Data collected and processed by SMART Technologies ULC
Overview
This document provides information about the type of data SMART processes regarding the installation and use of its products and services.
It is important to remember that customers and users are two distinct groups. Typically, a SMART customer is an organisation (government, business, school, etc.) and not an individual end user (business person, teacher, student, etc.). Our users are generally not the ones who purchased or set up a trial of the product or service from SMART; our users are accessing the SMART product or service because the customer has granted them access. When using our products, the customer is the data controller and SMART is the data processor. As such, most requests from users must be directed to the customer and not to SMART.
Customer purchase data collected so an order can be processed
SMART is considered the controller when data is collected in the course of selling a product or service. The following table lists the category and the associated data collected for this category:
| Category | Data collected |
|---|---|
|
Name and address of the organisation, local authority, MAT, school, or institution |
|
|
Information about the organisation, local authority or MAT, school, or institution |
|
|
Information on individual purchasing for the organisation, local authority or MAT, school, or institution |
|
|
Information about the products ordered |
|
|
Information for training |
If a customer signs up for SMART training courses (https://training.smarttech.com), this is recorded and duplicated within SMART’s customer support database. |
The following table provides a list of processors, the purpose of processing, the location of those processors, and if they have provided a Data Processing Addendum (DPA).
Processors of customer purchase data
| Processors | Purpose | Location | DPA |
|---|---|---|---|
|
SMART authorised distributors and resellers |
For the sale and support of SMART products. |
Global |
These organisations operate under agreements with SMART that contain standard commercial contractual clauses that adequately protect the data with confidentiality clauses and representations that they comply with all privacy laws in their jurisdiction. |
|
For online (e-commerce) order taking. |
Canada USA |
Yes |
|
|
Maintain customer data |
USA |
||
|
Maintain customer data and licence key entitlement |
USA |
||
|
(SAP SE) |
Order information; customer data |
Germany |
Yes |
|
For credit card payment processing (SMART does not collect credit card information). |
USA |
Yes |
User data for software
Applicable SMART software
|
SMART Learning Suite SMART amp SMART Ink SMART lab SMART Learning Suite Online SMART Notebook SMART Response 2 Product drivers |
SMART Bridgit software SMART Bridgit (app) SMART Exchange SMART Identity (ID) SMART InkScan (app) SMART kapp (app) SMART Meeting Pro SMART Notebook for iPad (app) SMART Admin Portal SMART Support (app) |
SMART is considered the processor when data is collected in the course of providing its service. The following table provides details about the user data (this includes personal and non-personal data) collected when using the above SMART software:
|
Data collected |
Purpose of collection |
Product |
|
Anonymous analytics that are aggregated but include information such as operating system, system platform, browser, browser language, referrer (if from a search engine or another site), screen resolution, whether cookies are enabled, whether Java is enabled, and last page seen on SMART site (handles navigation). |
Improving the product and monitoring product health |
All software |
|
Assessment scores |
Teacher review |
SMART amp SMART lab SMART Learning Suite Online SMART Response 2 |
|
Content services – user-generated content such as uploaded files and any changes made to that content |
Optional product functionality |
SMART amp SMART lab SMART Learning Suite Online SMART Notebook SMART Response 2 SMART Exchange |
|
Class membership (what classes the user belongs to) |
Associates user with correct classes |
SMART amp SMART lab SMART Learning Suite SMART Response 2 |
|
Crash data |
Installer and system crash information that could include user’s email address and user’s optional comments about what they were doing at the time, and installer error reports. Both include computer system information. |
SMART amp SMART Bridgit SMART lab SMART Meeting Pro SMART Notebook |
|
District ID and district name (what local education authority or MAT the user belongs to) |
Associates user with correct classes |
SMART amp SMART lab SMART Learning Suite Admin Portal |
|
Internet Protocol (IP) address. NOTE: If not anonymised by the user, an IP address can reveal the internet provider used (includes your company or school and ISP) and which country, region, and city the provider is located in. |
Required to support product functionality |
All software |
|
School name (what school the user belongs to) |
Associates user with correct classes |
SMART amp SMART lab SMART Learning Suite Admin Portal |
|
Self-chosen class name or meeting name (when a user (teacher) creates a class name) |
Required to support product functionality |
SMART amp SMART Bridgit SMART lab SMART Meeting Pro SMART Learning Suite |
|
Self-chosen username |
Required to support product functionality |
SMART lab SMART Learning Suite Admin Portal |
|
Student device type and operating system |
Used for analytics and formatting between browsers |
All software |
|
Student email (this is part of their Google or Microsoft profile) |
Required to support product functionality |
SMART amp SMART Learning Suite Admin Portal |
|
Student name (this is part of their Google or Microsoft profile) |
Required to support product functionality |
SMART amp SMART Learning Suite Admin Portal |
|
Teacher, parent, or admin email address |
Required to support product functionality |
SMART amp SMART ID SMART lab SMART Learning Suite Admin Portal SMART Notebook for iPad |
|
Teacher, parent, or admin name (this is part of their Google or Microsoft profile) |
Required to support product functionality |
SMART amp SMART Learning Suite Admin Portal |
Sub-processors of user data for software products
The following table provides a list of sub-processors for SMART’s software products, the purpose of processing, the location of those sub-processors, and if they’ve signed SMART’s Data Processing Addendum (DPA).
|
Software sub-processors |
Purpose |
Location |
DPA |
|
Amazon Web Services, Inc. (Amazon.com) |
Hosting |
USA |
|
|
Bing.com (Microsoft Azure) |
Users can search and add images (Bing Search API). The search terms used are shared with SMART. |
USA |
|
|
(*optional paid service; your privacy agreement is directly with Clever) |
Optional roster integration with your school’s LMS |
USA |
N/A |
|
(Google LLC) |
Crash data reporting for SMART hardware (reports can be turned off within hardware product) |
USA |
|
|
Firebase (Google LLC) |
Session management |
USA |
|
|
(*optional to sharing feature; privacy agreement would be direct with GeoGebra) |
Maths tools and calculators for graphing, geometry, 3D, and more |
Austria |
N/A |
|
(Google LLC) |
Anonymous analytics |
USA |
|
|
(Google LLC) |
Hosting |
USA |
|
|
(Google LLC) |
Google account for identity management (enables a user to log in using Google account credentials) |
USA |
|
|
(Google LLC) |
Document storage |
USA |
|
|
HockeyApp (Microsoft Corp.) |
Anonymous device model and OS version information |
USA |
|
|
Microsoft account for identity management (enables a user to log in using Microsoft account credentials) |
USA |
||
|
Usage and web analytics |
USA |
||
|
mLab (ObjectLabs Corporation) |
Anonymous data relating to uploaded images |
USA |
N/A |
|
Crash data reporting for SMART software (anonymised) |
New Zealand |
||
|
Licence key entitlement and SMART Admin Portal identity management |
USA |
||
|
(Mozilla Foundation, hosted on Amazon Web Services) |
Socorro is a set of components for collecting, processing, and analysing crash data. (Anonymised)
|
USA |
|
|
System logs and performance (anonymised) |
USA |
N/A |
|
|
YouTube (Google LLC) |
Users can add YouTube videos ( YouTube API) to their documents. Search terms are shared. |
USA |
User data for hardware
SMART is considered the controller when data is collected in the course of a customer or user using SMART hardware. This includes personal and non-personal data.
When a SMART Board® interactive display is used, it automatically reports the following information back to SMART:
- Model number
- OS and OS version
- App build details (version)
- Brand (SMART)
- Board configuration (Legacy, ENT, or EDU)
- Browser
-
Information obtained from IP address, such as:
- City
- Country
- Region
- Screen DPI
- Screen height and width
- Timestamp of when data collected
- Firmware version (iQ version)
- Hardware SKU (AM30, AM40, AM50, SB2000)
- Last seen (when the last report came)
- Panel family type (what model panel the iQ appliance is in)
- Update channel (Stable, Beta, or Developer)
Processors of user data for hardware products
The following table provides a list of processors for SMART’s hardware products, the purpose of processing, the location of those processors, and if they’ve signed SMART’s Data Processing Addendum (DPA).
|
Hardware processors |
Purpose |
Location |
DPA signed |
|
Compiles crash data (reports can be turned off within product) |
USA |
||
|
Usage analytics |
USA |
Marketing data
SMART is considered the controller when data is collected in the course of marketing. This includes personal and non-personal data that SMART collects for its marketing purposes. The following marketing data is collected:
- Area of interest
- Budget
- Contact history
- Conversion (whether the lead becomes a customer)
- Date
- Individual’s name
- Information to be sent or opted-out of
- IP address
- Language
- Opt-in and opt-out responses
- Organisation or school name
- Potential sale opportunity
- Public web content is anonymised, and aggregate information is relayed through Google Analytics
- Raffle or other contest entries.
- SMART EdTech Capabilities Profile survey results
- Trade shows attended or will attend
Processors of user data for SMART marketing data
The following table provides a list of processors for SMART’s marketing, the purpose of processing, the location of those processors, and if they’ve signed SMART’s Data Processing Addendum (DPA).
| Processors | Purpose | Location | DPA |
|---|---|---|---|
|
SMART authorised distributors and resellers |
To market SMART products for sale |
Global |
No, these organisations operate under agreements with SMART that contain adequate commercial contractual clauses |
|
To compile marketing data and send communications |
USA |
||
|
To compile marketing data and send communications |
USA |
||
|
Session cookies, website analytics, and navigation (anonymised). Optional opt-in to allow customised landing pages |
USA |
Yes |
|
|
Surveys and event management |
USA |
NOTE: If you have opted in to receive information from SMART, SMART will also use your personal data for SMART’s internal (marketing, sales, development) purposes. You may opt out at any time by clicking on a link in emails we send or by visiting here and manually entering your email address.
Support-related data
SMART is considered the controller when data is collected in the course of customer service. This includes personal and non-personal data that SMART collects when a person contacts SMART support. The following support call data is collected from the person who is contacting SMART support:
- First name
- Surname
- Organisation calling on behalf of
- Address
- Delivery address if parts needed
- Phone number
- Serial number of the product
- Issue reported
- Attachments (pictures, emails, etc.)
- Existing incident number (if any)
- Preferred reseller
- Comments about service received
Processors of user data for SMART support-related data
The following table provides a list of processors for SMART support, the purpose of processing, the location of those processors, and if they’ve signed SMART’s Data Processing Addendum (DPA).
| Processors | Purpose | Location | DPA |
|---|---|---|---|
|
Handles support calls |
Canada |
No, this organisation operates under an agreement with SMART that contains adequate commercial contractual clauses |
|
|
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 analyses customer support interactions, including recorded calls and emails, which are temporarily stored in Call Miner. The metadata is retained in Call Miner for analysis of the customer experience and trending information regarding the interactions between agent and customer. |
Canada |
N/A |
|
|
Amazon Connect (Amazon.com) |
Cloud-based contact centre and hosting of support calls |
USA |
|
|
Customer communications |
USA |
||
|
Customer surveys |
USA |