Updated Feb 20, 2024
This policy applies to all products built and maintained by X9 Studios Inc, doing business as Almanack (referred to as "Almanack" in this document).
This policy applies to our handling of information about site visitors, prospective customers, and customers and authorized users (in relation to their procurement of the services and management of their relationship with Almanack). We refer collectively to these categories of individuals as "you" throughout this policy.
Our website and other offerings collectively known as our "Services" offer educators and school personnel the ability to use artificial intelligence (AI) technology for educational purposes.
What we collect and why
Our guiding principle is to collect only what we need. Here’s what that means in practice:
Identity & access
When you sign up for an account, we ask for limited identifying information such as your name and email address. That’s so you can personalize your new account, and we can send you product updates and other essential information. We may also send you optional surveys from time to time to help us understand how you use our products and to make improvements. With your consent, we will send you our newsletter and other updates. We sometimes also give you the option to add a profile picture that displays in your profile.
We’ll never sell your personal information to third parties, and we won’t use your name or institution's name in marketing statements without your permission either.
If you sign up for a paid subscription, you will be asked to provide your payment information and billing address. Credit card information is submitted directly to our payment processor and doesn’t pass through Almanack's servers. We store a record of the payment transaction, including the last 4 digits of the credit card number, for purposes of account history, invoicing, and billing support. Our credit card processor stores your billing address so we can charge you for service, calculate any sales tax due, send you invoices, and detect fraudulent credit card transactions.
We store on our servers the content that you upload or receive or maintain in your Almanack account. This is so you can use our products as intended. We keep this content as long as your account is active. If you delete your account, we’ll delete the content within 30 days.
We collect information about your Almanack usage for analytics and statistical purposes such as conversion rate testing and experimenting with new product designs. This includes, for example, your browser and operating system versions, your IP address, which sections of our website you visited and how long they took to load, and which website referred you to us. If you have an account and are signed in, these web analytics data are tied to your IP address and user account until your account is no longer active. The web analytics we use are described further in the Advertising and Cookies section.
We use CAPTCHA across our applications to mitigate brute force logins and as a means of spam protection. We have a legitimate interest in protecting our apps and the broader Internet community from credential stuffing attacks and spam. When you log into your Almanack accounts and when you fill in certain forms, the CAPTCHA service evaluates various information (e.g., IP address, how long the visitor has been on the app, mouse movements) to try to detect if the activity is from an automated program instead of a human. The CAPTCHA service then provides Almanack with the spam score results; we do not have access to the evaluated information.
Advertising and Cookies
Almanack runs contextual ads on various third-party platforms. Users who click on one of our ads will be sent to the Almanack marketing site. Where permissible under law, we may load an ad-company script on their browsers that sets a third-party cookie and sends information to the ad network to enable evaluation of the effectiveness of our ads, e.g., which ad they clicked and which keyword triggered the ad, and whether they performed certain actions such as clicking a button or submitting a form.
We also use persistent first-party cookies and some third-party cookies to store certain preferences, make it easier for you to use our applications, and perform A/B testing as well as support some analytics.
A cookie is a piece of text stored by your browser. It may help remember login information and site preferences. It might also collect information such as your browser type, operating system, web pages visited, duration of visit, content viewed, and other click-stream data. You can adjust cookie retention settings and accept or block individual cookies in your browser settings, although our apps won’t work and other aspects of our service may not function properly if you turn cookies off.
When you email Almanack with a question or to ask for help, we keep that correspondence, including your email address, so that we have a history of past correspondence to reference if you reach out in the future.
We also store information you may volunteer, for example, written responses to surveys. If you agree to a customer interview, we may ask for your permission to record the conversation for future reference or use. We will only do so with your express consent.
When we access or disclose your information
To provide products or services you’ve requested, we use some third-party subprocessors to help run our applications and provide the Services to you. You can view the third-party subprocessors we use for each of our products at the end of this document.
We may disclose your information at your direction if you integrate a third-party service into your use of our products. For example, we may allow you, at your option, to connect your Google account to your Almanack account so we can publish resources to Google Classroom on your behalf.
To help you troubleshoot or squash a software bug. We ask you for the email address associated with your account. By providing us the email address, you grant us access to your account to help resolve the issue.
To investigate, prevent, or take action regarding restricted uses. Accessing a customer’s account when investigating potential abuse is a measure of last resort. We want to protect the privacy and safety of both our customers and the people reporting issues to us, and we do our best to balance those responsibilities throughout the process. If we discover you are using our products for a restricted purpose, we will take action as necessary, including notifying appropriate authorities where warranted.
Aggregated and de-identified data. We may aggregate and/or de-identify information collected through the services. We may use de-identified or aggregated data for any purpose, including marketing or analytics.
When required under applicable law, Almanack is a Canadian company and all data infrastructure is located in the U.S or Canada.
- Requests for user data. Our policy is to not respond to government requests for user data unless we are compelled by legal process or in limited circumstances in the event of an emergency request. However, if Canadian law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring us to disclose data, we must comply. Likewise, we will only respond to requests from government authorities outside Canada if compelled by the Canadian government through procedures outlined in a mutual legal assistance treaty or agreement. It is Almanack's policy to notify affected users before we disclose data unless we are legally prohibited from doing so, and except in some emergency cases.
- Preservation requests. Similarly, Almanack's policy is to comply with requests to preserve data only if compelled by the Criminal Code of Canada, specifically Section 487.012, or by a properly served subpoena for civil matters. We do not disclose preserved data unless required by law or compelled by a court order that we choose not to appeal. Furthermore, unless we receive a proper warrant, court order, or subpoena before the required preservation period expires, we will destroy any preserved copies of customer data at the end of the preservation period.
- If we are audited by a tax authority, we may be required to disclose billing-related information. If that happens, we will disclose only the minimum needed, such as billing addresses and tax exemption information.
Your rights with respect to your information
At Almanack, we strive to apply the same data rights to all customers, regardless of their location. Some of these rights include:
- Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security, and processing of that information.
- Right to Correction. You have the right to request correction of your personal information.
- Right to Erasure / "To Be Forgotten". This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, from all of our service providers. Fulfillment of some data deletion requests may prevent you from using Almanack services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.
- Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority.
- Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
- Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party. If you want to export data from your accounts, you can do so by contacting our support team.
- Right to not Be Subject to Automated Decision-Making. You have the right to object to and prevent any decision that could have a legal or similarly significant effect on you from being made solely based on automated processes. This right is limited if the decision is necessary for the performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.
- Right to Non-Discrimination. We do not and will not charge you a different amount to use our products, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights may, by virtue of your exercising those rights, prevent you from using our Services.
- Many of these rights can be exercised by signing in and updating your account information. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our services to you.
In some cases, we also need to take reasonable steps 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 and email address. If we are unable to verify you, we may be unable to respond to your requests. If you have questions about exercising these rights or need assistance, please contact us at email@example.com. If an authorized agent is corresponding on your behalf, we will need written consent with a signature from the account holder before proceeding.
Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. We will provide information about how to exercise that right in our response denying the request. You also have the right to lodge a complaint with a supervisory authority. If you are in the EU or UK, you can contact your data protection authority to file a complaint or learn more about local privacy laws.
How we secure your data
All data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted. In addition, we go to great lengths to secure your data at rest. For more information about how we keep your information secure, please review the Security page on our web site. Most data stored in our data stores is encrypted.
What happens when you delete content in your product accounts
In our product, we give you the option to delete content. Anything you delete in your Almanack is deleted immediately. Copies of the content may be held in backups of our application databases for up to another 30 days after that. Altogether, any content deleted in your product accounts should be purged from all of our systems within 60 days.
If you choose to cancel your account, your content will become immediately inaccessible and should be purged from our systems in full within 60 days. This applies both for cases when an account owner directly cancels and for auto-canceled accounts.
We keep your information for the time necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and your choices, after which time we may delete and/or aggregate it. We may also retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Through this policy, we have provided specific retention periods for certain types of information.
Location of site and data
Our products and other web properties are operated in the Canada and the United States. If you are located in the European Union, UK, or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to and stored in Canada or the United States. By using our websites or Services and/or providing us with your personal information, you consent to this transfer.
Almanack may transfer your personal data outside of the European Economic Area (EEA) to countries not deemed by the European Commission to provide an adequate level of data protection. In such cases, we ensure that appropriate safeguards, as required by the GDPR, are in place to protect your personal data. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and third-party providers, which require all parties to protect personal information they process from the EEA in accordance with European Union data protection law.
Our organization is dedicated to adhering to the U.S. Family Educational Rights and Privacy Act (FERPA), recognizing the critical need to safeguard student data. We do not collect or store Personally Identifiable Information (PII) for students.
Changes & questions
We may update this policy as needed to comply with relevant regulations and reflect any new practices. Whenever we make a significant change to our policies, we will refresh the date at the top of this page and take any other appropriate steps to notify users.
Almanack Data Subprocessors
- Amazon Web Services: Cloud services provider
- Microsoft Azure: Cloud & AI services provider
- Google Cloud Platform: Cloud services provider
- OpenAI: AI services provider
- Stripe: Payments provider
- New Relic: Application performance monitoring
- Google Analytics: Analytics provider
- Segment: Analytics provider
- Amplitude: Analytics provider
- Helicone: AI analytics provider