Children’s Online Privacy Protection Act

Edmentum understands that its Customers and third parties may have an interest in understanding Edmentum’s Online Learning Programs (“Programs”) as they may relate to certain laws aimed at protecting children online, specifically the Children’s Online Privacy Protection Act (“COPPA”).  COPPA makes it unlawful for websites and online services that are designed for children, or that know they are collecting personal information from children under the age of 13, to collect personal information from such children in a manner that violates specific regulations promulgated by the Federal Trade Commission. COPPA is not generally applicable to the Online Learning Programs as Edmentum does not knowingly collect personal information directly from children under the age of 13.

Nevertheless, in order to give assurance to Edmentum’s Customers and to parents whose children may benefit from the Online Learning Programs, Edmentum is providing the following statement of its practices relating to the collection, use, and disclosure of personal information regarding students:

• By contract, our Customers are responsible for Customer Data, which may include data and records relating to student information, performance, or use. Our Customers are also responsible for obtaining any necessary or legally required consents related to access and use of the Programs, including parental consent for students under the age of 13 who may access or use the Programs. Edmentum is not responsible for obtaining, and does not obtain, such parental consent for collecting information from or about children under the age of 13.
• Edmentum only collects personal information about children that is provided by Edmentum Customers. These Customers are solely responsible for determining what information, including personal information about students, they will provide to Edmentum or input into our Online Learning Programs.
• Edmentum’s Online Customer Privacy Policy is clearly posted on its Online Learning Programs site and appropriately provides notice to its Customers and any individuals who may use Edmentum’s site of what information Edmentum collects, including about children, how Edmentum uses that information, and its disclosure practices related to such information. Edmentum’s privacy policy confirms that Edmentum does not knowingly collect personal information directly from children under the age of 13.
• If Edmentum learns that it has collected, used, or disclosed personal information from children under the age of 13 through the Customer’s use of the Programs, Edmentum will notify the Customer and ensure that the Customer has provided appropriate notice to and obtained verifiable consent from the child’s parents, consistent with the requirements of COPPA and Edmentum’s agreement with the Customer.
• If Edmentum learns that it has received personal information from children under the age of 13, Edmentum will notify the Customer and ensure that the Customer provides a reasonable means for the child’s parent to review such information and refuse to permit its further use or maintenance, or request its deletion, consistent with the requirements of COPPA and Edmentum’s agreement with the Customer. If a parent requests that such information be deleted, the Customer will notify Edmentum for appropriate action.
• Edmentum has established and maintains reasonable procedures to protect the confidentiality, security, and integrity of personal information collected on this site, including any information about children.  Edmentum also takes reasonable steps to release personal information about children that it may obtain only to service providers and third parties who are capable of maintaining the confidentiality, security, and integrity of such information, and who provide assurances that they will maintain the information in such a manner.
• Edmentum does not condition the participation of a child under the age of 13 in the Online Learning Programs, or in any game, the offering of a prize, or any other activity, on the child disclosing personal information directly to Edmentum.