Privacy Notice for Prisms Products and Services
This Privacy Notice for Prisms’ Products and Services applies to the processing of personal information by Prisms of Reality, Inc. (“Prisms,” “we,” “us,” or “our”) through our VR-based learning applications, web-based dashboard, and related services (collectively, the “Services”).
Please note that we process personal information of students (“Students”) pursuant to agreements with our customers that are educational institutions or school districts (“Schools”). Our agreements with Schools may further restrict our processing of Student personal information, but we will still process Student personal information consistent with this Privacy Notice.
Disclosure Regarding the Children’s Online Privacy Protection Act (Direct Notice to Parents and Schools). For information on our processing of personal information that is subject to the Children’s Online Privacy Protection Act (“COPPA”), please see Annex A – Supplemental COPPA Privacy Notice.
- UPDATES TO THIS PRIVACY NOTICE
We may update this Privacy Notice from time to time at our sole discretion. If we do, we’ll let you know by posting the updated Privacy Notice on our website, and we may also send other communications.
- PERSONAL INFORMATION WE COLLECT
We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below.
- Personal Information You Provide to Us Directly
We may collect personal information that you provide to us.
- Student Account Information. We may collect personal information in connection with the creation or administration of Student accounts. This personal information may include, but is not limited to, the Student’s name, user name, student ID, email address, school enrollment, current grade level, assigned teachers, assigned courses, and account authentication information.
- School Employee Account Information. We may collect personal information in connection with the creation or administration of School employee accounts including, without limitation teachers. This personal information may include, but is not limited to, the employee’s name, email address, and professional details.
- Your Communications with Us. We, and our service providers, may collect the information you communicate to us, such as through email or our web chat tool.
- Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the surveys.
- Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered “public.”
- Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
- Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
- Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
- Personal Information Collected Automatically
We may collect personal information automatically when you use the Services.
- Device Information. We may collect personal information about your device, such as your Internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, and browser or device information, and location information (including, as applicable, an approximate location derived from the IP address and precise geo location information).
- Usage Information. We may collect personal information about your use of the Services, such as the pages that you visit, timestamps of recorded in-app activities, formative assessment data, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use the Services.
- Cookie Notice (and Other Technologies). We, as well as third parties, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect personal information through your use of the Services.
- Cookies. Cookies are small text files stored in device browsers.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects personal information about use of or engagement with the Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page. We may also include web beacons in emails to understand whether messages have been opened, acted on, or forwarded.
See “Your Privacy Choices and Rights” (Section 5) below to understand your choices regarding these Technologies.
- Personal Information Collected from Third Parties
We may collect personal information about you from third parties. For example, if you access the Services using a third-party website, application, service, products, or technology (each a “Third-Party Service”), we may collect personal information about you from that Third-Party Service that you have made available via your privacy settings. In addition, Schools may upload or otherwise provide personal information about their Students.
- HOW WE USE PERSONAL INFORMATION
We use personal information for a variety of business purposes, including to provide the Services, to improve the Services, and to operate our business, as described below.
- Provide the Services.
We may use personal information to provide the Services, such as:
- Providing access to certain areas, functionalities, and features of the Services;
- Fulfilling the educational purposes of the Services;
- Personalizing content shown within the Services;
- Ensuring the age-appropriateness of the Services;
- Answering requests; and
- Sharing personal information with third parties as needed to provide the Services.
- Improve the Services and Develop New Products and Services.
We may use personal information to improve the Services and to develop new products and services.
- Operate Our Business.
We may use personal information to operate our business, such as:
- Pursuing research and development, network and information security, and fraud prevention;
- Providing support for the internal operations of the Services;
- Ensuring service continuity;
- Carrying out analytics;
- Creating de-identified or aggregated information;
- Enforcing our agreements and policies; and
- Carrying out activities that are required to comply with our legal obligations.
- Marketing
We may use personal information to tailor and provide you with marketing communications, promotions and offers that may interest you.
However, we do not use Student personal information for marketing or advertising purposes including, but not limited to, behavioral advertising.
- With Your Consent or Direction
We may use personal information: (i) for other purposes that are clearly disclosed to you at the time you provide the personal information, (ii) with your consent, or (iii) as otherwise directed by you.
- HOW WE SHARE PERSONAL INFORMATION
We share personal information with third parties for a variety of business purposes, including to provide the Services, to protect us or others, or in connection with a major business transaction such as a merger, sale, or asset transfer, as described below.
- Disclosures to Provide the Services
We may share any of the personal information we collect with the categories of third parties described below.
- Service Providers. We may share personal information with service providers that assist us with the provision of the Services. This may include, but is not limited to, service providers that provide us with hosting services, customer service, analytics, marketing services, IT support, and related services. In addition, personal information and chat communications may be shared with service providers that help provide our chat features.
- Other Users You Share or Interact With. The Services may allow Prisms users to share personal information or interact with other users of the Services.
- Third-Party Services You Share or Interact With. The Services may link to or allow you to interface with, interact with, share information with, direct us to share information with, access, and/or use Third-Party Service.
Any personal information shared with a Third-Party Service will be subject to the Third- Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.
- Business Partners. We may share your personal information with business partners with whom we work to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
Once your personal information is shared with our business partner, it will also be subject to our business partner’s privacy policy. We are not responsible for the processing of personal information by our business partners.
- Authorized Users of Prisms Customers. In cases where you use our Services as an employee, contractor, or other authorized user of a Prisms customer, we may share any information associated with your use of the Services with the Prisms customer, including, but not limited to, account information, usage information, files, and the contents of the communications associated with your account. Your personal information may also be subject to the Prisms customer’s privacy policy. We are not responsible for the Prisms customer’s processing of your personal information.
- Affiliates. We may share your personal information with our corporate affiliates.
- Disclosures to Protect Us or Others
We may share your personal information and related information with external parties if we, in good faith, believe doing so is required or appropriate to comply with law enforcement requests, national security requests, or other government requests; comply with legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual unauthorized or illegal activity.
- Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be shared, sold, or transferred as part of such a transaction.
- YOUR PRIVACY CHOICES AND RIGHTS
The privacy choices you may have about your personal information are described below.
- Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will not be able to opt out of certain communications (e.g., communications regarding the Services or updates to this Privacy Notice).
- “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
- Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Services may not work properly. Please note you must separately opt out in each browser and on each device.
In accordance with applicable law, you may have the right to:
- Request Access to or Portability of Your Personal Information;
- Request Correction of Your Personal Information; and
- Request Deletion of Your Personal Information.
In some cases, Schools and/or Parents may be able to exercise these rights as it relates to Student personal information.
If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below.
- INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. However, our contract with a School may restrict or limit where we can host or transfer personal information that we process on behalf of the School. In these cases, we will comply with the requirements of our contract with the School.
- RETENTION OF PERSONAL INFORMATION
We store the personal information we collect as described in this Privacy Notice for as long as you use the Services, or as long as necessary to fulfill the purpose(s) for which it was collected, or as long as necessary to pursue our business purposes.
To determine the appropriate retention period for personal information, we may consider applicable legal requirements; the amount, nature, and sensitivity of the personal information; certain risk factors; the purposes for which we process your personal information; and whether we can achieve those purposes through other means.
- CONTACT US
If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at: hello@prismsvr.com.
Annex A - SUPPLEMENTAL COPPA Privacy Notice
This Supplemental COPPA Privacy Notice (“COPPA Privacy Notice”) governs Prisms’ collection, use, and disclosure of personal information from Students under the age of thirteen in the United States (each a “Child” and collectively “Children”) when providing the Services.
This COPPA Privacy Notice supplements the Privacy Notice for Prisms’ Products and Services and provides information about our information practices with regard to Children. Capitalized terms not defined in this COPPA Privacy Notice have the meaning set forth in our Privacy Notice. If this COPPA Privacy Notice conflicts with our Privacy Notice, this COPPA Privacy Notice will control as it relates to the collection, use, and disclosure of Children’s personal information.
- DIRECT NOTICE TO PARENTS AND SCHOOLS
- Parental Consent Required. COPPA requires that we obtain a Parent's consent to collect, use, or disclose personal information from their Child. We rely on each School to provide consent on behalf of each Child’s Parent. Prisms will not knowingly collect, use, or disclose any personal information from a Child without the required consent.
- Collection, Use, and Disclosure of Children’s Personal Information. For details on our collection, use, and disclosure of Children’s personal information, please review the sections of this COPPA Privacy Notice titled “Children’s Personal Information We Collect,” “How We Use Children’s Personal Information,” and “How We Disclose Children’s Personal Information.”
- CHILDREN’S PERSONAL INFORMATION WE COLLECT
- Child Account Information. We may collect personal information in connection with the creation or administration of Child accounts. This personal information may include, but is not limited to, the Child’s name, user name, student ID, email address, school enrollment, current grade level, assigned teachers, assigned courses, and account authentication information.
- Device Information. Prisms may collect personal information about a Child’s device, such as Internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, browser or device information, Internet service provider, and location information (including, as applicable, an approximate location derived from the IP address).
- Usage Information. We may collect personal information about a Child’s use of the Services, such as the pages that the Child visits, timestamps of recorded in-app activities, formative assessment data, performance information, the types of content a Child interacts with, information about the links a Child clicks, the frequency and duration of a Child’s activities, and other information about how Children use the Services.
- Cookies and Other Technologies. Prisms, as well as third parties, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect personal information from Children when they access and navigate through the Services and use certain of its features.
- Cookies. Cookies are small text files stored in device browsers.
- Pixel Tags and Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects personal information about use of or engagement with the Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page. We do not use pixels for third-party targeted advertising.
- HOW WE USE CHILDREN’S PERSONAL INFORMATION
We may use Children’s personal information for authorized educational purposes, including as directed by the School or the Child’s parent or legal guardian (“Parent”), and for a variety of business purposes as described below.
- Provide the Services.
We may use personal information to provide the Services, such as:
- Providing access to certain areas, functionalities, and features of the Services;
- Fulfilling the educational purposes of the Services;
- Personalizing content shown within the Services;
- Ensuring the age-appropriateness of the Services;
- Answering requests; and
- Sharing personal information with third parties as needed to provide the Services.
- Improve the Services and Develop New Products and Services.
We may use personal information to improve the Services and to develop new products and services.
- Operate Our Business.
We may use personal information to operate our business, such as:
- Pursuing research and development, network and information security, and fraud prevention;
- Providing support for the internal operations of the Services;
- Ensuring service continuity;
- Carrying out analytics;
- Creating de-identified or aggregated information;
- Enforcing our agreements and policies; and
- Carrying out activities that are required to comply with our legal obligations.
- No Marketing
We do not use Children’s personal information for marketing or advertising purposes including, but not limited to, behavioral advertising.
- HOW WE DISCLOSE CHILDREN’S PERSONAL INFORMATION
We may share the Children’s personal information we collect with the categories of third parties described below.
- Service Providers. We may share personal information with service providers that assist us with the provision of the Services.
- Other Users Children Share or Interact With. The Services may allow Children to share personal information or interact with other users of the Services. For example, Schools and teachers may access personal information about Children they are responsible for.
- Third-Party Services You Share or Interact With. The Services may link to or allow Children to interface with, interact with, share information with, direct us to share information with, access, and/or use a Third-Party Service.
For example, Schools often have students use the Services in connection with another Third-Party Service that the School uses for educational purposes.
Any personal information shared with a Third-Party Service will be subject to the Third- Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.
- Affiliates. We may share Children’s personal information with our corporate affiliates.
- Disclosures to Protect Us or Others. We may share your personal information and related information with external parties if we, in good faith, believe doing so is required or appropriate to comply with law enforcement requests, national security requests, or other government requests; comply with legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual unauthorized or illegal activity.
- Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be shared, sold, or transferred as part of such a transaction.
- No Features That Allow Public Sharing. Our Services do not include any features allowing a Child to make their personal information publicly available.
- PARENTAL RIGHTS AND CONTROLS
Parents and Schools have the following controls over Children’s personal information for which they are responsible.
At any time, a Parent or a School may:
- review a Child’s personal information that we maintain;
- refuse to permit us to further collect or use a Child’s personal information; and
- request that we delete a Child’s personal information.
Parents and Schools may exercise these rights by sending us an email at hello@prismsvr.com. We may require you to take certain steps or provide additional information to verify your identity before we act upon your request.
Please note that if you refuse to permit us to further collect or use your Child’s personal information, or if you request deletion of your Child’s personal information, we may terminate our Services we provide to the Child.
If you request that we delete your Child’s personal information, we will delete as much information as we are legally permitted.
- RETENTION OF CHILDREN’S PERSONAL INFORMATION
We retain Children’s personal information in accordance with our data retention policy described below.
| Category of Children's Personal Information Collected |
Purposes for Which Children's Personal Information Is Collected |
Business Need for Retaining Children's Personal Information |
Timeframe for Deletion of Children's Personal Information |
| Account Information |
- To provide the Services
- To improve the Services and develop new products and services
- To operate our business
|
- To provide the Services
- To improve the Services and develop new products and services
- To operate our business
|
Deleted or de-identified within 30 days of contract termination, or written request from School or Parent if sooner |
| Device Information |
- To provide the Services
- To improve the Services and develop new products and services
- To operate our business
|
- To provide the Services
- To improve the Services and develop new products and services
- To operate our business
|
Retained for 30 days in AWS CloudWatch, then automatically deleted. Logs also retained for 30 days and error logs retained for 90 days via Sentry.io. |
| Usage Information |
- To provide the Services
- To improve the Services and develop new products and services
- To operate our business
|
- To provide the Services
- To improve the Services and develop new products and services
- To operate our business
|
Deleted or de-identified within 30 days of contract termination, or written request from School or Parent if sooner |
| Cookies and Other Technologies |
- To provide the Services
- To improve the Services and develop new products and services
- To operate our business
|
- To provide the Services
- To improve the Services and develop new products and services
- To operate our business
|
Retained for 30 days in AWS CloudWatch, then automatically deleted. Logs also retained for 30 days and error logs retained for 90 days via Sentry.io. |
- CONTACT US
Prisms is the organization that operates the Services and collects or maintains personal information from Children through the Services.
You may send any questions about this COPPA Privacy Notice, our privacy practices, or our use of Children’s personal information to:
Prisms of Reality, Inc.
26 O'Farrell Street
7th Floor
San Francisco, CA 94108
hello@prismsvr.com
714-788-6226