Effective Date: July 31, 2015
Students’ Access to Our Online Learning Programs
Our Online Learning Programs are provided to students under the age of 18 (or through high school graduation to the extent that occurs at age 18 or later) solely through fixed-term subscriptions purchased by schools, school districts, and other educational entities (our “Customers”). Edmentum’s Online Learning Programs are not available to students under age 18 except when they are enrolled for access as an authorized user by one of our Customers. Our Customers are required to obtain any and all legally required consents and authorizations from a student’s parent/guardian prior to their enrolling for access a student under age 18. Our Customers also dictate which aspects of our Online Learning Programs students are able to access.
By using (or allowing your child/student to use) Edmentum’s Online Learning Programs you (on behalf of yourself and your child/student) accept, and agree to be bound by, the terms of this Policy. If you do not accept and agree to the terms of this Policy, neither you nor your child/student may use our Online Learning Programs.
Information We Collect and How We Use It
We collect the following information about students who use our Online Learning Programs:
- Personally identifiable information provided by the Customer who enrolled the student for access, by the student’s parent/guardian, or by the student. This information may include information such as the student’s name, name of school, grade level, and e-mail address.
- Browser information, such as IP address, the name of a student’s operating system, the name and version of a student’s browser, the date and time of a student’s visit, and the pages the student visits. This information is not personally identifiable, but it can be linked to information that identifies a student, and we reserve the right to do so.
- Tracking information, including information collected by cookies, such as which pages students visit, which links they use, and how long they stay on each page. The tracking information we collect is not personally identifiable but can be linked to information that identifies a student, and we reserve the right to do so. Please note that a student’s browser must be set to accept cookies for our Online Learning Programs to be fully functional.
Entities With Whom We Share Student’s Information
We share students’ personally identifiable information with the Customer who enrolled the student for access to our Online Learning Programs. We may also share such information with vendors, suppliers, licensors and/or subcontractors (“Contractors”) that perform services on our behalf. Our agreements with these Contractors generally contain confidentiality and non-disclosure provisions requiring that such Contractors maintain the confidentiality of any personally identifiable information that may be disclosed or made available to them so that Edmentum can use Contractor’s product or services. We reserve the right to share students’ personally identifiable information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order or a subpoena. We may also disclose such information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of our Online Learning Programs; or to protect our own rights or property or the rights, property or safety of our users or others. Finally, we reserve the right to transfer students’ personally identifiable information to a successor organization if, for example, we transfer the ownership or operation of our Online Learning Programs to another organization, if we liquidate and sell our assets, or if we merge with or are acquired by another organization. If such a transfer occurs, the successor organization’s use of students’ personally identifiable information will still be subject to this Policy.
Children Under the Age of 13 and COPPA
Our Customers determine which of their students will be enrolled to access and use our Online Learning Programs, and our Customers determine what information about those students they will provide to Edmentum or input into the Online Learning Programs. For students under the age of 13, we require our Customers to obtain any necessary or legally required parental consents before allowing students to access or use the Online Learning Programs. Even then, we do not knowingly collect personal information directly from children under the age of 13. If you have knowledge that a child under the age of 13 has provided personal information to us, please contact us using the information provided below. Edmentum’s COPPA assurance statement can also be accessed here.
Security Measures and Data Retention
Edmentum maintains a comprehensive security program that is reasonably designed to protect the security, privacy, confidentiality, and integrity of students’ personally identifiable information against risks—such as unauthorized access or use or unintended or inappropriate disclosure—through the use of administrative, technological, and physical safeguards appropriate to the sensitivity of the information. However, we cannot guarantee the security of information provided over the Internet or stored in our databases and will not be responsible for breaches of security beyond our reasonable control.
Unless students and their parents/guardians separately authorize us to do so, we will not knowingly retain students’ personally identifiable information beyond the time period required to support the educational and other purposes authorized by the Customer, except that we reserve the right to retain data on backed-up, electronically stored records, the destruction of which would be unreasonably burdensome.
Requests for Access and Deletion of Student’s Personally Identifiable Information
Any student or parent/guardian who is interested in accessing the information Edmentum stores about the student should request such information from their student’s school (Edmentum’s Customer). Likewise, requests to have a student’s information modified or deleted should be directed to the student’s school. Edmentum will work with its Customers to respond to all reasonable requests for access, modification, or deletion that the Customers receive and will comply with all applicable laws regarding data retention/destruction. However, there are various circumstances when Edmentum may deny a request for access, modification, or deletion, including (but not limited to) when Edmentum believes that applicable law or a court order requires it to retain information, when Edmentum believes that retention of the information is necessary to protect its rights, or when the request extends to backed-up, electronically stored records, the destruction of which would be unreasonably burdensome.
Links to Other Web Sites
Edmentum Assurances Related to the Family Educational Rights Privacy Act
Edmentum understands that many of its Customers are subject to the Family Educational Rights Privacy Act (“FERPA”) and provides a list of FERPA-related assurance to our Customers. Students and their parents/guardians may obtain a copy of those assurances upon request, by contacting the student’s school or by contacting Edmentum using the information provided below. Edmentum’s FERPA assurance statement can also be accessed here.
Protection of Pupil Rights Amendment (“PPRA”)
The programs and activities of our Customers that receive funds under any program funded by the U.S. Department of Education may obligate our Customers to satisfy certain PPRA obligations. Edmentum does not administer to our Customer’s students any surveys or analysis concerning any of the PPRA protected areas nor does Edmentum intentionally collect any student information related to such administration.
Student Privacy Pledge
Edmentum is a current signatory to the Student Privacy Pledge. As a signatory, Edmentum uses commercially reasonable efforts to comply with the commitments made as a signatory. Specific details on the Pledge can be found at http://www.studentprivacypledge.org.
Changes to This Policy
Please contact us at firstname.lastname@example.org if you have any questions or comments about this Policy. You can also contact us by general mail or phone listed below. General comments about our web site can be directed to email@example.com.
5600 W 83rd Street, Suite 300
Bloomington, Minnesota, 55437