Privacy Policy
Last updated: March 16, 2026
Effective date: March 16, 2026
At Snack (“Openfire LLC DBA Snack,” “we,” “us,” or “our”), we take your privacy seriously. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, applications, and related services (collectively, the “Services”).
This Privacy Policy describes our practices, not a contract of consent. The legal basis for processing and your applicable rights depend on your jurisdiction and are described in the relevant sections below.
Use of the Services is governed by our Terms of Service.
1. Information We Collect
a. Information You Provide Directly
- Account & Profile Information: name, email address, profile picture, job title, and organization name when you create or update your account.
- Authentication Credentials: hashed passwords or identity-provider tokens (e.g., Google OAuth). We store passwords only in hashed form and do not store OAuth tokens beyond active session management.
- Content You Upload: videos, images, documents (PDFs, Office files), and other materials you create, upload, or record through the Services.
- Interactive Responses: answers to quizzes and knowledge-check questions within learning content.
- Billing Information: our PCI-compliant payment processor collects your payment method and billing details on our behalf. We do not store full card numbers on our servers.
- Communications: information you provide when contacting us for support, submitting feedback, or subscribing to newsletters.
b. Information Collected Automatically
- Device & Browser Data: browser type, operating system, screen resolution, and general device identifiers.
- Log Data: IP address, access times, pages visited, referring URLs, and HTTP request metadata.
- Learning Analytics: video watch progress, quiz responses, completion rates, and mastery scores.
- Diagnostic Data: error details, navigation breadcrumbs, and user agent string collected when application errors occur. This may include your user identifier and organization name.
- Analytics Data: we use first-party behavioral event data to understand route templates, key-action clicks, funnel steps, reload signals, and stuck or error indicators inside the product. We do not use session replay, heatmaps, form values, transcript text, or full URL query strings for this telemetry.
c. Information Processed by AI Features
If your organization enables AI-powered features (such as automatic transcription or AI-generated quiz questions), portions of your content, such as video audio and transcript text, are sent to our AI service providers for processing. All AI providers operate under zero-data-retention agreements, meaning they delete submitted content immediately after processing and do not use your content to train their models. See Section 3 for details.
d. Sensitive Personal Information
We do not intentionally collect sensitive personal information as defined under applicable privacy laws (such as precise geolocation, biometric identifiers, racial or ethnic origin, health data, or financial account numbers beyond payment processing). If you believe sensitive information has been submitted inadvertently, please contact us at support@snack.io and we will take steps to delete it.
Student personal information, including education records, is subject to enhanced protections described in Section 13.
2. How We Use Your Information
We use the information we collect only for the following purposes:
- Service Delivery & Operations: create and manage accounts, authenticate sessions, deliver video content, process uploads, and enable team collaboration.
- Billing & Subscriptions: process payments, manage subscription plans, and send billing communications.
- Learning & Analytics: track learning progress, generate engagement insights for learners and organization administrators, and personalize the learning experience.
- AI-Powered Features: transcribe video audio, generate quiz questions, and create content summaries when these features are enabled by your organization.
- Communications: send transactional messages such as invitations, assignment reminders, and account notifications.
- Security & Diagnostics: detect fraud, investigate errors, monitor service health, and maintain audit trails.
- Service Improvement: analyze first-party usage patterns such as route templates, key-action clicks, funnel steps, and stuck signals to improve existing features and develop new ones. Student and school data is never used for product improvement or development, including in anonymized or aggregated form.
- Legal Compliance: comply with applicable laws, respond to lawful requests, and enforce our Terms of Service.
4. Data Controller and Processor Roles
- Organization-Managed Accounts: when Snack is deployed by an organization (employer, school, or other entity), the organization is the data controller for its users’ personal information. Snack acts as a data processor, processing personal information according to the organization’s instructions and as described in any applicable Data Processing Agreement (DPA). Organizations may request a DPA by contacting support@snack.io.
- Direct Accounts: for users who create accounts directly (not through an organization), Snack is the data controller and determines the purposes and means of processing as described in this Privacy Policy.
6. Data Security
We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:
- Encryption of data in transit (TLS 1.2+) and at rest
- Role-based access controls and multi-factor authentication requirements for administrative access
- Immutable audit logging for sensitive administrative operations
- Regular security assessments and vulnerability monitoring
- Time-limited, signed URLs for access to stored media
- Logical separation of student data from non-educational customer data
No method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.
Breach Notification
In the event of a security breach that reasonably affects your personal information, we will notify affected customers and, where applicable, relevant authorities, without undue delay and as required by applicable law. For Educational Institution customers, we commit to notifying the affected institution promptly upon discovering a breach reasonably believed to involve student personal information, and in any case within the timeframe agreed in your contract or DPA. Customer-specific breach notification timelines are available in our DPA.
7. Data Retention
We retain personal information for as long as necessary to provide our Services, comply with legal obligations, resolve disputes, and enforce our agreements. The table below sets out our specific retention periods and criteria:
When you request deletion of your account, we initiate a 30-day grace period during which you can recover your account. After this period, your data is permanently deleted from our primary systems and purged from all backups within 90 days.
8. Your Rights and Choices
Depending on your location and applicable law, you may have some or all of the following rights regarding your personal information. To exercise any of these rights, please contact us at support@snack.io. We will respond within the timeframe required by applicable law and will not discriminate against you for exercising your rights.
a. Core Rights (All Users)
- Access: request a copy of the personal information we hold about you.
- Correction: request correction of inaccurate or incomplete information.
- Deletion: request deletion of your personal information, subject to legal retention requirements.
- Data Portability: download your content, analytics, and account data in a portable format.
- Opt-Out of Communications: unsubscribe from non-essential communications at any time using the unsubscribe link in our emails.
b. U.S. State Privacy Rights
Depending on the state in which you reside, additional rights may apply. The following rights are available to residents of states with comprehensive privacy laws (including California, Colorado, Connecticut, Texas, Virginia, and others):
- Right to opt out of the sale of personal information: we do not sell personal information, so this right is not triggered.
- Right to opt out of targeted advertising: we do not engage in cross-context behavioral advertising. This right is not triggered.
- Right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects: contact us at support@snack.io if you believe such profiling applies to you.
- Right to appeal: if we deny your privacy rights request, you may appeal by contacting support@snack.io with the subject line “Privacy Rights Appeal.” We will respond within the timeframe required by your state’s law.
- Authorized Agent: you may designate an authorized agent to submit requests on your behalf. We will verify the agent’s authority before processing the request.
- Universal Opt-Out Signals: where required by applicable state law (including Colorado), we honor recognized universal opt-out mechanisms such as Global Privacy Control (GPC) for non-essential data collection.
c. Identity Verification
To protect your privacy, we will verify your identity before processing access, correction, deletion, or portability requests. Verification may include confirming your email address, account details, or other information we have on file. We will not require you to create an account to submit a request.
9. California Privacy Rights
This section applies to California residents and supplements the rest of this Privacy Policy. It is provided pursuant to the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA).
a. Categories of Personal Information Collected
The table below describes the categories of personal information we collect, the sources, purposes, and parties to whom it is disclosed. We do not sell or share (as defined under California law) any categories of personal information.
b. Sensitive Personal Information
We do not collect sensitive personal information as defined under the CPRA (such as government IDs, precise geolocation, racial or ethnic origin, religious beliefs, union membership, health data, sex life or sexual orientation, or biometric data) except as incidentally submitted by users in uploaded content. We do not use or disclose sensitive personal information for purposes beyond providing the Services.
c. Retention Periods
Retention periods by category are set out in Section 7 above.
d. Do Not Sell or Share
We do not sell personal information for monetary consideration. We do not share personal information for cross-context behavioral advertising as defined under California law. Our first-party behavioral analytics do not use advertising features, third-party trackers, or session replay, and do not constitute “sharing” under California law.
e. Your California Rights
California residents have the right to know what personal information is collected and how it is used; correct inaccurate information; delete personal information; opt out of sale or sharing; limit use of sensitive personal information (not applicable here); and not be discriminated against for exercising these rights. To exercise these rights, contact us at support@snack.io or by mail at 2655 N Ocean Drive, STE 405, Singer Island, FL 33404.
10. International Data Transfers
Our Services are primarily hosted and operated in the United States. If you access the Services from outside the United States, your information will be transferred to and processed in the United States or other countries where our service providers operate, which may have different data-protection laws than your country of residence.
Our Services are primarily intended for users in the United States. We do not actively market to or target users in the European Union, United Kingdom, or Switzerland. If you are located in those regions and use our Services, please be aware that data transfers to the United States occur, and we will implement appropriate safeguards (such as Standard Contractual Clauses) if required by applicable law. Contact support@snack.io for more information.
As our Services expand internationally, we will update this section to address applicable legal bases, transfer mechanisms, and regional rights.
11. Children’s Privacy
Our Services are not directed to children under the age of 13 in a consumer context. We do not knowingly collect personal information from children under 13 outside of the school operator context described in Section 13. If you believe we have inadvertently collected information from a child under 13 outside of an Educational Institution context, please contact us immediately at support@snack.io and we will take prompt steps to delete such information.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, features, or applicable laws. We will notify you of material changes by posting the updated policy on our website, updating the “Last Updated” date above, and providing direct notification to organizational customers where required. Your continued use of our Services after any changes indicates your acknowledgment of the updated Privacy Policy.
13. Education & Student Privacy
Snack is committed to protecting the privacy of students and complying with all applicable federal and state education privacy laws. This section applies to schools, school districts, and other educational institutions (“Educational Institutions”) that use our Services.
a. FERPA Compliance
Snack acknowledges that Educational Institutions may share “education records” as defined by the Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. § 1232g. When an Educational Institution provides student education records to Snack, we act as a “school official” with a “legitimate educational interest” as those terms are defined under FERPA, and only where the Educational Institution retains direct control over Snack’s use and maintenance of those education records through its contract and instructions. In this capacity, Snack will:
- Not disclose education records to third parties without the prior written consent of the Educational Institution, except as permitted by FERPA or required by law.
- Use education records solely to provide and support the Services as directed by the Educational Institution.
- Allow the Educational Institution to inspect, review, and request correction of education records in our possession upon written request.
- Return or delete education records upon termination of services, as directed by the Educational Institution.
b. COPPA — School Operator Consent
Snack’s Services may be used by Educational Institutions that serve students under the age of 13. Where this is the case, Snack relies on the school-operator consent model under the Children’s Online Privacy Protection Act (COPPA), 15 U.S.C. § 6501 et seq. Under this model:
- Snack provides Educational Institutions with the operator disclosures required by COPPA so that the institution may provide informed authorization on behalf of parents and guardians.
- Snack collects and uses personal information from children under 13 only for school-authorized educational purposes and only to the extent necessary to provide the Services to the institution.
- Snack does not use children’s personal information for commercial purposes, advertising, or any purpose outside the school-authorized educational context.
- Educational Institutions represent and warrant that they have obtained all necessary parental consents and authorizations before allowing students under 13 to access the Services, and that use of the Services complies with their obligations under COPPA.
- Parents and guardians may request to review, correct, or delete their child’s personal information through the Educational Institution or by contacting us directly at support@snack.io.
c. Prohibition on Commercial Use of Student Data
Snack will not use any student personal information, including education records, learning analytics, quiz responses, or any other data generated by student users, for the following purposes:
- Targeted advertising or behavioral profiling of students or their families
- Sale or rental to third parties
- Product improvement, product development, or any internal research purpose
This prohibition is absolute and applies regardless of whether the data has been deidentified or aggregated.
d. State Student Privacy Laws
Snack is designed to support compliance with applicable state student data privacy laws, including:
- California: Student Online Personal Information Protection Act (SOPIPA) and CCPA/CPRA where applicable.
- New York: Education Law § 2-d and its implementing regulations.
- Other States: we contractually support school- and district-specific requirements under applicable state student privacy laws. If your state has specific requirements not addressed here, contact us at support@snack.io and we will work with you to meet your district’s needs.
e. PPRA
To the extent that Snack’s Services are used to administer surveys, evaluations, or assessments to students, Educational Institutions are responsible for ensuring compliance with the Protection of Pupil Rights Amendment (PPRA), 20 U.S.C. § 1232h, including obtaining any required parental consent prior to administering such activities.
f. Data Security for Student Information
In addition to the general security measures described in Section 6, Snack implements the following safeguards specifically for student data:
- Access to student information is restricted to authorized personnel who require it to perform their job functions.
- Student data is logically separated from non-educational customer data.
- We will notify affected Educational Institutions of any confirmed breach involving student personal information without undue delay and within the timeframe specified in your contract or DPA.
g. Contact for Education Privacy Matters
Educational Institutions with questions, concerns, or data requests regarding student privacy may contact us directly:
Openfire LLC DBA Snack
2655 N Ocean Drive, STE 405, Singer Island, FL 33404
Email: support@snack.io
Phone: 502-617-6225
14. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
Openfire LLC DBA Snack
2655 N Ocean Drive, STE 405, Singer Island, FL 33404
Privacy Inquiries & General Support: support@snack.io
Phone: 502-617-6225
Jurisdiction: Florida, United States
For Data Processing Agreements or sub-processor lists, please contact support@snack.io with the subject line “DPA Request.”