1. Introduction
This Privacy Policy describes how SumHubs collects, uses, discloses, and protects personal information in connection with the Service. It applies to Enterprise Users, such as schools, districts, organizations, service providers, and businesses using SumHubs under enterprise accounts, and End Users, such as students, parents, educators, and consumer mobile app users.
By using the Service, you consent to this Policy and acknowledge that it forms part of the Terms of Service.
2. Information We Collect
Personal information
Name, email, phone number, organization or school affiliation, payment details, billing information, and other identifiers provided by users.
Account and usage data
Login credentials, device identifiers, IP address, browser type, session activity, and interaction logs.
Educational records
If used in schools, student data provided by schools, subject to FERPA and equivalent laws.
Cookies and tracking
Authentication tokens, preferences, analytics cookies, and similar technologies.
Sensitive data
We do not intentionally collect sensitive categories of data unless required by law or explicitly authorized.
3. How We Use Information
We process information to:
- Provide, secure, and improve the Service.
- Manage accounts for students, educators, and enterprise clients.
- Authenticate logins and detect fraud.
- Support compliance with Applicable Laws, including FERPA, COPPA, ADA, GDPR, and CCPA.
- Process payments and enforce account rules.
- Communicate updates, notices, and support responses.
4. Legal Bases for Processing
Where required under GDPR and equivalent laws, processing is based on:
- Performance of a contract, including providing the Service.
- Compliance with legal obligations.
- Legitimate interests, including security, fraud prevention, and product improvement.
- Consent, where expressly required.
5. Dual Compliance Framework
Educational use
When used by schools, SumHubs acts as a school official under FERPA and requires verifiable parental or school consent under COPPA for children under 13. ADA and Section 508 accessibility may apply.
Business use
When used outside education, SumHubs processes data under GDPR, CCPA, and equivalent laws. FERPA and COPPA do not apply in those contexts.
6. Children's Privacy
COPPA
Children under 13 may use the Service only with verified parental or school consent.
GDPR
In the European Union, parental consent is required for children under the age of consent set by national law, which may be between 13 and 16.
Deletion
If parental consent is not obtained, accounts will be deleted. SumHubs does not knowingly sell or share children's data.
7. User Rights
Parents and students
Rights to review, correct, or delete educational records are exercised through the school.
EU and UK users
Rights of access, rectification, erasure, restriction, data portability, and withdrawal of consent may apply.
California users
Rights to know categories of data collected, request deletion, opt out of sale or sharing of personal information, and request correction may apply.
Brazil and Canada
Equivalent GDPR-style rights may apply under LGPD, PIPEDA, or similar laws.
Requests can be made to support@sumhubs.com.
8. Data Security
We implement industry-standard safeguards, including:
- Encryption in transit and at rest.
- Role-based access controls.
- Administrative audit logging.
- Incident response procedures, including GDPR notification timelines where applicable.
- SOC 2 readiness for secure hosting.
9. Retention and Deletion
Educational data
Retained only as long as authorized by schools or required by law, and deleted upon school request.
Enterprise and business data
Retained as long as necessary for service provision, billing, or legal compliance.
Deletion requests
Users may request deletion at any time via support@sumhubs.com or in-app tools.
11. Marketplace Safeguards
Enterprise Users offering services through SumHubs must comply with marketplace rules. SumHubs may suspend or remove Enterprise accounts for fraud, scams, or unlawful conduct. Enterprise Users are responsible for refunds and chargebacks.
12. CSAE and Prohibited Content
SumHubs strictly prohibits child sexual abuse material (CSAM) or any form of child sexual abuse and exploitation (CSAE). Violations result in immediate termination and referral to appropriate reporting organizations and law enforcement where required.
13. International Data Transfers
For transfers outside the European Economic Area, United Kingdom, or Switzerland, SumHubs relies on legally recognized safeguards, including:
- Standard Contractual Clauses.
- UK Addendum or International Data Transfer Agreement.
- EU-U.S. Data Privacy Framework where applicable.
- Other legally recognized safeguards.
14. Mobile Applications
In-app purchases
Payments made via Apple App Store or Google Play Store are processed by those platforms, and refunds are governed by their policies.
Permissions
The app may request access to device features, such as camera, microphone, or location, solely for service functionality.
Data deletion
End Users may request deletion through in-app settings or by contacting support@sumhubs.com.
15. Data Processing Addendum
When acting as a data processor on behalf of an Enterprise User, SumHubs processes personal data in accordance with a Data Processing Addendum, available upon request. The DPA specifies roles, responsibilities, sub-processor disclosures, and transfer mechanisms.
16. Third-Party Services
The Service may integrate with third-party services, including hosting, analytics, payments, and platform APIs. SumHubs is not responsible for failures, security vulnerabilities, or damages caused by third-party services.
17. Accessibility
SumHubs is committed to accessibility and works to support WCAG 2.1 AA, ADA, and Section 508 standards where applicable.
19. Changes to this Policy
SumHubs may update this Policy from time to time. Notice may be provided via email, in-app alerts, or posting on our website. Continued use of the Service after updates constitutes acceptance.
20. Governing Language
This Policy is drafted in English. Any translations are provided solely for convenience. In the event of conflict, the English version controls.
21. Contact
SumHubs LLC
Email: support@sumhubs.com
Website: www.sumhubs.com