Notebook Privacy Policy

This privacy policy for SMART Notebook^® (“Notebook Privacy Policy”) desktop software forms part of the Terms agreed upon between you and SMART. This policy explains how SMART works with you to protect your information and privacy when using Notebook.

By using Notebook you are consenting to SMART's collection, retention, use and disclosure of certain information as necessary to provide Notebook to you. If you do not agree, you must not use Notebook.

Automatic Error Reporting: If an SLS application encounters an issue, the application automatically sends the following anonymous information to SMART’s sub-processor Sentry.io (located in the United States):

• Lesson ID (no PII)
• User ID and Session IDs (hashed and salted to maintain anonymity)
• request header (application and version, platform, operating system, browser, language, date and time)
• bread crumbs (last pages visited and links clicked)

Optional User Error Reporting: After automatic error reporting is complete, users are given the option to provide their name, email address, and additional information about the error. Users are also asked if they wish SMART to follow up with them. This optional personal information is stored in Salesforce (located in the United States) and shared with our customer support team.

It is important to remember that customers and users are two distinct groups:

Still concerned?

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PRODUCT USER DATA COLLECTED AND PROCESSED

This section outlines what data is collected, used, and disclosed from the two types of Notebook users:

• Notebook Basic Users (not signed-in, no sharing)
• Signed-In Notebook Users

Deletion requests for users’ data is controlled by the customer. If you are accessing Notebook through your school, you should make your deletion request to them. If you are a minor, SMART reserves the right to provide access to your account to your parents, guardian, or other authorized adult (teacher, school administrator) or, if required by law.

The term “identifiable” used in the below charts does not necessarily mean personally identifiable information.

 SMART Notebook^® Basic Users (not signed-in; no online sharing)

The basic version is free software designed for use with a SMART Board^® interactive display. It comes with many features that you can use to create and edit lessons. You can use it without an Internet connection. A watermark appears on each lesson page if the computer on which you are running the basic version is not connected to a SMART Board. Typically, SMART Notebook users are using it with a SMART Board^®.

Where	Who	Role	Data & Purpose	Type
	SMART Technologies ULC	Manufacturer	Required. If used offline no information is transmitted to SMART or any other party for that matter. When connected to the Internet we collect anonymous analytics and optional (opted-in) crash report data. SLS Terms GDPR - EC Adequacy Decision	Anonymous
	Mixpanel, Inc.	Monitoring	Required for product improvement and service monitoring. Mixpanel allows us to analyze how our anonymous basic free users interact with Notebook. It is designed to identify trends, understand common aggregated usage behavior, and helps us make better decisions on how to improve the usability and features of our product. Mixpanel Privacy Mixpanel GDPR	Anonymous
	Google, LLC	Monitoring	Required for product improvement and service monitoring. Google Analytics allows us to analyze how our anonymous basic free users interact with Notebook. It is designed to identify trends, understand common aggregated usage behavior, and helps us make better decisions on how to improve the usability and features of our product. Google Privacy Google GDPR	Anonymous

 SIGNED-IN NOTEBOOK USERS (teachers)

A subscription to SMART Learning Suite gives you access to all of SMART Notebook’s features. Without a subscription, you can still get access to the basic version of SMART Notebook (see above). The sharing of user created Content with students over the Internet is done via Lumio.

Where	Who	Role	Data & Purpose	Type
	SMART Technologies ULC	Manufacturer	Required account details: display name, name, email, public profile picture. language preference. Required account profile settings: opt-ins, user type, location. We also offer an optional opt-in to SMART’s Customer Experience Program that collects and transmits additional information about the computing environment and the frequency with which our software and its features are used. You can turn off the Customer Experience Program at any time. Sending anonymous crash data is optional. SLS Terms GDPR - EC Adequacy Decision	Identifiable
	Microsoft, Inc.	Product Functionality	Required if you use Microsoft as your single-sign-on (SSO) provider to access Notebook. Microsoft provides SMART with required account details. Microsoft SSO Microsoft Privacy Microsoft GDPR	Identifiable
	Google LLC	Product Functionality	Required if you use Google as your single-sign-on (SSO) provider to access Notebook. Microsoft provides SMART with required account details. Google SSO Google Privacy Google GDPR	Identifiable
,	Amazon Web Services, Inc.	Product Functionality	Required for storage. We offer both an American and European data storage option. AWS Privacy AWS GDPR	Identifiable
,,	Firebase, Google LLC	Product Functionality	Required for basic functionality (Firebase is a Backend-as-a-Service (BaaS) cloud-computing solution we use for real time (temporary) automated computer processing.) Firebase Privacy Firebase GDPR	Identifiable
	Mixpanel, Inc.	Monitoring	Required for product improvement and service monitoring. Mixpanel allows us to analyze how our de-identified users interact with Notebook. It is designed to identify trends, understand common aggregated usage behavior, and helps us make better decisions on how to improve the usability and features of our product. This data is also used to track how long it takes our servers to complete actions like open files, which helps us measure service health and up/downtime. Mixpanel Privacy Mixpanel GDPR	Pseudonymized
	Google, LLC	Monitoring	Required for product improvement and service monitoring. Google Analytics allows us to analyze how our anonymous basic free users interact with Notebook. It is designed to identify trends, understand common aggregated usage behavior, and helps us make better decisions on how to improve the usability and features of our product. Google Privacy Google GDPR	Pseudonymized
	Third-party content and activity providers	Optional Product Functionality	Optional content or activity a teacher may add to a lesson such as a YouTube or other embedded content a user voluntarily adds. We cannot control what data a third party directly collects via the content when a teacher or student decides to include it in a lesson. For premium content that SMART provides however, we only report anonymous usage to the third-party publisher.	Identifiable

CUSTOMER DATA COLLECTED AND PROCESSED

This section outlines what data is collected, processed, and disclosed from customers (purchasers, prospects, and SMART’s authorized channel partners). You can request, through our Customer Support, data and account deletion at any time, but we must retain all data relevant to purchases and financial transactions until it is no longer required by applicable law. The term “identifiable” used in the below chart does not necessarily mean personally identifiable information.

The customer must install SMART Notebook desktop software on the applicable computers and give teachers access to the software using one of the two activation methods (support pages do not form part of this Notebook Privacy Policy or Terms; they are provided for convenience only).

Where	Who	Role	Data & Purpose	Type
	Reseller & SMART’s Regional Office	Seller	Required contact information: organization name, e-mail, title, phone, address. Required order information: product, quantity, price and tax, delivery. Ask your local regional reseller about their privacy policies.	Identifiable
	SMART Technologies ULC	Manufacturer	Required account information: organization name, e-mail, title, phone, address, reseller, current subscriptions. Required order information: product, quantity, price and tax, delivery. Required admin portal information for license provisioning: licenses and activations, teachers’, and admins’ first and last names (can provide non-PII version to comply with GDPR) and e-mail address, and class names (can be non-PII version to comply with GDPR). SLS Terms GDPR - EC Adequacy Decision	Identifiable
	Blue Ocean Contact Centers, Inc.	Support	Optional. Blue Ocean is a subcontractor providing live (telephone, e-mail, and web) support. Information collected includes organization name, caller name (can use company title only if preferred for GDPR reasons), e-mail (can provide non-PII version to comply with GDPR), title, phone, address and a description of the issue and any shared details to help solve the problem. Calls are recorded. Blue Ocean Privacy GDPR - EC Adequacy Decision	Identifiable
	Amazon Web Services, Inc.	Processing, Back-Office	Required for product infrastructure including the hosting of support call recordings. AWS Privacy AWS GDPR	Identifiable
	Google, LLC.	Processing, Back-Office.	Optional. Only used for processing of support forms. Google Forms are used when a purchaser is engaged with our Field Services (i.e., onsite support). Google Privacy Google GDPR	Identifiable
	Microsoft, Inc.	Processing, Back-Office	Required for our enterprise resource planning (ERP) system, which is software to manage the day-to-day business activities such as accounting, procurement, project management and supply chain operations, as well as our e-mail, PowerBI® (data visitation) and SharePoint® (document management), as well as all the other standard Microsoft Office software titles, like Word, Excel, etc. Microsoft Privacy Microsoft GDPR	Identifiable
	BigCommerce, Inc.	Ordering	Optional. Only used when a customer purchases through our e-commerce store: customer name, e-mail, title, phone, address, product, or service purchased and whether payment is received. BigCommerce Privacy BigCommerce GDPR	Identifiable
,	Stripe, Inc. and Stripe Payments Europe, Ltd.	Ordering	Optional. Only used when a customer purchases through our e-commerce store using a credit card: customer name, e-mail, title, phone, address, product, or service purchased, credit card details. Residents of the European Economic Area (EEA), the UK and Switzerland. The entity responsible for the collection and processing of credit card personal data for residents of the EEA, the UK and Switzerland is Stripe Payments Europe, Ltd., a company incorporated in Ireland and with offices at 1 Grand Canal Street Lower, Grand Canal Dock, Dublin. To exercise your rights, the Data Protection Officer may be contacted via dpo@stripe.com. Stripe Privacy Stripe GDPR	Identifiable
	Salesforce.com, Inc	Ordering, Marketing, Channel Support	Required order information (product, quantity, price and tax, delivery). Required for our customer relationship management (CRM). Required to allow our authorized distributors and resellers to work together with SMART. Basic customer and purchase information is shared between SMART and its authorized distributors and resellers. Salesforce Privacy Salesforce GDPR	Identifiable
	HubSpot, Inc.	Marketing	Optional. We use HubSpot, which is a customer relationship management (CRM), for individuals that have expressly opted in to receive certain communications, such as marketing, training, news, and offers from us. Hubspot Privacy Hubspot GDPR	Identifiable
	Mixpanel, Inc.	Monitoring	Required for product improvement and service monitoring. Mixpanel allows us to analyze how our de-identified users interact with Notebook. It is designed to identify trends, understand common aggregated usage behavior, and helps us make better decisions on how to improve the usability and features of our product. This data is also used to track how long it takes our servers to complete actions like open files, which helps us measure service health and up/downtime. Mixpanel Privacy Mixpanel GDPR	Pseudonymized
	Google, LLC	Monitoring	Required for product improvement and service monitoring. Google Analytics allows us to analyze how our anonymous basic free users interact with Notebook. It is designed to identify trends, understand common aggregated usage behavior, and helps us make better decisions on how to improve the usability and features of our product. Google Privacy Google GDPR	Pseudonymized
	Gainsight, Inc.	Marketing	Applicable only to USA Customers. We use Gainsight, which is a customer relationship management (CRM) tool, for e-mail (name, e-mail address, company information) marketing to individuals and organizations. Gainsight Privacy	Identifiable

THIRD PARTIES

To the extent functionality is not directly provided or managed by SMART, such as single sign-on (SSO) via Google and Microsoft, YouTube^®, etc., you agree it is your responsibility to review and accept these third-party service providers’ terms and privacy policies. Links to their policies have been provided.