SmartPAL AI Inc. – Privacy Policy

Last updated: July 2026

SmartPAL AI Inc. ("SmartPAL", "we", "our", "us") is committed to protecting the privacy of students, instructors, and institutions who use our learning support platform. This Privacy Policy explains how we collect, use, store, and protect personal information when you use SmartPAL through our website, mobile application, or learning management system integrations (such as Canvas).

1. Overview

SmartPAL is an AI-powered learning support tool designed to enhance student engagement and provide instructors with timely insights. We collect only the minimum data required to operate our services and never sell personal information or use it for advertising.

2. Information We Collect

A. Information Provided by Institutions or Instructors

  • Course roster information (name, email, institutional identifier)
  • Course enrollment details
  • Assignment titles, due dates, descriptions
  • Course structure and teacher-defined settings

B. Information from Learning Management Systems (e.g., Canvas)

  • Assignment submissions and completion status
  • Grades and score visibility (subject to instructor settings)
  • Course activity logs (e.g., page views, last login)
  • Deadline adherence, late submissions, and activity patterns

C. Information Students Provide in SmartPAL

  • Reflections, goals, and check-ins
  • Messages sent to the AI assistant
  • Task planning or habit-building entries
  • Support requests

D. Automatically Collected Technical Information

  • Device type and browser
  • Log data and usage patterns
  • Approximate location based on IP (city-level only)

SmartPAL does NOT collect: home address, phone number, photos, camera data, microphone data, GPS location, biometric data, or sensitive personal information unless explicitly provided by the user.

3. How We Use Information

SmartPAL uses collected information for the following purposes:

  • To deliver personalized learning support, reminders, and nudges
  • To generate weekly summaries and insights for instructors
  • To operate and improve SmartPAL’s AI models and services
  • To support self-regulated learning habits (reflection, planning, goal tracking)
  • To maintain service reliability, security, and performance
  • To provide customer support

All processing aligns with institutional policies and applicable privacy laws (including FERPA when used in an educational context).

4. AI and Data Usage

  • AI-generated explanations and summaries are intended as learning support, not as a replacement for completing assignments.
  • Identifiable student content is never used to train general-purpose third-party AI models.
  • SmartPAL may use anonymized or aggregated data to improve product performance and conduct internal analytics.

5. Features Designed for Privacy

A. Initials-Only Leaderboard

If a leaderboard or engagement ranking feature is enabled, SmartPAL displays student initials only (e.g., “A.P.”). Full names, photos, and identifying details are never shown to other students.

B. Private Reflections

SmartPAL includes a Private Reflection mode. Entries created in this mode are visible only to the student and are not shared with instructors, administrators, or institutions.

C. Minimal Visibility to Peers

SmartPAL does not allow students to view other students’ messages, reflections, or coursework.

6. Who Can Access Your Information

Depending on institutional configuration, access may be granted to:

  • The student (their own data only)
  • The instructor(s) of the course
  • Authorized institutional administrators
  • SmartPAL technical staff with restricted, audited access

We do not share personal information with advertisers, data brokers, or unrelated third parties.

7. Data Retention & Deletion

  • Identifiable course and student data is retained only as long as necessary to provide SmartPAL’s services.
  • Institutions or users may request deletion of identifiable data at any time by contacting us at contact@smartpal.org.
  • De-identified data may be retained for product improvement and analytics.

8. Security Practices

SmartPAL uses industry-standard security protocols, including:

  • AWS-hosted infrastructure
  • Encryption in transit (TLS) and at rest
  • Strict role-based access controls
  • Regular security reviews and monitoring

9. Children's Privacy

SmartPAL may be used in K–12 settings. For users under 13, SmartPAL complies with COPPA through institutional authorization. We do not knowingly collect personal information directly from children without institutional or parental consent as required.

10. Institutional Use & FERPA

When SmartPAL is used by educational institutions, the institution controls which data is shared and acts as the primary steward of student records under FERPA. SmartPAL acts as a “school official” with legitimate educational interest, using data solely to provide educational services on behalf of the institution.

11. Third-Party Services (Subprocessors)

SmartPAL uses trusted third-party service providers (“subprocessors”) to host our platform, deliver AI features, and maintain reliability and security. These providers process data only on our instructions, under contractual obligations, and may not use it for their own marketing or unrelated purposes.

Our primary subprocessors include:

  • Amazon Web Services (AWS) — cloud hosting and infrastructure (authentication, databases, file storage, email delivery, and operational monitoring within SmartPAL-managed accounts). AWS Privacy
  • Vercel — hosting and content delivery for our web application. Vercel Privacy
  • Microsoft Azure (Azure OpenAI) — AI inference and embeddings for the learning assistant (responses and course-content retrieval). Identifiable student content is not used to train general-purpose foundation models under our enterprise configuration. Microsoft Privacy
  • Pinecone — vector search over course materials to support retrieval-augmented answers in the chatbot. Pinecone Privacy
  • Sentry (Functional Software, Inc.) — error monitoring and alerting for application reliability. Configured for U.S. data storage with PII scrubbing; session replay is disabled. Events are limited to technical diagnostic data (e.g., stack traces, environment, and release tags). Sentry Privacy

We may update this list as our service evolves. Material changes will be reflected in this Privacy Policy. Institutions with contractual notice requirements may contact us at contact@smartpal.org for subprocessor disclosures.

12. Your Rights

Depending on your location and institutional policies, you may have rights to:

  • Access your information
  • Request correction or deletion
  • Request a copy of your data
  • Limit certain types of processing

Requests may be submitted to contact@smartpal.org.

13. Contact Us

For privacy questions, data requests, or concerns:

SmartPAL AI Inc.
Email: contact@smartpal.org