Privacy Policy

Introduction

Curriculum Advantage, Inc. (“CAI”) is leading the way in K-12 curriculum and assessment. Curriculum Advantage’s programs provide teachers with powerful tools that help them understand and respond to the needs of every student and use data in a way that is safe, secure, and effective.


This Customer Privacy Policy (“Privacy Policy”) or (“Policy”) describes how CAI collects, uses, and discloses personal information and data through the provision of its education products and services (“Products”), including Classworks, Classbloom, and any other product or service that links to this Customer Privacy Policy, to its users (K-12 students, educators, staff and families) and School Customers (School Districts and State Agencies, as defined below). In the course of providing the Products to the Customer, CAI may collect or have access to “education records,” as defined by the federal Family Educational Rights and Privacy Act of 1974 (“FERPA”) and personal information that is directly related to an identifiable student (collectively, “Student Data”). This Policy does not apply to CAI’s company website; information collected from users of the website is governed by our website privacy policy.


We consider Student Data to be confidential and we collect and use Student Data solely for the purpose of providing our Products to, or on behalf of, our School Customer and for the purposes set out in this Privacy Policy and Customer Agreements. We take numerous measures to maintain the security and confidentiality of Student Data collected or stored by CAI on behalf of our School Customers, and we enable our School Customers to control the use, access, sharing and retention of the data. Our collection and use of Student Data is governed by our Agreements with our School Customers, including this Privacy Policy, and applicable laws including FERPA, the Children’s Online Privacy Protection Act (“COPPA”), as well as other applicable federal, state and local privacy laws and regulations (“Applicable Laws”). With respect to FERPA, CAI receives Student Data as a “school official” under Section 99.31 of FERPA for the purpose of providing its Products, and such Student Data is owned and controlled by the School Customer.


CAI is also an early adopter and proud signatory of the Student Privacy Pledge, an industry-wide pledge to safeguard privacy and security of student data. For more information on the pledge, see https://studentprivacypledge.org/.

Classworks has been vetted by the 1EdTech TrustEd Apps Program. The 1EdTech Data Privacy team reviewed CAI policies, including, but not limited to, Privacy Policy, Terms of Service, AI Policy, etc., using the 1EdTech Data Privacy Rubric. It notes that policies mention applicable privacy laws (COPPA, FERPA, GDPR) and accessibility features.

There may be different contractual terms or privacy policies in place with some of our School Customers. Such other terms or policies may supersede this Policy for information collected or released under those terms. If you have any questions as to which legal agreement or privacy policy controls the collection and use of your information, please contact us using the information provided below.

1. Definitions

Capitalized terms not defined in this section or above will have the meaning set forth by Applicable Laws.


2. Student Data Collected

CAI receives Student Data in two ways: (i) from our School Customers to implement the use of our Products and (ii) from Authorized Users.


3. Use of Student Data

CAI uses Student Data collected from, or on behalf of, a School Customer to support the learning experience, to provide the Products to the School Customer and to ensure secure and effective operation of our Products, including:



CAI may use de-identified data as described in Section 5 below.


4. Disclosure of Student Data

We share or disclose Student Data only as needed to provide the Products under the Agreement and as required by law, including but not limited to the following:


5. De-Identified Data

CAI may use de-identified or aggregate data for purposes allowed under FERPA and other Applicable Laws, to research, develop and improve educational sites, services and applications and to demonstrate the effectiveness of the CAI Products. We may also share de-identified data with research partners to help us analyze the information for product improvement and development purposes.


Records and information are considered to be de-identified when all personally identifiable information has been removed or obscured, such that the remaining information does not reasonably identify a specific individual. We de-identify Student Data in compliance with Applicable Laws and in accordance with the guidelines of NIST SP 800-122. CAI has implemented internal procedures and controls to protect against the re-identification of de-identified Student Data. CAI does not disclose de-identified data to its research partners unless that party has agreed in writing not to attempt to re-identify such data.

6. Prohibitions; Advertising; Advertising limitations

CAI will not:


CAI may, from time to time, provide customized content, advertising, and commercial messages to School Customers, teachers, school administrators or other non-student users, provided that such advertisements shall not be based on Student Data. CAI may use Student Data to recommend educational products or services to users, or to notify users about new educational product updates, features, or services.

7. External Third-Party Services

8. Security

9. Review and correction

10. Student Data retention

We will retain Student Data for the period necessary to fulfill the purposes outlined in this Policy and our agreement with that School Customer. We do not knowingly retain Student Data beyond the time period required to support a School Customer’s educational purpose, unless authorized by the School Customer. Upon notice from our School Customers, CAI will return, delete, or destroy Student Data stored by CAI in accordance with applicable law and customer requirements. We may not be able to fully delete all data in all circumstances, such as information retained in technical support records, customer service records, back-ups and similar business records. Unless otherwise notified by our School Customer, we will delete or de-identify Student Data after termination of our Agreement with the School Customer.

11. COPPA

We do not knowingly collect personal information from a child under 13 unless and until a School Customer has authorized us to collect such information through the provision of Products on the School Customer’s behalf. We comply with all applicable provisions of the Children’s Online Privacy Protection Act (“COPPA”). To the extent COPPA applies to the information we collect, we process such information for educational purposes only, at the direction of the partnering School District or State Agency and on the basis of educational institutional consent. Upon request, we provide the School Customer the opportunity to review and delete the personal information collected from students. If you are a parent or guardian and have questions about your child’s use of the Products and any personal information collected, please direct these questions to your child’s school.

12. Updates to this policy

We may change this Policy in the future. For example, we may update it to comply with new laws or regulations, to conform to industry best practices, or to reflect changes in our product offerings. When these changes do not reflect material changes in our practices with respect to use and/or disclosure of Student Data, such changes to the Policy will become effective when we post the revised Policy on our website. In the event there are material changes in our practices that would result in Student Data being used in a materially different manner than was disclosed when the information was collected, we will notify School Customers affected by the changes via the email contact information provided by the customer and provide an opportunity to opt out before such changes take effect.

13. Contact us

If you have questions about this Policy, please contact us at:


PO Box 3243

Duluth, GA 30096

Attn: General Counsel


To report a security vulnerability, email us at security@curriculumadvantage.com.

Supplemental Disclosures

Nevada. This section applies if you are a resident of the state of Nevada.  While CAI does not sell personal information, as defined in Nevada law, Nevada residents may email a request for no sale of their personally identifiable information to privacy@curriculumadvantage.com.  


California.  This section applies to you if you are a resident of the state of California and for purposes of this section the term “personal information” has the meaning provided by the California Consumer Privacy Act (the “CCPA”). Residents of California may be entitled to certain rights with respect to personal information that we collect about them under the CCPA: the Right to Know, the Right to Request Deletion and the Right to Opt-Out of Personal Information Sales. You also have the right to be free of discrimination for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you the Products or engage with you in the same manner. To request to exercise your California consumer rights, please contact us at privacy@curriculumadvantage.com with the subject line “California Rights Request.” 


Note for students and other users who engage with CAI in connection with a School Customer’s use of CAI: Because CAI provides the Products to School Customers as a “School Official,” we collect, retain, use and disclose Student Data only for or on behalf of our School Customers for the purpose of providing the Products specified in our agreement with the Customer and for no other commercial purpose.  Accordingly, we act as a “service provider” for our School Customers under the CCPA.  If you have any questions or would like to exercise your California rights, please contact your School directly.