Speechbound Classroom Privacy Policy

Moonspire Games Inc. | Institutional classroom product only

Document status

Institutional privacy policy

Scope: This policy applies to Speechbound Classroom, the browser based institutional product for schools and education organizations. It does not apply to the separate consumer Steam version of Speechbound.

Student data use restriction: Moonspire does not sell student personal information, use it for advertising or behavioral marketing, provide it to data brokers, use it for unrelated profiling, or use identifiable student information to train general purpose artificial intelligence or large language models. Student information and Institution specific usage data will not be used for commercial research, efficacy claims, product evaluation, case studies, investor validation materials or unrelated product improvement unless the Institution separately authorizes the activity in writing and the activity has a lawful basis.

Moonspire Games Inc. (“Moonspire”, “we”, “us” or “our”) provides Speechbound Classroom to schools, school boards, language colleges and other education institutions. This Privacy Policy explains how personal information is handled when an Institution uses Speechbound Classroom for teachers and students.

Speechbound Classroom is designed around data minimization, institutional control, student privacy and secure access. Student personal information is used only to provide, operate, secure, troubleshoot and support the classroom service for the Institution, subject to the Institution’s instructions, the applicable institutional agreement and applicable law.

1. Who this policy applies to

This policy applies to institutional administrators, teachers, staff and students who use Speechbound Classroom through a school, school board, language college or other education organization (an “Institution”). An authorized institutional representative accepts or incorporates the applicable Speechbound Classroom Terms of Use. Student users are not required to enter a separate commercial agreement with Moonspire.

Where the Institution determines the educational purpose and administration of student accounts, Moonspire handles student information for that institutional purpose. Legal terminology for the parties may differ by jurisdiction. The characterization required by applicable law and the signed institutional agreement will control.

2. Institutional control and jurisdiction specific requirements

For institutional deployments, the Institution determines which teachers and students use Speechbound Classroom, which classes and assignments are created, and the educational purposes for which the service is used. Moonspire may have custody of information while operating the service, but will not independently determine new purposes for Institution student information.

For institutional deployments, the Institution retains control of student information to the extent required by applicable law and the applicable institutional agreement. Where Moonspire acts as a contracted service provider processing personal information on an Institution’s behalf, Moonspire will process that information only for authorized purposes and will cooperate with the Institution so it can meet applicable collection, use, disclosure, correction, access, security, retention, incident response, privacy assessment and oversight obligations.

The Institution remains responsible for determining the lawful authority, purpose and required content of any legally required collection notice. The parties may document who presents that notice in the applicable institutional agreement or implementation plan. Where Speechbound directly collects personal information from a student or other individual and applicable law or the agreement requires Moonspire to present the notice on the Institution’s behalf, Moonspire will display or otherwise provide the Institution approved notice at or before the relevant collection. Moonspire will provide the data inventory and technical information reasonably needed to support that process, including information about the automated learning logic described below.

Alberta public body customers

For an Alberta public body, the public body retains control of personal information processed on its behalf. Under Alberta’s Protection of Privacy Act (“POPA”), a contracted service provider handling personal information on behalf of the public body is treated as an employee of that public body for the relevant contracted activities. Access to records is governed by Alberta’s Access to Information Act (“ATIA”). Moonspire will cooperate with an Alberta public body so it can meet applicable POPA and ATIA obligations, including collection notices, correction, access, security, retention, incident response, privacy impact assessment and oversight requirements.

3. Information we collect

We collect only information reasonably necessary to operate Speechbound Classroom for the Institution.

Institution and teacher information

Teacher or administrator name, institutional email address, Institution name, account role and class associations.
Authentication information, login events and account security information.
Support communications and information an authorized institutional user chooses to provide to us.

Student identity and account information

Student display name, entered or imported by an authorized teacher or Institution. Speechbound uses a pseudonymized account structure in which the student’s identity information is maintained separately from learning and performance records and linked through a randomly generated internal Student ID. Student identity information is protected using appropriate technical safeguards, including encryption and access controls.
A random internal Speechbound Student ID used to link the student to learning and performance records.
Class membership and assignments.
A generated or Institution assigned student username. A student email address is not required for the core classroom account.
A secure password hash or equivalent authentication record. Moonspire does not store student passwords in readable form.

Student learning and gameplay information

Assignment results and completion status.
Vocabulary and sentence performance.
Accuracy, progress, mastery and adaptive practice information.
Playtime, activity and session information.
Timestamps required to provide longitudinal progress reporting.
Character customization and avatar preferences. These are gameplay settings and are not intended to represent or verify the student’s actual sex or gender.

Technical and security information

IP address, browser type, device information, session identifiers and similar technical information generated when the service is accessed.
Security, authentication, error and diagnostic logs reasonably necessary to protect, troubleshoot and operate the service.

Information the core classroom product does not require

Speechbound Classroom does not require students to provide a home address, personal phone number, personal email address, date of birth, age, actual sex or gender, photographs, videos, voice recordings, audio recordings, parent information or open student chat content as part of the core classroom experience. Institutions should not provide unnecessary personal information through class names, support messages or other free text fields.

4. Pseudonymized student architecture

Speechbound Classroom is designed to separate student identity information from learning records where practical. A student’s name is associated with a random internal Student ID. Learning and performance records are linked primarily to that Student ID rather than repeatedly storing the student’s name with each performance event.

The identity mapping that connects a Student ID to a student name is protected through access controls and encryption. Authorized teachers can still see the student’s name and performance in the teacher dashboard because the service resolves the Student ID for that authorized educational purpose.

This is pseudonymization, not anonymization. Authorized systems can reconnect the Student ID to the student when necessary to provide the service. Moonspire will not describe pseudonymized records as anonymous or non personal data merely because the name is stored separately.

5. How we use information

Moonspire uses personal information only as reasonably necessary to:

Create and administer Institution, teacher, class and student accounts.
Authenticate users and protect accounts from unauthorized access.
Deliver assigned language learning content and gameplay.
Record student progress and provide teacher dashboards, reports and longitudinal learning history.
Apply performance based repetition and adaptive practice within Speechbound.
Provide support, troubleshoot defects and maintain service reliability.
Protect the security and integrity of Speechbound Classroom.
Follow lawful Institution instructions and applicable legal obligations.

6. Automated learning logic and artificial intelligence

Speechbound uses automated learning logic to respond to a student’s recorded performance. For example, the service may select, repeat or prioritize vocabulary, sentences or practice activities based on accuracy, mastery or prior activity. This automated logic is used to personalize practice within Speechbound. It is not intended to make official school grades, admissions decisions, disciplinary decisions, special education eligibility decisions or other high stakes institutional decisions. Teachers and Institutions remain responsible for instructional and assessment decisions.

Some jurisdictions impose specific transparency requirements for automated systems. Where applicable, the Institution should assess whether Speechbound’s performance based practice logic must be described in a collection notice, privacy assessment or similar process. Moonspire will provide reasonable technical information about the logic, inputs, outputs and safeguards and, where required by the deployment, will present an Institution approved notice within Speechbound.

Separately, Moonspire may use artificial intelligence assisted tools in its internal content and development workflow, for example to help prepare or localize educational content before it is included in Speechbound. Student personal information is not provided to general purpose artificial intelligence or large language model services for training or content generation. Educational content intended for the classroom product is prepared before gameplay and reviewed through Moonspire’s content quality process rather than generated from student personal information during live gameplay.

7. Accounts, passwords and future single sign on

Students do not need personal email addresses to use the core Speechbound Classroom service. Student accounts may use generated or Institution assigned usernames and passwords. Passwords are stored using secure password hashing or an equivalent secure authentication method and are not stored in readable form.

Authorized teachers or institutional administrators may reset student credentials. The product is not designed to allow them to retrieve a student’s existing password in readable form.

Speechbound does not require school single sign on for the initial classroom product. Moonspire may later offer optional single sign on or federated authentication with an Institution’s identity provider. If an Institution enables such an integration, Moonspire will limit identity attributes to those reasonably necessary for authentication and account administration and will document the integration before activation.

8. Cookies, session technologies and operational telemetry

Speechbound Classroom may use strictly necessary cookies or similar technologies for authentication, session management, security, load balancing and other functions required to provide the service. Moonspire does not place advertising trackers in the student classroom experience and does not use student accounts for behavioral advertising.

Operational telemetry may be processed only where reasonably necessary for security, reliability, performance monitoring and troubleshooting. Moonspire will not use student telemetry or Institution specific usage data for commercial product evaluation, efficacy claims, case studies or unrelated research unless the Institution separately authorizes that activity in writing and applicable law permits it.

9. Who may receive information and subprocessors

Personal information may be made available only to the following categories of recipients, and only for the purposes described in this policy or the applicable institutional agreement:

Authorized teachers, administrators and other Institution users who have a legitimate educational or administrative need for the information.
Moonspire personnel and contractors who require access to operate, secure or support the service and who are subject to appropriate confidentiality and access restrictions.
Infrastructure and technical service providers used to host, secure, back up or operate Speechbound Classroom.
Government, regulatory or law enforcement authorities where disclosure is legally required, subject to the legal demand safeguards described below.

Core student data infrastructure is currently planned around Amazon Web Services and MongoDB Atlas. Before a live public body deployment, Moonspire will document the subprocessors that may receive Institution personal information, the data each receives, the applicable region and the relevant contractual and security controls. Moonspire will require downstream providers to handle Institution personal information only for the services they provide to Moonspire and subject to applicable contractual restrictions.

Generic game assets, educational images, text to speech audio and similar content may be delivered through technical infrastructure that does not contain student names or learning records. Network services may nevertheless receive limited connection information such as an IP address. Moonspire will review those services before a deployment where the Institution imposes regional or other privacy requirements on technical identifiers.

10. Data location and regional hosting

Speechbound Classroom is designed to support region specific hosting. The location used for a particular Institution may depend on the Institution’s location, applicable law, contractual requirements and deployment configuration.

Where Moonspire contractually commits to a particular data residency region, Moonspire will configure persistent student personal information and routine backups for storage in that region before student personal information is introduced. For Canadian institutional deployments that require Canadian data residency, Moonspire will configure the relevant AWS and MongoDB Atlas services and routine backups for Canadian regions. Other customers may use different approved regions based on their contract, location and applicable law.

This commitment concerns the storage and processing scope agreed with the Institution. It is not a statement that every Internet routing, security or support component worldwide is inherently Canadian. Any additional regional requirement covering technical identifiers, support systems or other service providers must be identified and implemented before the applicable data is introduced.

Other institutional customers may use different regional hosting arrangements where appropriate. Moonspire does not represent that every Speechbound deployment worldwide is always stored in Canada.

Ordinary business communications with adult institutional contacts may use business communication services that operate in other jurisdictions. Student names, performance reports and other student records should not be sent through ordinary email. Support requests should use the internal Speechbound Student ID or another nonidentifying reference whenever possible.

11. Retention, export, correction and deletion

Student learning history is retained while needed to provide the Institution with longitudinal progress reporting and other classroom functions, subject to the Institution’s instructions, the applicable agreement and applicable records retention requirements.

An authorized Institution may instruct Moonspire to export, correct, delete or, where lawful and specifically authorized, deidentify student information. Requests may apply to an individual student, a class or the Institution’s account data. Moonspire will not delete records that the Institution instructs it to retain or that applicable law requires to be retained.

Unless a separate institutional agreement requires a different period, Moonspire’s operational targets are:

At termination, make Institution data available for a reasonable export period of up to 30 days, unless the Institution requests immediate deletion or another period is agreed.
Delete requested personal information from active production systems within 30 days after an authorized deletion instruction or the end of the applicable export period.
Remove the information through routine backup expiration within 90 days. Backup copies retained during that period are used only for disaster recovery and are not used for ordinary business purposes.
Retain only information that the Institution instructs Moonspire to retain, or that Moonspire is legally required to retain, and only for the required period.
If a backup is restored during the deletion window, reapply the deletion instruction to the restored environment.
Where required by an institutional agreement, provide written confirmation that the agreed destruction process has been completed.

12. Access, correction and privacy complaints

For school controlled student records, the Institution ordinarily remains responsible for receiving and deciding requests from students, parents, guardians or other authorized representatives. Moonspire will provide reasonable technical assistance, searches, corrections, exports and deletion support so the Institution can respond under the law that applies to it.

Where a student, parent or guardian contacts Moonspire directly about school controlled educational records, Moonspire may direct the request to the Institution so the Institution can verify identity, authority and applicable legal requirements. Moonspire will cooperate with the Institution in responding.

Questions or complaints about Moonspire’s own privacy practices can be sent to the Privacy Officer listed below. Moonspire will review the concern, investigate where appropriate and provide a response consistent with applicable law and the relevant institutional agreement.

13. Security safeguards

Before institutional student information is introduced into a production deployment, Moonspire will verify safeguards appropriate to the sensitivity of the information. The intended controls include:

Encryption in transit and encryption at rest for personal information stored in production systems.
Pseudonymization of student learning records using random internal Student IDs where practical.
Role based access controls so authorized users can access only information required for their role.
Least privilege access for Moonspire personnel and contractors with production access.
Secure password hashing and credential reset controls.
Security and diagnostic logging designed to avoid unnecessary student content.
Protected backups and controlled restoration procedures.
Subprocessor review and access restrictions.
Documented incident response procedures.

No Internet service can guarantee absolute security. Moonspire will review safeguards as Speechbound Classroom develops and as contractual or legal requirements evolve.

14. Privacy and security incidents; legal demands

If Moonspire becomes aware of a suspected or confirmed incident involving Institution personal information, Moonspire will investigate, take reasonable containment and remediation steps, preserve relevant evidence and notify the affected Institution without undue delay in accordance with the applicable agreement. The institutional data protection agreement should specify the required notification timeline so the Institution can meet any statutory notice obligations.

If Moonspire receives a legally binding demand for Institution personal information, Moonspire will, to the extent legally permitted, notify the Institution before disclosure, give the Institution a reasonable opportunity to respond where practicable, and disclose only the information legally required. Moonspire will cooperate with the Institution regarding any record of the demand or related notification obligations.

15. Students and minors

Speechbound Classroom is an Institution administered educational service and may be used by minors. Student users are not required to accept a separate commercial Terms of Use agreement. The Institution is responsible for determining its legal authority to use Speechbound Classroom and for providing notices or obtaining parental or guardian consent where required by applicable law or Institution policy. Moonspire does not assume that parental consent is required in every school use case where the Institution has another lawful authority.

Moonspire does not use student personal information to advertise to minors or to build commercial marketing profiles about them.

16. Research, product evaluation and external use of pilot results

Moonspire will not use student personal information or Institution specific usage data for commercial research, product evaluation, efficacy claims, case studies, structured surveys, investor validation materials or unrelated product improvement unless the Institution separately authorizes that activity in writing and applicable law permits it. Any external use of pilot results must be appropriately aggregated, deidentified or otherwise approved so that student identities are not disclosed.

This restriction does not prevent Moonspire from processing information strictly necessary to provide the agreed service, secure the environment, investigate a support issue, correct a defect affecting the deployment or comply with Institution instructions. Any structured evaluation, research, publication or investor facing validation activity will be treated as a separate activity rather than being implied by the ordinary classroom service.

17. Changes to this policy

Moonspire may update this Privacy Policy as the classroom product, legal requirements or deployment models evolve. Moonspire will provide institutional customers reasonable notice of material changes where required by the applicable agreement or law. Moonspire will not use previously collected Institution student information for a materially different purpose merely by changing this policy. A new use requires an appropriate legal basis and, where required, Institution authorization.

18. Privacy contact

Moonspire Games Inc. has designated the following individual as its Privacy Officer for Speechbound Classroom:

Manuel Tausch
Chief Executive Officer and Privacy Officer
Moonspire Games Inc.
Vancouver, British Columbia, Canada
policy@moonspiregames.com