At Renzulli Learning, digital learning is an essential part of our educational system, whether students are learning remotely or in-person. The data we collect and use is essential to furthering our work to provide an equitable educational opportunity to every child and ensure that they are prepared for college, career, and life. As an Ed-Tech company, Renzulli Learning is committed to protecting privacy through ongoing and continuous safeguarding of personal information. This commitment ensures trust between families, schools, and third-party service providers to support the safe and effective use of student data for student, teacher, and school success. We respect and follow applicable privacy laws, such as the Children’s Online Privacy Protection Act (COPPA), Family Educational Rights and Privacy Act (FERPA), applicable U.S. state privacy laws, and applicable international privacy laws.

1. How We Process Personal Information

Renzulli Learning’s website (Site) and software as a service (Software), process personal information as described below. We consider personal information (sometimes also referred to as personal data) as any information that relates to an identified or reasonably identifiable person. When we refer to the processing of personal information, we mean any operation or set of operations which is performed on personal information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

With respect to our Site, we determine the purposes and means for which we collect and process personal information. We respect to our Software, and the educational services we provide using the Software, we process personal information only as directed by our client educational institutions, educational agencies, educators, or parents.

Personal Information Collection

With regard to our Site, we collect the following categories of Personal Information:

• With respect to educators or parents who request information about our products and services: information about their interests, institutional affiliation, goals, budget, number of students, how the individual learned about us, and participation timeframe
• With respect to individuals who send us feedback or correspondence: the contents and contact information associated with the feedback or correspondence
• With respect to individuals who tender payments on our site: name, contact information, institutional affiliation, payment amount, and payment method information.

For individuals in jurisdictions where a lawful basis for personal information processing is required, we process this personal information based on consent, our legitimate interests, and to carry out our contracts with our users.

With regard to our Services, we collect the following categories of personal information:

• Login information, such as username and password
• Name, contact information, and profile information about Software users
• Information supplied by educators or parents regarding their students’ learning preferences
• Information about educational content accessed, used, and completed by students
• Information in students’ virtual project showcases
• Information provided by students and educators (or parents) as part of our Global Collaboration solution, which provides opportunities for students to collaborate with other students anywhere in the world
• Information about the consent that teachers or parents have provided for the processing of personal information relating to their students/children

Purposes for Personal Information Collection

• To administer, secure, and provide the Site and Software on behalf of our clients
• To deliver the Software and its educational services on behalf of our clients
• With regard to educators or parents who request information, for our marketing purposes
• With regard to individuals who send us feedback or correspondence, to review and respond to such messages

Sharing of Personal Information

Within our Software, you may opt-in to share personal information with other users who opt-in to the Software’s collaboration features.

We also hire third party service providers that process personal information on our behalf. We require such service providers to maintain the confidentiality of any personal information they process and to refrain from using the personal information they process on our behalf for any purposes other than those we direct.

In addition, we may share your personal information with:

• Our affiliates, to support our provision of services toyou.
• Any successor business that may acquire our business or any part of it.
• Law enforcement, government officials, or other official parties to the extent required by applicable law.
• Payment service providers, which enable us to process payments for the use of the Services.

We may also collect information the way users use our Site and Software and the devices they use to connect to our Site and Software. We maintain this information in aggregated or anonymized fashion so that it does not relate to an identified or identifiable individual.

We do not sell personal information to third parties. We also do not engage in cross-contextual behavioral advertising.

Data Retention

We retain personal information for no longer than necessary to accomplish the purposes for which the personal information was collected.

2. Your Privacy Rights

You may have rights relating to your the personal information under the law of the jurisdiction in which you live. These may include rights such as: (1) the right to access your personal information; (2) the right to correct inaccuracies in your personal information; (3) the right to request deletion of your personal information; and (4) the right to obtain a portable copy of your personal information. To request to exercise your rights with regard to the Software, please contact your educational institution, agency, or education. To exercise your rights with regard to our Site, please submit a request by contacting us through any of the means outlinedbelow.

Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. We will verify that any requests from persons other than you have your legal authorization. You may also make a request on behalf of your child.

To exercise your rights, you can contact us as set forth in section 11, below. Your request must:

• Include your first and last name, e-mail address, telephone number, and a description of your request;
• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We do not respond to “do not track” signals transmitted by web browsers. We also do not respond to the Global Privacy Control signal because we do not sell personal information, share personal information for cross-contextual behavioral advertising purposes, or engage in profiling for decisions that produce legal or similarly significant effects.

Appeal process. You may appeal our decision with respect to your request to exercise your legal rights with regard to your personal information. To submit such an appeal, you may contact us using the contact information below. You must include sufficient information to allow us to reasonably verify your identify, reference the date and time of your previous request to exercise your legal rights, and explain why you believe our decision was insufficient or improper. We will ordinarily respond to your appeal in accord with the timelines set forth in applicable law.

3. Additional Information for Users from the European Union/European Economic Area, United Kingdom, and Switzerland

Under applicable data protection laws, you may have right to make certain requests with regard to your personal information, subject to exceptions and limitations set forth in those laws. To exercise any of these rights with regard to our Site, please contact us using the information in section 11, below. Contact your educational agency, educational institution, or educator/parent regarding your rights with regard to the personal information in the Software.

• Access/Data Export. You may have a right to access the personal information we process and to request it in a common portable format of our choice.
• Rectification. You may request that we correct any personal information that you believe is inaccurate.
• Deletion. You may request that we delete your personal information. We may delete your data entirely, or we may anonymize or aggregate your information such that it no longer reasonably identifies you.
• Restriction of Further Processing. You may request that we restrict the processing of personal information under certain circumstances. For example, you may make this request if you withdraw consent you gave us previously and we have no other legal basis for us to retain your personal information it, or where you object to our use of your personal information for particular legitimate business interests.
• Objection. You may have the right under applicable law to object to any processing of personal information based on our legitimate interests. We may not cease or limit processing based solely on that objection, and we may continue processing where our interests in processing are appropriately balanced against individuals’ privacy interests. In addition to the general objection right, you may have the right to object to processing:
  • for profiling purposes
  • for direct marketing purposes (we will cease processing upon your objection); and
  • involving automated decisionmaking with legal or similarly significant effects (if any).

You have the right to file a complaint with regulators about our processing of personal information. To do so, please contact your local data protection or consumer protection authority.

4. Cookies

We use cookies for user session tracking, but we do not use cookies to share data with third parties or allow third parties to have access to our cookies.

5. Other Sites

Renzulli Learning’s Site and Services may contain links to or incorporate functionality from other carefully chosen websites. In particular, we provide video content from YouTube. Renzulli Learning cannot be responsible for the privacy practices or the content of such websites. You should review the privacy policy of each specific site. YouTube’s privacy statement can be viewed athttps://policies.google.com/privacy?hl=en.

6. Security

We review our security on a regular basis. Information collected from registered users of our products is stored on databases and other servers kept in secure locations under our custody and control. Renzulli Learning also uses technologies and processes, such as encryption, access control procedures, and network firewalls to protect such servers. We take commercially reasonable efforts to protect such information and to limit its use and disclosure but cannot guarantee that such efforts will be successful.

We maintain a comprehensive security program that is reasonably designed to protect the security, privacy, confidentiality, and integrity of personal 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.

We incorporate privacy and security when developing or improving our educational products, tools, and services and comply with applicable laws.

Please note that sending data over the internet is never completely secure. Although we will endeavor to fully protect your information, we cannot guarantee the security of the data you transmit to us, and you do so at your own risk.

7. Provider Resources

We provide resources to support educators, educational institutions/agencies, parents, and students to protect the security and privacy of personal information while using our Site and its educational services.

8. Notice of Changes to our Privacy Policy

We reserve the right, at our discretion, to change, modify, add, or remove portions of this Privacy Policy relating to our Site at any time. If our policy changes, we will post a notice on our Site.

9. Privacy Officer

We have a Privacy Officer who you may consult it have any questions or concerns about our personal information processing practices. You can reach our privacy officer by contacting us using the information in section 11, below.

10. Children’s Privacy (COPPA)

We do not knowingly collect any information from children under the age of 16 in connection with our Site.

With respect to our Software, in the United States, we do not collect personal information from children under the age of 13 unless and until our client educational institution, educational agency, or educator (or parent) has provided consent and authorization for a student under 13 to use the products and services and for us to collect personal information from the student. Under such circumstances, we process such personal information only as necessary to provide the educational services on behalf of our client educational institution, educational agency, or educator (or parent) and for the purposes set forth in our agreement with that client. We collect only as much information as is necessary to provide the service and the client may access, delete, or withdraw consent for continued processing of the child's information at any time. If you have any questions about reviewing, modifying, or deleting personal information of a child under the age of 13, please contact your educational institution directly.

Please contact us using the information in section 11, below you believe we have inadvertently or improperly collected personal information from a child under 13 without proper consent so that we can promptly delete such information.

With regard to children in the European Union, United Kingdom, or other jurisdictions that require a holder of parental responsibility to provide consent for the collection of personal information from a child under the age of 16 (or such other age as may be provided by the law in the relevant jurisdiction), we process children’s’ personal information only after our client educational institution, educational agency, or educator has confirmed that they have obtained or can legally provide such consent and authorization or we have received such consent or authorization directly from a parent.

11. Contact Us

If you have any questions about our policy, contact us via e-mail at info@RenzulliLearning.com or by telephone at +1 (203) 680-8301.

Last revised: August 20, 2023

Effective date: September 1, 2023