and Swiss-United States Data Privacy Framework: We comply with the European Union-United States Data Privacy Framework, the UK Extension to the European Union-United States Data Privacy Framework, and the Swiss-United States Data Privacy Framework (collectively, the “Framework” and their principles, the “Framework Principles”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of “personal data” (as defined under the Framework Principles, “Personal Data”) from applicable EEA countries, the UK, and Switzerland, respectively. We have certified that we adhere to the Framework Principles with respect to Personal Data transferred under the Framework. To the extent there is any conflict between the terms in this Product Privacy Policy and the Framework Principles, the Framework Principles shall govern. To learn more about the Framework and view our certification, visit the U.S. Department of Commerce’s Framework list by clicking here. We may also protect Personal Data through other legally valid methods, including international and data transfer agreements.
As required under the Framework Principles, when we receive Personal Data under the Framework and then transfer it to a third-party service provider acting as an agent on our behalf, we have certain liability under the Framework if both (i) the agent processes the information in a manner inconsistent with the Framework; and (ii) we are responsible for the event giving rise to the damage.
Choices of International Users: Some international users (including those whose information we collect under the Framework) of Offerings have certain legal rights to access certain information that we hold about them and to request its deletion. Please see the section titled “Your Rights and Choices About Information Collected Through Our Offerings” above for more information.

8.3 How to Contact Us

Individuals located outside the U.S. who have questions or concerns regarding our Product Privacy Policy or practices may direct a complaint in writing to Liminex, Inc., 8605 Santa Monica Blvd., #996559, West Hollywood, CA, 90069-4109, Attn: General Counsel or to privacy@goguardian.com. Within a reasonable time of receiving the written complaint, we will review and address the complaint, as appropriate, and inform the individual of the results of such review and any steps taken to address the complaint.

8.4 Dispute Resolution

Dispute Resolution for EU, UK, and Swiss Residents: If you are a resident of the EU, UK, or Switzerland whose personal data is subject to the Framework and you are dissatisfied with the manner in which we have addressed your concerns or we fail to respond to you within 45 days of your complaint, you may seek further assistance, at no cost to you, from our designated Framework independent recourse mechanism, the JAMS Data Privacy Framework Program, which you can learn more about here. Residents of the EU, UK, or Switzerland whose Personal Data is subject to the Framework may, in certain circumstances, elect to arbitrate unresolved complaints by invoking binding arbitration pursuant to the Framework’s Recourse, Enforcement and Liability Principle and Annex I of the Framework (see here) but, prior to initiating such arbitration, you must: (1) afford us the opportunity to resolve the issue; (2) seek assistance via our recourse mechanism above; and (3) contact the U.S. Department of Commerce (either directly or through the relevant Data Protection Authority) and afford the U.S. Department of Commerce time to attempt to resolve the issue. Each party shall be responsible for its own attorney’s fees. Please be advised that, pursuant to the Framework, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Framework Principles with respect to the individual. We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

For Australian residents: If you are located in Australia, and are dissatisfied with the way we have handled a privacy issue, you may contact the Office of the Australian Information Commissioner for more information.

For Singapore residents: If you are located in Singapore, and are dissatisfied with the way we have handled a privacy issue, you may contact the Personal Data Protection Commission for more information.

9. Cookies Notice

9.1 What are cookies?

“Cookies” are small text files stored on your computer that allow us to understand usage of Offerings. Cookies include cookies, internet server logs, tags, Software Development Kit/SDKs, tracking pixels, and other similar tracking technologies. A number of Cookies that we use last only for the duration of your session, expiring when your session ends (so-called "session cookies"). Other Cookies are used to help our systems recognize you if you return to Offerings and will thus be retained longer (so-called "persistent cookies"). Some of the Cookies used on our Offerings are set by us, and some are set by third parties that are delivering services on our behalf.

9.2 What types of Cookies do we use and what data do they collect?

We use Cookies in the Offerings that automatically collect information to:

understand usage of the Offerings and to improve these Offerings;
authenticate your account; and
remember your settings and account information.

We do not use any advertising Cookies in our Offerings and we do not place advertisements in the Offerings.

9.3 What are my choices about Cookies?

You can learn more about how Cookies work and how to turn them off in your particular browsers. Please remember that if you replace, change or upgrade your browser, or delete your Cookies, you may need to use these opt-out tools again.

For information about Cookies used by the developers of these browsers, please visit:

For controls specific to advertising and analytics services offered by Google, click here from each of your browsers.

Note About Do Not Track: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Some browsers do not recognize DNT settings. At this time, we do not recognize or respond to browser-initiated DNT signals because we do not track you across websites.

10. Changes to this Product Privacy Policy

We reserve the right to make changes to this Product Privacy Policy from time to time, including to reflect changes in Applicable Law, our data collection and use practices, and the features of the Offerings. At the top of this Product Privacy Policy, we will indicate the date of the most recent update to this Product Privacy Policy. We will notify your School of material changes to the Product Privacy Policy on our Website and make additional efforts to notify your School of material changes that impact the treatment of data collected via the Offerings, including via email. We will also obtain your School’s consent before any material changes to our Product Privacy Policy apply to your School where required by Applicable Law.

11. How to Contact Us

If you have questions or concerns, the best way to reach us is by emailing privacy@goguardian.com. You can also reach us by calling 888-310-0410 or by writing to Liminex, Inc., 8605 Santa Monica Blvd., #996559, West Hollywood, CA, 90069-4109.