Last Updated: October 4, 2021
Effective Date: May 25, 2026
This Privacy Policy explains how interactiveX, Inc. d/b/a Classavo ("Classavo," "we," "us") collects, uses, shares, and protects information when you use our Services. Capitalized terms not defined here have the meanings given in our Terms of Service.
If your Institution has a separate written agreement with Classavo (for example, a Master Subscription Agreement or Data Processing Addendum), that agreement governs how Classavo handles Institution and Student data and controls to the extent it conflicts with this Policy.
If you don't agree with this Policy, don't use the Services.
These definitions apply across all Classavo agreements (Terms of Service, MSA, DPA) unless that agreement says otherwise.
Where Classavo receives Personal Information from an Institution about a Student (such as roster data), we treat that information consistent with our obligations to the Institution under FERPA and the relevant DPA, even if the Student has not separately interacted with Classavo.
If your Instructor enables location-based attendance, our mobile app may request approximate location at the moment of attendance check-in, and only if you grant permission. We do not track location outside attendance check-ins. Location data is deleted or anonymized after attendance is verified. If you decline location permission, your Instructor must provide an alternative method of attendance verification.
Classavo does not ask for, require, or solicit biometric identifiers, Social Security numbers, government identification numbers, precise continuous geolocation, or information about reproductive or sexual health, immigration status, sexual orientation, or gender identity. We do not design fields, forms, or AI prompts to elicit this information.
If you voluntarily include sensitive information in free-text fields (such as discussion posts, comments, support messages, or AI prompts), we recommend you not do so. We treat any sensitive information received this way with the same care as other Personal Information. Deletion requests follow the process and exceptions described in Section 10.
For California residents, the categories of Personal Information we collect are: identifiers; education information; commercial information (purchase history); internet and device information; geolocation (only as described in Section 2.4); and inferences derived from the above. We collect this information for the business purposes described in Section 3.
We use the information we collect to:
Our AI Features process User Content to generate hints, explanations, summaries, questions, feedback, recommendations, and similar output.
Generated Output may be inaccurate. See the Terms of Service for AI Features usage terms and limits.
We do not sell Personal Information and we do not share Personal Information for cross-context behavioral advertising as those terms are defined under California law. As used in this Policy, "sell" and "share" have the meanings given under California law.
We share Personal Information only as follows:
When Classavo provides Services to a U.S. educational Institution, Classavo acts as a "School Official" with "legitimate educational interest" under FERPA. We treat student education records as confidential, use them only for the educational purposes for which they were provided and as authorized by the Institution, and do not redisclose them except as permitted by FERPA or directed by the Institution.
For FERPA-related access, correction, or deletion requests, Students should contact their Institution, which is the entity responsible for education records under FERPA.
If this Policy conflicts with FERPA or another education-privacy law, the more protective rule applies.
The Services are not directed to children under 13 unless their use is authorized through a school under COPPA. We do not knowingly collect Personal Information directly from children under 13 outside of that context. If we learn we have collected such information improperly, we will delete it. Parents and guardians can contact privacy@classavo.com with concerns.
We retain Personal Information only as long as needed to provide the Services, to comply with legal obligations, to resolve disputes, and to enforce our agreements.
Typical retention periods include:
Institutions can request earlier deletion in writing, subject to legal-hold obligations. Instructors and Institutions are responsible for exporting required records (grades, gradebooks, audit data) before the retention period ends. Export tools are documented in our help center.
We use cookies and similar technologies for the following purposes:
You can manage cookies through your browser settings or through cookie controls on our website. Disabling some cookies may affect functionality.
We honor the Global Privacy Control (GPC) signal as a request to opt out of any "sale" or "sharing" of Personal Information as those terms are defined under applicable law. We do not currently respond to "Do Not Track" browser signals because no uniform standard exists.
Depending on where you live, you may have some or all of the following rights regarding your Personal Information:
Classavo does not currently engage in profiling using sensitive Personal Information or in solely automated decision-making that produces legal or similarly significant effects on Users.
State coverage. Residents of California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia have specific rights under their state privacy laws. We honor those rights as required by the law of your state.
How to exercise these rights. Email privacy@classavo.com or use the request form at classavo.com/privacy-rights. We will acknowledge receipt within 10 business days and respond substantively within 45 days. If we need additional time, we will notify you within the original 45-day period and may extend by an additional 45 days where permitted by law. We may verify your identity before responding.
Authorized agents. You may use an authorized agent to submit a rights request on your behalf. We may require you to directly verify your identity with us, or to provide written authorization confirming the agent is acting on your behalf, before we respond.
Appeal of denied requests. If we deny a rights request, we will tell you why. You may appeal by replying to our denial email or by writing to privacy@classavo.com with "Privacy Appeal" in the subject line. We will respond to your appeal within 45 days. If your appeal is denied and you remain dissatisfied, you may contact the Attorney General of your state.
For Students whose data is held under FERPA. Contact your Institution. FERPA gives access and correction rights through the Institution, not directly through Classavo.
We use reasonable administrative, technical, and physical safeguards designed to protect Personal Information. No security program can guarantee absolute security, and we cannot guarantee the security of communications transmitted to or from the Services.
You are responsible for keeping your login credentials confidential. See Section 2 of the Terms of Service.
If a security incident affects your Personal Information, we will notify affected Institutions without undue delay after confirmation of the incident, and in any event consistent with applicable law. We will notify Users directly when required by law or institutional agreement.
For institutional security commitments, see the relevant Data Processing Addendum or Master Subscription Agreement.
The Services are operated from and primarily hosted in the United States. If you access the Services from outside the United States, your information may be transferred to and processed in the U.S. and other countries where our Service Providers operate. By using the Services, you consent to these transfers.
For Personal Information transferred from the European Economic Area, United Kingdom, or Switzerland to the United States, we rely on Standard Contractual Clauses approved by the European Commission.
The Services may link to or integrate with third-party services (LMS platforms, payment processors, AI providers, content providers). Classavo is not responsible for the privacy or security practices of these third parties. We encourage you to review their privacy policies before interacting with them.
We may update this Policy from time to time. We will post the updated Policy with a new Effective Date. Material changes will be communicated by reasonable means (in-app notice, email, or both). Your continued use of the Services after the update means you accept the changes.
interactiveX, Inc. d/b.a. Classavo
701 Ellicott Street
Buffalo, NY 14203
Email: privacy@classavo.com
