Privacy Policy

1. Introduction & Our Commitment

Boggl Inc. (“Struggly”, “we”, “us”, or “our”) is dedicated to protecting the privacy of educators, parents, and students. This Privacy Policy describes how we collect, use, store, and protect personal information when you access or use our website, applications, and educational services (collectively, the “Service”). We do not utilize or share any customer information, student or teacher, for advertising or commercial purposes.

By accessing or using the Service, you agree to the terms of this Privacy Policy. If you are using Struggly on behalf of a school, school district, or local educational agency (“LEA”), this policy governs our handling of Student Data in coordination with your educational institution.

2. Federal & State Educational Privacy Compliance

Struggly maintains full compliance with federal and state student data privacy laws including, as a non-limiting example:

• FERPA: The Family Educational Rights and Privacy Act (20 U.S.C. § 1232g).
• COPPA: The Children’s Online Privacy Protection Act (15 U.S.C. §§ 6501–6506).
• State Laws: Applicable state student online personal protection acts (e.g., California SOPIPA/CalOPPA, Illinois SOPPA, New York Education Law 2-d).
• Student Privacy Pledge: Struggly adheres to the core principles of the Student Privacy Pledge to safeguard student data.

School Official Designation

When Struggly is provided to a school, district, or educator for educational purposes, Struggly acts as a "School Official" (as defined under FERPA 34 CFR § 99.31(a)(1)(i)(B)) operating under the direct control of the school regarding the use and maintenance of student education records. All Student Data remains the property of, and under the legal control of, the school or district.

3. Information We Collect

We limit data collection to only what is necessary to provide, support, and evaluate our educational software:

A. Adult & Institutional Accounts (Teachers, Administrators)

• Contact Data: Name, work or personal email address, job title, and school/district affiliation.

B. Student Data & Performance Records

• Identifiers: First name, last initial or school-assigned display name/PIN, grade level, and class assignment. We do not collect student email addresses, phone numbers, or social security numbers for student accounts.
• Learning Analytics & Activity Data: Played and completed tasks, struggle time, streak metrics, problem-solving paths, and performance milestones. This data is collected strictly to support Struggly's growth-mindset methodology and allow educators and parents to track learning progress.

C. Technical & Device Information

Browser type, operating system, IP address, device type, and system logs required to maintain account authentication, system security, and operational integrity.

4. Cookies and Web Analytics

• Essential Cookies: We use session cookies to maintain user authentication and save account preferences.
• Web Analytics: We utilize Google Analytics to understand overall usage trends and website traffic. Analytics reporting is compiled on an aggregated basis without identifying individual student visitors. You can opt out of Google Analytics via https://tools.google.com/dlpage/gaoptout.
• No Advertising Cookies: Third-party tracking cookies, remarketing pixels, or behavioral advertising cookies are strictly prohibited within the Struggly experience.

5. How We Use Information & Research

We use personal information solely for educational and administrative purposes.

• Delivering, operating, and personalizing the Struggly learning platform.
• Displaying progress dashboards to authorized teachers, parents, and school administrators.
• Securing account logins and conducting system maintenance.
• Communicating service updates and instructional support to adult account holders.

Educational Efficacy & Research

Struggly may compile and analyze de-identified or aggregated data (stripped of all personal identifiers) to conduct educational efficacy research, evaluate problem-solving frameworks, and improve our curriculum tasks. Aggregated research never identifies any individual student, teacher, or school.

6. Strict Data Safeguards & Protections

• No Selling or Renting: We do not sell, rent, trade, or lease Student Data or personal information to third parties under any circumstances.
• No Targeted Advertising: We do not use Student Data to target advertisements, build commercial student profiles, or market third-party products.
• No In-App Purchases for Students: Student accounts cannot make financial transactions or access commercial offers.

7. Third-Party Subprocessors

To operate our platform efficiently, we partner with specialized service providers bound by strict contractual privacy agreements. Subprocessors are granted access only to the data necessary to perform their specific services:

8. Technical Data Security Standards

Following standard educational data security protocols, Struggly protects personal data through Access Controls: Administrative access to user data is protected by role-based access controls (RBAC) and mandatory multi-factor authentication (MFA) for Struggly personnel. Technical and physical controls are provided through our service providers with relevant security certifications including:

• Encryption in Transit: All data transmitted between user devices and Struggly servers is encrypted using standard TLS (Transport Layer Security) 1.2 or higher protocols.
• Encryption at Rest: Backups of our databases, including those containing student data, are stored in cloud environments and encrypted at rest using industry-standard AES-256 bit encryption.

9. Data Subject Rights, Retention & Deletion

A. Access, Corrections, and Review

• Parents & Guardians: Parents may inspect, review, or request corrections to their child’s personal information by submitting requests directly to their school; Struggly will assist the school in fulfilling verified requests.
• Adult Users: Teachers can review or update their profile settings directly within their account settings.

B. Account Retention & Deletion Schedule

• School Deletion Requests: Upon written request from an authorized school administrator, Struggly will delete or de-identify Student Data within 60 days.
• Contract Expiration & Inactivity: Student Data associated with expired or inactive school accounts is purged or de-identified according to Struggly's standard retention schedule unless a longer retention window is requested by the educational institution.

10. Data Transfers & Corporate Transitions

If Struggly participates in a merger, acquisition, or sale of assets, Student Data will only be transferred to a successor entity that agrees to uphold privacy commitments no less stringent than those stated in this policy. If the successor’s policy changes materially, schools will be given prior notice and the opportunity to delete Student Data prior to transfer.

11. Changes to This Privacy Policy

We may revise this Privacy Policy periodically. When changes are made, the "Last Revised" date will be updated.

If we make any material changes regarding how Student Data is collected, used, or shared, we will provide advance notice to registered school administrators and parents via email or prominent in-app notification prior to the changes taking effect.

12. Contact Us

If you have questions, feedback, or data privacy requests regarding this Privacy Policy or Struggly’s data protection practices, please contact us:

• By Email: [email protected]
• By Mail:
  Boggl Inc.
  Attn: Data Privacy Officer
  539 W. Commerce Street, Suite 1010
  Dallas, TX 75208

last revised on October 13, 2026