Notebook privacy policy

Thank you for choosing SMART Notebook® collaborative learning software.  This privacy policy is applicable to SMART Notebook® and SMART Notebook® Plus (collectively, “Notebook software”).   Starting with Version 22 the paid subscription features were renamed as “SMART Notebook Plus”.

This privacy policy for Notebook 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 software 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 Notebook software 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:

Typically, a customer is an organization (e.g., district, school, company) and not a personally identifiable individual. The identifiable information we require is from the organizational purchaser for transactional purposes. The customer should not be providing SMART with personally identifiable information unless permissible by law and the customer’s policies.

Our users (e.g., teachers using Notebook) are generally not the ones who purchased or setup the account and users are only accessing Notebook because the customer’s administrator has granted them access. As such, SMART’s exposure to personally identifiable information only comes from how the customer operates when providing e-mail addresses and names of users to SMART and from user created Content. If you have a concern as a user about your PII you must demand the customer provide only non-identifiable information to SMART and you as a user must only create Content with no PII in it.

Still concerned?

Teachers can use SMART Notebook without signing-in.

Teachers can choose to share their created content in a number of ways that do not require students to sign-in.

You own your data and SMART does not sell it or use it for advertisement purposes. We use your data to provide Notebook to you. Data portability and deletion is managed by the customer who can request its deletion at any time.

SMART does not advertise or market to minors.  

Optional sign-in and therefore account security, is handled by the world class providers Google and Microsoft. Both providers support two-step (dual) authentication and enforce strong password creation. Both providers state you can use their services in compliance with GDPR.

User data is encrypted at rest and in-transit.

What about GDPR, CCPA, and FERPA?

User created Content is not a student or educational record, transcript, gradebook, health or directory information. Notebook is not a learning management system (LMS).

SMART supports the European Union General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and numerous other laws including the Family Educational Rights and Privacy Act (FERPA). SMART is committed to helping our customers work under these and other stringent regulations and we continue to add in-region solutions. We currently offer American and European data storage for user created Content and we are satisfied our out-of-region user data processors provide appropriate safeguards for the data they handle.

Remember, SMART only receives information because you provide it; you are the data controller. In this way, customers and users are obligated to comply with their local laws and are responsible for any obligations they owe to their users with respect to their personally identifiable information.


PRODUCT USER DATA COLLECTED AND PROCESSED

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

  • SMART Notebook Users (not signed-in, no sharing)
  • Signed-In SMART Notebook Plus 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® 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. On older versions 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. Starting with Version 22 of SMART Notebook the software may not operate with a non-SMART Board.

Country Data is Processed/Stored Sub-Processor Role Data & Purpose Data
USA 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. Anonymous
Global 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. Anonymous

SIGNED-IN SMART NOTEBOOK PLUS USERS

A subscription to SMART Learning Suite gives you access to SMART Notebook Plus features. Without a subscription, you can still get access to the basic version of SMART Notebook (see above).

Country Data is Processed/Stored Sub-Processor Role Data & Purpose Data
Global 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. Identifiable
Global 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. Identifiable
USA
Germany
Amazon Web Services, Inc.

Product Functionality 

Required for storage. We offer both an American and European data storage option. Identifiable
USA
Germany
Belgium
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. The processing is done regionally through either Google’s American or European centres. Identifiable
USA
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.
Pseudonymized
Global
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. Pseudonymized
Global
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

Country Data is Processed/Stored Sub-Processor Role Data & Purpose Data
Global 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
Canada 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. Identifiable
Canada Call Miner
Support
Optional for telephone interactions (option to opt out of call recordings), required for email. Call Miner is a subprocessor providing omnichannel interaction analytics powered by AI and machine learning. Call Miner analyzes customer support interactions, including recorded calls and emails, which are temporarily stored in CallMiner. The metadata is retained in CallMiner for analysis of the customer experience and trending information regarding the interactions between agent and customer.
Identifiable
USA Amazon Web Services, Inc. Processing, Back-Office
Required for product infrastructure including the hosting of support call recordings. Identifiable
Global
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). Identifiable
Global
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. Identifiable
USA
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. Identifiable
USA
Ireland
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. Identifiable
USA
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. Identifiable
Germany HubSpot, Inc
Marketing / Customer Communications
We use HubSpot, which is a customer relationship management (CRM), for certain communications, such as marketing, training, news, and offers from us. Identifiable
USA 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. Pseudonymized
USA Gainsight, Inc.
Customer Communications
Applicable only to North American 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. 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, or videos on YouTube®, etc., you agree it is your responsibility to review and accept these third-party service providers’ terms and privacy policies.


COOKIES

SMART and some of its processors use cookies to provide Notebook to you. Cookies are small files that are placed on your computer or device. Most web browsers allow some control over cookies through the browser settings. Blocking all cookies will, however, have a negative impact upon the usability of Notebook. Thus, you may prefer to accept cookies and then delete them later or upon exiting your session.

Who Cookie Purpose
SMART id.smarttech-prod.com
_ga
_gid
_ids
_ids_legacy
_ssos
_ssos_legacy
Required for providing navigation, log-in status, and user identification for the purpose of providing Notebook software to the user, including the proper linking of user created Content.
Microsoft login.microsoftonline.com
AADSSO
CCState
ESTSAUTH
ESTSAUTHLIGHT
ESTSAUTHPERSISTENT
ESTSSC
SignInStateCookie
brcap
buid
ch
clrc
esctx
fpc
stsservicecookie
x-ms-gateway-slice
login.live.com
MSPRequ
uaid
Required for providing single-sign-on functionality and identification of the user for the purpose of providing Notebook software to the user. These cookies are installed by Microsoft and SMART has no control over what Microsoft does with the information. Click here for additional information on Microsoft’s cookies.
Google LLC accounts.google.com
ACCOUNT_CHOOSER
LSID
__Host-3PLSID
__Host-GAPS
user_id
google.ca
APISID
HSID
NID
SAPISID
SID
SSID
__Secure-3PAPISID
__Secure-3PSID
google.com
APISID
HSID
NID
SAPISID
SID
SIDCC
SSID
__Secure-3PAPISID
__Secure-3PSID
__Secure-3PSIDCC
youtube.com
APISID
HSID
SAPISID
SID
SSID
__Secure-3PAPISID
__Secure-3PSID
Required for providing single-sign-on functionality and identification of the user for the purpose of providing Notebook software to the user. YouTube cookies are installed during sign-on and support additional functionality (adding videos) within Notebook software. These cookies are installed by Google and SMART has no control over what Google does with the information. Click here for additional information on Google’s cookies.
Google LLC _utma This cookie is typically written to your browser upon the first visit to www.smarttech.com and our admin portal site. If the cookie has been deleted by the browser operator, and the browser subsequently visits our site, a new __utma cookie is written with a different unique ID. This cookie is used to determine unique visitors to our site and it is updated with each page view. Additionally, this cookie is provided with a unique ID that Google Analytics uses to ensure both the validity and accessibility of the cookie as an extra security measure. This cookie is a persistent cookie with a lifespan of 2 years from set/update.
Google LLC _utmb This cookie is used to establish and continue a visitor session with our admin portal site. When a visitor views a page on our site, the Google Analytics code attempts to update this cookie. If it does not find the cookie, a new one is written and a new session is established. Each time a visitor visits a different page on our site this cookie is updated and will expire in 30 minutes, thus, continuing a single session for as long as visitor activity continues within 30-minute intervals. This cookie is a session cookie with a lifespan of 30 minutes from set/update.
Google LLC _utmc Historically, this cookie operated in conjunction with the __utmb cookie to determine whether to establish a new session for the visitor. For backwards compatibility purposes with sites still using the urchin.js tracking code, this cookie will continue to be written and will expire when the user exits the browser. This cookie may or may not be set and is a session cookie with a lifespan of the browser session.
Google LLC _utmz This cookie stores the type of referral used by the visitor to reach our site, whether via a direct method, a referring link, a website search, or a campaign such as an ad or an email link. It is used to calculate search engine traffic, ad campaigns and page navigation within our site. The cookie is updated with each page view to our site. This cookie is a persistent cookie with a lifespan of 6 months from set/update.
Identity Client library software_portal When administrator signs in from SMART’s admin portal, this cookie is set to remember the authorization information for the current signed in session. The cookie will be refreshed automatically to keep the session alive. This cookie is set by SMART and is a persistent cookie with a lifespan of 365 days. The content of the cookie is the encrypted id access token and id refresh token
Language Cookie website#lang, support#lang, training#lang This cookie saves your language selection for our website.
Sitecore SC_ANALYTICS_GLOBAL_COOKIE This cookie is associated with our Sitecore content management system and is used for web analytics to identify repeat visits by unique users.
Smart ID SMARTId, SMARTIdState, SMARTIdReturnUrl These cookies are written to your browser when you sign-in to SMART ID. Signing out of your SMART ID deletes this cookie. These cookies store encrypted authentication information that only our servers can decrypt. This cookie is persistent and lasts for several hours.

HAVE A QUESTION FOR US? We would love to hear from you:
SMART Technologies ULC
Attention: Legal Department
3636 Research Road N.W.
CALGARY, AB CANADA T2L 1Y1
+1.403.245.0333
SMART’s Privacy Office
privacy@smarttech.com

Last Updated: October 27, 2023