Privacy Policy

Introduction

New Perspectives on Learning, LLC (“Company,” “We,” or “Our”) respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you visit the website https://newperspectivesonlearning.com, https://studio.newperspectivesonlearning.com, and/or https://app.studioaddelaide.com (collectively, our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On this Website; and
• In email, text, and other electronic messages between you and this Website.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party; or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

• By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or other identifier by which you may be contacted online or offline (“Personal Information”); and/or
• About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

• Directly from you when you provide it to us; and/or
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, and other tracking technologies.

Information You Provide to Us

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. We may also ask you for information when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses) if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

Important Limitations for Educational Users

When our services are used by K-12 educational institutions and their students, we do not:

• Use technologies to track student online activities over time or across third-party websites or other online services for advertising or marketing purposes
• Collect or use persistent identifiers (such as advertising IDs, device IDs, or cookies) for targeted or behavioral advertising directed at students
• Build student profiles for advertising or marketing purposes unrelated to the educational services we provide

The information we collect automatically from educational users is used solely for:

• Providing and maintaining our educational services
• Service functionality and security purposes
• Improving our services (using only de-identified or aggregated data that cannot identify individual students)

General Website Users (Non-Educational Context)

For visitors to our general marketing website who are not using our educational services, some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser “do not track” signals on our general marketing website.

The information we collect automatically may include personal information. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
• Web Beacons. Pages of the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, register on the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any username you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@newperspectivesonlearning.com.

Children's Privacy and COPPA Compliance

We are committed to protecting the privacy of children and complying with the Children's Online Privacy Protection Act (“COPPA”).

General Website Use

Our general Website (https://newperspectivesonlearning.com) is not intended for or directed to children under 13 years of age. We do not knowingly collect personal information from children under 13 through our general Website without verifiable parental consent. If you are under 13, do not use or provide any information on the general Website or through any of its features, register on the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any username you may use.

If we learn we have collected or received personal information from a child under 13 through our general Website without verification of parental consent, we will delete that information as quickly as possible. If you believe we might have any information from or about a child under 13, please contact us at privacy@newperspectivesonlearning.com.

Educational Institution Use

When K-12 educational institutions (schools, school districts, and other educational agencies) and their employees use our application (https://studio.newperspectivesonlearning.com and/or https://app.studioaddelaide.com), they should not provide personally identifying information about students. Even though we do not require or expect educational institutions to provide any personally identifying information about students, we comply with FERPA and COPPA requirements in the following ways:

• We rely on the school or district to obtain any necessary parental consent under COPPA and to provide authorization for us to collect student information solely for educational purposes authorized by the school.
• We act as a “School Official” under the Family Educational Rights and Privacy Act (“FERPA”) with legitimate educational interests in student data. All student data collected through school use is collected and used solely for legitimate educational purposes as authorized by the school.
• We comply with all COPPA requirements when providing services to schools, including maintaining reasonable data security procedures and using student information only for the educational services we provide to the school.
• We do not use student information collected through schools for any commercial purposes unrelated to providing our contracted educational services.

What Constitutes Personal Information Under COPPA

Under COPPA, personal information includes, but is not limited to:

• First and last name
• Email address or other online contact information
• Physical address including street name and city or town
• Telephone number
• Social Security number
• Persistent identifiers (such as IP address, device IDs, advertising IDs, or customer numbers) when used for tracking purposes or targeted advertising
• Photos, videos, or audio files containing a child's image or voice
• Geolocation information
• Any other information collected from a child that is combined with any of the above

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account.
• To notify you about changes to our Website.
• To allow you to participate in interactive features on our Website.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

Research and Development

We may use your personal information for research and development purposes, including to analyze and improve the Website and our business and to develop new products and services. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Website and promote our business.

Service Improvement and Analytics

We may use your personal information to analyze your usage of the Website, improve the Website, improve the rest of our business, help us understand user activity on the Website, including which pages are most and least visited and how visitors move around the Website, as well as user interactions with our emails, and to develop new products and services.

Student Data Privacy

Our technology does not require the collection or use of personally identifiable student data to function, and users of our technology should not disclose personally identifiable student information when using our technology. The educational purposes of our technology can be achieved without any students' personally identifiable information.

Because K-12 students are not users of our technology, we do not engage in targeted advertising or behavioral advertising directed at K-12 students. Specifically, we do not:

• Display any third-party advertisements to students using our educational services
• Use student data to build behavioral profiles for advertising purposes
• Allow third-party advertising networks to collect information from students using our educational services

If we display any information about our own services or features to educational users, such communications are:

• Contextual only: Based on the current content or activity, not on tracking individual behavior
• Educational in nature: Related to features, updates, or educational services
• Not based on personal information: Do not use student personal information or behavioral profiles
• Controllable by schools: Schools can request that we disable product update notifications

Disclosure of Your Information

Important Limitation for Student Data

Personally identifiable student data are not collected through our educational services. In the event personally identifiable student data are provided by a user of our technology, those data are governed by the “Student Data Privacy” section above and is subject to strict limitations. We do not disclose student data except as required by law, authorized by the school in writing, or to subprocessors who are contractually bound to protect the data in accordance with FERPA, COPPA, and applicable state laws.

Disclosure Unrelated to Student Data

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect, or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of New Perspectives on Learning, LLC's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by New Perspectives on Learning, LLC about our Website users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Use and other agreements.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of New Perspectives on Learning, LLC, our customers, or others.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us.

For General Website Visitors

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

For Educational Institution Users (Students and Schools)

• Schools should not need to provide any personally identifiable student data, and control whether student data is shared with us
• Schools can request deletion of student data at any time
• Parents can exercise their rights under FERPA by contacting their school
• Students and parents can opt out of optional features through their school
• Schools can disable product update notifications if desired

No Targeted Advertising Opt-Out Needed

Because we do not engage in targeted or behavioral advertising to students, there is no need to opt out of such practices. Our services for educational users are advertising-free by design.

Accessing and Correcting Your Information

If you have a user account, you can review and change your personal information by logging into the Website and visiting your account profile page. Whether you have a user account or not, you may also send us an email at privacy@newperspectivesonlearning.com to request access to, correct or delete any personal information that you have provided to us. If you have a user account, we cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms of Use.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Other Sites and Services

The Website may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you by email to the email address specified in your account or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: privacy@newperspectivesonlearning.com.

Student Privacy Contact Information

For questions specifically related to student data privacy, FERPA, or COPPA compliance, contact us at schoolprivacy@newperspectivesonlearning.com. We commit to responding to student privacy inquiries and requests within 10 business days, or sooner when required by applicable state law.

Regulatory Compliance Information

COPPA – Children's Online Privacy Protection Act

• Administered by: Federal Trade Commission (FTC)
• File a complaint: https://www.ftc.gov/complaint
• More information: https://www.ftc.gov/coppa

FERPA – Family Educational Rights and Privacy Act

• Administered by: U.S. Department of Education, Family Policy Compliance Office
• Address: 400 Maryland Avenue, SW, Washington, DC 20202
• Website: https://studentprivacy.ed.gov/