Children’s Privacy Policy

Last Updated: October 3, 2025

At Learning.com, protecting children’s privacy is a priority. This Children’s Privacy Policy (“Policy“) describes our practices for collecting, using, and disclosing personal information from children under the age of 13 (“children” or “child“) when you access and use the [Student Product Site, or SP] through our websites https://login.learning.com or https://www.codesters.com/login (the “Sites“) or our mobile application (the “App“) (the Sites and the App are collectively, the “Platform“).

This Policy notifies parents of:

• Collection. The types of personal information we may collect from children.
• Use. How we use the personal information we collect from children.
• Disclosure. Our practices for disclosing children’s personal information, including specific information about third parties.
• Your Rights. Your privacy choices.
• Operators. All operators that collect or maintain information from children through the Platform.

This Policy only applies to children and supplements our [Platform Privacy Policy]. Only our [Platform Privacy Policy] applies to teens and adults.

Terms that are defined in the Platform Privacy Policy have the same meanings as used in this Policy, unless otherwise defined in this Policy.

1. Collection of Children’s Personal Information

Learning.com only collects and processes personal information from children where that children’s school, district and/or teacher has contracted with Learning.com and has obtained parental consent to the collection of the children’s personal information. Learning.com collects, discloses, and uses personal information from children solely for the educational purposes authorized by the school, district, or teacher, and not for any other commercial purpose.

We only collect as much personal information from children as is reasonably necessary for the child to access and use the Platform, and we do not condition participation on the disclosure of more personal information than is reasonably necessary.

Learning.com collects the following personal information from children:

Identifiers

The child’s name, email address, and account credentials.

Educational Information

Grade level, school enrollment, district user ID, class assignments, educational progress, activity completion, performance metrics, teacher names, and responses to educational activities and assignments.

Internet Activity

We may collect Student Personal Information concerning your interaction with the Platform, including when you access the Platform and your browsing activity on the Platform. To support internal operations, we may assign a session ID and a unique user identifier to help maintain a student’s session and recognize when such student returns to the Platform.

Third-Party Integrations

We offer third-party integration services to allow educators to migrate class rosters and coursework to the Platform. Children’s personal information collected by these third-parties is governed by their respective privacy policies. We permit schools to integrate the following tools and applications: Google Classroom and single sign-on (SSO).

Google Classroom. Google Classroom is a cloud-based learning management system. For schools that integrate Google Classroom, student information will be imported from Google to the Platform. We may receive your name, email address, profile picture, coursework, and teacher information.

Single Sign-On. SSO is an authentication process that allows a user to access multiple applications or systems using a single set of login credentials (e.g., username and password). Our platform integrates SSO’s (e.g., Clever, ClassLink, Google, and Microsoft).

2. Use of Children’s Personal Information

At Learning.com, we value transparency and want to provide you with the details of why we are collecting children’s personal information. Short answer: for educational purposes, but see below for more details.

Personal Information Category	Purpose
Identifiers. (Specifically, name, email, account credentials)	Used to create and manage user accounts, authenticate logins, and provide access to educational services. Enables us to respond to questions, deliver requested feedback, and maintain secure access to the platform. Helps us comply with legal and contractual obligations.
Student Submitted Content (Specifically, class assignments and responses to educational activities and assignments)	Deliver and support educational services, including grading and feedback. Enable teachers to review and respond to student work and provide personalized learning experiences. Retain as necessary to meet legal and compliance requirements.
Teacher Submitted Content (Specifically, class assignments and feedback)	Support the creation and delivery of educational content and assessments. Facilitate communication and feedback between teachers and students. Maintain as required for compliance with applicable laws and institutional policies.
Educational Information (Specifically, grade level, school of enrollment, educational progress, activity completion, and performance metrics)	Tailor educational services, track student progress, and generate performance reports. Help teachers and administrators monitor learning outcomes and provide targeted support. Retain to comply with legal and reporting obligations.
Internet Activity (e.g., Platform access times)	Monitor and improve user experience and platform performance. Detect and prevent security incidents or unauthorized activity. Support analytics for service optimization and compliance reporting.

We may also use persistent identifiers to support our internal operations, including helping to maintain a session and recognize when your child returns to the Platform. We conduct audits to ensure that persistent identifiers are not used or disclosed to contact an individual, to create a profile, or for any other purpose, except as permitted under COPPA to provide support for the internal operations of the Platform.

3. Disclosing Children’s Personal Information

Learning.com takes reasonable steps to release children’s personal information only to service providers and third parties capable of maintaining the confidentiality, security, and integrity of such information. Learning.com may disclose children’s personal information with these service providers and third parties in connection with the services they provide, and we contractually prohibit the service providers and third parties from retaining, using, or disclosing any personal information belonging to children, other than as is required to provide such services. You have the right to consent to the collection and use of your child’s personal information for the Platform, while prohibiting further disclosure to third parties or service providers, unless such services are part of the Platform. We disclose children’s personal information with specific service providers and third parties and we explain who they are, when the children’s personal information is shared, and why:

Categories of Third Parties	Under What Circumstances	Purpose of Disclosure
Cloud Services	Children’s use of the Platform	To securely store and manage data necessary for delivering educational services and maintaining system functionality.
IT Services	In the event of technical support	To diagnose and resolve technical issues, with the goal to provide uninterrupted and reliable service.
	Instances of suspected fraud or criminal activity	To investigate and mitigate potential security threats or unlawful activities.
	To respond to unauthorized use or disclosure of children’s personal information	To protect the integrity of children’s personal information and enforce compliance with privacy obligations.
Professional Advisors	In the event of a change to the control or financial status of Learning.com	To facilitate corporate restructuring, including mergers, acquisitions, or divestitures, and ensure continuity of services.
	In the event of a change to the control or financial status of Learning.com	To support financial transactions such as sales, financing, or reorganization.
	In the event of a change to the control or financial status of Learning.com	To manage legal processes related to bankruptcy, receivership, or asset transfers.
Government Authorities	In connection with a lawful request for information	To comply with legal obligations, including cooperation with law enforcement or regulatory investigations.
	In connection with a lawful request for information	To protect our legal rights and ensure compliance with applicable laws and regulations.

4. Privacy Choices: Review, Deletion, and Refusal Rights for Children’s Personal Information

If you are a parent and wish to review your child’s personal information, direct us to delete such information, or refuse to allow further collection or use of such information, please contact your school administrator to submit a request. Upon request by the school administrator, Learning.com will then provide you access to your child’s personal information, deletion of such information, or will stop collection or use of such information.

Learning.com allows teachers, schools, and/or districts to review and delete the personal information collected from their students.

If we learn we have collected personal information from a child other than pursuant to this section, or if we learn that a child has provided us personal information beyond what we requested, we will delete that information as quickly as possible. If you believe that a child may have provided us personal information in violation of this section, please contact us at privacy@learning.com.

In the event we make material changes to our processing practices parents previously agreed to, we will provide such parents an updated direct notice.

5. Security and Retention

We implement comprehensive security measures designed to protect student and educator personal information, including encryption for personal information in transit and at rest, access controls, secure U.S.-based infrastructure, employee training, and continuous monitoring. Our security practices are independently verified annually through industry-recognized audits, such as SOC 2 Type II.

Technical Safeguards

• Encryption of data at rest and in transit (e.g., AES-256, TLS).
• Multi-Factor Authentication (MFA) for user access.
• Firewalls and Intrusion Detection/Prevention Systems (IDS/IPS) to monitor and block malicious traffic.
• Access Control Mechanisms (role-based or attribute-based).
• Endpoint Protection (antivirus, anti-malware, EDR solutions).
• Regular Patch Management to address vulnerabilities.
• Data Loss Prevention (DLP) tools to prevent unauthorized data transfers.
• Network Segmentation to isolate sensitive systems.
• Logging and Monitoring for anomaly detection and incident response.
• Secure Software Development Practices (e.g., code reviews, vulnerability scanning).

Physical Safeguards

• Controlled Facility Access (badges, biometric scanners).
• Surveillance Systems (CCTV monitoring).
• Locked Server Rooms and Cabinets for hardware security.
• Environmental Controls (fire suppression, temperature regulation).
• Device Disposal Procedures (secure wiping or shredding of drives).
• Visitor Management Systems (sign-in logs, escorts).
• Backup Media Protection (locked storage for tapes or drives).

Administrative Safeguards

• Information Security Policies (acceptable use, data classification).
• Employee Training and Awareness Programs on phishing, social engineering.
• Vendor Risk Management (due diligence, security questionnaires).
• Incident Response Plan with defined roles and escalation paths.
• Regular Security Audits and Risk Assessments.
• Access Reviews to ensure least privilege.
• Data Retention and Disposal Policies.
• Business Continuity and Disaster Recovery Plans.
• Compliance Monitoring (HIPAA, FERPA, CCPA, etc.).
• Third-Party Contractual Safeguards (security clauses, breach notification).
• Learning.com will maintain children’s personal information only as long as is reasonably necessary for the purpose for which it was collected. Accounts belonging to children that are inactive for 90 days are securely deleted.

6. Operators that Collect or Maintain Personal Information from Children

A list of all operators that may collect or maintain personal information from children through the Platform is available below. Please direct inquiries about any third-party operator’s privacy practices and use of children’s personal information through the contact information provided on the list.

7. How to Contact Us

If you have any questions or comments about this Policy, how Learning.com collects, uses, and discloses children’s personal information, your rights and choices regarding such use, or if you wish to exercise your rights, please contact us at:

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Learning.com
Operators That Collect or Maintain Children’s Information

The following are all operators that may collect or maintain personal information from children through the Platform:

Name	Address	Telephone Number	Email
ClassKey Corp.	19951 Palmer Classic Pkwy, Ashburn, VA 20147	708.232.0645	support@classkick.com
ClassLink Inc.	45 E Madison Ave, Suite 7, Clifton, NJ 07011	1.888.963.7550	info@classlink.com
Clever Inc.	575 Market Street, Suite 1850, San Francisco, CA 94105	1.877.578.5572	trust@clever.com
Google LLC	1600 Amphitheatre Parkway Mountain View, CA 94043	650.253.0000	support-privacy@google.com
Microsoft Corp.	One Microsoft Way, Redmond, WA 98052	1.800.642.7676	privacy@Microsoft.com