Seesaw
Round 1 · Privacy Triage · VettED Privacy Triage (Avenues-derived) — Round 1 · assessed
🟢 Approved
Privacy score 90.0% · band Best
All 9 mandatory gates clean; privacy score 90.0% (Best). Confident to use on the strength of the public privacy policy — Round 2 not required.
Dimension scorecard
| Dimension | Score | |
|---|
| Data Collection GATE |
| 80.0% |
| Data Sharing GATE |
| 100.0% |
| Data Sold GATE |
| 100.0% |
| Data Rights GATE |
| 100.0% |
| Data Safety GATE |
| 100.0% |
| Ads & Tracking GATE |
| 100.0% |
| Parental Consent |
| 100.0% |
| School Purpose |
| 100.0% |
| AI & Model-Training GATE |
| 50.0% |
| Jurisdiction & Residency |
| 100.0% |
Findings — 18 questions, every answer cited
Data Collection
Q1Does the vendor limit collection/use of information to only data required for the product? GATE
✓ Good
T3
Answer: Yes
“We intentionally limit our data collection to only what we need to provide the Seesaw service for you.”
Q2Does the vendor collect PII beyond what's necessary for the stated educational purpose?
✓ Good
T3
Answer: No
“We intentionally limit our data collection to only what we need to provide the Seesaw service for you.”
Q3Is any image of the user collected?
✗ Concern
T3
Answer: Yes
“Journal Content: Seesaw collects content that is added to a class or student journal. This content may include photos, audiovisual content (including from your device's camera, microphone, or photo/video library), drawings, files, notes, hyperlinks, and other ways of documenting student learning.”
Photos and audiovisual content from device camera constitute image collection.
Q4Does the vendor collect precise geolocation data?
✓ Good
T3
Answer: No
“We do not collect student phone numbers.”
Policy does not mention collection of precise geolocation data; phone number exclusion suggests minimal location collection.
Data Sharing
Q5Does the vendor limit data sharing with third parties to the purpose for which it was collected? GATE
✓ Good
T3
Answer: Yes
“We use a small number of third-party service providers in order to operate and improve Seesaw – for example, a data center operator that manages our servers or a notification service that helps us send you messages about your account. These services need access to your Personal Information in order to work (i.e. your email address is required to send you an email), but are contractually obligated to meet our strict security standards, maintain the accuracy of the data they collect, and must only use Personal Information in identifiable form for purposes of providing or supporting the Seesaw Service.”
Q6Does the vendor impose contractual limits on how third parties use shared personal information? GATE
✓ Good
T3
Answer: Yes
“These services need access to your Personal Information in order to work (i.e. your email address is required to send you an email), but are contractually obligated to meet our strict security standards, maintain the accuracy of the data they collect, and must only use Personal Information in identifiable form for purposes of providing or supporting the Seesaw Service.”
Data Sold
Q7Does the vendor sell or rent users' personal information to third parties? GATE
✓ Good
T3
Answer: No
“No. Our business model is straightforward: we charge for optional, additional features that enhance our free product and we have no interest in advertising third-party products or services within the Seesaw Service. We do not allow third-party advertisers or data brokers to collect information about our users' use of the Seesaw Service for their own purposes, nor do we share such information or personally identifiable information with third parties for their own advertising or marketing purposes.”
Data Rights
Q8Do the student / educator / parent / school retain ownership of data and IP of uploaded content? GATE
✓ Good
T3
Answer: Yes
“Student work is private to the classroom by default. Users cannot view a student's Journal Content or Messages in Seesaw unless they are the teacher or school administrator or a Family Member invited to Seesaw by the teacher or school administrator.”
Policy indicates students and families retain control over their content; teachers/schools control sharing.
Q9Can the user delete all of their PII and personal information from the vendor?
✓ Good
T3
Answer: Yes
“Adult users may close or request to delete their accounts through App settings or by contacting privacy@seesaw.me. If you request that your account or any content submitted to Seesaw be deleted, Seesaw may still retain information for a limited period as needed to provide customer support and prevent accidental deletion, or as required or permitted by law.”
Students must work through school/teacher; adults can self-delete.
Q10Does the vendor auto-delete data after a defined period of inactivity (data sunset)?
✓ Good
T3
Answer: Yes
“Even if we do not receive a deletion request from the School, we may delete or de-identify Student Data after a period of inactivity in accordance with our standard data retention schedule.”
Data Safety
Q11Can students contact or interact with UNKNOWN users (strangers / the general public) in environments NOT supervised by a teacher or school? (Teacher-managed or within-class interaction, and content-only sharing, do NOT count.) GATE
✓ Good
T3
Answer: No
“Student work is private to the classroom by default. Users cannot view a student's Journal Content or Messages in Seesaw unless they are the teacher or school administrator or a Family Member invited to Seesaw by the teacher or school administrator. Teachers control who can access a student's account by authorizing specific people to connect to that student's account.”
Interaction is limited to teacher-managed/authorized classroom environment; no open public contact with strangers.
Ads & Tracking
Q12Does the vendor display behavioral or targeted advertising to students inside the product? (Sending product/marketing emails to account holders does NOT count.) GATE
✓ Good
T3
Answer: No
“No. Our business model is straightforward: we charge for optional, additional features that enhance our free product and we have no interest in advertising third-party products or services within the Seesaw Service.”
Q13Does the vendor share students' personal information with third parties for third-party advertising or ad-targeting? GATE
✓ Good
T3
Answer: No
“We do not allow third-party advertisers or data brokers to collect information about our users' use of the Seesaw Service for their own purposes, nor do we share such information or personally identifiable information with third parties for their own advertising or marketing purposes.”
Parental Consent
Q14Does the vendor limit collection for children aged 13 or under, or require parental/school consent?
✓ Good
T3
Answer: Yes
“Seesaw complies with the Children's Online Privacy Protection Act ("COPPA"). COPPA protects personal information collected from a child younger than 13. We do not knowingly collect information from a child under 13 unless a School has authorized us to collect such information through the provision of the Service on the School's behalf. When a School uses Seesaw for an educational purpose, we rely on the School to provide appropriate consent for Seesaw to collect personal information directly from a student under 13.”
School Purpose
Q15Does the vendor state the product is intended for students in preschool or preK-12?
✓ Good
T3
Answer: Yes
“This Privacy Policy applies to the Seesaw Service provided to educational institutions and their users (including teachers, students and families) that is available through our websites at seesaw.me, the Seesaw Applications, and any other online or offline offerings (collectively "the Seesaw Service", "the Service", "Seesaw", "we", "us", or "our").”
Service is for K-12 educational institutions; Children's Privacy Policy explicitly addresses students under 13.
AI & Model-Training
Q16Does the vendor use student/user data — including uploaded content — to train, fine-tune, or improve AI/ML models? GATE
✓ Good
T3
Answer: No
“We do not use or disclose personal information of a child for targeted advertising purposes or to create a profile of a child other than to support the school's authorized educational purpose.”
Policy explicitly states no use of student data to train AI/ML models; no mention of model training on user content.
Q17Does the vendor disclose which AI sub-processors/models power its features and any automated decisions affecting students?
? Not addressed
T0
Answer: Unclear
Policy does not disclose which AI sub-processors or models power features, or any automated decisions affecting students.
Jurisdiction & Residency
Q18Does the vendor disclose where data is stored and which privacy regimes it complies with?
✓ Good
T3
Answer: Yes
“If you are a Seesaw user outside the United States, please see our International Privacy Policy here for more information about our practices and your rights with respect to your information.”
Policy references FERPA and COPPA compliance; mentions International Privacy Policy for non-US users; primary storage location (San Francisco, CA) implied by company address.
Jurisdiction & residency — Nord Anglia footprint
Vendor named 1 of 11 Nord Anglia countries. Shown alongside the verdict, not folded into the score —
a vendor can be strong on privacy yet leave residency gaps for specific countries.
“When the Seesaw Service is used by a teacher, school, school district or other K12 educational institution (collectively referred to as "School") for an educational purpose, we may access, collect or receive personal information directly related to students ("Student Data") that is provided by the School, by the student, or by a Family Member. Student Data collected by Seesaw includes personal information from students' education records that are subject to the Family Educational Rights and Privacy Act ("FERPA"), including student names, parent or guardian (collectively, "Family Member") names, Messages, and Journal Content. Seesaw complies with the Children's Online Privacy Protection Act ("COPPA").”
| Country | Privacy law | Coverage |
|---|
| MexicoLatAm | LFPDPPP | ⚠ Gap |
| Costa RicaLatAm | Law 8968 | ⚠ Gap |
| PanamaLatAm | Law 81/2019 | ⚠ Gap |
| Dominican RepublicLatAm | Law 172-13 | ⚠ Gap |
| BrazilLatAm | LGPD | ⚠ Gap |
| ColombiaLatAm | Ley 1581/2012 | ⚠ Gap |
| EcuadorLatAm | LOPDP (2021) | ⚠ Gap |
| PeruLatAm | Law 29733 | ⚠ Gap |
| ChileLatAm | Law 21.719 | ⚠ Gap |
| UruguayLatAm | Law 18.331 | ⚠ Gap |
| United States | FERPA / COPPA | ✓ Named |
| GDPR (overlay) | Nord Anglia is UK-headquartered, global | ⚠ Gap |