INSIGHT NINJA

Privacy Policy

PLEASE READ OUR PRIVACY POLICY CAREFULLY BEFORE USING OUR PLATFORM AND/OR OUR SERVICES. This Privacy Policy describes how Insight Ninja, a cloud-based platform located at https://insightninja.org (“We” or “us”), manages and processes personal information when we make available our platform to subscribers (the “Platform”) and manage our business and business relationships (the “Services”). Insight Ninja is a platform owned and operated by Green Ninja, Inc.

We are committed to ensuring the privacy, security, and integrity of the personal information that subscribers and users share with us or that we otherwise collect as we make available the Platform and the Services. As described more fully below, we use the personal information we collect on a very limited basis for the provision of our Platform and the Services only, and we refrain from selling the personal information we collect.

1. INFORMATION WE COLLECT

We may collect personal information directly from you, or we may collect personal information from third parties as we make available our Platform and our Services.

To the extent applicable, we indicate when we need personal information and the consequences for failing to provide it. If you do not provide personal information when requested, we may not be able to provide our Platform or Services, if either the personal information is required to provide the Platform or Services, or alternatively, we are legally required to collect it.

Below is a description of the different types of personal information we process or manage and the sources from which we collect that information:

1. Teachers/School Staff Member: If you are a teacher or a school staff member utilizing the Platform, we may collect your name, work email, password, role, and school and district affiliation. Also, if you are a teacher attending a professional development event that we host, we may collect your name, email, and school.
2. Students: If you are a student whose information is uploaded to the Platform, we may collect your name, grade level, class enrollment, school-issued email (if available), roster identifiers assigned by the school’s roster system, assessment answers, and assessment scores.
3. Subscribers: If you are a subscriber entering into a subscription with us, we may collect your name, email, school or organization, phone number, billing address, and shipping address (only to the extent physical materials will be shipped), the token generated by Intuit for merchant processing purposes, and the last four digits of the credit card. In the case of district direct subscribers, we may collect your district name, title, work email, phone, billing address, the signed agreement and purchase order, as well as the Quickbooks invoice records.
4. Prospective Subscribers: If you are a prospective subscriber to the Platform, we may collect your name, email address, name of your organization, the district name, administrative contact name and the contents of any message you share.
5. Technical Information: We may collect standard server logs such as IP address and browser type, session cookies, and in-product usage events.

Except for credit card information which is processed by our merchant processor but which we do not store to our servers (we retain only the processor token and last four digits of the credit card number) and educational record-related information on children under thirteen (13) years of age, we do not collect sensitive personal information, including but not limited to government identification numbers; financial details; precise geolocation data; genetic, biometric or health information; sexual orientation information or other private life information; or information on personal beliefs or other background information. We also intentionally do not collect demographic information on race or ethnicity.

2. COOKIES AND OTHER TECHNOLOGIES

We may also collect personal information for the operation and improvement of the Platform and the Services.

For example, if you use our Platform, we may collect the IP address of your computer and aggregate Platform usage data, in order to enable us to better manage Platform traffic and to gather other analytics on the Platform.

We may also use “cookies,” which are small data files placed and stored on your computer, to help you manage your use of our Platform. We use cookies in accordance with the terms of our Cookie Policy which linked to this Privacy Policy and incorporated herein by reference.

We utilize Google Analytics on our pages directed to marketing as well as our pages directed to teachers; however, we do not use Google Analytics on any of our pages directed to students. We also do not utilize Google Analytics for advertising purposes.

3. HOW YOUR INFORMATION IS USED

We will use your personal information only for the purposes disclosed at the time of collection or as otherwise set out in this Privacy Policy, unless we have your consent for another use, or unless such other use is required by law. The purposes which we use personal information, include the following:

1. Responding to Inquiries. To respond to inquiries from subscribers and potential subscribers.
2. Authenticate Users. To authenticate the users of the Platform.
3. Operate the Platform and Services. To import the roster that a school authorizes, to deliver assessments, provide AI-assisted scoring, and show teachers’ student-progress reports.
4. Improve Business Operations. To improve the Product with aggregated/de-identified statistics.
5. Manage Relationships. To manage the relationship with our subscribers.
6. Process Payments. To process subscription payments by our subscribers.
7. Legal Defense or Compliance. To defend our legal rights or comply with our legal obligations.
8. Necessary Business Purposes. For all other necessary business purpose.
9. Other Legal Purposes. As otherwise required by law.

We do not use or process information or data for profiling purposes or to train AI models; we do not use the data we collect for advertising purposes; and we do not sell personal information. Furthermore, we will never direct any marketing communications to students and/or children.

4. DISCLOSURE OF PERSONAL INFORMATION

We may disclose personal information only as described below:

1. Provide the Platform or Services. As necessary to provide the Platform and perform the Services on behalf of subscribers.
2. Process Subscription Payments. As necessary to process subscription payments on behalf of subscribers.
3. Manage the Relationship. As necessary to manage the relationship with subscribers.
4. Communication. To our prospects, subscribers, and service providers, as is necessary to communicate with them.
5. Market & Sell to Prospects, Subscribers. Only as needed to market and sell the Platform and Services to our subscribers and prospective customers.
6. Judicial Process. If required by law, or if we believe that the disclosure is required or necessary to protect our rights and/or comply with a judicial processing or legal process served on us.
7. Merger or Acquisition. As part of the transaction in the case of a merger, sale, or other asset transfer of our business, or if we are involved in any transaction in which we will not continue our business or will be transitioning our Platform and Services to another company.
8. Compliance and Legal Necessity. To address legal concerns or liabilities, respond to suspected illegal activity or fraud, defend against legal claims, or respond to a potential threat to the physical safety of a third party.
9. As Required by Law. We may share personal information with third parties upon receipt of your consent as required by law.

Except as expressly stated above, we do not disclose personal information and we do not share personal information to third parties for marketing and promotional purposes.

For the avoidance of doubt, we do not sell personal information to third parties.

5. SHARING PERSONAL INFORMATION WITH LAW ENFORCEMENT

Please be advised that we may share personal information in response to lawful requests by public authorities, including but not limited to national security or law enforcement requirements. We may also be required to share personal information pursuant to court orders or subpoenas of records.

6. RIGHTS WITH RESPECT TO YOUR PERSONAL INFORMATION

Depending on your state or other location of residence, you may have the following rights with respect to your personal information:

1. Disclosure: Right to request that we disclose personal information or categories of personal information that we collect, use, disclose, and sell; the purposes for which the categories of information collected by us are used; the sources of information from which we collect personal information; and the specific pieces of information we have collected on you;
2. Deletion: Right to request that we delete personal information we have collected from you;
3. Opt-Out: Right to request that we opt you out of the sale, disclosure, or processing of your personal information;
4. Opt-In: Right to opt in for sensitive personal information processing;
5. Non-Discrimination: Right to non-discrimination;
6. Correct: Right to correct inaccurate personal information;
7. Portability: Right to the portability of your personal information;
8. Limit: Right to limit the use and disclosure of sensitive personal information collected about you; and
9. Automated Decision Making: Right to opt out of automated decision making.

We make every effort to extend all of the above-stated rights to all users of our Platform, prospective subscribers, and subscribers, regardless of their state or other location of residence.

However, given the nature of our business, we may be subject to certain exemptions from these rights and be unable to extend them to you in all cases.

If you submit a request and we are unable to act for one of the reasons listed above or another reason, we will advise you accordingly and provide the reason for our denial. We will not discriminate against you because you exercised your rights.

7. ADMINISTRATION OF YOUR RIGHTS AND CHOICES

If you are a teacher or staff member, you may access, update, or correct personal information through the Platform.

If you are a district administrator, you may access, update, or correct personal information via your roster, and deletions can be also made via technical support at contact@greenninja.org. If you are a parent or student, you should direct all access, update, deletion or correction requests to your school at its designated email address or phone number.

To opt out of communications, subscribers or potential subscribers should submit unsubscribe requests to Hubspot, which manages our marketing communications. We do not direct marketing communications to students.

For all other questions about how we collect and use personal information, or for other requests involving personal information, please submit your request to us at contact@greenninja.org.

8. RIGHT TO EDUCATIONAL RECORDS

8.1 Compliance with Educational Privacy Laws

We recognize that student personal information and educational records are subject to strict privacy protections under applicable laws, including the Family Educational Rights and Privacy Act (FERPA) and applicable state student privacy laws. When we provide services to an educational institution ("School"), we act as a "School Official" with a legitimate educational interest under the direct control and direction of the School regarding the collection, use, and maintenance of educational records.

8.2 Inspection and Access Rights

Parents, legal guardians, and eligible students (students who have reached 18 years of age or are attending a post-secondary institution) have the right to review and inspect personal information and educational records contained within our platform.

• Direct Requests via Schools: Because the School controls the educational records, access or inspection requests should generally be submitted directly to the student’s School. We will assist the School in fulfilling verified requests within a reasonable timeframe.

8.3 Right to Request Corrections

If a parent, legal guardian, or eligible student believes that an educational record maintained on our platform is inaccurate, misleading, or violates the student’s privacy rights, they have the right to request an amendment.

• Requests regarding school-issued accounts must be submitted to the School administrator, who will instruct us on any required modifications.
• We will promptly correct, update, or delete inaccurate data upon written instruction from an authorized School administrator or verified parent account holder.

8.4 Data Control and Non-Disclosure

Educational records are used solely to provide and improve educational services as authorized by our agreement with the School. We do not sell educational records, use student data for targeted advertising, or build behavioral profiles for non-educational purposes.

9. CATEGORIES OF INFORMATION, SOURCES, USE, DISCLOSURE

The categories of personal information we have collected in the past twelve (12) months are as follows:

10. PROCESS USED TO VERIFY A REQUEST

If you make an access or a deletion request, you may be required to submit several identifying pieces of information. We will use this information to search our systems and determine if we have information about you. In the case of subscribers, we can verify by a confirmation link to your account email. If we are able to locate information about you, we will fulfill your request. If we are not able to match all three pieces of information you submit, we may provide you with a report that includes the categories of information we collect, use, disclose and sell.

If you are an authorized agent making an access or deletion request, you may be required to submit your name, address, and phone number, as well as the name, address, and phone number of the person on whose behalf you are making a request. If we are able to locate the information about the person, on whose behalf you are making the request, we will fulfill your request. As an authorized agent, you will also be required to complete a form certifying you have the right to make this request on behalf of the third party.

If you represent a subscriber school district, you may request district-wide deletion upon the expiration or termination of our agreement pursuant to the terms of our data sharing agreement.

11. HOW TO SUBMIT A VERIFIABLE REQUEST

You can make or submit a request related to the exercise of your privacy rights by contacting the district administrator or via support at contact@greenninja.org. You also may make a request in writing to the mailing address provided in Section 20 below.

12. DATA PROCESSORS

We may utilize certain third-party service providers, which may have access to personal information provided in conjunction with the Platform and Services and perform the role of a third-party data processor. The name, location, business and website address of these third-party service providers is provided below, along with a description of the services they provide

13. OUR USE OF GOOGLE DATA

(a) Scope of Use

Our Platform and Services make use of certain Google data, as we further define below:

(b) Purpose for Our Use of Google Data

Our Platform and Services are designed to be utilized by teachers and to connect to their data and information uploaded to the Google Classroom. If you are a teacher and you connect our Platform and Services to Google Classroom, we access your course list and the class roster that you select (which may contain student names and school-issued email addresses). We also post assessments and announcements into the selected course at your direction. From this Google data, we store the following: course name and identifier, student and teacher names, school-issued email addresses, and Google’s stable identifiers. We do not request or import demographic information.

Google data from Google Classroom is used solely to provide the service that you request. For the avoidance of doubt, we do not use Google data for advertising. Furthermore, it is neither sold nor used to train AI models. You may disconnect Google Classroom at any time, either using the app or at https://myaccount.google.com/permissions. Upon disconnecting Google Classroom, we will delete your stored access authorization.

Our use and transfer to any other app of data or information received from the Google APIs will adhere to the Google API Services User Data Policy, including the limited use requirements set forth therein.

14. EUROPEAN UNION RESIDENTS

Insight Ninja is marketed and sold to US-based schools only. We do not target or knowingly collect the data of residents of the European Union.

15. ALTERNATIVE FORMAT REQUESTS

If you have a physical disability you have the right to request this privacy policy in an alternative format. To make a request for an alternative format, please submit your request to contact@greenninja.org. We also accept requests made in writing to the mailing address provided in Section 20 below.

16. DATA TRANSFER, STORAGE, & PROCESSING

If you are accessing our Platform or Services from Canada, the United Kingdom, Australia, the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that your personal information will be transferred to, stored, and processed in the United States. We take steps to ensure that the service providers that we work with utilize industry best practices for maintaining data privacy and security.

17. SECURITY

We have implemented commercially reasonable security measures and follow generally accepted industry standards to protect all personal information in our possession, which includes employing commercially reasonable administrative, physical, and technical safeguards to maintain the confidentiality and security of all personal information.

To protect the information delivered to us, we have implemented transport layer security (“TLS”) encryption when data is in transit and AWS Key Management Service (“KMS”) when the data is at rest. We keep credential and integration tokens in AWS Secrets Manager rather than the application database. Additionally, we utilize multi-tenant isolation, so that every record is scoped to its district; role-based access controls; least-privilege IAM; virtual private cloud (“VPC”); application log restrictions; and a documented incident-response process.

We also utilize additional security protocols to protect sensitive personal information, protecting hashed passwords with an industry-standard algorithm; secrets in a dedicated encrypted secrets store, and restricting production access to a small operations group.

Although we strive to protect your personal information, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. We make every effort to protect personal information, but we cannot guarantee its absolute security.

18. DATA RETENTION

We retain Student Data for the duration that a teacher or school maintains an active account with Insight Ninja to allow for year-over-year progress reporting.

• Deletion upon Request: Schools may request the deletion of Student Data at any time by contacting our support team.
• Account Termination: Data is purged within 90 days of account termination or contract expiration, unless otherwise required by a specific Data Privacy Agreement (DPA).

19. CHANGES AND UPDATES TO THIS PRIVACY POLICY

We may amend this Privacy Policy at any time at our sole discretion and without prior notice. If we make any material amendments, we will advise you about those changes by notifying you in a prominent place on the Platform. You should check back with us from time to time in order to confirm that there have been no significant changes.

Please note that the use of information that we gather is subject to the Privacy Policy then in effect at the time of use.

20. CONTACT US

If you have any questions or concerns over this Privacy Policy or if you need further information regarding the access to your personal information, or how your personal information is used, you may contact us at:

21. CORPORATE INFORMATION

Green Ninja is a corporation, which is incorporated under the laws of the State of California. Our headquarters is located at 421 Loreto Street, Mountain View, CA 94041.

22. EFFECTIVE DATE

This Privacy Policy was last modified on August 13, 2026.

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