Please see below the full K-12 Schools Privacy Statement.
K-12 Schools Privacy Statement
Last updated: December 2020
InSpace is committed to continually improving how we communicate our privacy practices. This privacy statement explains how we handle personal information of Student Users (as defined below) of K-12 Accounts (as defined below) who are under the age of 18 years. It also reflects our compliance with the applicable requirements of the Children’s Online Privacy Protection Act (“COPPA”) and the Family Educational Rights and Privacy Act (“FERPA”).
For purposes of this K-12 Privacy Statement, personal information (or “personal data”) means information that relates to an identified or identifiable individual.
Certain K-12 Accounts may be created under contracts between InSpace and the School Subscriber that include a data processing addendum or other specific provisions governing Student User personal information. To the extent there is any conflict between such contracts and the terms of this K-12 Privacy Statement, the terms of our contracts with School Subscribers will overrule.
- School Subscriber means a primary school, secondary school, school district or school system that is responsible for controlling all K-12 Accounts under the domain applicable to such school, district or system.
- K-12 Account Administrator means technical or administrative personnel designated by the School Subscriber with the right to use K-12 Accounts provided to the School Subscriber by InSpace for the purpose of administering the Service and responding to Student User personal information access requests from parents or legal guardians of Student Users.
- K-12 Account Hosts means teachers, principals, and other educators and school personnel authorized by a School Subscriber to use its K-12 Account for educational purposes, including to facilitate meetings with Student Users.
- Student User means a student that the School Subscriber permits to use the Services under the supervision of K-12 Account Hosts.
School Subscribers can use InSpace’s communications platform by establishing K-12 Accounts for their K-12 Account Hosts. K-12 Account Hosts can create K-12 Spaces as authorized representatives of a School Subscriber but should only use InSpace’s Services with the permission of their school, school district or school system (the School Subscriber).
InSpace encourages K-12 Account Hosts to securely and confidentially provide meeting information and to Student Users to ensure that the School Subscriber can supervise and control its Student Users’ meeting experiences.
Student Users are not permitted to create InSpace Accounts, they can only join meetings created by Account Hosts under the School Subscriber account. Student Users, even if under the age of 13, may join a meeting hosted by a K-12 Account Host. School Subscribers are responsible for obtaining any parental consent necessary for use of the Services under their K-12 Accounts by Student Users, including children under the age 13.
The School Subscriber is the K-12 Account Owner and Administrator. For purposes of FERPA, each K-12 Account Host is a “school official” of the School Subscriber. The School Subscriber is the decision-maker that determines how personal information is processed in connection with InSpace’s provisions of Services under a K-12 Account. The School Subscriber decides if and why to host an InSpace meeting, and what features to use. For example, depending on how the School Subscriber has configured its K-12 Account, a K-12 Account Host may record a meeting. Therefore, the School Subscriber is responsible for obtaining any necessary consent from meeting participants. (InSpace features provide visual and audio cues designed to help the host alert meeting participants of a recording.) A K-12 Account Host may choose to store a recording of a meeting on the K-12 Account Host’s local storage device, or in InSpace’s cloud (available in early 2021).
When a Student User uses InSpace’s Services through a School Subscriber, the processing of Student User personal information by the applicable School Subscriber is determined and administered by the School Subscriber under its privacy policies. If a parent or legal guardian of a Student User has questions about how and why Student User personal information is collected, the legal basis for processing, or access requests, the parent or legal guardian should refer to the School Subscriber’s privacy policies and direct all inquiries to the K-12 Account Administrator or K-12 Account Host.
InSpace provides a communications platform to K-12 Account Hosts on behalf of and at the direction of the School Subscriber. For purposes of FERPA, InSpace is considered a “school official” and may receive Student User personal information through its contractual agreements because InSpace is performing a service that furthers a “legitimate educational interest” (i.e., the provision of educational services in a remote setting). InSpace maintains Student User personal information on behalf of, and at the direction of, the School Subscriber and does not use the Student User personal information for other purposes except as permitted by applicable law, including FERPA and applicable agreements with School Subscribers.
InSpace is responsible for following the directions of the School Subscriber. For example, on a School Subscriber’s instructions, InSpace may provide reports containing personal information relating to the K-12 Account and its users (including Student Users) to that School Subscriber.
Information We Collect
From the K-12 Account Host
When creating a K-12 Account under the direction of a School Subscriber, the K-12 Account Host must provide certain information, such as:
- K-12 Account Host’s first and last name
- school or district name
- school issued-email address
From Student Users
Depending on how the School Subscriber configures its K-12 Account, InSpace may receive personal information contained in “Customer Content.” Customer Content is any data a K-12 Account Host uploads to the InSpace platform connected with use of the Service.
For example, School Subscribers may enable features that allow meeting hosts or co-hosts to record meetings locally or to InSpace’s cloud, allow K-12 Account Hosts to display or upload information that may be seen by other users of that K-12 Account, allow meeting participants to share files, allow hosts or co-hosts to create meeting transcripts, or allow meeting participants (including Student Users) to communicate in-meeting via chat and create chat logs.
Such Customer Content may include personal information that is part of an “educational record” as defined by FERPA.
InSpace accesses Customer Content only upon the documented request of a School Subscriber, or if required by law.
InSpace collects certain personal information automatically through the use of a K-12 Account including:
- Information about the use of the InSpace platform, including type and frequency of actions taken, number of log-ins or meeting entries, date and time, duration, quantity, quality, network connectivity, other platform performance metrics, and feature usage information, including use of video and screen sharing; and
- Information about a user’s device, network, and internet connection, such as IP address(es), MAC address, other device ID, device type, operating system type and version, type of camera, microphone and speaker, and client version.
Use of Personal Information
InSpace uses personal information collected from and about Student Users only as needed to deliver the functionality of the InSpace platform, operate the business (including to enhance or improve the Services), and as directed by School Subscribers. For Student Users, this means that:
- InSpace never sells Student User personal information
- InSpace does not use Student User personal information to deliver behavioral advertising
- There are no third-party advertising or analytics cookies on InSpace’s product pages
Regarding cookies, InSpace publishes two types of webpages: product and marketing. A product webpage enables a Student User to click on a hyperlink and join an InSpace meeting. InSpace’s product webpages serve only third-party cookies that are necessary for technical support and to deliver the service. There are no advertising or analytics cookies on our product webpages.
Sharing Personal Information
We do not share personal information with companies, organizations, or individuals outside of InSpace unless one of the following circumstances applies:
With Consent: We will share personal information with companies, organizations, or individuals outside of InSpace when we have K-12 Account Host consent (as applicable) and in compliance with applicable laws (including FERPA as applicable).
With or As Directed by School Subscribers: School Subscribers have access to personal information (including Student User information) connected with their K-12 Account. School Subscribers may also direct us to share personal information with others.
To Provide Our Services: We provide personal information to third-party service providers to help us provide the Service. Such service providers are prohibited from using personal information for any reason other than to provide the contracted-for services, and in compliance with appropriate privacy and security obligations.
With Other Meeting Participants: We may share personal information collected during an InSpace meeting with other participants of the same meeting during the use of the Service. For example, video and audio recordings, chat messages and other content shared by a Student User during a meeting, which may contain personal information of Student Users, may be available to all other participants in that meeting, as well as to any K-12 Account Hosts who host or co-host that meeting and the K-12 Account Administrator.
For Certain Corporate Transactions: We may share personal information where, whether for strategic or other business reasons, InSpace decides to sell, buy, merge, or otherwise reorganize its businesses. In such transactions, we may disclose or transfer personal information to actual purchasers or receive personal information from sellers. Student User personal information will remain subject to this K-12 Privacy Statement unless it is changed by a successor entity.
For Legal Reasons: We share personal information outside of InSpace if we believe that access, use, preservation or disclosure of the information is reasonably necessary to:
- comply with any applicable law, regulation, legal process or enforceable governmental request
- enforce applicable provisions of the Terms of Service, including investigation of potential violations
- detect, prevent, or otherwise address fraud, security or technical issues
- protect against harm to the rights, property or safety of InSpace, our users or the public as required or permitted by law, including to help prevent the loss of life or serious injury of anyone
InSpace does not share personal information with third parties other than as described herein, or as required by law, except at the direction and on behalf of a School Subscriber.
Maintaining the confidentiality, security, and integrity of students’ personal information is a top priority. We use appropriate technical and organizational measures designed to help protect personal information from unauthorized access, use, or disclosure. Customer Content is encrypted in transit between any devices running inSpace and at rest when in permanent storage in the InSpace Cloud. We also have taken steps to minimize the risk that meetings that include Student Users are disrupted by uninvited participants. Examples include creating a closed space where only pre-approved users can enter the space and virtual waiting rooms by default for K-12 Accounts and configuring default screen share settings to limit in-meeting content sharing. K-12 Account Hosts also have the ability to immediately remove any user from their meeting space at any time.
Report a User
All K-12 Accounts have the Report a User feature enabled by default. The Report a User feature is available to the meeting host or co-host via the Security icon on the meeting taskbar. If an unwelcome participant joins the meeting, the host or co-host can immediately remove the user and should send an email to firstname.lastname@example.org. A member of the Support team will review and investigate the reported user(s) for violation of our Terms of Service. Confirmed offending users will have their accounts terminated, and, where appropriate, we will notify relevant law enforcement authorities.
InSpace retains K-12 Account Hosts’ and Student Users’ personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.
Access and Deletion of Information
If a Student User or his or her parent would like to request to access, review, refuse further collection of or delete a Student User’s personal information, they must contact their School Subscriber with his or her request. Because InSpace is required to comply with contractual confidentiality obligations related to Student Users’ data, we are not able to respond to parental or student requests directly. School Subscribers may direct requests to access, delete or restrict further collection or use of a Student User’s personal information to email@example.com. InSpace also deletes information associated with K-12 Accounts upon receiving a valid deletion request from a School Subscriber or automatically following the termination of the K-12 Account.