Learning.com Platform Privacy Policy

Last Updated: October 3, 2025

1. Scope of This Policy

The Learning Internet, Inc. (“Learning.com,” “we,” “us,” “our“) respects your privacy and values your trust. This Privacy Policy explains how we collect, use, disclose, and protect personal information when you access and use the [title of portal] through our websites https://login.learning.com/ or https://www.codesters.com/login/ (the “Sites“) or our mobile application (the “App“) (the Sites and App are collectively the “Portal“). This policy does not apply to our public websites or any other interaction you have with us outside of the Portal, which are covered by a separate privacy policy (available here). If you have questions about this Privacy Policy or our privacy practices, please refer to the How to Contact Us section below.

The Portal is designed for administrators, teachers, and students and is provided under agreements with schools. For children under the age of 13, please see the Children’s Privacy Policy.

2. Agreement to Terms

If you do not agree with the terms of this Privacy Policy and our Terms of Use, you should immediately discontinue use of the Portal without providing us with any personal information.

3. Personal Information We Collect

Student Personal Information

Learning.com collects, uses, and discloses personal information from students ages 13 to 17 only when their school, district, or teacher has a contract with us. This personal information, which we refer to as “Student Personal Information,” may include “educational records,” which are protected under the Family Educational Rights and Privacy Act (FERPA) or other state privacy laws. For purposes of FERPA, Learning.com is a “school official.” Student Personal Information is a subset of personal information. Learning.com collects and uses Student Personal Information solely for the educational purposes authorized by the school, district, or teacher, and not for any other commercial purpose.

We may collect the following categories of Student Personal Information from either your school or cookies on the Portal:

Identifiers

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

Student Submitted Content

The student’s class assignments and responses to educational activities and assignments.

Educational Information

The student’s grade level, school of enrollment, class assignments, educational progress, activity completion, performance metrics, and responses to educational activities and assignments.

Internet Activity

We may collect Student Personal Information concerning your interaction with the Portal, including when you access the Portal and your browsing activity on the Portal. 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 Portal.

Administrator and Teacher Personal Information

We may collect the following categories of personal information from your employer and from cookies and similar technologies on the Portal.

Identifiers

We may collect your first name, last name, account username, account password, email address. We may assign a session ID and a unique user identifier to help maintain your session and recognize you when you return to the portal.

Professional and/or Employment Information

We may collect name of your employer, job title, and work email.

Internet Activity

We may collect personal information concerning your interaction with the Portal, including when you access the Portal and your browsing activity on the Portal (such as which pages you visit, in what order, and for how long).

You are not required to provide all personal information identified in this Privacy Policy to use our Portal or to interact with us, but certain functionality will not be available if you do not provide certain personal information.

4. Cookies

We automatically collect certain personal information through cookies and similar technologies. A cookie is a small string of information that a website that you visit transfers to your browser for identification purposes. Cookies on the Portal are generally divided into the following categories:

• Strictly Necessary Cookies. These are required for the operation of the Portal. They include, for example, cookies that enable you to log into password-protected portions of the Portal. These cookies are session cookies that are erased when you close your browser.
• Functional Cookies. We may use limited, essential cookies to ensure the Portal operates securely and reliably. These tools support functions such as load balancing, error detection, and performance monitoring—not for marketing or cross-site tracking. We do not use analytics or advertising cookies in the Portal.

You can also prevent the use of certain cookies by modifying your Internet browser settings, typically under the sections “Help,” “Internet Options,” or “Settings.” If you disable or delete certain cookies in your Internet browser settings, you may still access our Portal, however, you might not be able to access or use important functions or features of our Portal, and you may, for example, be required to re-enter your log-in details.

Do-Not-Track Signals

At this time, we do not recognize automated “do-not-track” browser signals.

5. Children’s Privacy

See our Children’s Privacy Policy to understand how Learning.com collects, uses, discloses and protects personal information from children under that age of 13 when they use the Portal as part of the educational services we provide to schools.

6. Our Use of Personal Information

We collect and use your personal information for the following purposes:

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.
Teacher/Administrator Information: (Specifically, name of employer, job title, and work email.)	Verify educator identity, manage accounts, and provide access to administrative tools. Facilitate communication and support for educational services. Maintain as necessary for compliance and contractual purposes.
Internet Activity (e.g., Portal 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.

7. Our Disclosure of Personal Information

We may disclose your personal information with the following third parties:

• Our group companies, including any affiliates, subsidiaries, or parent entities of Learning.com.
• Service providers. We may disclose personal information with trusted third-party service providers and contractors who perform functions on our behalf—such as web hosting, data storage, analytics, and related operational services.
• Advisers and financial institutions, including auditors, notaries, business continuity support service providers, and legal, tax, and risk and compliance advisors.
• Third parties in connection with a change to the control or financial status of the company, including a corporate restructuring, sale, acquisition, financing, reorganization, bankruptcy, receivership, transfer, assignment of assets, or business merger or divestiture. Personal information and other information may be disclosed in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction.
• Government authorities, dispute resolution organizations, law enforcement agencies, or other third parties in connection with (a) responding to a subpoena, search warrant, or other lawful request for personal information that we receive; (b) cooperating in a law enforcement or similar investigation; or (c) otherwise protecting our rights, as applicable.

Learning.com processes all student education records in accordance with the Family Educational Rights and Privacy Act (FERPA). We act as a “school official” with a legitimate educational interest under FERPA when providing services to schools.

8. Security

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.

Whenever you give out personal information online there is a risk that third parties may intercept and use that information for their own purposes. Although we seek to protect your personal information and privacy, we cannot guarantee the security of any personal information you disclose online.

You play an important role in keeping your personal information secure. You should not disclose your username or password with anyone. If you have reason to believe that your account is no longer secure, please contact us immediately at privacy@learning.com at the contact information in the How to Contact Us section below.

9. Links to Other Websites

For your convenience, the Portal may include links to our public website or other third-party sites. For example, when you select the “Help, Support, & Training” button, it will lead you to our general website. When you follow these links, the privacy practices of those sites—including our public website—apply, not this [Portal Privacy Policy] or the Children’s Privacy Policy. For example, our public website uses different types of cookies that are not present in the Portal. We encourage you to review the applicable privacy policies before interacting with any linked site. We are not responsible for the privacy practices or content of third-party websites.

10. Additional Disclosures for Residents of California

For residents of California, this section describes how we collect, use, and disclose the personal information of California residents, and the rights you may have under California law. These disclosures are intended to supplement this Privacy Policy with information required by California law.

To understand what personal information we may have collected about you in the past 12 months, and from where we collected it, please see the section Personal Information We Collect and Children’s Privacy Policy above.

We use this personal information, as further described in the Our Use of Personal Information and Children’s Privacy Policy section.

We may disclose personal information with the third parties listed above in the section Our Disclosure of Personal Information and Children’s Privacy Policy. Below, we have provided additional detail, as required by California law.

No “Selling” or “Sharing” of Personal Information

We do not sell or share your or your child’s personal information.

Disclosure of Personal Information for a Business Purpose

To manage our business and provide services to you, we sometimes disclose personal information with third parties. These third parties cannot further collect, sell, or use the personal information we disclose with them.

In the past 12 months, we may have disclosed the following categories of personal information to the following third parties for our operational business purposes:

Personal Information Category	Third-party
Identifiers	• Service Providers
Device Information	• Service Providers
Internet Activity	• Service Providers

Your Rights

Under California law, you have the right to receive notice, at or before the point of collection, regarding the categories of personal information collected about you or your child and the purposes for which that information will be used. You also have the right to request access to the categories and specific pieces of personal information that we collect, use, disclose, and/or sell about you or your child. Additionally, you may request the deletion of your personal information, subject to certain exceptions. You have the right to opt out of the “sale” and “sharing” of your personal information (but, we do not “sell’ or “share” your personal information), as well as the right to limit the use and disclosure of your sensitive personal information (including children’s information). Finally, you have the right to be free from discrimination for exercising any of your privacy rights.

Profiling for Legally Significant Effects

Learning.com does not engage in profiling of consumers in furtherance of automated decisions that produce legal or similarly significant effects, as those terms are defined under Applicable State Laws.

Sensitive Personal Information

We collect and process children’s information in accordance with our Children’s Privacy Policy.

Exercising Your Rights

You may submit a request to exercise your rights to access, correction, deletion, and data portability by contacting your school administrator. You may also revoke your consent for the processing of sensitive personal information at any time by contacting your school administrator.

Retention

Learning.com determines the retention period(s) for the categories of personal information through analysis including requirements under applicable law and legal considerations, financial audit and recordkeeping needs, consumer care needs and accuracy of records.

11. Additional Disclosures for Residents of Certain U.S. States

For residents of U.S. States with applicable comprehensive consumer privacy laws, including Nebraska and Texas (but, excluding California) (“Applicable State Laws“), this section describes how we collect, disclose, and use your personal information and the rights you may have under such laws. These disclosures are intended to supplement our main Privacy Policy with information required by these Applicable State Laws.

Our Collection, Use, and Disclosure of Personal Information

To understand what personal information we may have collected about you, and from where we collected it, please see the Personal Information We Collect and Children’s Privacy Policy section.

We collect this personal information, as further described in the Our Use of Personal Information and Children’s Privacy Policy section above.

We may disclose personal information with the third parties as detailed in Our Disclosure of Personal Information and Children’s Privacy Policy section.

No “Selling” of Personal Information and Targeted Advertising

We do not sell or use your or your child’s personal information for targeted advertising purposes.

Profiling for Legally Significant Effects

Learning.com does not engage in profiling of consumers in furtherance of automated decisions that produce legal or similarly significant effects, as those terms are defined under Applicable State Laws.

Your Rights

Under Applicable State Laws, you may have a right to notice, upon collection, of the categories of personal information collected and the purposes for which the information will be used. In addition, subject to certain limitations, you may have the following rights:

• Access: The right to confirm whether we are processing your personal information and to access such personal information, including receiving a copy of the personal information we have collected about you.
• Correction: The right to request that we correct inaccurate personal information that we hold about you, taking into account the nature of the personal information and the purposes of the processing.
• Deletion: The right to request that we delete your personal information, with certain exceptions.
• Data Portability: The right to obtain a copy of your personal information in a portable, and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
• Opt-Out Rights
  • the “sale” of your personal information
  • targeted advertising
  • profiling in furtherance of decisions producing legal or similarly significant effects concerning you.
• Revoke Consent: You have the right to revoke consent to the processing of sensitive personal information.
• No Retaliation: The right to be free from unlawful discrimination for exercising your rights.

Exercising Your Rights

You may submit a request to exercise your rights to access, correction, deletion, and data portability by contacting your school administrator. You may also revoke your consent for the processing of sensitive personal information at any time by contacting your school administrator.

Retention

Learning.com determines the retention period(s) for the categories of personal information through analysis including requirements under applicable law and legal considerations, financial audit and recordkeeping needs, consumer care needs and accuracy of records.

12. How to Contact Us

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