Last Updated: June 10th, 2025

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1. Purpose and Scope

This Data Deletion Policy outlines the procedures followed by Speakable Technologies, Inc. (“Speakable”) for the return and destruction of student data (“Student Data”) collected during the provision of educational technology services. This policy is designed to comply with applicable data privacy laws, including New York Education Law § 2-d, and reflects industry best practices, including the NIST Special Publication 800-88 Revision 1: Guidelines for Media Sanitization.

This policy applies only under the following conditions:

• The customer is located in a jurisdiction that mandates data deletion or return upon service termination (e.g., New York State); or
• The customer has executed a contract or data privacy agreement (DPA) with Speakable that includes data deletion or return requirements.

This policy does not apply to customers or users outside those circumstances, unless otherwise agreed in writing.

2. Deletion or Return of Data Upon Contract Termination

When required by law or by the terms of a contract or DPA, Speakable will, within sixty (60) days of the expiration or termination of the service agreement:

• Return Student Data to the customer in a reasonably accessible format, or
• Securely delete Student Data in accordance with this policy.

The method, return or deletion, shall be determined based on the applicable contract terms or, in the absence of express language, by written election of the customer.

Unless otherwise required by law or agreement, no deletion or return will occur automatically without direction from the customer.

3. Deletion Upon Written Request

Speakable will honor written requests for the return or deletion of Student Data submitted by any educational institution or organization using its services, regardless of whether deletion is legally required.

Such requests must:

• Be submitted in writing by an authorized representative; and
• Be sent to hello@speakable.io

Speakable will complete the deletion or return within sixty (60) days of receipt, in accordance with a mutually agreed process.

This section does not apply to individual users or to student-created accounts not provisioned or managed by a school or educational institution.

4. Exclusions from Deletion

This policy does not require deletion of:

• De-identified Data: Student Data that has been de-identified in accordance with applicable law and industry standards. Speakable will not attempt to re-identify such data or transfer it to any third party.
• Student-Controlled Accounts: Student data associated with accounts created and managed independently by students outside of a school or district relationship.

5. Secure Data Destruction Standards

When data is deleted pursuant to this policy, Speakable adheres to the data sanitization standards outlined in NIST SP 800-88 Rev. 1, including:

• Electronic Media: Secure wiping, cryptographic erasure, or physical destruction of storage media
• Physical Media: Shredding, incineration, or similar means ensuring permanent data loss
• Backups and Archives: Student Data is purged from backup systems in the next scheduled cycle, typically within thirty (30) days

Note: Redaction is not an acceptable method of destruction.

6. Certification of Deletion

Where required by law, contract, or upon written request, Speakable will provide the customer with a written certification confirming the completion of data return or secure deletion. This certification will include:

• The date of deletion
• The method used
• A summary of the data types deleted

‍7. Contact Information

Questions or deletion requests may be directed to:

Speakable Technologies, Inc.

1606 Headway Circle, Suite 9278, Austin, Texas 78754

Email: hello@speakable.io

8. Amendments to this Policy

Speakable reserves the right to modify this policy from time to time. Revisions will not affect previously executed contracts or statutory obligations in effect at the time of service. Any changes to this policy will be published at www.speakable.io/privacy or made available upon request.

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