Clever Privacy Policy changes — 20230131_rev01

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**Information about Others:** We also collect personal information from Developers and other individuals who create an account, correspond with us online or otherwise use or interact with the Clever Service, including a name, contact information and information relating to the Developer business or service. We may also retain information if the Developer sends us a message, posts content to our website or through our Service, or responds to emails or surveys. Once a Developer begins using the Clever Service, we will collect content and information about the Developer's use of and interaction with the Service and we will keep records of activities related to the Service. We use this information to operate, maintain, and provide to the features and functionality of the Service, to analyze and improve our Service offerings and functionality, and to communicate with our Developers and others.

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**Information collected through use of the Service:** We may collect information you provide or upload to the Service as well as activity and actions within our Service. For example, we collect information from files that you upload or content you post to the Service (such as in a classroom dashboard), messages you send or receive through the Service, and content you post such as in product reviews or comments. If you are a Developer, we will also collect information you make available to us when developing an Application via the Service.

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**Information collected through technology:** Like most websites and online services, we and our third-party partners automatically collect certain types of usage information when you visit our Services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, file information and similar technology (collectively, "tracking technologies"). For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device, or your account, and other such information. We also collect information about the way you use our Service, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, how frequently you access the Service, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, and other actions you take on the Service. When you access our Service from a mobile device, we may collect unique identification numbers associated with your device or our mobile application, mobile carrier, device type, model, and manufacturer, and mobile device operating system. We may be able to determine your approximate location by analyzing other information, like an IP address to associate a user with their School. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service. Although we do our best to honor the privacy preferences of our visitors, we are not able to respond to Do Not Track signals from your browser at this time.

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Cookies and related technology allow us to provide you with a better user experience. For example, we may use the data collected through cookies to: (a) remember information so that a user will not have to re-enter it during subsequent visits; (b) provide custom, personalized content and information; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our Service; (e) monitor aggregate metrics such as total number of visitors, traffic, and usage on our website and our Service; (f) diagnose or fix technology problems; (g) help users efficiently access information after signing in; and (h) otherwise to plan for and enhance our Service.

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Cookies and related technology allow us to provide you with a better user experience. For example, we may use the data collected through cookies to: (a) remember information so that a user will not have to re-enter it during subsequent visits; (b) provide custom, personalized content and information; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our Service; (e) monitor aggregate metrics such as total number of visitors, traffic, and usage on our website and our Service; (f) diagnose or fix technology problems; (g) help users efficiently access information after signing in; and (h) otherwise to plan for and enhance our Service. On certain portions of our website, we and our third party partners may also collect device and usage data for purposes of tracking adult visitors to our websites and for other targeted advertising, attribution, research and analytics purposes. While we may permit third party advertising partners to collect information from visitors to adult-directed pages of our site (such as the support pages), we do not permit third party advertising networks to collect information about authenticated users of our Service for the purpose of serving targeted advertising and we will never use Student Data for targeted advertising.

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If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

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For more information about the types of tracking technologies we use and how you can control them, please see our [Cookie Notice](https://www.clever.com/trust/privacy/cookies).

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Third Party Tracking: We do not permit third party advertising networks to collect information about your use of our website and Service over time and across websites for the purpose of serving targeted advertising and we will never use Student Data for targeted advertising.

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## Student privacy is very important to us. Student Data is only shared in limited circumstances - and never shared with or sold to third parties for marketing purposes.

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Clever only shares personal information in a few limited circumstances, described below. We do not rent or sell information for marketing purposes and we will never share or sell Student Data with third parties for marketing purposes.

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**Who we may share information with:**

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1	1	## Clever's Commitment to Your Privacy
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3		Effective Date: June 30, 2022
	3	Effective Date: January 1, 2023
4	4
5	5	Clever is a proud signatory of the [Student Data Privacy Pledge](https://studentprivacypledge.org/).
6	6
7	7	Clever ("Clever," "we," or "us") understands that privacy is tremendously important to our online visitors to our website ("Website Visitors"), to schools who use our Service ("Schools"), and to students whose information we may access on behalf of a School ("Students"). Clever provides a platform that enables Schools to securely provision the accounts with the third-party applications that they use. As we describe below, Schools decide which data is integrated with Clever, and Schools are responsible for determining whether data is ever shared with applications through Clever. This privacy policy applies to our website [https://clever.com/](https://www.clever.com/) and to the Clever platform (our "Service") and describes the steps we take to protect your data.
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9	9	Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our [Terms of Use](https://www.clever.com/trust/terms).
17	17	5. [Children's Privacy]()
18	18	6. [Links to Other Websites and Services]()
19	19	7. [How to Contact Us]()
20	20	8. [Jurisdiction-Specific Disclosures]()
21	21	9. [Changes to Our Privacy Policy]()
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	23	In certain jurisdictions, we are required by applicable data protection laws to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions or states. If you are a resident of the states of California, Colorado, Connecticut, Nevada, Virginia or Utah, or if you are located in the European Economic Area, Switzerland or the United Kingdom, Canada or Australia, please click on [Jurisdiction-Specific Disclosures]() for additional disclosures that may be applicable to you.
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23	25	## We strive to be transparent in our data collection and use practices. This is the type of personal information we may collect. Student Data is used only for educational purposes at the direction of the School.
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25	27	### 1\. HOW WE COLLECT AND USE INFORMATION
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27	29	We collect the following types of information:
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41	43	Information about Others: We also collect personal information from Developers and other individuals who create an account, correspond with us online or otherwise use or interact with the Clever Service, including a name, contact information and information relating to the Developer business or service. We may also retain information if the Developer sends us a message, posts content to our website or through our Service, or responds to emails or surveys. Once a Developer begins using the Clever Service, we will collect content and information about the Developer's use of and interaction with the Service and we will keep records of activities related to the Service. We use this information to operate, maintain, and provide to the features and functionality of the Service, to analyze and improve our Service offerings and functionality, and to communicate with our Developers and others.
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43	45	Information collected through use of the Service: We may collect information you provide or upload to the Service as well as activity and actions within our Service. For example, we collect information from files that you upload or content you post to the Service (such as in a classroom dashboard), messages you send or receive through the Service, and content you post such as in product reviews or comments. If you are a Developer, we will also collect information you make available to us when developing an Application via the Service.
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45	47	Information collected through technology: Like most websites and online services, we and our third-party partners automatically collect certain types of usage information when you visit our Services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, file information and similar technology (collectively, "tracking technologies"). For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device, or your account, and other such information. We also collect information about the way you use our Service, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, how frequently you access the Service, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, and other actions you take on the Service. When you access our Service from a mobile device, we may collect unique identification numbers associated with your device or our mobile application, mobile carrier, device type, model, and manufacturer, and mobile device operating system. We may be able to determine your approximate location by analyzing other information, like an IP address to associate a user with their School. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service. Although we do our best to honor the privacy preferences of our visitors, we are not able to respond to Do Not Track signals from your browser at this time.
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47		Cookies and related technology allow us to provide you with a better user experience. For example, we may use the data collected through cookies to: (a) remember information so that a user will not have to re-enter it during subsequent visits; (b) provide custom, personalized content and information; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our Service; (e) monitor aggregate metrics such as total number of visitors, traffic, and usage on our website and our Service; (f) diagnose or fix technology problems; (g) help users efficiently access information after signing in; and (h) otherwise to plan for and enhance our Service.
	49	Cookies and related technology allow us to provide you with a better user experience. For example, we may use the data collected through cookies to: (a) remember information so that a user will not have to re-enter it during subsequent visits; (b) provide custom, personalized content and information; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our Service; (e) monitor aggregate metrics such as total number of visitors, traffic, and usage on our website and our Service; (f) diagnose or fix technology problems; (g) help users efficiently access information after signing in; and (h) otherwise to plan for and enhance our Service. On certain portions of our website, we and our third party partners may also collect device and usage data for purposes of tracking adult visitors to our websites and for other targeted advertising, attribution, research and analytics purposes. While we may permit third party advertising partners to collect information from visitors to adult-directed pages of our site (such as the support pages), we do not permit third party advertising networks to collect information about authenticated users of our Service for the purpose of serving targeted advertising and we will never use Student Data for targeted advertising.
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49	51	If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
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51	53	For more information about the types of tracking technologies we use and how you can control them, please see our [Cookie Notice](https://www.clever.com/trust/privacy/cookies).
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53		Third Party Tracking: We do not permit third party advertising networks to collect information about your use of our website and Service over time and across websites for the purpose of serving targeted advertising and we will never use Student Data for targeted advertising.
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55	55	## Student privacy is very important to us. Student Data is only shared in limited circumstances - and never shared with or sold to third parties for marketing purposes.
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57	57	Clever only shares personal information in a few limited circumstances, described below. We do not rent or sell information for marketing purposes and we will never share or sell Student Data with third parties for marketing purposes.
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59	59	Who we may share information with:
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111	111	If a Student contacts Clever with a question about our Service, we will collect personal information from that Student only as necessary to respond to the Student's request and direct the Student to contact the Student's School, and we will then delete or anonymize the personal data of the Student after providing our response.
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113	113	### 8\. JURISDICTION-SPECIFIC DISCLOSURES
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115	115	We may be required by law to provide additional privacy disclosures, depending on the jurisdiction in which you reside. Please refer below for disclosures that may be applicable to you:
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117		- _California._ If you are a California resident, please click [here](https://www.clever.com/trust/privacy/ccpa) for additional California-specific privacy disclosures.
118		- _Nevada._ Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the Nevada resident. At this time, we do not engage in data "sales" as defined by the Nevada law. However, if you would like to submit a request to opt-out of future sales (if any), please contact us directly by visiting our Help Center. You can also email us at _[trust@clever.com](mailto:trust@clever.com)_ with the subject line "Nevada opt-out."
	117	- _United States._ If you are a resident of California, Colorado, Connecticut, Nevada, Utah or Virginia, please click [here](https://www.clever.com/trust/privacy/us-disclosures) for additional privacy disclosures.
119	118	- _Europe._ If you are located in the European Economic Area, Switzerland or the United Kingdom ("Europe"), please click [here](https://www.clever.com/trust/privacy/europe) for additional Europe-specific privacy notice.
120	119	- _Canada._ If you are located in Canada, please click [here](https://www.clever.com/trust/privacy/canada) for additional Canadian-specific privacy notice.
	120	- _Australia._ If you are located in Australia, please click [here](https://www.clever.com/trust/privacy/australia) for additional Australia-specific privacy notice.
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122	122	### 9\. CHANGES TO OUR PRIVACY POLICY
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124	124	Clever may modify or update this Privacy Policy from time to time so you should review this page periodically. [Click here](https://www.clever.com/trust/privacy/change-history) to see all changes to this Privacy Policy. If we change the policy in a material manner, for example if we seek to use personal information in a materially different way than we had previously, we will provide at least 30 days' notice. Of course, you can always opt-out by deleting your account before the changes take effect.

Privacy Policy

Full text changes — 20220702_rev01 to 20230131_rev01