Clever provides a platform for learning applications to connect with schools and school districts to have a central location to manage their technology. Clever does not directly provide social interactions through its services, but some elements enable schools to interact with parents, students, teachers and third party applications, for the benefit of the student’s education. In addition, Clever's terms say they collect personal information when a school administrator registers a school with Clever and non-personal usage information is collected automatically through use of the service. Clever's terms say they maintain strict administrative, technical and physical procedures to protect information stored in their servers. Lastly, Clever's terms say they consider student data that schools provide to be education records, as defined by the Family Educational Rights and Privacy Act (“FERPA”).

Clever can be accessed through its website, and is available for download at the iOS App Store. The Privacy Policy and Terms of Use used for this evaluation can be found on Clever’s website, and iOS App Store. Additionally, other policies used for this evaluation include: Clever Additional Terms of Use for Schools, Clever Additional Terms for Parent Accounts, Privacy Principles, Security Principles, and Compliance Principles. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

Clever does not directly provide social interactions through its services, but some elements enable schools to interact with parents, students, teachers and third party applications, for the benefit of the student’s education. The terms state that users are fully responsible for interactions with other users. Users can control their profile visibility, but it is unclear from the terms what information is visible on the profile.

Privacy

Clever's terms state they collect personal information when a school administrator registers a school with Clever and non-personal usage information is automatically collected through use of the service. Information collected may include a name, school name, school district, school email address and/or account name and password, phone number, message content, and information relating to the school's information systems. The type of student data Clever collects will depend on how the school uses the service and the learning applications which the school connects through the service.

Clever may maintain anonymized or aggregated data, including usage data, for analytics purposes. For example, Clever may use and share aggregate or anonymized data to study and improve the service, user functionality, and product offerings. Clever’s terms state they will never share or sell student data with third parties for marketing purposes or targeted advertising. In addition, Clever does not permit third party advertising networks to collect information about users’ use of the service over time and across websites for the purpose of serving targeted advertising.

Security

Clever's terms state they recommend users create strong passwords to access the service that use a combination of upper and lower case letters, numbers and symbols, and are not reused with any other service to avoid unauthorized use. Clever provides access controls to personal information on the service such as password credentials and two factor authentication. Clever's terms state they maintain strict administrative, technical and physical procedures to protect information stored in their servers. Contractors and third-party service providers who may have access to student data in the course of performing their services are subject to confidentiality and data security requirements. In addition, only those employees who require access to personal information to perform their job functions are provided access. Lastly, Clever uses industry-standard Secure Socket Layer (SSL) encryption technology to safeguard data in transit, while other security safeguards include: data encryption at rest, firewalls, and physical access controls to building and files.

Compliance

Clever's terms state they consider student data that schools provide to be education records, as defined by the Family Educational Rights and Privacy Act (“FERPA”). Clever states they treat student data as confidential and not to be used for any purpose other than to provide the services on the school's behalf, in accordance with contractual agreements with the school. Clever's terms state they do not knowingly collect any information from children under the age of 13 unless the school has obtained appropriate parental consent for the student to use the service. Because Clever collects and uses student data at the direction and under the control of a school, Clever relies on each school to provide appropriate notice to parents of the school's use of third party service providers such as Clever, and for the Schools to provide consent. Users should be aware that Clever requires them to contact the school directly in order to review, modify, or delete personal information.

Clever's terms require schools they contract with to provide each student with login credentials and confirm that it has obtained appropriate parental consents, before any student is permitted to access the service. If a student contacts Clever with a question about the service, Clever will collect personal information from that student only as necessary to respond to the student's request and direct the student to contact the student's school, and they will then delete or anonymize the personal data of the student after providing their response.