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Privacy Policy

Working draft. This Privacy Policy is being finalized with our legal counsel before public launch. The substance below reflects how we intend to operate. Questions in the meantime? Use our contact form.

Last updated: June 18, 2026. Effective: upon final counsel review.

1. Who We Are and Scope of This Policy

Social World, LLC ("SoWo," "we," "us," or "our") is a learning company that builds an AI-powered, facilitator-led language-learning web application for teachers and learners. We are a limited liability company registered in Colorado, United States. Our website is joinsowo.com (currently served at social-world.odoo.com).

This Privacy Policy explains what personal information we collect, how and why we use it, who we share it with, and the choices and rights you have. It applies to our website, our application, and the services we provide (together, the "Services").

This policy covers personal information about facilitators, administrators, learners (including minors who use SoWo through a school or with parental consent), and visitors. Where SoWo is provided to a learner through a school or district, the school or district directs how student information is used, and Section 11 (Student Records) applies.

Questions? Reach us through our contact form.

2. Information We Collect

We collect only what we need to make SoWo work, to keep it safe, and to improve it: information you (or your school) give us, information we collect automatically, and information from the providers that help us operate.

2.1 Information you provide

  • Account information. Name, email, role (facilitator, learner, administrator), school or program, password.
  • Learner content. Writing samples, speech recordings, responses to practice prompts, and other work created in the app.
  • Payment information. When payment processing is activated, billing is handled by Stripe. We do not store full card numbers.
  • Communications. Emails, support tickets, survey responses.

2.2 Information we collect automatically

  • Usage and analytics data. Which features you use, how long, what worked, what you skipped.
  • Device and connection data. IP address, browser and device type, operating system, collected through cookies (see Section 7).

2.3 Categories of personal information

Categories we collect include: identifiers (name, email); account and education-related information (role, school); commercial information (subscription and billing records); audio and electronic information (speech recordings, learner content); and internet or network activity information (usage data). Some, such as speech recordings, may be sensitive personal information under certain laws.

3. How and Why We Use Information

  • Deliver SoWo to you and your learners.
  • Personalize learning based on each learner's baseline, level, and goals (see Section 6).
  • Support facilitators with insights about their classes.
  • Improve features, fix bugs, maintain security, and build what educators ask for.
  • Communicate about SoWo (updates, billing, support).
  • Process payments and keep billing records (when active).
  • Comply with legal obligations and enforce our agreements.

We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We do not use student or learner data for advertising.

4. Legal Bases for Processing (EU/UK)

If you are in the EEA, the UK, or Switzerland, we process personal information only with a valid legal basis: performance of a contract; legitimate interests (to operate, secure, and improve SoWo); consent (e.g., non-essential analytics cookies; withdrawable anytime); and legal obligation. Where SoWo is deployed by a school, the school is generally the controller of student data and we act as a processor (or, under FERPA, a "school official") on the school's instructions. See Section 11.

5. How We Share Information

We share the minimum necessary with the providers (subprocessors) that help us run SoWo, who are contractually bound to protect it and use it only to provide services to us:

  • Hosting and CRM. Odoo.
  • Payments. Stripe, when activated. No full card numbers stored.
  • AI service providers. our third-party AI service providers, for the features in Section 6.
  • Analytics providers. our analytics provider. You can opt out of non-essential analytics (Section 7).

A current list of our subprocessors is available on request by emailing us.

We may also share information to comply with law or valid government requests; to protect the rights, safety, and security of SoWo, our users, and the public; and in a merger, acquisition, financing, or sale of assets (we will require the recipient to honor this policy or notify you of material changes).

We do not sell personal information, and we do not share it for cross-context behavioral advertising.

6. Artificial Intelligence and Automated Processing

SoWo uses artificial intelligence to generate practice content and personalize learning.

  • How AI is used. Learner content and certain account information may be processed by our AI providers to generate and personalize content.
  • Training stance. We do not use student or learner content to train third-party AI models.
  • No solely automated significant decisions. We do not use AI to make decisions producing legal or similarly significant effects without human involvement. AI supports facilitators and learners; it does not replace the educator's judgment.

7. Cookies and Tracking Technologies

  • Essential cookies. Keep SoWo working (sign-in, session). These cannot be turned off through our controls.
  • Analytics cookies. Help us understand and improve SoWo. Non-essential; you can decline them.

Manage non-essential cookies through our cookie banner and your browser. Where required by law, we honor browser opt-out signals, including Global Privacy Control (GPC), as a request to opt out of sale or sharing from that browser or device. We do not use advertising cookies and do not engage in cross-context behavioral advertising.

8. Your Privacy Rights (General)

Depending on where you live, you may have rights to: access a copy of your information; correct it; delete it (subject to legal exceptions); port or export it; object to or restrict certain processing; and withdraw consent where we rely on it. To exercise rights, contact us using Section 17. If your information is managed by a school or district, we may direct the request to them or fulfill it on their instructions. We will not discriminate against you for exercising your rights.

9. United States State Privacy Rights

9.1 California (CCPA/CPRA)

California residents have rights under the CCPA, as amended by the CPRA. We collect the categories in Section 2.3 from you directly, from your school or program, and automatically through use of the Services, and we use them for the purposes in Section 3 and disclose them for business purposes to the providers in Section 5. Some information (speech recordings, credentials) may be sensitive personal information, which we use only to provide and improve the Services and for other permitted purposes. You have the right to know/access, delete, correct, opt out of sale or sharing, and limit the use of sensitive personal information, and to use an authorized agent (subject to verification). To request that we limit the use of your sensitive personal information, contact us using the details in Section 17. We do not sell or share personal information as defined under California law, and not for consumers under 16. We will not discriminate against you for exercising rights.

9.2 Colorado, Virginia, Connecticut, and Other States

Residents of Colorado, Virginia, Connecticut, and other states with comprehensive privacy laws may have rights to confirm and access, correct, delete, obtain a portable copy, and opt out of sale, targeted advertising, and certain profiling. We do not sell personal data and do not use it for targeted advertising. Where required, we honor universal opt-out mechanisms including Global Privacy Control. If we deny a request, we will provide appeal instructions, and you may contact your state attorney general.

10. Children's Privacy (COPPA)

Protecting children's information is central to SoWo. Children under 13 cannot create their own SoWo accounts.

  • School-consent model. In a school setting, the school may consent on behalf of parents to collection of a student's personal information for the use and benefit of the school's educational program, consistent with COPPA, acting as the parent's agent.
  • Verifiable parental consent. Outside a school relationship, we do not knowingly collect personal information from children under 13, and we do not offer individual (non-school) accounts to children under 13.
  • Limited use. We use children's information only to provide and support the educational Services, not for advertising or unrelated commercial purposes.
  • Parental rights. A parent, or a school acting on their behalf, may review the child's information, request deletion, and refuse further collection.

If you believe a child under 13 provided information without appropriate consent, contact us through our contact form and we will delete it.

11. Student Records (FERPA) and School Responsibilities

  • School official role. Where a school designates SoWo as a "school official" with a "legitimate educational interest" under FERPA, and we have a written data-protection agreement in place, we perform a service the school would otherwise perform itself, using student education records only for the authorized educational purposes the school directs, under the school's control.
  • No secondary use. We do not sell student data, do not use it for advertising or commercial profiles, and do not use student or learner content to train third-party AI models. We do not share student records outside the providers in Section 5.
  • School and facilitator responsibilities. Schools, districts, and facilitators are responsible for obtaining required consents, designating SoWo as a school official where they rely on that exception, using the Services consistent with FERPA and state student-privacy laws, and managing access within their organization.
  • Access and deletion. Parents and eligible students should direct requests to their school or district, which we will support per our agreement and applicable law.

12. International Data Transfers

SoWo is operated from the United States; information may be processed in the US and other countries where we or our providers operate. When we transfer personal information out of the EEA, UK, or Switzerland, we rely on appropriate safeguards such as the Standard Contractual Clauses (and the UK IDTA where applicable). You have the rights in Sections 4 and 8 and the right to lodge a complaint with your supervisory authority. Where an EU or UK representative is required, we will identify one and update this policy.

13. Data Retention

  • Account data. Kept while your account is active; deleted within 90 days of closure unless we must keep it longer for legal, tax, or accounting reasons.
  • Learner content. Retained as long as needed to track progress; you or your school can request earlier deletion.
  • Other records. Communications and billing kept as needed for support, recordkeeping, and compliance.

14. Security

We use encryption in transit (HTTPS/TLS) and at rest, restrict access to those who need it, and maintain administrative, technical, and physical safeguards. No method is completely secure, but we work to protect your information and improve our safeguards. If we discover a breach affecting your information, we will notify you and the authorities as required by law.

15. Information We Do Not Collect or Do

  • We do not sell personal information.
  • We do not share personal information for cross-context behavioral advertising, and do not use advertising cookies.
  • We do not use student or learner data for advertising or to build advertising profiles.
  • We do not use student or learner content to train third-party AI models.
  • We do not make solely automated decisions producing legal or similarly significant effects about you.

16. Changes to This Policy

If we make material changes, we will notify you by email and post the updated policy here at least 30 days before it takes effect. The "Last updated" date shows the latest revision. For material changes, we will ask you to affirmatively accept the updated policy before you continue using SoWo. Continued use after the effective date means you accept the update.

17. How to Contact Us and Exercise Your Rights

For privacy questions or to exercise rights, contact us through our contact form. For general inquiries, see our Contact page. Our mailing address is available on request. We respond to verifiable requests within the time required by law, generally 30 to 45 days, and may need to verify your identity (or an agent's authority). Where information is controlled by a school or district, we may direct your request to them.