Privacy Policy

1. Zero Learner PII Architecture (All Subscription Tiers)

When an enterprise learner launches a SCORMShield dispatch connector from an LMS (such as Workday, Cornerstone, SAP SuccessFactors, Canvas, or Moodle), SCORMShield never records, logs, or stores student personally identifiable information on our servers.

• Edge Pseudonymization: Learner student IDs (cmi.core.student_id) and student names (cmi.core.student_name) emitted by the host LMS are cryptographically pseudonymized using salted one-way HMAC-SHA256 hashing directly at runtime edge.
• No Demographic or Sensitive Data: We do not collect Social Security numbers, dates of birth, employee payroll records, emails, or demographic classifications.
• Direct LMS Gradebook Commit: CMI progress metrics (e.g. lesson status, raw score, session time) synchronize back directly to the client LMS through standard SCORM API mechanisms.

2. Dynamic Runtime Watermarking & In-Memory Rendering

Our Dynamic Learner Watermarking feature renders a visible or forensic watermark overlay on course video/HTML5 canvas during runtime. This overlay operates strictly in the client’s local browser memory using short-lived session claims provided by the host LMS. No student names or personal identifiers are written to disk or stored in SCORMShield backend databases to generate watermarks.

3. Information We Collect from Publishers (Customers)

To provide the Service to course publishers, we collect limited business account information:

• Account Registration: Name, work email address, and encrypted password hash (bcrypt).
• Billing & Payments: Payment processing is handled entirely by our payment processor, Stripe, Inc. We store only Stripe customer IDs and subscription status tokens; we never receive or store full credit card numbers or bank account credentials.
• Course & License Metadata: Course titles, SCORM standard versions, active connector license keys, allowed domain whitelists, and seat quotas.

4. Authorized Sub-Processors & Infrastructure Controls

SCORMShield engages third-party infrastructure sub-processors that maintain industry-standard security certifications (SOC 2 Type II, ISO 27001):

5. Cookies & Telemetry Disclosures

SCORMShield uses strictly necessary first-party cookies for session authentication (scormshield_session). We use Vercel Analytics for privacy-preserving aggregate performance monitoring, which collects zero personal identifiers, does not use tracking cookies across websites, and complies fully with GDPR without requiring cookie banners.

6. GDPR Compliance & Data Subject Rights

For publishers and contacts located in the European Economic Area (EEA) and the United Kingdom, you have the right to:

• Request access to the personal data we hold about your publisher account.
• Request rectification of inaccurate account details.
• Request erasure (“Right to be Forgotten”) of your publisher account data.
• Export your course metadata and license configurations in a structured, portable format.

To exercise any of these rights, email privacy@scormshield.com. We respond to all verified requests within thirty (30) days.

7. California Consumer Privacy Act (CCPA / CPRA) Notice

SCORMShield does not sell, rent, or share personal information with third parties for cross-context behavioral advertising. We collect personal information only for business purposes as described in this policy. California residents may submit data requests by contacting our privacy team.

8. FERPA Compliance & Higher Education Certification

Under the Family Educational Rights and Privacy Act (34 CFR Part 99), educational records must remain protected. Because SCORMShield pseudonymizes learner telemetry at the edge and never records student names or education records, publishers distributing courses to colleges, universities, and K-12 school districts can deploy SCORMShield dispatch connectors without breaching FERPA data custodian restrictions.

9. Data Security, Encryption & Retention

All communications are encrypted in transit using TLS 1.3 and at rest using AES-256. Publisher accounts and license configurations are retained for the duration of your active subscription and deleted within ninety (90) days following account closure upon written request.

10. Data Protection Officer & Inquiries

For Data Processing Agreements (DPA), custom enterprise security questionnaires, or privacy officer communications: