This Privacy Policy describes how Seed & Sew, LLC (“Seed & Sew,” “we,” “our,” or “us”) collects, obtains, uses, discloses, and safeguards personal information in connection with our website at https://www.seedandsew.org/ and the Seed & Sew mobile and web application (the “App” and, together with the website, the “Services”), including the Schools Excelling in Emotional Development (S.E.E.D.) Certification® program and related tools and resources. The Privacy Policy applies to both our website and our App. We will not collect, obtain, use, or disclose personal information except as described in this Privacy Policy, unless you consent or as permitted or required by law.
We encourage you to read this Privacy Policy carefully. By accessing or using the Services, you agree to the practices described here. If you do not agree with this Privacy Policy, please do not access or use the Services.
We may change this Privacy Policy periodically (see “Changes to This Privacy Policy,” below). If you continue to use the Services after we post changes, you agree to the updated Privacy Policy, so please check it periodically.
Seed & Sew is located in the United States, and the Services are intended for users in the United States. Any personal information you provide is transmitted, processed, and stored in the United States.
1. Personal Information We Collect or Obtain
We collect or obtain several categories of personal information, depending on who you are and how you use the Services:
1.1 Information You Provide Directly
- name, email address, and telephone number;
- date of birth;
- account login credentials (username and password);
- Regulation Questionnaire profiles (our “Regulation Questionnaire” is a proprietary tool designed to identify an individual’s nervous system profile and to recommend sensory, emotional, and behavioral supports and tools for that person);
- payment and billing information, such as payment card and billing address;
- content you create, upload, or submit within the Services, including notes, reflections, and other materials;
- communications you send us, including support requests, feedback, and interactions with our artificial intelligence (AI)-powered chatbot.
The above may include information directly provided by minors between the ages of 13-17 (“Minor Data”). Certain restrictions apply to our use and sharing of Minor Data.
1.2 Automatically-Collected Information
- device and browser information, including device type, operating system, browser type, IP address, and unique device identifiers;
- usage and analytics data, including pages visited, features used, time spent, and navigation patterns; and
- as described below under “Cookies and Other Tracking.”
1.3 Student Data
Information directly related to an identified or identifiable student (“Student Data”) may be collected through a school, district, or other educational institution using the Services for educational purposes (a “School Partner”), or from a parent or legal guardian, including:
- student name and school-assigned identifiers;
- grade level, classroom, or program information;
- Regulation Questionnaire profiles completed on behalf of a student;
- behavioral incident records (this may include a description or category of the observed behavior or dysregulation event; the date, time, and setting; the supports or interventions used; and any outcomes or follow-up notes); and
- educator observations, notes, and assessments related to social-emotional learning and regulation.
Student Data does not include information about educators, administrators, parents, or individual adult users acting in their own capacity.
2. Why We Collect, and How We Use, Personal Information
We collect and use the personal information described above for a variety of purposes, depending on the specific user of the Services.
2.1 All Account Holders and Website Visitors
- to provide access to subscriptions, courses, and content purchased;
- to create and manage your account and provide, operate, and improve the Services;
- to communicate with you about our Services (this may include responding to your questions, requests, and support inquiries or sending service-related communications, such as account notices, updates, and policy changes);
- to process payments and send transaction confirmations;
- to monitor usage and analyze trends in order to improve our offerings;
- to improve our products and services;
- to keep internal records;
- to generate and store the individual’s personal Regulation Questionnaire profile;
- to personalize the experience based on usage history and preferences;
- to send marketing communications about our new offerings, research, and events as well as about affiliates that we recommend (you may opt out at any time);
- for the purposes described below under “Disclosure of Personal Information”;
- for the purposes described below under “Cookies and Other Tracking”;
- to detect, prevent, and investigate fraud, abuse, and security incidents;
- to comply with applicable law and enforce our Terms of Service; and
- for any other purpose with your consent.
We also provide some AI-enabled features such as a chatbot to use the Services. Our AI-enabled features are trained by us. These features are within closed systems and do not use or share information from the open Internet. If you are School Partner user, you will only be able to access information within a classroom or specific student’s profile. Family users and individual subscribers can access information for their families. To provide further privacy assurances, our service agreements with the providers of artificial intelligence models used to power our AI-enabled Features do not permit the providers to use input data to train their models.
Please note that certain limitations apply to subsets of the personal data we collect, as described in the “Students and Minors” subsection below.
2.2 Educators and Administrators
- to deliver the Schools Excelling in Emotional Development (S.E.E.D.) Certification® program and related professional-development tools;
- to generate and store Regulation Questionnaire profiles for themselves and for students in their care;
- to log and track behavioral incidents for individual students;
- to track educator progress and participation within a School Partner’s program; and
- to generate reports and data summaries for authorized administrators and to facilitate communication among authorized school users.
2.3 Students and Minors
We use Student Data and Minor Data, including Regulation Questionnaire profiles and behavioral incident records, only to provide the Services to a School Partner and/or for the purpose for which the data was disclosed to us. You can learn more about our use and restrictions on use for Student Data in the “Student Data & Minor Data” section below.
2.4 Parents and Legal Guardians
- to provide access to their child’s Regulation Questionnaire profile and behavioral records, as authorized by a School Partner;
- to allow a parent to complete or contribute to a Regulation Questionnaire on behalf of their child; and
- to send communications relevant to the child and to allow the parent to manage account preferences and data rights.
3. Student Data & Minor Data
Student Data that we hold on behalf of a School Partner, including Regulation Questionnaire profiles and behavioral incident records tied to a named student, may constitute “education records” and “personally identifiable information” under the Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. § 1232g and 34 C.F.R. Part 99. FERPA treats records that are directly related to a student and maintained by a party acting for the school as education records, and we handle them accordingly, working with School Partners to protect Student Data consistent with FERPA. Our collection and use of Student Data for School Partners is governed by our contracts with the School Partners, by our Privacy Policy, and by applicable privacy laws. If your school or district requires an agreement, contact us as shown in the “Contact Us” section below.
We do not (a) use Student Data or Minor Data to build profiles of students or minors for any commercial purpose; (b) sell, rent, or lease Student Data or Minor Data; (c) use Student Data or Minor Data to target advertising to children or their families; or (d) use behavioral records or regulation profiles to make automated decisions that affect a student’s or minor’s educational standing or opportunities.
3.1 School Official Role and Direct Control
When we provide the Services to a School Partner, we act as a “school official” with a legitimate educational interest under FERPA (34 C.F.R. § 99.31(a)(1)). In that role, we perform a function the School Partner would otherwise use its own employees to perform, remaining under the direct control of the School Partner with respect to the use and maintenance of education records. We use Student Data only for the authorized educational purpose for which it was disclosed; we do not redisclose Student Data to any other party without the prior consent of the parent or eligible student, except as FERPA permits; and we use reasonable physical and technological access controls to limit access to education records to those with a legitimate educational interest.
3.2 No Forced Waiver of FERPA Rights
We do not condition the Services on any parent or student waiving rights under FERPA, and our terms do not claim any right to use, reproduce, distribute, or promote Student Data beyond providing the Services to the School Partner. Student Data is owned and controlled by the School Partner, not by Seed & Sew.
3.3 Parental and Eligible-Student Rights
For students in schools that use the Services, parents and legal guardians (and “eligible students” once a student turns 18 or enrolls in a postsecondary institution) have the right under FERPA to inspect and review the student’s education records, to request correction or amendment of records that are inaccurate or misleading, and to consent to or withhold consent from disclosure of records except where FERPA authorizes disclosure without consent. Because Student Data is controlled by the School Partner, requests regarding Student Data should be directed first to the school or district. We will work with the School Partner to fulfill requests within the timeframes required by law. Parents with their own accounts may also contact us directly as shown in the “Contact Us” section below.
3.4 De-Identified Data
We may create and use de-identified or aggregated information that cannot reasonably be used to identify a particular student to operate, evaluate, and improve the Services and educational products, consistent with FERPA and applicable state law. We do not attempt to re-identify de-identified information.
3.5 State Student Data Privacy Laws
Many states regulate providers of educational technology that handle student information. Where these laws apply to us as an operator or service provider, and consistent with our School Partner agreements, we:
- do not sell student covered information;
- do not use student covered information to engage in targeted advertising or to amass a profile about a student except in furtherance of school purposes;
- do not disclose student covered information except in furtherance of the school purpose, to comply with law or legal process, to protect safety, or to work with a service provider under a contract that bars other uses and redisclosure and requires reasonable security;
- implement and maintain reasonable security procedures appropriate to the nature of the information (see the “Data Security” section below); and
- delete student covered information at the direction of the School Partner and honor authorized deletion requests, subject to any mandatory-records or legal-retention exceptions.
Seed & Sew is based in Vermont and partners with Vermont schools. We are committed to compliance with Vermont’s student-privacy law (9 V.S.A. § 2443 et seq.), which applies to operators serving PreK-12, and with Vermont’s security-breach-notification law (9 V.S.A. § 2435). We also observe applicable minor- and student-focused requirements in other states in which our users are located, such as California’s K-12 Pupil Online Personal Information Protection Act (KOPIPA) (Cal. Bus. & Prof. Code § 22584) and New York’s Child Data Protection Act (N.Y. Gen. Bus. Law § 899-ff). In compliance with New York Education Law § 2-d, we limit internal access to those with legitimate educational interests; prohibit use of data for any purpose other than those explicitly authorized in the contract with the New York-based School Partner; maintain reasonable administrative, technical, and physical safeguards; use encryption for data in motion and at rest; and provide prompt breach notification to the educational agency when legally required. We may use or share de-identified or aggregated student information to develop, improve, and demonstrate the effectiveness of educational products where permitted by these laws.
4. Cookies and Other Tracking
When you use the Services, we collect information from you by automatic means, including cookies, pixel tags, or similar files. These are small text or electronic files (some of which may be placed on your device) that allow us to recognize and remember things about users of the Services, such as preferences; to perform analytics, such as counting the number of users; to determine how you got to the Services and track your activity here; to gather technical information about your devices, browsers, operating systems, IP addresses, etc.; to assess and enhance the App’s performance; to help protect the App against certain attacks; and to assist with marketing. We also use cookies to connect users to websites and apps. The cookies used on the Services may identify other devices you use to access the Services, which helps us to ensure that the Services function correctly on any device you may be using. Cookies do not give us access to your computer or device.
Specifically, the Services use the following: google analytics and meta pixel.
You can also manage or disable cookies through your browser settings and, where offered, through our cookie-consent tools. If you reject cookies, some features of the Services may not function properly. Please note that our Services do not currently respond to “Do Not Track” signals or similar browser requests.
5. Disclosure of Personal Information
In the course of providing our Services, we may disclose personal information to the following outside parties:
- Service Providers. We work with trusted service providers who assist us in operating the Services. These include payment processors (Stripe), email and communications platforms (SendGrid and Mailerlite), analytics providers (Google Analytics), cloud hosting and infrastructure providers, customer-support tools, and other vendors, consultants and service providers working on our behalf. Our service providers are contractually required to use information only to provide services to us, to keep it confidential and secure, and not to redisclose it. Any service provider that receives Student Data is bound by a written agreement addressing use limits, no redisclosure, and reasonable security.
- School Partners. When you access the Services through a School Partner, we may share usage, progress, Regulation Questionnaire data, and behavioral records with authorized administrators at that school or district, as directed by the School Partner. The School Partner controls what data it authorizes us to share within its program.
- Parents or Legal Guardians. Parents or legal guardians with an account may be granted access to their child’s Regulation Questionnaire profile and behavioral incident records and other Student Data as authorized by the School Partner.
- Legal Requirements and Safety. We may disclose personal information in order to comply with applicable law or valid legal process, including a subpoena, court order, or government request; to protect the safety, rights, or property of Seed & Sew, our users, students, or the public; to detect, prevent, and investigate fraud, abuse, security incidents, or any other illegal activity; to defend our legal interests where necessary for our legitimate interests or the legitimate interests of others; or to otherwise protect our rights.
- Business Transfers. If Seed & Sew is involved in a merger, acquisition, or sale of assets, personal information may be transferred as part of that transaction. We will not transfer Student Data as part of a business transfer except to a successor that agrees in writing to be bound by the commitments in this Privacy Policy and applicable student-data-privacy laws.
- Other Third Parties (with your consent). In some instances, you may be able to grant us permission to disclose your information to authorized partners and other entities that are not affiliated with us. In these cases, we will only provide to these third parties the information you have authorized or asked us to disclose, for the specific purpose you authorize.
We may also disclose de-identified or aggregated information that does not reasonably identify any individual.
We do not share information generated through our Regulation Questionnaire or any behavioral records with third parties for commercial, advertising, or research purposes without express consent.
We do not sell (as defined in applicable privacy laws) your personal information for monetary or other consideration under any circumstances, nor do we use or share your personal information for targeted or cross-context behavioral advertising (as defined under applicable privacy laws) based upon your activities over time and across nonaffiliated websites or online services/applications, or for profiling in furtherance of decisions that produce legal or similarly significant effects on you (as defined under applicable privacy laws).
6. Retention and Deletion of Personal Information
We retain personal information only for as long as reasonably necessary to provide the Services and fulfill the purposes described in this Privacy Policy, to provide customer service, or to satisfy our legal obligations. When information is no longer needed, we delete, de-identify, or anonymize it in a manner designed to prevent reconstruction of the original data. Our systems support hard deletion (not merely soft deletion), student-record export, and automated retention expiration.
6.1 Retention by Data Type
In determining how long we retain data, we consider how keeping the information will assist the user, meet our legal requirements, and serve other business needs. Our retention periods will vary depending on the type of data involved. For example, individual user account data and parent account data is retained for the duration of the active subscription plus 7 days after account closure or last activity, then it is deleted or anonymized. Student Data is retained only for the period necessary to provide the Services to the School Partner, and is deleted or returned within 30 days of a written request from the School Partner or upon program termination.
When we have no ongoing legitimate business need to process personal information, our policy is to delete or de-identify the data. We may retain and use de-identified or anonymized data for longer periods for purposes such as product development, research, analytics and for demonstrating the impact of our Services.
6.2 Requesting Deletion and Account Deletion
You, or your School Partner on your behalf, may request deletion of your personal information at any time by contacting us as shown in the “Contact Us” section below or by using the account-deletion page at https://www.seedandsew.org/delete-account. When you submit an account-deletion request, your account and associated data will be scheduled for permanent deletion within 7 days, except where retention is required by law (for example, financial, tax, fraud-prevention, or regulatory obligations) or for the resolution of active legal matters. We will acknowledge your request within 5 business days, complete deletion or provide a status update within 30 days, and confirm in writing when deletion is complete.
For deletion of Student Data, requests should be directed first to the School Partner, who will coordinate with us; parents may also submit requests directly to us using the contact information in the “Contact Us” section below, and we will work with the school to fulfill them.
7. Your Rights Concerning Personal Information
7.1 All Website Visitors and Account Holders
To learn what personal information we have about you, and to update, correct, or delete that information, please contact us as indicated in the “Contact Us” section below. Please note that under certain circumstances we may not be able to honor requests to delete certain information. You may also opt out of marketing emails at any time by using the “unsubscribe” link or contacting us.
Regardless of where you reside, we will consider all requests you make regarding your information and will respond within any time period required by applicable law. Please note, however, that certain information may be exempt from such requests, such as if we need to keep the information to comply with our own legal obligations or to establish, exercise, or defend legal claims. Your rights and our response obligations also may vary based on your state or country of residency. Please note that you may be located in a jurisdiction where we are not obligated, or are unable, to fulfill a request. In such a case, your request may not be fulfilled.
We also reserve the right to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name, email address, phone number, or other information unique to you (e.g., a password).
If you would like further information on requests concerning your information, please contact us as indicated in the “Contact Us” section below.
7.2 Parents and Legal Guardians
Parents and legal guardians with an account may request access to, correction of, or deletion of their child’s Regulation Questionnaire profile and behavioral incident records. Because Student Data is controlled by the School Partner under FERPA, some requests may require School Partner authorization, and we will work with the school to fulfill them.
7.3 State-Specific Rights
Depending on your state of residence and current privacy laws in your state, you may have additional rights.
California Residents. If you are a California resident, you have the following rights, unless certain exceptions apply:
- To be notified, at the time of or before collection, of (1) the categories of personal information we collect, (2) the purposes for which we collect or use the information, (3) whether we sell the information or share it for cross-context behavioral advertising; and (4) how long we retain the information
- To request that we inform you – for the period covering the past 12 months – about (1) the categories of information we have collected about you; (2) the categories of sources of that information; (3) to the extent applicable, the business or commercial purpose for collecting, selling, or sharing that information; (4) the categories of third parties to whom we disclose that information; and (5) in a readily useable format, the specific pieces of information we have collected about you
- To request that we inform you – for the period covering the past 12 months – about (1) to the extent applicable, the categories of information about you that we have sold, shared with third parties for cross-context behavioral advertising, or disclosed for a business purpose; and (2) to the extent applicable, the categories of third parties to whom we have sold, shared, or disclosed information about you
- To request that we delete certain information we have about you
- To request that we correct any inaccurate information we have about you
- To request that we provide you with information about financial incentives that we offer to you, if any, for the collection, use, or sharing of your information
- To opt out of the sale of information about you, to the extent applicable
- To opt out of the sharing of information about you with third parties for cross-context behavioral advertising, to the extent applicable
- To limit the use or disclosure of any sensitive personal information we have collected about you, to the extent applicable
- To not be discriminated or retaliated against, or have adverse action taken against you, for making requests about your information or exercising other rights concerning your information
See Section 8 below for an additional California notice.
Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia Residents. If you are a resident of any of these states, you have the following rights, unless certain exceptions apply:
- To confirm whether we process (e.g., collect, use, store, etc.) your personal information
- To access your personal information
- To delete certain personal information
- To correct inaccuracies in your personal information, taking into account the nature of the information and our purpose for processing it
- To obtain a copy of your personal information in a portable and, to the extent technically feasible, readily-usable format, under certain circumstances
- To opt out of any processing of your personal information by us for targeted advertising purposes, to the extent applicable
- To opt out of any sale of your personal information by us, to the extent applicable
- To opt out of any processing of your personal information by us for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects on you, to the extent applicable
- To not be discriminated or retaliated against, or have adverse action taken against you, for making requests about your information or exercising other rights concerning your information
Additionally, if you are a Delaware, Maryland, or Minnesota resident, you may also obtain a list of categories of third parties to which we have disclosed your personal information. If you are an Oregon resident, you may also obtain a list of the categories of your personal information we have processed and specific third parties to which we have disclosed personal information.
Nevada Residents. If you are a Nevada resident, you have the right to request that we not sell your “covered information” (as defined under Nevada law) to any person, by contacting us at the designated email address provided in the “Contact Us” section below. Any such request made to us must be verifiable before we have any obligation to fulfill it.
7.4 Exercising Your Rights
To exercise any of your applicable data rights, or to withdraw any consent you have provided, please contact us via any of the means provided in the “Contact Us” section below. Any request must include sufficient detail so that we can understand, evaluate, and respond to the request.
Any data rights requests made to us must be verifiable before we have any obligation to fulfill them. A request must provide details sufficient to enable us to reasonably verify that you are the person about whom the requested information pertains. This verification process may include, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name, email address, phone number, or other information unique to you (e.g., a password).
Depending on where you reside, applicable law in your state may also allow you to designate an authorized agent to submit data rights requests on your behalf. In order for an authorized agent to be verified, the agent must provide us with signed written permission from you or a power of attorney. We may also follow up with you to verify your identity and permission before processing the authorized agent’s request.
Finally, under applicable law in your state of residence, you may also be entitled to appeal any decision we make with respect to your data rights request. To make an appeal, please contact us – within 30 days of our decision – via any of the means provided in the “Contact Us” section below.
8. Additional Notice for California Residents
This section provides additional disclosures under the California Consumer Privacy Act, as amended (“CCPA”). In the past twelve months, we have collected the categories of personal information described in Sections 1, 3, and 4 above, and have disclosed those categories to the categories of third parties described in Section 5 above, for the business purposes described in this Privacy Policy. We do not sell, and have not sold, personal information, and we do not share personal information for cross-context behavioral advertising as defined in the CCPA. We collect and use sensitive personal information (including some Regulation Questionnaire profile data) only as necessary to provide the Services and for other purposes permitted. With respect to California’s “Shine the Light” law, we do not provide your personal information to third parties for their direct marketing purposes within the meaning of that law.
9. Notice Regarding Children’s Privacy
Our Services are not targeted to children as visitors of our website or users of our app, and we do not knowingly or intentionally request, collect, use, or disclose personal information from children under 13 years of age. If we discover or are notified that this has occurred, we will immediately delete the information from our servers and instruct any third parties to whom we have disclosed the information to do so as well.
10. Protection of Your Information
We maintain reasonable and appropriate technical, administrative, and physical safeguards designed to protect personal information from accidental or unauthorized access, use, disclosure, alteration, destruction, or loss. These measures include:
- encryption of data in transit (using industry-standard TLS) and at rest, including encrypted backups, snapshots, and logs;
- secure storage of questionnaire results in private cloud storage and one-way hashing of passwords;
- role-based access controls, least-privilege access, and school-level tenant isolation, so that an educator cannot access information on students outside an assigned roster;
- multi-factor authentication for all users, short-lived session tokens, token rotation, device and session revocation, and automatic logout after inactivity;
- hosting on established cloud infrastructure (Amazon Web Services) with network segmentation and monitoring; and
- periodic review of our security practices and vendor agreements, including periodic security testing.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time in order to reflect changes to our practices or for other operational, legal, or regulatory reasons. Whenever we make any changes to this Privacy Policy, we will update the “Effective Date / Last Updated” date above. For any material change to this Privacy Policy, we will send an email to addresses we have on file. We encourage you to check our Privacy Policy often to always be up-to-date on the current version and to review any updates we have made.
12. Contact Us
If you have questions, comments, or concerns about this Privacy Policy or our privacy practices, or if you would like to exercise a data right, you can reach us here:
Name: Seed & Sew
Mailing Address: 10 State Road #221 Bath, ME 04530
Phone: (802) 448-5116
Email: support@seedandsew.org
For urgent matters involving Student Data, regulation profiles, behavioral records, or a potential data breach, please include “URGENT – Student Privacy” or “URGENT – Data Breach” in the subject line of your email.