Bullseye, LLC understands that your privacy is important to you. We are committed to protecting the privacy of your personally-identifiable information as you use this website. This Privacy Policy tells you how we protect and use information that we gather from you. By using this website, you consent to the terms described in the most recent version of this Privacy Policy. You should also read our Terms of Use to understand the general rules about your use of this website, and any additional terms that may apply when you access particular services or materials on certain areas of this website. “We,” “our” means Bullseye, LLC and its affiliates. “You,” “your,” visitor,” or “user” means the individual accessing the Services. This Privacy Policy applies to the Bullseye website and to the Bullseye platform and related services (collectively, the “Services”). For school and district customers, the collection, use, and protection of district and student data is governed by any Data Privacy Agreement and/or AI Supplement entered into between Bullseye and the district. In the event of any conflict between this Privacy Policy and any applicable Data Privacy Agreement and/or AI Supplement, the Data Privacy Agreement and/or AI Supplement controls with respect to district and student data.

PERSONAL AND NON-PERSONAL INFORMATION

Our Privacy Policy identifies how we treat your personal and non-personal information.

WHAT IS NON-PERSONAL INFORMATION AND HOW IS IT COLLECTED AND USED?

Non personal information is information that cannot identify you. If you visit this web site to read information, such as information about one of our services, we may collect certain non-personal information about you from your computer’s web browser. Because non-personal information cannot identify you, we may use and share it for purposes such as analytics, research, and improving the Services. We do not attempt to re-identify de-identified or aggregated information, and we require any party with whom we share such information to agree not to re-identify it. What is personal information and how is it collected? Personal information is information that identifies you as an individual, such as your name, mailing address, e-mail address, telephone number, and fax number. We may collect personal information from you in a variety of ways:

• When an educator or administrator registers for or is provisioned an account on the Services. 

• When a school or district provides information to us in connection with an agreement for the Services. 

• When you enter observation, coaching, or related content into the platform. 

• When you contact us with a request, inquiry, or support matter, or sign up to receive information from us..

ARE COOKIES OR OTHER TECHNOLOGIES USED TO COLLECT PERSONAL INFORMATION?

Yes, we may use cookies and related technologies, such as web beacons, to collect information on our web site. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you register with us, a cookie helps Bullseye, LLC to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Bullseye, LLC website, the information you previously provided can be retrieved, so you can easily use the features that you customized. A web beacon is a small graphic image that allows the party that set the web beacon to monitor and collect certain information about the viewer of the web page, web-based document or e-mail message, such as the type of browser requesting the web beacon, the IP address of the computer that the web beacon is sent to and the time the web beacon was viewed. Web beacons can be very small and invisible to the user, but, in general, any electronic image viewed as part of a web page or e-mail, including HTML based content, can act as a web beacon. We may use web beacons to count visitors to the web pages on the web site or to monitor how our users navigate the web site, and we may use similar technologies in our own communications to understand whether messages were delivered and opened.

Third party vendors also may use cookies on our web site. For instance, we may contract with third parties who will use cookies on our web site to track and analyze anonymous usage and volume statistical information from our visitors and members. Such information is shared externally only on an anonymous, aggregated basis. These third parties use persistent cookies to help us to improve the visitor experience, to manage our site content, and to track visitor behavior. We may also contract with a third party to send e-mail to our registered users/members.

To help measure and improve the effectiveness of our e-mail communications, the third party sets cookies. All data collected by this third party on behalf of Bullseye, LLC is used solely by or on behalf of Bullseye, LLC and is shared externally only on an anonymous, aggregated basis. 

Bullseye does not display third-party advertising on the website or platform, and does not permit third-party advertising networks or ad servers to collect information through the Services. Bullseye does not use any information collected through the Services, including any student, district, or educator account data, for targeted, behavioral, or any other advertising. Separately, Bullseye markets its own products to schools, districts, and education professionals. This marketing may use business and prospect contact information that Bullseye obtains from third-party data providers, and Bullseye may provide that contact information to advertising platforms in order to present Bullseye’s own products to potential customers. This marketing activity does not use any information collected through the Services. The cookies we use are limited to those necessary to operate the Services and those that help us understand and improve how the Services are used.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Bullseye, LLC websites you visit.

HOW DOES BULLSEYE, LLC USE PERSONAL INFORMATION?

Bullseye, LLC may keep and use personal information we collect from or about you to provide you with access to this web site or other products or services, to respond to your requests, to bill for the Services under an applicable agreement, to provide ongoing service and support, to contact you with information about Bullseye’s products and services, to ask for your feedback about our products, and for record keeping, analytical, research, and product improvement purposes.

Personal information collected online may be combined with information you provide to us through other sources We may also remove your personal identifiers (your name, email address, social security number, etc). In this case, you would no longer be identified as a single unique individual. Once we have de-identified information, it is non-personal information and we may treat it like other non-personal information. We do not attempt to re-identify information that has been de-identified. Finally, we may use your personal information to protect our rights or property, or to protect someone’s health, safety or welfare, and to comply with a law or regulation, court order or other legal process.

ARTIFICIAL INTELLIGENCE AND AUTOMATED PROCESSING

Certain features of the Bullseye platform use artificial intelligence and machine learning technologies (“AI Features”) to assist educators with observation analysis, coaching recommendations, instructional trend identification and content creation capabilities such as rephrasing, shortening, or elaborating observation notes, generating next steps from text, and processing custom prompts. This section describes how these technologies interact with your data.

How AI Features Work. When you use AI-assisted features within Bullseye, the observation or coaching data you are working with may be processed by our AI systems. Before any data is transmitted to our AI sub-processors, Bullseye applies automated pre-processing controls designed to remove personally identifiable information, including student and teacher names, from the data (“Name Scrubbing”). For free-text fields such as observation notes, Bullseye uses Named Entity Recognition (NER) technology to detect person names and replace them with anonymous placeholders. For structured data fields, Bullseye anonymizes personally identifiable information using fixed logic prior to transmission. Images are filtered out entirely and are never transmitted to AI sub-processors. Only de-identified observation text is transmitted to the AI sub-processor for analysis.

AI Sub-Processors. AI Features are provided through the following third-party large language model providers: OpenAI, Inc.; Anthropic, PBC; and Google LLC (each, an “AI Sub-Processor”).. Our agreement with each AI Sub-Processor requires that: (a) all data is processed within the United States; (b) customer data is not used to train, tune, or improve the provider’s AI models; (c) input and output data is not retained beyond the processing session, and metadata is retained for no more than ninety (90) days for abuse monitoring purposes and then permanently deleted; (d) data is encrypted in transit and at rest; and each AI Sub-Processor maintains SOC 2 Type 2 and ISO 27001 compliance certification. Bullseye has opted out of all AI Sub-Processors’ service improvement and model training programs. Confirmation of these opt-outs is available upon request.

Teacher and Performance Data. Because Bullseye is a teacher coaching and observation platform, the data processed by AI Features may include teacher performance observation data, coaching feedback, and related professional development information. In jurisdictions where teacher evaluation or performance review data (such as APPR Data under New York Education Law or Teacher Data under New Hampshire law) carries specific statutory protections, Bullseye applies the same de-identification, security, and sub-processor safeguards to teacher data as it does to any other data processed through the platform.

No Student Data Collection. Bullseye is designed as an administrator and teacher-facing platform and is not designed or intended to collect student data. To the extent that student names or identifiers may be incidentally present in observation notes entered by users, Bullseye’s Name Scrubbing controls are designed to strip such information before it is transmitted to AI sub-processors.

No Model Training. Neither Bullseye nor its AI sub-processors use your data, observation content, coaching feedback, or any derivative thereof to train, tune, or improve AI or machine learning models. Bullseye has opted out of all AI sub-processors’ service improvement and model training programs. Confirmation of these opt-outs is available upon request.

Opt-Out. AI Features are not enabled by default. AI Features are configurable at the district administrator level and are enabled only upon district opt-in through district configuration settings or by contacting a Bullseye Customer Success Manager. Disabling AI Features does not affect access to the core Bullseye platform.

Additional Information. For a complete description of AI data flows, sub-processor commitments, security safeguards, and technical architecture, please see our AI Supplement at https://bullseye.education/bullseye-ai-supplement/.

DOES BULLSEYE, LLC SHARE PERSONAL INFORMATION WITH OTHERS?

We will not share your personal information collected from this web site with an unrelated third party without your permission, except as otherwise provided in this Privacy Policy. In the ordinary course of business, we may share some personal information with companies that we hire to perform services or functions on our behalf. In all cases in which we share your personal information with a third party for the purpose of providing a service to us, we will not authorize them to keep, disclose or use your information with others except for the purpose of providing the services we asked them to provide. This includes the transmission of de-identified observation and coaching data to our AI sub-processor as described in the Artificial Intelligence and Automated Processing section above. Our AI sub-processor is contractually required to use such data solely for the purpose of providing analytical services to Bullseye and is prohibited from using the data for any other purpose, including model training.

We do not sell, rent, lease, or trade your personal information. We may transfer personal information in connection with a merger, acquisition, sale of assets, or similar transaction, and in any such transaction, we will require the successor to agree to be bound by the commitments in this Privacy Policy with respect to personal information. 

We may be legally compelled to release your personal information in response to a court order, subpoena, search warrant, law or regulation.

We may cooperate with law enforcement authorities in investigating and prosecuting web site visitors who violate our rules or engage in behavior, which is harmful to other visitors (or illegal). We may disclose your personal information to third parties if we feel that the disclosure is necessary to protect our rights or property, protect someone’s health, safety or welfare, or to comply with a law or regulation, court order or other legal process. 

HOW IS PERSONAL INFORMATION USED FOR COMMUNICATIONS?

We may contact you periodically by e-mail, mail or telephone to provide information regarding programs, products, services and content that may be of interest to you. In addition, some of the features on this web site allow you to communicate with us using an online form. If your communication requests a response from us, we may send you a response via e-mail. The e-mail response or confirmation may include your personal information. We cannot guarantee that our e-mails to you will be secure from unauthorized interception.

HOW IS PERSONAL INFORMATION SECURED?

We may contact you with information about the Services, your account, and Bullseye’s products and services. You may opt out of promotional communications at any time by following the unsubscribe instructions in the message or by contacting us at the address below. We will continue to send communications necessary to administer your account and the Services. We encrypt personal information in transit and at rest and maintain administrative, technical, and physical safeguards designed to protect it. In the event of a security incident affecting personal information, we will notify affected customers and individuals as required by applicable law and by any applicable Data Privacy Agreement.  Only authorized personnel and third-party vendors have access to your personal information, and these employees and vendors are required to treat this information as confidential. Despite these precautions, we cannot guarantee that unauthorized persons will not obtain access to your personal information.

HOW LONG IS PERSONAL INFORMATION RETAINED?

We retain personal information only for as long as necessary to provide the Services, to comply with our legal obligations, to resolve disputes, and to enforce our agreements.For school and district customers, the collection, use, and protection of student, educator, and other district data is governed by any Data Privacy Agreement (DPA) and/or AI Supplement entered into between Bullseye and the school or district. If there is any conflict between this Privacy Policy and an applicable DPA or AI Supplement, the DPA or AI Supplement controls with respect to that data.

LINKS

This site contains links to other sites that provide information that we consider to be interesting. Bullseye, LLC is not responsible for the privacy practices or the content of such web sites.

HOW CAN A USER ACCESS, CHANGE, AND/OR DELETE PERSONAL INFORMATION?

You may access, correct, update, and/or delete any personally-identifiable information that you submit to the web site. You may also unsubscribe from mailing lists or any registrations on the web site. To do so, please either follow instructions on the page of the web site on which you have provided such information or subscribed or registered or contact us at info@bullseyeedu.com.

YOUR PRIVACY RIGHTS

Depending on where you live, you may have rights under applicable privacy laws, such as the the California Consumer Privacy Act as amended by the California Privacy Rights Act, and similar state laws. These rights may include the right to access, correct, or delete personal information, and the right to opt out of the sale of personal information or of targeted advertising. Bullseye does not sell personal information and does not engage in targeted advertising using personal information or any information collected from or through the Services. To exercise any applicable right, contact us at info@bullseyeedu.com. Where personal information was provided to us by, or is controlled by, a school or district, we will direct your request to that school or district and support it as provided in any applicable Data Privacy Agreement.

CHILDREN’S PRIVACY

Bullseye operates as an administrator and teacher-facing platform under the direction of the schools and districts it serves, and does not intentionally collect personal information (such as a child’s name or email address) from children under the age of 13.  If you think that we have collected personal information from a child under the age of 13, please contact us. Bullseye’s AI Features do not intentionally process data about or from children under the age of 13. To the extent that student names or other child-identifying information may be incidentally present in observation notes, Bullseye’s Name Scrubbing controls are designed to remove such information before it is transmitted to AI sub-processors.

CHANGES

This Privacy Policy is effective as of the Last Updated date shown above.

Bullseye, LLC reserves the right to modify this statement at any time. Any changes to this Privacy Policy will be listed in this section, and if such changes are material, a notice will be included on the homepage of the web site for a period of time. If you have any questions about privacy at any websites operated by Bullseye, LLC or about our website practices, please contact us at: info@bullseyeedu.com. If your personal information was provided to us by, or is controlled by, a school or district, you should direct access, correction, or deletion requests to that school or district, and we will support the request as directed and consistent with the applicable Data Privacy Agreement.