Data Collected and Processed by SMART Technologies ULC

Last Updated: May 23, 2018

Overview

This document provides information about the type of data SMART collects for installment and use of its products and/or services.

It is important to remember that customers and users are two distinct groups.  Typically, a SMART customer is an organization (government, business, school, etc.) and not an individual end user (i.e., business person, teacher, student, etc.).  Our users are generally not the ones who purchased or setup 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. 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

This includes personal and non-personal data collected when a SMART product is purchased.

Customer Data Collected so an Order Can be Processed

The following table lists the category and the associated data collected for that category:

Category

Data collected

Name and Address of the Organization, District, School, or Institution

  • Street address
  • City
  • Postal/Zip
  • Country
  • Phone number(s)
  • E-mail

Information About the Organization, District, School, or Institution

  • Tax registration numbers
  • Size of organization
  • Segment (education versus business)
  • Reseller (including the Reseller’s address) and the Reseller’s Tier (if any) at SMART
  • Preferred reseller, if different than above
  • Interests (opt-ins for additional materials)
  • DUNS number by Dun & Bradstreet (D&B)

Information of Individual Purchasing for the Organization, District, School, or Institution

  • First name
  • Last name
  • Job Title / Role
  • Industry
  • E-mail
  • Phone number

Information about the Products Ordered

  • Products Ordered
  • Quantity Ordered
  • Software License Number(s) / Entitlements
  • End customer shipped to
  • End customer billed to
  • Dates
  • Price and currency
  • Stock quantity
  • Rebate claim
  • Sales Representative (if any) involved
  • Oracle number assigned to Customer
  • Tracking Number used for Order Tracking

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.

Sub-Processors of Customer Purchase Data

The following table provides a list of Sub-Processors, the purpose of processing, location of those Sub-Processors, if they have provided a Data Processing Addendum (DPA) and if they are EU-U.S. Privacy Shield certified. 

Sub-Processors

Purpose

Location

DPA

Privacy Shield

SMART Authorized Distributors and Resellers

For the sale and support of SMART products.

Global

No. These organizations 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. 

Not applicable

BigCommerce, Inc

For online (e-commerce) order taking.

Canada

USA

No

Yes

Hubspot, Inc.

Maintain customer data

USA

Yes

Yes

Salesforce.com, Inc.

Maintain customer data and license key entitlement

USA

Yes

Yes

SAP Hybris

(SAP SE)

Order information; customer data

Germany

No

Not applicable – German company

Stripe, Inc.

For credit card payment processing

(SMART does not collect credit card information).

USA

No

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 Software Portal

SMART Support (app)

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, browner language, referrer (if from a search engine or another site), screen resolution, whether cookies are enabled, whether java is enabled, and last page on SMART site seen (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 education district the user belongs to)

Associates user with correct classes

SMART amp

SMART lab

SMART Learning Suite

Software Portal

Internet Protocol (IP) address.  NOTE: If not anonymized by the user, an IP address can reveal the internet provider used (includes your company or school and ISP) and which country, state 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

Software 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

Software 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

Software Portal

Student name – this is part of their Google or Microsoft Profile

Required to support product functionality 

SMART amp

SMART Learning Suite

Software Portal

Teacher / admin email address

Required to support product functionality 

SMART amp

SMART ID

SMART lab

SMART Learning Suite

Software Portal

SMART Notebook for iPad

Teacher Name – this is part of their Google or Microsoft profile

Required to support product functionality 

SMART amp

SMART Learning Suite

Software 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, location of those Sub-Processors, if they’ve signed SMART’s Data Processing Addendum (DPA), and if a privacy shield exists.

Software Sub-Processors

Purpose

Location

DPA

Privacy Shield

Amazon Web Services, Inc. (Amazon.com)

Hosting

USA

Yes

Yes

Bing.com (Microsoft Azure)

Users can search and add images (Bing Search API).  The search terms used are shared with SMART.

USA

Yes

Yes

Clever, Inc.

(*optional paid service)

Optional roster Integration with your school’s LMS

USA

No

No

Fabric.io

(Google LLC)

Crash data reporting of SMART hardware (reports can be turned off within hardware product)

USA

Yes

Yes

Firebase (Google LLC)

Session management

USA

Yes

Yes

GeoGebra GmbH

(*optional to sharing feature)

Math tools and calculators for graphing, geometry, 3D, and more

Austria

No

N/A (EU member)

Google Analytics

(Google LLC)

Anonymous Analytics

USA

Yes

Yes

Google App Engine

(Google LLC)

Hosting

USA

Yes

Yes

Google Identity

(Google LLC)

Google account for identity management (enables a user to log-in using Google account credentials)

USA

Yes

Yes

Google Realtime API

(Google LLC)

Document storage

USA

Yes

Yes

HockeyApp (Microsoft Corp.)

Anonymous device model and OS version information

USA

Yes

Yes

Microsoft Corporation

Microsoft account for identity management (enables a user to log-in using Microsoft account credentials)

USA

Yes

Yes

Mixpanel, Inc.

Anonymous usage analytics

USA

Yes

Yes

mLab (ObjectLabs Corporation)

Anonymous data of uploaded images

USA

No

No

Raygun, Limited

Crash data reporting of SMART software

New Zealand

Yes

No

Salesforce.com, Inc.

License key entitlement and SMART Software Portal identify management

USA

Yes

Yes

Socorro

(Mozilla Foundation, hosted on Amazon Web Services)

Socorro is a set of components for collecting, processing, and analyzing crash data.

           

USA

Yes

Yes

Splunk, Inc.

System logs and performance

USA

No

Yes

YouTube (Google LLC)

Users can add YouTube videos (YouTube API) to their documents. Search Terms are shared.

USA

Yes

Yes

User Data for Hardware

This includes personal and non-personal data collected when using SMART hardware.

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
  • Brand (SMART)
  • Browser
  • Information obtained from IP address, such as:
    • City
    • Country
    • Region
    • Screen DPI
    • Screen height and width
    • Timestamp of when data collected

Sub-Processors of User Data for Hardware Products

The following table provides a list of Sub-Processors for SMART’s hardware products, the purpose of processing, location of those Sub-Processors, if they’ve signed SMART’s Data Processing Addendum (DPA), and if a privacy shield exists.

Software Sub-Processors

Purpose

Location

DPA Signed

Privacy Shield

Fabric.io

Compiles crash data (reports can be turned off within product)

USA

Yes

No

Mixpanel, Inc.

Anonymous usage analytics

USA

Yes

Yes

Marketing Data

This includes personal and non-personal data that SMART collects for its marketing purposes. The following marketing data is collected:

  • Opt-in and Opt-out information, including:
    • Date
    • Language
    • Individual’s Name
    • E-mail
    • Organization or school name
    • IP address
    • Information to be sent or opted-out of
    • Contact history
    • Area of Interest
    • Potential sale opportunity
    • Budget
    • Tradeshows attended or will attend
    • Conversion (whether the lead becomes a customer)
    • Public web content is anonymized, and aggregate information is relayed through Google Analytics
    • Raffle or other contest entries.

Sub-Processors of User Data for SMART Marketing Data

The following table provides a list of Sub-Processors for SMART’s Marketing, the purpose of processing, location of those Sub-Processors, if they’ve signed SMART’s Data Processing Addendum (DPA), and if a privacy shield exists.

Sub-Processors

Purpose

Location

DPA

Privacy Shield

SMART Authorized Distributors and Resellers

To market SMART products

Global

No, these organizations operate under agreements with SMART that contain

standard commercial contractual clauses that adequately protect the data with confidentiality clauses and representations

Not applicable

Hubspot, Inc.

To compile marketing data; and send communications

USA

Yes

Yes

Salesforce.com, Inc.

To compile marketing data; and send communications

USA

Yes

Yes

SiteCore USA, Inc.

Session cookies, website analytics and navigation.  Optional opt-in to allow customized landing pages

USA

Yes

No

Qualtrics LLC

Surveys and event management

USA

Yes

Yes

NOTE: If you have opted-in to receive information from SMART, SMART will also use your personal data for SMART’s purposes. You may opt-out at any time by clicking on a link in e-mails we send or by visiting http://go.smarttech.com/hs/manage-preferences/unsubscribe-test?d=eyJlYSI6ImV4YW1wbGVAZXhhbXBsZS5jb20ifQ%3D%3D&v=1 and manually entering in your e-mail address. 

Support-Related Data

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
  • Last name
  • Organization calling on behalf of
  • Address
  • Shipping Address if parts needed
  • E-mail
  • Phone number
  • Serial number of the product
  • Issue reported
  • Attachments (pictures, e-mails, etc.)
  • Existing incident number (if any)
  • Preferred reseller
  • Comments about service received

Sub-Processors of User Data for SMART Support-Related Data

The following table provides a list of Sub-Processors for SMART Support, the purpose of processing, location of those Sub-Processors, if they’ve signed SMART’s Data Processing Addendum (DPA), and if a privacy shield exists.

Sub-Processors

Purpose

Location

DPA

Privacy Shield

Blue Ocean

Handles support calls

Canada

No, this organization operates under an agreement with SMART that contains standard commercial contractual clauses that adequately protect the data with confidentiality clauses and representations

Not applicable – Canadian Company

Amazon Connect (Amazon.com)

Cloud based contact centre and hosting of support calls

USA

Yes

Yes

Salesforce.com, Inc.

Customer communications

USA

Yes

Yes

Qualtrics LLC

Customer surveys

USA

Yes

Yes