Privacy Policy

    How SAM Labs collects, uses, and protects your information.

    Last updated: October 1, 2026

    SAM Labs Inc. ("SAM Labs," "we," "us," or "our") respects your privacy. This Privacy Policy explains how we collect, use, share, and protect personal information when you visit our websites, contact us, buy our products, or use our software platforms.

    This Privacy Policy applies to:

    • our websites, including samlabs.com, and related marketing pages, forms, and communications;
    • SAM Studio, our coding and STEAM learning platform;
    • FRST (Future-Ready Skills Tracker), our platform for recording and reporting on students' future-ready skills;
    • SAM Code, our Scratch-based coding platform for SAM Labs customers;
    • other SAM Labs apps and online services that link to this policy (together with SAM Studio, FRST, and SAM Code, the "Services").

    When a school, district, or other educational institution uses our Services, our written agreement with that institution (including any data privacy or data processing agreement) also applies. If that agreement conflicts with this policy, the agreement controls. For more about children and students, see our Child Privacy Policy.

    1. Our Role

    How we handle personal information depends on whose information it is and why we have it.

    • School and student data. When a school, district, or other educational institution uses SAM Studio, FRST, or SAM Code, we process student and educator information on behalf of, and under the direction of, that institution. The institution decides what information is entered and how it is used. Where FERPA applies, we act as a "school official" with a legitimate educational interest. Under EU and UK data protection law, the institution is the controller and SAM Labs is a processor.
    • Our own business data. For website visitors, prospective customers, purchasers, partners, and people who contact us, SAM Labs decides how the information is used. Under EU and UK data protection law, SAM Labs is the controller of this information.

    2. Information We Collect

    We may collect the following types of information:

    • Contact and communication information, such as name, email address, phone number, school or organization, job title, country, and messages you send us through forms, email, support channels, surveys, or events.
    • Account information, such as login details, user ID, username, school or district affiliation, and classroom or group information. Accounts may be created by a school, district, teacher, or administrator, through rostering or single sign-on (SSO) services, or by adult users directly.
    • Educational and student record information, such as lesson activity, student projects and code, skill and competency information (including educator-entered observations, scores, and notes on future-ready skills), audio observations, uploaded images or files, classroom or group information, progress and growth reports, and related educational records.
    • Product and service-use information, such as usage logs, device interactions (including with SAM Labs hardware), feature activity, error reports, support requests, and related service data.
    • Transaction and order information, such as billing details, shipping address, purchase history, and payment-related information. Payments may be processed by third-party payment providers.
    • Technical information, such as IP address, browser type, device type, operating system, referring URLs, pages visited, timestamps, and cookie or similar identifiers.

    We do not intentionally collect more personal information than is reasonably necessary for the purposes described in this Privacy Policy.

    Our Services are not designed to collect sensitive information, such as health, disability, disciplinary, or biometric information, or government ID numbers. Educators should not enter this kind of information unless their school has authorized it and it is needed for an educational purpose.

    Images, audio, and uploaded files

    Some Services, including FRST, allow educators to record audio or upload images and files as evidence of student learning. This content may show or identify students.

    • Educators and schools are responsible for making sure they have any notice, consent, or authorization required by school policy or applicable law before recording or uploading content, and for uploading only content needed for an educational purpose.
    • We store this content only to provide the Services to the school or district. We do not use images or audio for facial recognition, voice recognition, or any other biometric identification, and we do not use them for marketing.
    • A school or district may ask us to remove specific content at any time. Parents, guardians, or other affected individuals should contact the school or district, or contact us at info@samlabs.com and we will work with the school. We will remove content without undue delay once a request is verified.

    3. How We Use Information

    We may use personal information to:

    • Provide, operate, maintain, and improve our websites, products, and Services.
    • Respond to inquiries, demo requests, support requests, and customer communications.
    • Process purchases, shipments, billing, returns, and related customer service.
    • Manage school, teacher, administrator, reseller, or partner relationships.
    • Send service updates, administrative messages, and important notices.
    • Send marketing communications to educators and business contacts where permitted by law, with the ability to opt out.
    • Analyze website traffic, product usage, and service performance.
    • Maintain security, prevent misuse, debug issues, and protect our rights and users.
    • Comply with legal obligations and enforce applicable terms.

    Student and school data

    We use educational and student record information only to provide and support the Services for the applicable school or district, including to:

    • Create and manage accounts, classrooms, and groups.
    • Save projects, code, and lesson progress.
    • Support skill and competency tracking, including educator-entered observations and scores, generate related reports, and show student growth over time to authorized teachers, administrators, and school district personnel.
    • Provide support, keep the Services secure, and fix problems.
    • Maintain and improve the Services, as permitted by our agreements with schools and applicable law.

    We do not use student personal information for advertising or marketing, to build profiles for non-educational purposes, or to train artificial intelligence models. We do not sell student personal information.

    4. Cookies and Similar Technologies

    We use cookies, pixels, analytics tools, and similar technologies on our websites to operate them, remember preferences, understand how visitors use them, improve performance, and support marketing.

    Marketing and advertising technologies are used only on our public, non-student-facing websites. We do not use advertising cookies, pixels, or cross-context behavioral tracking within SAM Studio, FRST, or SAM Code. Within these Services, we use only the cookies and similar technologies needed to run, secure, and improve them, such as keeping users signed in.

    You can control cookies through your browser settings and, where available, through cookie preference tools on our websites. Some features may not work properly if certain cookies are disabled.

    Where required by law, we treat Global Privacy Control (GPC) signals as a request to opt out of targeted advertising or "sharing" on our websites. We do not otherwise respond to browser "Do Not Track" signals.

    5. How We Share Information

    We do not sell student personal information.

    We may share personal information in the following circumstances:

    • With service providers that help us host data, operate our websites and Services, provide analytics, process payments, fulfill orders, deliver products, provide customer support, send communications, or perform other business functions.
    • With schools, teachers, administrators, districts, or other authorized educational institutions when information relates to their use of our Services, and only with authorized users for legitimate educational purposes. The school or district controls who has access.
    • With resellers, distributors, logistics providers, or business partners where necessary to fulfill orders or support customers. We share student educational records with these partners only when needed to provide support the school or district has requested.
    • With professional advisors, such as legal, accounting, insurance, or security advisors.
    • If required by law, subpoena, court order, or government request, or to protect our rights, safety, users, or the public.
    • In connection with a merger, acquisition, financing, reorganization, sale of assets, or similar business transaction. Any successor will be required to protect student personal information under commitments at least as protective as this Privacy Policy.

    Our service providers are contractually required to use personal information only as needed to provide services to SAM Labs, to keep it confidential, and to protect it. Service providers that handle student personal information on our behalf are held to privacy and security standards consistent with our school agreements and applicable student privacy laws.

    6. Children's Privacy and Student Information

    SAM Labs products are used in educational settings. When our Services are used by schools, teachers, districts, or other educational institutions, those institutions may provide or authorize the collection of student information.

    For children under 13 in the United States, SAM Labs is committed to complying with the Children's Online Privacy Protection Act (COPPA). In school settings, schools or teachers may provide consent on behalf of parents where permitted by law and solely for educational purposes.

    Student records in our Services are created and managed by authorized school or district personnel. Students cannot sign up for FRST or SAM Code on their own; only teachers and authorized school staff can create these accounts. Schools and districts are responsible for providing any required notices and obtaining any necessary consents or authorizations. Parents or guardians seeking access to, correction of, or deletion of a student's information should first contact the applicable school or district. SAM Labs will support the school or district in responding to such requests as required by applicable law and our agreements with the school or district.

    We do not knowingly collect personal information from children under 13 outside of an authorized educational context without appropriate parental consent. If we learn that we have collected personal information from a child under 13 without appropriate authorization, we will take reasonable steps to delete it.

    When providing educational platforms such as SAM Studio, FRST, and SAM Code to schools, SAM Labs acts as a "school official" with a legitimate educational interest under the Family Educational Rights and Privacy Act (FERPA). We process student educational records, including skill observations and scores, only on behalf of and under the direct control of the authorizing school or district. Our Services are not designed to survey students about the protected topics listed in the Protection of Pupil Rights Amendment (PPRA). We also comply with applicable state student privacy laws, such as California's SOPIPA, New York Education Law § 2-d, and Illinois' SOPPA.

    For more information, please see our Child Privacy Policy.

    7. Data Security

    We use reasonable administrative, technical, and organizational safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction. More information is available on our Trust & Security page.

    No method of transmission or storage is completely secure, so we cannot guarantee absolute security. If we become aware of a security incident affecting personal information, we will take appropriate steps as required by applicable law. If a security incident affects student educational records, we will notify the affected educational institution(s) without unreasonable delay, in line with applicable data breach notification laws and our agreements, so that schools can meet their own obligations to parents.

    8. Data Retention

    We retain personal information for as long as reasonably necessary to provide our Services, fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, enforce agreements, and maintain business records.

    When personal information is no longer needed, we will delete, de-identify, or anonymize it. If we keep de-identified data for analysis or product improvement, we will keep and use it only in de-identified form and will not attempt to re-identify it.

    For student data in our Services, including FRST, we will securely delete or de-identify student records upon the written request of the school or district, or upon termination of the applicable school agreement, in accordance with that agreement and applicable law.

    9. Your Choices and Rights

    Depending on where you live, you may have rights regarding your personal information, such as the right to access, correct, delete, or receive a copy of certain personal information, or to opt out of certain uses.

    You may unsubscribe from marketing emails by using the unsubscribe link in those emails or by contacting us.

    To make a privacy request, contact us at info@samlabs.com. We may need to verify your identity before completing certain requests.

    Please note: Because student educational records, including those in FRST, are created and managed by the applicable educational institution, requests to access, review, correct, or delete student records should be submitted directly to the student's school or district. SAM Labs will support the institution in responding to such requests as required by applicable law and our agreements with the institution.

    10. U.S. State Privacy Rights

    Residents of certain U.S. states may have additional privacy rights under applicable state privacy laws. These may include the right to know what personal information we collect, to access, correct, or delete personal information, to opt out of certain processing, or to appeal a decision about a privacy request.

    SAM Labs does not sell student personal information or share it for cross-context behavioral advertising. If we use technologies on our public websites that may be considered targeted advertising or "sharing" under applicable state laws, we will provide any required choices or opt-out mechanisms.

    If your request relates to student records we hold for a school or district, we will refer it to that institution, as described in Section 9.

    To exercise applicable state privacy rights, contact us at info@samlabs.com.

    11. International Users

    SAM Labs Inc. is based in the United States. If you access our websites or Services from outside the United States, your information may be processed in the United States or other countries where we or our service providers operate. Those countries may have data protection laws that differ from those of your country.

    Users in the European Economic Area, the United Kingdom, and Switzerland

    This section applies if you are located in the EEA, the UK, or Switzerland. SAM Labs' local entities are Sam Labs Ltd in the United Kingdom and Sam Labs Belgium in the European Union (contact details in Section 14).

    • Schools and students. When a school or other institution uses our Services, the institution is the controller and SAM Labs processes personal data on its behalf under a data processing agreement, which is available on request. Requests about student data should be sent to the institution, and we will support it in responding.
    • Our legal bases. Where SAM Labs is the controller, we process personal data to perform a contract with you or take steps before entering one; for our legitimate interests in running, securing, and improving our websites and Services, responding to inquiries, and communicating with educators and business contacts; with your consent, for example for non-essential cookies or certain marketing; and to comply with legal obligations.
    • Your rights. You may have the right to access, correct, delete, restrict, or object to the processing of your personal data, to data portability, and to withdraw consent at any time. To exercise these rights, contact us at info@samlabs.com. You also have the right to complain to your local data protection authority.
    • International transfers. When we transfer personal data outside the EEA, UK, or Switzerland, we use appropriate safeguards, such as the European Commission's Standard Contractual Clauses and the UK International Data Transfer Addendum.

    12. Third-Party Links and Integrations

    Our websites and Services may contain links to, or integrations with, third-party websites, services, and resources. These include roster syncing, rostering services, and single sign-on (SSO) integrations, such as Clever, ClassLink, Google Classroom, Microsoft, Canva, or other LMS, SSO, and rostering platforms enabled by schools or districts.

    When schools use these integrations to access SAM Studio, FRST, or SAM Code, the handling of data before it reaches our Services is governed by the school's agreements with those third-party providers. We are not responsible for the privacy practices or content of third parties, and we encourage you to review their privacy policies.

    13. Changes to This Privacy Policy

    We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date at the top of this page. If changes are material, we may provide additional notice where required by law. We will not make material changes to how we handle student personal information without giving schools and districts advance notice, as required by our agreements and applicable law.

    14. Contact Us

    If you have questions about this Privacy Policy or our privacy practices, contact us at:

    SAM Labs Inc.
    1321 Upland Dr. PMB 17412
    Houston, Texas, 77043
    United States
    Email: info@samlabs.com

    Sam Labs Ltd (United Kingdom)
    Gable House, 18-24 Turnham Green Terrace, Chiswick, London W4 1QP, United Kingdom

    Sam Labs Belgium (European Union)
    Chaussée de Waterloo 930, 1000 Brussels, Belgium