Edmentum Product Privacy Policy
Updated November 1, 2024
As of December 1, 2024 this Product Privacy Policy replaces our Customer Privacy Policy which you can find posted here.
Edmentum Online Learning Services (the “Services”) are web and mobile-based education platforms and applications designed to measure student performance and needs, and to inform development and delivery of customized learning plans. Edmentum Online Learning Services are owned and operated by Edmentum, Inc. (“Edmentum,” “we,” “us”).
Our Services support our educational institution and organizational partners (“Institutional Customers”), their administrators and educators, parents (which, in this Privacy Policy, includes legal guardians), and the students we collectively serve (“Institutional Services”). Our Services also support parents and students who engage with the Services independently of our Institutional Customers (“Individual Customers” and “Individual Services,” respectively). This Policy is intended to inform our Institutional Customers and Individual Customers (collectively, “Customer(s)”) of the types of Personal Information we collect and how we may use and disclose it. In this Privacy Policy, we refer to anyone who accesses or uses our Services, or who administers our Services on behalf of those who access or use our Services as “you” or “your.”
For our Institutional Customers, in addition to this Privacy Policy, our collection, use, and disclosure of Personal Information may be subject to terms of a contractual agreement we have with the Institutional Customer.
By accessing or using the Services or permitting your student or child to access or use the Services, you acknowledge that you have read and understood this Privacy Policy.
Personal Information You Provide
- Edmentum Institutional Services and Institutional Customers
- Edmentum Individual Services for Individual Customers
- Personal Information We Collect Directly From Students Accessing or Using the Services
Family Educational Rights and Privacy Act
Information We Collect Automatically
How We May Use and Share Personal Information
How You May Access and Modify Personal Information
Notice for California and Other U.S. Residents
Changes to this Privacy Policy
Personal Information You Provide
When accessing the Services, we may ask for information that identifies or reasonably relates to you or to another specific person, or that is otherwise defined as personal information, personal data, or protected data under applicable laws (“Personal Information”). In all such cases, we treat Personal Information as required under applicable laws.
Edmentum Institutional Services and Institutional Customers:
When you purchase our Services as an Institutional Customer, we will ask you for certain Personal Information in order to create your administrator and educator accounts. This may include administrator and educator first and last names, email addresses, usernames, and passwords, as well as their role within the institution, the teacher ID, business phone number, and the institution address. For Institutional Customers who are not educational institutions, we may also ask for parent contact information to facilitate our collection of verifiable parental consent where necessary under applicable law.
Our Institutional Customers may also choose to have their administrators, educators, and students sign into the Institutional Services through a third-party single sign-on portal, when available, in which case, in addition to the above, we also will receive a token that authenticates the individual to allow access to the Institutional Services.
Personal Information We Collect About Students from Institutional Customers:
We will ask our Institutional Customers to provide Personal Information about their students so that we can create student user accounts and set up the classroom roster. This information may include the student’s first and last name, email address, username and password, school name, and grade level.
If the Institutional Customer decides students should access the Institutional Services through a third-party single sign-on portal, we will receive a token that authenticates the individual to allow access to the Institutional Services, as noted above.
Institutional Customers may, if they choose, authorize their administrators and educators to provide additional, optional Personal Information about students at their discretion. This may include, for example, a unique ID, academic level, ID photo, date of birth, and gender, a phone number to allow for communication with their Edmentum educator, assessment results and other school records, English language learner status, ethnicity, and other demographic data. When provided, this optional information may be used to enhance the reporting provided to the Institutional Customer.
Some of our Institutional Services may be used by educators to create lessons and communicate with their students, including assigning grades, providing instructional support, sending student performance feedback, and that information is stored in each Institutional Customer account. Periodically, when permitted by the Institutional Customer, some of our Institutional Services may be used by Edmentum educators to collect parent and student feedback regarding their experience with the Services and with our educators. This information is collected for our instructional quality assurance purposes.
Personal Information We Collect About Students from Partners:
Customers of certain Institutional Services may also direct us to collect student assessment information from their third-party assessment service providers (“Partners”). In these situations, Customers provide us with the student information system ID and state ID for matching the student’s third-party assessment results so that we may provide a personalized learning path for students in the Institutional Services.
Personal Information We Collect About Parents:
In some of our Institutional Services, we offer Institutional Customers the ability to create parent accounts so that parents can view their student’s progress and receive updates from the Institutional Customer through the Institutional Services. To create these accounts, we may ask the Institutional Customer or the parent, depending on the service requested, to provide the parent’s first and last name, relationship type, an ID number, phone number, username, password, and email addresses.
In addition, parents of students expecting to receive printed or other physical materials provided in connection with the Services or a diploma through our accredited virtual academy services may be asked to provide a mailing address and/or email address to receive the student’s materials or diploma.
Edmentum Individual Services for Individual Customers:
Some of our Services are available for purchase by an individual (“Individual Services”). We request certain billing information, including first and last name, billing address, phone number, email address, and credit card number to facilitate purchase of our Individual Services.
Personal Information We Collect from Parents/Legal Guardians:
When parents register their students for our Individual Services, we ask for certain Personal Information in order to create their account, including the parent’s first and last name, email address, password, and mailing address. We also ask for their student’s first and last name, grade, username, password, academic year, and desired grade level content. We may also request academic transcripts from the parent or from the student’s prior educational provider. We use this information to enroll the student, create the student accounts, and assign content to the student.
Parents of students expecting to receive printed or other physical materials provided in connection with the Services or a diploma through our accredited virtual academy services may be asked to provide a mailing address and/or email address to receive the student’s diploma, as they are with Institutional Services.
Personal Information We Collect from Adult Students at Registration:
If you are an adult student over the age of majority (“Adult Student”), when you register for your own use of the Individual Services, we ask for certain Personal Information to create your account, including your first and last name, email address, password, and mailing address. We also ask for your grade, username, password, academic year, and desired grade level content. We use this information to enroll you, create your student account, and assign content to you.
If you are an Adult Student expecting to receive printed or other physical materials provided in connection with the Services, you may be asked to provide a mailing address to receive the materials.
Personal Information We Collect Directly From Students Accessing or Using the Services:
Within the Institutional and Individual Services, students complete educational tasks and assignments, which may include submission of student-generated content as well as other course work. Work completed by a student is made available for the student and their teachers or parent to review and analyze.
When classroom activities are conducted by an Edmentum educator via video conference as part of the Services, due to the nature of the activity, students’ screen name, image and voice may be shared with the classroom activity participants. Sometimes, a classroom activity cohort may be comprised of student participants of more than one Customer, such as, for example, our Services offered for targeted skills instruction. Periodically, the classroom activity may be recorded for Edmentum’s instructional quality assurance and Edmentum educator training purposes.
Family Educational Rights and Privacy Act (FERPA)
Our obligations when the Institutional Customer is subject to the Family Educational Rights and Privacy Act (FERPA) are described in our Standard Terms or in a separate agreement with the Institutional Customer. Under the Standard Terms, the Customer agrees to appoint us as a “school official” as the term is used in FERPA §§ 99.31(a)(1). We agree to be bound by all relevant provisions of FERPA, including that we remain under the “direct control” of the Institutional Customer with respect to our use and handling of student Personal Information and that we use or share student Personal Information only as necessary to provide the Services as described in the Standard Terms and any other agreement we may have with the Customer.
Students Under Age 13
We operate in compliance with the Children’s Online Privacy Protection Act (COPPA). For Institutional Services, if the Institutional Customer is an educational institution, the educational institution determines which of their students will be enrolled in our Services. In these instances, we require our educational Institutional Customers to affirm that they have the necessary authority to permit us to collect Personal Information from students under the age of 13 before allowing those students to access or use the Services.
For our Institutional Customers who are not educational institutions and for our Individual Services, we require the parent or legal guardian to consent to our collection of Personal Information from students under the age of 13 before we collect Personal Information from students.
If we learn that we have inadvertently collected Personal Information from an individual under age 13 without having first obtained the necessary consent, we will take steps to promptly delete it.
Information We Collect Automatically
Our servers automatically record information sent from browser of everyone who accesses and uses our Services (“Log Data”). Log Data may include information such as the computer’s Internet Protocol (“IP”) address, device ID, name and version of the browser, pages of the Services visited, the time spent on those pages, access times and dates, and geolocation sufficient to identify your country or city. We aggregate this information and use it to monitor, analyze use of, and administer the Services, for security purposes, and to improve how the Services function. When Log Data is available to us in a format that would be considered Personal Information, we treat it as such in accordance with this Privacy Policy.
To collect this information, we use different tracking technologies, including:
Cookies. A cookie is a small piece of data sent from a website or application and stored on your computer or device. Cookies allow us to recognize each browser, serve certain features, better understand how individuals interact with the Services, and monitor aggregated usage. Most browsers have settings such that the user may delete cookies, stop accepting cookies or receive a prompt before accepting a cookie. More information about cookies, including information about how to manage or delete them, look in the Tools, Help or similar section of each web browser or browsers, and at allaboutcookies.org.
HTML5 Local Storage. This type of storage also allows some data to be stored in the browser. The browser will typically provide tools that can be used to “clear” local storage. These tools are often usually part of the same list of controls where cookie controls are located.
Clicktracking. Clicktracking allows us to capture “clickstream data” about use of the Services. It includes information about individual “clicks” or actions in the Services, such as what the user sees or clicks on during a visit and how the user interacted with certain features. This can include information such as the order in which buttons were clicked or links on a page were accessed, or allow us to develop insights about how individuals move through the Services.
Third Party Cookies:
We use third-party service providers to assist us in collecting and understanding Log Data. Most browsers can be set to detect browser cookies and to let a user reject them, but refusing cookies may impact how the Services function. A list of companies that may use cookies on the Services, the functions and features those Companies provide is included in our Subprocessor Notice. To learn more about browser cookies, including how to manage or delete them, refer to the Tools, Help or similar section of each web browser used.
How We May Use and Share Personal Information
We do not sell or rent Personal Information, and we do not build profiles of users except to support an educational purpose as part of our delivery of the Services to the Customer. We use and disclose Personal Information only as described above, to deliver the Services, and as follows. The legal basis for processing is included for those countries where it is applicable.
- To provide reporting and insights to our Customers into how the Services are being used and information about their student’s progress, including improvements, coursework, and completion;
- To deliver the customized and adaptive learning features of the Services;
- To conduct research on behalf of a Customer in accordance with a separate agreement with that Customer;
- To develop and deliver course transcripts for the Customer and students and to deliver transcripts to third parties as directed by the Customer;
- To provide Customer support, including troubleshooting, responding to Customer inquiries, and providing Services-related communications; To share with our third-party service providers so that they may support us in providing the Services (see Third Party Service Providers section below);
- When printed or other physical materials are part of the Services for order fulfillment.
Where we operate as a data controller for our Individual Customers, and where applicable, our legal basis for processing to provide the Services, including for the above-referenced uses, are our legitimate interests and performance of a contract with the Customer.
- To investigate a suspected violation of our Standard Terms, suspected fraud, or other unlawful activity;
- To protect the security and integrity of our Services;
- To comply with a law or court order, in which case, where legally permitted, we shall attempt to notify the Customer and work with the Customer to seek to limit the scope of the required disclosure;
- In the event of a reorganization, merger, sale, assignment, bankruptcy, or other disposition of our business, we may share the Personal Information with the reorganized or other new entity, in which case the Personal Information will be transferred in accordance with the terms of this Privacy Policy;
Where we operate as a data controller for our Individual Customers, where applicable, our legal basis for processing for the above is our legitimate interests and fulfilling our legal obligations.
- With consent as authorized or required by the Institutional Customer or Individual Customer and as permissible under applicable laws and regulations.
Where we operate as a data controller for our Individual Customers, where applicable, our legal basis for processing for the above is the Individual Customer’s consent.
Third-Party Service Providers
We partner with certain third parties to help us deliver the Services and to provide certain Service-related features on our behalf, such as, though not limited to, maintenance services, database management, security, implementation support, rostering, data integration services, and customer support. Third parties also help us deliver features available in certain Services, such as rostering, videoconferencing for instruction, tutoring and other instructional supports, and evaluation, translation, apostilling, issuance, and transmission for transcripts and diplomas. They must handle the Personal Information in compliance with applicable law and may use the Personal Information only to provide the Services.
How You May Access, Modify, and Request Deletion of Personal Information
Institutional Services:
If you are an administrator or educator, you may access your Personal Information directly in the Services. To request deletion or modification of your Personal Information, please contact us at Privacy@Edmentum.com.
Students or parents who are interested in accessing, modifying or deleting Personal Information from their education Institutional Services account should contact the Institutional Customer with the request. We will work with our educational Institutional Customers as needed to facilitate responding to those requests.
Individual Services:
If you are a parent of a student using the Individual Services, you may request to access, modify, or delete your Personal Information or your student’s Personal Information, or revoke the consent you have provided for our collection of Personal Information from your student by contacting us at Privacy@Edmentum.com. We may ask you for additional information to verify your identity and relationship with the student before fulfilling your request.
If you are an Adult Student using the Individual Services, you may request to access, modify, or delete your Personal Information, by contacting us at Privacy@Edmentum.com. We may ask you for additional information to verify your identity before fulfilling your request.
Data Retention
For our accredited virtual academy Services, we may operate as the diploma-granting education institution, in which case we retain student Personal Information from these Services in accordance with applicable state student data retention laws or as required by the Customer.
For other Institutional Services and our Individual Services, Personal Information is retained no longer than needed to support the educational and other purposes authorized by the Customer or within 30 days of request from the Customer.
For all Services, we may create and retain de-identified information to use for legally permissible purposes, including to develop and improve our educational products and services and demonstrate the effectiveness of our educational products and services, provided that the information does not identify any individual or customer.
Security
We implement and maintain administrative, technical, and physical safeguards designed to help protect the confidentiality, integrity, and availability of Personal Information, including restrictions against unauthorized access to Personal Information by Edmentum employees or contractors and authorizing access to Personal Information by Edmentum employees or contractors only as necessary to fulfill their official duties.
However, no method of transmission over the internet or method of electronic storage is 100% secure, and we are not responsible for security incidents not reasonably foreseeable or reasonably within our control.
Please contact us promptly at support@edmentum.com with any known or suspected unauthorized use of account credentials.
Links
Our Services may contain links to third-party websites. We provide links to these websites when they contain content that we believe may be of interest and value to our Customers and their students. These websites are owned and controlled by independent operators. We do not control these sites or their data privacy and security practices. Those websites have their own privacy policies and other terms that apply to their collection and use of your Personal Information.
Notice For California and Other U.S. Residents
Several U.S. states, including California, have laws granting their residents certain rights with respect to their Personal Information, as described below. We provide these rights to all U.S. residents.
We do not “sell” or “share” Personal Information as those terms are defined under California and other applicable state privacy laws. We do not otherwise disclose Personal Information to third parties who may use it for their commercial benefit or the commercial benefit of others. When we share Personal Information with third parties, those third parties are contractually prohibited from using the Personal Information for any purpose other than to provide us with their Services.
Right to Know and Access Information: You have the right to request access to the Personal Information we maintain about you in the ordinary course of business and to receive it in a machine-readable format.
Right of Correction: You have the right to correct inaccuracies in the Personal Information we maintain about you.
Deletion of Information: You have the right to request that we delete your Personal Information.
To Exercise Your Rights:
For those who are accessing the Institutional Services, please contact the Institutional Customer to exercise the rights described above regarding your Personal Information. We will work with them should they require our assistance in fulfilling the requests. For those who are accessing Individual Services, please email Privacy@Edmentum.com to exercise the rights described above regarding your Personal Information.
Before fulfilling a rights request in relation to our Services, we are required by law to verify the identity of the requestor in order to prevent unauthorized access to Personal Information. When we facilitate rights requests through our Institutional Customers, we will rely on their identity verification to process requests. We may be required to request additional Personal Information from our Individual Customers to verify their identity before addressing a rights request. In these situations, the additional Personal Information we request will only be used to verify identity, after which we will promptly delete it.
Where authorized by applicable state law, individuals may be entitled to use an authorized agent to exercise a privacy right described above. If the request is made by an authorized agent acting on behalf of a US resident who is using the Services under an Institutional Customer account, the agent should contact the Institutional Customer with the required supporting verification information. We will work with the Institutional Customer to address the rights request.
Please note that the exercise of the above rights is subject to certain exemptions to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege). We will respond to rights requests within the time frames set forth under applicable law. Requests to exercise these rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. If we reject a request, where required by applicable law, we will notify the requestor of any reasons why we are unable to honor the request.
Non-discrimination: We do not discriminate or otherwise penalize anyone for exercising their rights under applicable law or this Privacy Policy.
The following reflects our current practices and our practices that have been in place over the past 12 months.
| Categories of Personal Information we collect | Administrators and Educators:
Parents (including legal guardians):
Students:
Purchasers of Individual Services:
Adult Students:
|
| Categories of sources from which Personal Information is collected | We collect Personal Information directly from the education institution or other organization customer, our Partners, the individual customer, the student users, or automatically through the Services as described above. |
| Business or commercial purpose for sharing or selling Personal Information | We may use and share Personal Information for the purposes described above, which include:
We do not “share” (as the term is defined under applicable law) Personal Information with individuals or organizations to use for their own or others’ commercial purposes. We disclose Personal Information only to service providers who support us in delivering the services as described above. |
| Categories of third parties with whom we share Personal Information | We share Personal Information with the following categories of third parties:
|
| Specific pieces of Personal Information we have collected | About educators and administrators:
About students:
About parents:
|
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Additional Information for Users from the European Economic Area (EEA), the United Kingdom (UK), and Switzerland:
Typically, when we provide Institutional Services to an Institutional Customer, we function in the capacity of a “data processor.” In these cases, our processing of Personal Information is governed by this Privacy Policy and the contract in place with the Institutional Customer.
However, in some cases, where an Institutional Customer has engaged with our virtual school services to issue a diploma, we may function as a joint data controller with the Institutional Customer.
When we provide Individual Services, we function in the capacity of a “data controller.”
All International Users:
Individuals located outside the United States should be aware that Edmentum will transfer Personal information to third-party servers for storage in the United States.
By submitting Personal Information, you acknowledge that we may transfer, process, and store that Personal Information in this way. Wherever the Personal Information is, it will be treated and protected in accordance with this Privacy Policy and applicable privacy laws. These laws may be different from the privacy laws in other countries. However, this does not change our commitment to safeguard individuals’ privacy, and we will comply with all applicable laws relating to the cross-border transfer of Personal Information.
Where required, we will implement Standard Contractual Clauses with our Customers and with our third parties to ensure that the transfer of Personal Information outside of the EEA, UK or Switzerland is lawful. Individuals may request details of the transfer mechanisms that we rely on to transfer Personal Information outside of these regions by emailing us at Privacy@Edmentum.com.
Additional Rights
Please note that the rules in certain countries may provide individuals additional rights related to our processing of Personal Information or may limit these rights. In all cases, we respect the rights provided to individuals under applicable laws.
For example, individuals based in the EEA, UK, or Switzerland may have the right to access, update, or correct their Personal Information, to request deletion of such Personal Information, and to object to certain processing, including that related to marketing, to receive a machine-readable copy of their Personal Information that they provided to us, or request us to transfer that Personal Information to an applicable third party in certain circumstances.
In addition, where consent was granted for our processing of Personal Information, the consent may be withdrawn by contacting us using the details provided in the “Contact” section. Individuals may also restrict how we use their Personal Information while a complaint is being investigated.
Exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege). To exercise privacy rights, users of Institutional Services should contact the Institutional Customer, and we will work with them to facilitate the request in circumstances in which they require our assistance. Individual Customers may exercise their rights by making a request to Privacy@Edmentum.com.
Changes to This Policy
If we make changes to this Privacy Policy, we will provide notice as required by law, which may include providing notice in the Services, by email to our Customer contacts, or through other means. Changes will be effective once posted, and the “Updated and Effective” date at the top of this page will reflect when it was last revised. If we make material changes to the Privacy Policy, we’ll provide notice to our Customer contacts and obtain any legally-required consent.
Contact Information
If you have questions about this Privacy Policy, please get in touch with us at Privacy@Edmentum.com. You may also contact us by mail or phone listed below:
Edmentum
5600 W 83rd Street, Suite 300
8200 Tower
Bloomington, Minnesota, 55437
800.447.5286
If you have concerns or complaints regarding this Privacy Policy or our data handling procedures, you may have a right to lodge a complaint with a supervisory authority.
Our Data Protection Officer may be reached at Privacy@Edmentum.com.