Privacy Policy

Summit Learning Privacy Policy

Effective Date: January 9, 2023 (Summary of updates)

We have done our best to write this Privacy Policy in simple and clear terms. We have also added summaries below each section that provide short explanations of the legal language in plain English.

Introduction

The Summit Learning Program is a personalized approach to teaching and learning inspired by the vision to equip every student to lead a fulfilled life. Gradient Learning (“Gradient Learning” “we”, “us” and “our”), a California nonprofit public benefit organization and a 501(c)(3) nonprofit organization, operates the Summit Learning Program (the “Program”), including the Summit Learning Platform located at www.summitlearning.org (the “Platform”). With support from the Chan Zuckerberg Initiative, LLC (“CZI”), Gradient Learning offers the Program and Platform as a free service to schools that sign an agreement with Gradient Learning.

The Learning Services (defined below) are designed to facilitate strong relationships between teachers and students through real-time data about progress towards goals, access to ongoing feedback, and access to a wide range of learning resources that enable students to build on what they learn from the teacher by self-directing some of their learning, too.

Gradient Learning does not place ads in its Services or use personal information that we collect for ad purposes, including for behaviorally-targeted advertising purposes. We do not, and will not, make or seek to make money from students or their schools, teachers, or caregivers. We do not, and will not, sell, rent or lease the personal information of students, teachers, or anyone else.

Gradient Learning and CZI are signatories to the Future of Privacy Forum’s and SIAA’s Privacy Pledge (“Privacy Pledge”).

As with any technology used in the classroom, protections must be in place to safeguard student information. We have established this Privacy Policy (the “Privacy Policy”) to explain the personal information that we collect and how we protect, use, and share it. Use of the Services is also governed by the User Agreement (the “User Agreement”).

This Privacy Policy applies to www.summitlearning.org, https://blog.summitlearning.org and demo.summitlearning.org (“Web Services”) and the Program features accessed through www.summitlearning.org (“Learning Services”) (collectively, the Web Services and Learning Services are “Services”). This Privacy Policy applies to those who register for the Learning Services (“Licensed Users”) and also applies to visitors to our Web Services who do not have registered accounts or anyone who is not logged in to their registered account (“Visitors”). This Privacy Policy also describes how we collect and use information from students (“Student Users”) attending “Partner Schools” (defined below) (Student Users together with Licensed Users are “Users”).

For clarity, this Privacy Policy does not apply to any other product or service offered by Gradient Learning, such as Along, which is offered under its own Privacy Policy and Website Privacy Notice.

This Privacy Policy does not apply to the following: information collected by Summit Public Schools (a separate legal entity that pioneered the Summit Learning Program); personal information relating to our employees, contractors, or other personnel; and websites or online services of companies that Gradient Learning does not own or control even if accessible from our Services. The Services may contain links (e.g. educational content) that take you outside our Services. This Privacy Policy does not apply to such services that are not operated by Gradient Learning. Access to and use of such outside websites or online services is subject to their respective terms of use and privacy policies.

1. Contract and Services.

When you use our Services you agree to all the terms in this Privacy Policy and our User Agreement. You agree that by registering for, accessing or using our Services, you are entering into a legally binding contract with Gradient Learning (even if you are using our Services for your work at a school).

2. Visitors

If you are a Visitor, we will collect personal information that you provide to us, including if you contact us with questions, sign up for a newsletter, or otherwise submit data to us. We will also automatically collect information described in 3.1(b) for Visitors. We will use this information for the purposes described in Section 3.1(b), in our Cookie Policy (“Cookie Policy”), and in accordance with any of the notices provided at the point you submit any personal information (e.g., to be contacted for more information about the Program).

3. Users of the Learning Services

We provide the Program directly to schools and school districts that enter into a “Program Agreement” (“Program Agreement”) with us for their educational purposes (“Partner Schools”). To operate the Program for Partner Schools, we collect certain information through the Learning Services and only use and share the information to provide the Learning Services in accordance with such Program Agreements (or other terms agreed upon with applicable schools), this Privacy Policy, and applicable laws. Each Program Agreement includes a Data Privacy Addendum that includes protections for Student User information, and limits our use and sharing of Student User personal information to the Learning Services. Parents, legal guardians, or caregivers (“Caregivers”) can get more information about the Learning Services on our website.

3.1. Information We Collect

We collect different information depending on whether the User is a teacher, school administrator, Caregiver or Student User and how the User uses the Services. We get information, including personal information, about and from Users in two ways: (1) from information provided directly to us and (2) from information we collect through Services engagement. Information provided directly to us can include information provided by Partner Schools and external parties. Regardless of how we get personal information about Users, including Students, we only use the information to provide the Program in accordance with our commitments to our School Partners and as otherwise provided in this Privacy Policy or our agreement with the User.

(a) Information Provided Directly to Us

Licensed Users or their Partner School may provide us with personal information, and Partner Schools may direct that personal information be provided to us by others for use with the Program. Examples of such information include the following:

• Account Sign-Up and Profile Information
  • Contact information such as full name and email address;
  • Username and password; and
  • Teacher information, including, but not limited to, name and years of experience.
• Class and Student User Information. Partner Schools may choose to import the below information from outside third-party services into the Services:
  • Class rosters, homeroom, and grade level;
  • Student name;
  • Student email address;
  • Student identification numbers such as a school identification number or school information system identification number;
  • Student record information such as attendance, suspension, and expulsions;
  • Student demographic data, including date of birth, gender, ethnicity or race;
  • Student subgroups, such as English learners, students with disabilities, or low income status;
  • Mentor observations;
  • Student outcome information such as grade level promotion and matriculation, AP and IB test information, college admission test scores, college eligibility and acceptance, and employment; and
  • Academic or extracurricular activities a student may belong to or participate in.
• Course Information and Student User Scores
  • Course data including coursework in applicable media (e.g., video, audio, text and images) and course progress;
  • Student scheduled courses;
  • Test scores, grades, standardized test results (such as NWEA MAP, SBAC, etc.), and teacher feedback on coursework; and
  • Teacher curricula and notes and feedback to or about students.
• Caregiver Information
  • Names, mobile phone numbers and email addresses of Caregivers, if provided to us by the Partner School or the Caregiver.
• Other
  • Answers to surveys about the Services or curricula; and
  • Feedback, suggestions, questions, and ideas submitted to us.

For a more comprehensive list of information, see Exhibit A of the Data Privacy Addendum. A detailed explanation of how information is collected and used is provided in this Summit Learning Help Center Article (“What data is collected and why is it needed?”).

(b) Information We Collect Through Services Engagement

We may collect certain information from Users’ and Visitors’ computers and devices as they use or engage with the Services. Examples of such information include:

• Device and Network Information:
  • We may collect information about networks (such as language, Internet protocol (IP) addresses, internet service provider, and connection speed) and other identifiers that are automatically assigned to a User’s or Visitor’s computer or device (such as browser type and operating system). We also collect the date and time of your use of the Services, and information about the links clicked and pages viewed within the Services. We collect this information to better distinguish users of the Services, which helps us to better secure our Services, understand which of our content and features users find valuable and, for Licensed Users, to provide reliable and personalized Services.

• Cookies, Pixel Tags, and Similar Technologies:

  • We use technologies such as cookies, pixel tags, local storage, and similar technologies to automatically collect this information. By using the Services, you consent to our use of cookies and similar technologies to collect information as you engage with the Services. You have control over the collection of information through these technologies per our Cookie Policy. Most browsers allow you to block or delete cookies through settings they provide, but please know that some of our Services may not work properly.

  • Cookies. Cookies are small text files placed on your device consisting of a string of numbers and letters that uniquely identifies your device. This helps us do things such as save your preferences and to identify users who are Student Users in order to limit our collection and use of personal information accordingly.

  • Pixels. Pixels are a type of technology placed on a website or within the body of an email for the purpose of tracking certain activity, such as views of a website or when an email is opened. Pixels are often used in combination with cookies. For additional information, see our Cookie Policy.

  • Click-through URLs. If you “opt in” to receive newsletters, updates, or other information from us, our emails may use a “click-through URL” linked to content on our sites. When you click one of these URLs, they pass through a separate web server before arriving at the destination page on our sites. We use this click-through data to help us understand how recipients respond to, or interact with, our emails. If you prefer not to be tracked in this way, please do not click text or graphic links in emails you receive from us.

(c) Information Received from External Sources

We may also obtain information, including personal information, from external sources, such as content partners, providers of tests and assessments, and Student User information systems, to update or supplement the information we have about Users. For example, this may include data schools choose to provide us via School Information System (SIS) integrations with providers such as Clever (see Section 3.1(a) for examples). You can see more information about such integrations in this Summit Learning Help Center Article (“Setting up your Clever Account”). Local law may require that you authorize the external sources to share your information with us before we can acquire it. We treat personal information we receive from these external sources in accordance with this Privacy Policy, including if we directly combine that personal information with other personal information that we collect through the Learning Services.

(d) Information We Do Not Seek to Collect or Store

We do not seek to collect sensitive information about students, such as precise location or biometric data. If we become aware that such information has been provided, we will delete it within a reasonable time of such awareness or get the appropriate school or caregiver consent to keep it if it is reasonably necessary for the Learning Services.

3.2. We Limit The Use Of The Personal Information We Collect

We use the personal information we collect from the Learning Services for educational purposes as directed by Partner Schools, including to:

• Provide curricula choice or recommendations;
• Drive learning engagement and progress via content suggestions to Users;
• Maintain the security and reliability of the Services, troubleshoot, and perform audits;
• Administer surveys, studies, and interviews;
• Operate, develop, analyze, evaluate, and improve Gradient Learning’s educational sites, services, or applications;
• Manage the oversight and use of the Services, pursuant to Partner School’s policies;
• Communicate with Users in connection with providing the Services;
• Send Caregivers who are Users informational alerts or other communications via SMS or email messages (see Section 9 (“How We Communicate with You”) for information on how to manage or opt-out of communications);
• Evaluate the efficacy of the Services and Program;
• Perform other activities requested by Partner Schools for educational purposes or with the consent of a Caregiver or Student User of the age of majority;
• Protect or defend the rights, safety, or property of Gradient Learning, Partner Schools or Users, or to comply with any law enforcement, legal, or regulatory process;
• De-identify the information for other Gradient Learning purposes; or
• Comply with applicable laws.

To be clear, we will not:

• Seek to make money from students or their schools, teachers, or Caregivers through the Services;
• Include advertising in the Services including behaviorally-targeted advertising to Users;
• Sell, rent or lease (or authorize Service Providers (defined in Section 3.3. below) to sell, rent or lease) any personal information we collect from Student Users for any purpose – including for advertising and marketing purposes;
• Use the personal information we collect from Student Users for marketing purposes (but we may ask Users to participate in surveys or provide feedback regarding the Services);
• Get paid to make recommendations to students or use (or authorize Service Providers to use) the personal information we collect from students for advertising purposes, including behaviorally-targeted advertising purposes. [Note: Our personalized learning may include recommendations for further learning resources, including some resources provided by others.];
• Use (or authorize Service Providers to use) the personal information we collect from Users for the creation of commercial products or services; or
• Use information collected from Student Users for any purposes other than educational purposes of our Partner Schools unless we have de-identified the information such that it cannot reasonably be linked to an identifiable Student User.

De-identified information. We de-identify personal information and use de-identified information for other purposes, including research and product improvement. We consider “de-identified” information to be information that has direct and indirect personal identifiers removed such that the data cannot reasonably be used to identify or contact an individual. Such identifiers include persistent unique identifiers, name, ID numbers, date of birth, and school ID.

3.3. We Limit How Personal Information Is Shared

In order to provide the Learning Services, we share your personal information in the limited ways outlined below:

• Within a school. Partner Schools and their Licensed Users within a school share information with each other as authorized by the Partner School and for the Partner School’s educational purposes. The Learning Services do not include features that make Student User personally identifiable data publicly available.
• School officials. Because the Learning Services is an educational tool, authorized school officials have legal rights to view, export, and request deletion of information in the Learning Services.
• Caregivers. With a Student User’s Caregivers as authorized by the Partner School or as required by applicable law.
• Service Providers. We use Service Providers to support the operation of the Services, such as through document management, data hosting, and provisioning customer service tools related to the Learning Services. CZI is our long-term technology partner and works as a Service Provider to help us develop and support the Services. We do not and will not grant Service Providers the right to sell your personal information or to use your personal information beyond what is reasonably necessary to assist us in providing the Services. We also require Service Providers to implement reasonable security practices in accordance with the Data Privacy Addendum. You can learn more about our security practices in our Security Whitepaper (“Security Whitepaper”). We maintain a list of our Service Providers (“Service Providers”), which may be updated from time to time.
• Gradient Learning Affiliates. We may share User information to and among our affiliates, in which case we will require them to honor this Privacy Policy. “Affiliates” refers to entities controlled by Gradient Learning. Information is shared for the purposes of providing and improving Partner School support, product analytics and development, and other internal usage as permitted by law.
• Law enforcement requests. We may access, preserve, and share User information in response to any law enforcement, legal, or regulatory process (e.g., warrants, subpoenas, court orders), or other applicable laws and regulations, if we have a good-faith belief that the law requires us to do so. In such cases, to the extent permitted by law, we will attempt to provide the Partner School or Caregiver (as applicable depending on the circumstances) with notice of such legal request prior to complying with respect to requests for Student User personal information.
• New owners. If the ownership or control of all or part of the Learning Services changes, we may transfer information to that new owner. We, along with other signatories to the Privacy Pledge, have committed to protecting Student User personal information in the event of such a change of ownership so that we honor commitments made prior to the change.
  • In the event of such a change, we will provide notice to Users through the Services (or other contact information we have for a User) and this Privacy Policy will continue to apply and any new owner would be permitted to use and share personal information only pursuant to this Privacy Policy (unless Users agree otherwise). If a new owner does not agree to comply with this Privacy Policy, Users will be given a chance to opt out before any personal information is transferred to the new owner.
  • In the unlikely event that we file for bankruptcy or dissolution, we will protect your personal information by seeking to require that it be used only in accordance with this Privacy Policy, and we will not sell personal information to any third party.
• With other third parties as required. With entities that we are obligated to share information with, as required by law or our agreements with Partner Schools. We may share personal information with third parties if we believe in good faith that sharing information is necessary or appropriate (i) to protect or defend the rights, interests, safety, or security of us, our Partner Schools, Users, or Service Providers; (ii) to prevent violations of the terms of use that govern the Learning Services; and (iii) as otherwise required by law.
• With other third parties as permitted. We may share information with other third parties, if directed or authorized by the Partner School or with Caregiver consent, to the extent permitted by law and subject to our User Agreement.

De-identified information. In the event we wish to demonstrate how the Program is used or its efficacy, or otherwise provide information or marketing materials related to the Program, we will only share de-identified information. We may share aggregated and/or non-personally identifiable information publicly (such as statistics about visitors and traffic patterns).

4. We Support Caregiver Engagement

We support and encourage the involvement of Caregivers in their Student Users’ education. Caregivers and Student Users may, at any time, make a request to access, review, correct or delete of personal information in the Services by contacting the appropriate official at the Student User’s Partner School. If the Partner School determines that the request should be implemented, the Partner School may either make the change themselves or ask us to make such change. We will process such Partner School requests within thirty (30) days of receiving a written request in a manner consistent with applicable law, and the terms of the Data Privacy Addendum.

5. Student User’s Personal Information

All students who use the Program will be enrolled in a Partner School that has signed a Program Agreement to participate in the Program, including the Learning Services. Pursuant to each Program Agreement (including the Data Privacy Addendum), each Partner School has consented to our practices regarding the collection, use, and disclosure of personal information from Student Users as permitted by law.

Prior to a student accessing the Learning Services, the Student User’s teacher or Partner School administrator must create the Student User’s account on the Learning Services. When the Partner School administrator or teacher registers its students, we rely on consent obtained from Partner Schools acting as an agent of the Student User’s Caregivers. For more information, please see our Privacy & Security FAQs (“FAQs”) including our commitment to the Privacy Pledge.

COPPA governs the collection of certain information from children under the age of 13 (“child” or “children”); for more information about COPPA and generally protecting children’s online privacy, please visit the Federal Trade Commission COPPA FAQs and OnGuard Online. While COPPA does not directly apply to non-profit organizations such as Gradient Learning, we voluntarily comply with COPPA’s guidelines regarding students under the age of 13 as part of our commitment to transparency with Caregivers regarding the collection and use of their child’s data.

The commitments we make regarding information collected from or about students apply equally to all students regardless of their age. Accordingly, where this Privacy Policy references students or any information collected from or about students, our Privacy Policy applies to students under 13 years old as well as students 13 years old and above. For more information about how we protect student information, see Section 12.

6. Security and Accuracy of Personal Information

The security of personal information from our Users is important to us, and we work hard to protect it from unauthorized access and use. In an effort to prevent unauthorized access, disclosure, or improper use of User information, and to maintain data accuracy, we have established physical, technical, and administrative safeguards designed to protect the personal information we collect. For additional technical details regarding Gradient Learning’s security programs and measures, please see our Security Whitepaper.

We’re constantly evolving our security procedures as technology changes, but our security procedures at a minimum include the following:

• We restrict access to personal information to authorized Gradient Learning employees, agents, service providers, or independent contractors who reasonably need to know that information in order to process it for us, and who are subject to confidentiality obligations. Employees and contractors (“Staff”) are subject to discipline if they fail to meet these obligations.
• We require our Service Providers with which we share Student User personal information to employ industry standard data protection and security protocols.
• We use strong authentication methods including multi-factor authentication for all Staff.
• We employ administrative, physical, and technical safeguards designed to protect personal information from unauthorized access, disclosure, and use or acquisition by an unauthorized person, including when transmitting and storing such information.
• We employ encryption technologies to securely transmit personal information, including data-in-transit encryption, and we encrypt personal information that is stored.
• We strive to maintain a data backup and recovery capability designed to help ensure a timely and accurate restoration of personal information.
• We work hard to maintain a secure software development lifecycle with industry standard security practices designed to establish secure application, infrastructure, and network architectures.
• We endeavor to maintain event monitoring and response procedures for events which could impact functionality, security and/or availability of the Learning Services.
• We provide Staff training for security incidents and maintain incident response policies, plans and procedures focused on timely and effective incident response.
• We employ trained security professionals with experience in security incident response and event monitoring.
• We perform application security testing (including penetration testing) and conduct security risk assessments focused on the identification and remediation of risks, and work hard to timely remediate identified security vulnerabilities
• We implement oversight and governance procedures for security risks, including a vulnerability disclosure program and reviews of incidents affecting the Summit Learning Platform.

We regularly develop and implement features to help keep personal information safe. You can find more information about our technical practices in our Security Whitepaper. Should you discover any security bugs or vulnerabilities in our Services or have any questions regarding our data practices, please contact our team at security@summitlearning.org.

Although we make concerted good faith efforts to maintain the security of personal information, and we work hard to ensure the integrity and security of our systems, no practice can be 100% guaranteed. The security of personal information can be compromised by outages, attacks, human error, system failure, unauthorized use or other factors at any time. If we learn of a breach of your personal information, we will provide notice which will include information required by applicable law.

For additional information on our security practices, please visit our FAQs.

7. Data Retention

We will only retain personal information, including personal information from Users, for the time period required to support the authorized educational purposes. If a Partner School leaves our Program or requests removal of any personal information, we will promptly direct our Staff to delete, dispose of, or de-identify the personal information. We will delete, dispose of, or de-identify the personal information within sixty (60) days following such Partner School requests unless, consistent with applicable law, there is a legitimate reason to retain such personal information. Our normal retention period will not apply if we have consent to retain such information or if we are required to retain such information to comply with our legal obligations or law enforcement requests, resolve disputes, protect the safety and security of our Users or our Services, or enforce the User Agreement, Program Agreement (including the Data Privacy Addendum and Partner School Terms of Service), or any posted guidelines, policies or rules applicable to specific features of the Services.

If you are an eligible Student User (or Caregiver of a Student User that is under the age of 18) and wish to have your (or your student’s) personal information removed from the Learning Services, please contact your Partner School and review the information in Section 8 (“Partner Schools Can Delete Information”). For additional information relating to deletion and retention policies, please see our FAQs.

8. Partner Schools Can Delete Information

Partner Schools may request the review or deletion of their Student User information in the Services. We will delete or de-identify such information within sixty (60) days, or in compliance with applicable law, unless we otherwise have consent to retain such information or are required to retain such information to comply with our legal obligations or law enforcement requests, resolve disputes, or enforce the User Agreement, Program Agreement, (including the Data Privacy Addendum and Partner School Terms of Service), or any posted guidelines, policies or rules applicable to specific features of the Services. Such information will be deleted when it is no longer needed for the purpose for which it was retained.

9. How We Communicate With You

If you created an account on the Services (or provided an email address or phone number to us, or otherwise opted-in to receive communications from us), we may send you messages related to the Services, including messages regarding your account, privacy and security notices, and updates and information regarding the Program, including the Learning Services. These communications may be sent through SMS, push notifications, email, telephone calls, and postal mail. [Note: Standard carrier fees may apply to messages sent to your mobile devices.] If you have an account with us, we’ll also use your contact information for customer service purposes, or to contact you for legal matters or purposes. We may receive a confirmation when you open an email from us if your device supports it.

For Parents, Legal Guardians, or Caregivers. If, as a Caregiver of a Student User, you provided contact information to your school, your account (“Parent Account”) will be set up by your Student User’s teacher or Partner School. At the direction of the Partner School, we may send an invitation to you to log in to your Parent Account via the contact information that your Student User’s teacher or Partner School provided to us to set up your Parent Account. The invitation may be sent via email or SMS text message. [Note: Your carrier may charge you fees for text messages.] We may also send you informational text messages, including, but not limited to, messages: (1) providing information related to your student’s use of the Services; (2) supplying information that you request; or (3) responding to your inquiries regarding your account or use of the Services. If, as a Caregiver of a Student User, you provide your telephone number to your Student User’s Partner School, you are consenting to Gradient Learning (on behalf of and at the direction of your student’s Partner School) sending informational text messages related to the Partner School’s mission. If, as a Caregiver, you would prefer not to receive our communications, you may opt-out using the instructions contained in these communications, you may text “STOP” at any time and/or contact us (see Section 11 below). After doing so, we will send you confirmation of this opt-out via text message.

10. We Are Transparent About Changes

We may modify this Privacy Policy or our User Agreement from time to time. If we make material changes to this Privacy Policy, including changes that impair your rights or change how your data will be used under this Privacy Policy, we will provide you at least 30 days prior notice pursuant to this Section 10. We will seek to provide you notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. We agree that changes cannot be retroactive. The notice will indicate which sections contain material modifications and what choices you may have. Your continued use of our Services after we publish or send a notice about our changes to these terms means that you are consenting to the updated terms following their “effective date.” If you object to any changes, you must stop using or accessing the Services. If we make any changes to this Privacy Policy or the User Agreement, you can request a copy of the prior versions by contacting us at privacy@summitlearning.org.

11. We Want To Hear From You

If you have any questions about this Privacy Policy or our practices, please contact privacy@summitlearning.org.

You can learn more about Gradient Learning on our website, http://gradientlearning.org/ and about the Summit Learning Program in our FAQs.

You can also reach us by emailing or writing to the contact information provided in this Summit Learning Help Center Article (“How can I contact Gradient Learning?”).

12. Useful Information Regarding Student Data

What Information Does Gradient Learning Collect from Students and How Does Gradient Learning Use the Information?

As described above, we use the information collected from Student Users to provide the Learning Services to Student Users and as described further in this Privacy Policy and the User Agreement. The Partner Schools have authorized us to collect the information from Student Users necessary to use our Learning Services, including:

• Classwork, for example: project submissions (including documents and other media), assessment responses, and academic goals;
• Communications with teachers and mentors, for example: responses to teacher feedback, free-form notes, and requests for guidance; and
• Non-academic information, for example: college and career interests, college preparation artifacts (essays, letters of recommendation), reflections on academic progress and other self-assessments, anonymous survey responses, and offers to tutor peers.

In addition to the information entered by the Student User, we automatically collect some information from any use of our Learning Services as set forth in Section 3.1(b) of this Privacy Policy. We also receive information from the Student User’s teacher or Student User’s Partner School, and link to the Student User’s account in our Learning Services as set forth in Section 3.1.

If we discover that we have collected personal information from a Student User in a manner inconsistent with this Privacy Policy, we will take appropriate steps to either promptly delete the information, or seek consent for that use for the Learning Services.

What Student Information is Visible to Others?

The Learning Services limit access to each Student User’s account and the content thereon to the Student User, the Student User’s Caregivers, teachers, school administrators, and other teachers in the Student User’s Partner School (depending on the setting selected by the Partner School’s administrator). Accordingly, the Learning Services do not permit any Student User’s account or the content and grades thereon to be viewed or accessed by the general public.

How Long Do You Keep a Student’s Information?

Please see Section 7 (“Data Retention”). If you are a Caregiver of a Student User under the age of 18 and you wish to have a Student’s personal information removed from the Learning Services, please contact your Partner School.

What Caregiver Choices are there?

Please see Section 4 (“We Support Caregiver Engagement”).

13. Your Choices Regarding Your Personal Information

We provide a variety of ways for you to control your personal information, including choices about how we use that data. In some jurisdictions, these controls and choices may be enforceable as rights under applicable law.

13.1 Access, portability, correction, and deletion

• Access personal information. You can ask us for a copy of your personal information, including in a machine-readable form (data portability).
• Change or correct personal information. You can also ask us to change, update, or fix inaccurate personal information in certain cases, subject to our legal obligations and lawful exceptions.
• Delete personal information. You can ask us to erase or delete all or some of your personal information subject to our legal obligations and lawful exceptions.

To make such requests, contact privacy@summitlearning.org. In the email, please provide us with your name, state in which you live, which of the above rights you would like to exercise, and sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information. Please also let us know if you have questions or concerns related to exercising any rights you have under applicable law.

13.2 Object to, limit, or restrict use of personal information

• Communications preferences. You can opt out from communications with Gradient Learning at any time via the unsubscribe link in emails from us.
• Targeted advertising and data sale / sharing. We do not use third-party advertising cookies on our website.
• Profiling and automated decisionmaking. Some privacy laws provide a right to opt-out of profiling or automated processing in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. Gradient Learning does not engage in such profiling or automated processing.

13.3 Browser or platform controls

• Cookie controls. Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain settings or features of our website. Please see our Cookie Policy for more information.
• Global Privacy Control. Some browsers and browser extensions support the “Global Privacy Control” or similar controls that can send a signal to the websites you visit indicating your choice to opt out from certain types of data processing, including data sales and/or targeted advertising, as specified by applicable law. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting or similar control that is recognized by regulation or otherwise widely acknowledged as a valid opt-out preference signal.
• Do Not Track. Some browsers include a “Do Not Track” (DNT) setting that can send a signal to the websites you visit indicating you do not wish to be tracked. Unlike the GPC described above, there is not a common understanding of how to interpret the DNT signal; therefore, our websites do not respond to browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the GPC, cookie controls, and advertising controls described above.

If you would like to appeal our decision with respect to a request to exercise any of your rights, please email us at privacy@summitlearning.org and explain the basis for your appeal.

Gradient Learning will not discriminate against you in any manner for exercising any of the above rights with respect to your personal information.

14. Additional Information for California Residents

While the CCPA does not apply to nonprofit organizations like Gradient Learning, we take privacy seriously and have chosen to inform our practices with the CCPA. Specifically, this means the below.

14.1 Data Subject Rights

In addition to the rights listed in section 13, California residents have the additional “right to know.” This right allows you to request the following information about the personal information that we’ve collected in the past 12 months:

• Information about Data Collection
  • The categories of personal information that have been collected.
  • The specific pieces of personal information that have been collected about you.
  • The categories of sources from which we have collected personal information.
  • The business purpose for which we have collected personal information.
• Information about Data Disclosure
  • The categories of personal information that we have sold, shared, or disclosed for a business purpose.
  • The categories of third parties with whom personal information has been sold, shared, or disclosed for a business purpose.

Note that general details about data collection and disclosure are provided in this Privacy Policy. If you wish to exercise your rights or request more specific details about the above, please email privacy@summitlearning.org and follow the instructions in Section 13.1 above. If you would like an authorized agent to make a request for you, please have that agent email privacy@summitlearning.org with the above information along with additional information sufficient for us to verify that the authorized agent is acting on your behalf.

14.2 Additional Disclosures / “Notice at Collection”

You have a right to receive notice of our personal information collection, use, retention, and disclosure practices at or before the collection of personal information. We have described in fuller detail in this Privacy Policy the personal information that we collect, how we use and disclose it, but provide the following additional disclosure:

• Information we collect. We have collected the following categories of personal information within the past 12 months: (1) identifiers; (2) internet or other similar network activity; (3) education information; and (4) audio and visual information as part of the content and communications exchanged between students and teachers using the Services. See Section 3.1 of this Privacy Policy for more details.
• Purposes of collection, use, and disclosure. As described in Sections 3.2 and 3.3 above, we do not “sell” or “share” personal information (as those terms are defined by the CCPA) of our users. In addition, we use or disclose the personal information we collect for one or more of the business purposes described in Sections 3.2 and 3.3 above.
• Retention of information. We only keep personal information for as long as it’s necessary to provide the Services. In certain cases, we may need to keep personal information if the law requires a different duration, or as directed by the teacher or school. See Section 7 above for more details.