Empower Learning ("Empower Learning, LLC") values your privacy. In this Privacy Policy, we describe how we collect, use, and disclose information that we obtain about users of our Learning Management System “Empower.” It also describes the choices available to you regarding our use of your personal information and how you can access and update your personal information.

By submitting personal data (as defined below) through our sites, apps or services, you agree to the terms of this Privacy Policy, and you expressly consent to the collection, use and disclosure of your personal data in accordance with this Privacy Policy.

IF YOU ARE A PARENT OR TEACHER OF A CHILD UNDER THIRTEEN YEARS OLD, PLEASE REVIEW OUR COPPA PRIVACY POLICY (below), WHICH CONTAINS IMPORTANT INFORMATION FOR PARENTS ABOUT HOW WE COLLECT, USE, AND DISCLOSE THE PERSONAL INFORMATION WE COLLECT FROM CHILDREN UNDER THIRTEEN YEARS OLD.

FERPA Privacy Policy

Empower Learning, LLC, recognizes the importance of data security and privacy to our users. This FERPA Privacy Policy is designed to comply with the Family Educational Rights and Privacy Act (FERPA). Empower strives to maintain effective and up-to-date technological and procedural safeguards for protecting personally identifiable customer information, including student information within the scope of FERPA, as described further below.

To help you ensure that your educational institution complies with its obligations under FERPA, we are able, as your educational services partner, to confirm that Empower takes numerous measures to maintain the security and confidentiality of all student records by, for example, providing secure hosting facilities for the storage of student data that use encryption and/or physical security measures, as well as firewall protection and restricted, password protected access.Empower’s learning management tools provide options that allow students, instructors and/or educational institutions to restrict or grant access to information by certain parties or “roles” within the platform. We also encourage all of our customers to help ensure that confidential information remains secure by using strong passwords and changing passwords frequently. Through our User Agreement with Educational Institutions, Empower requires that users maintain their passwords in the strictest confidence and prohibits the use or posting of student social security numbers in any manner, or posting of other sensitive personal information by users.

Empower is typically integrated with a school’s Student Information System (SIS) or the school uploads manually all to the Empower application on behalf of the end-user (student, staff or instructor), users must still consent to the disclosure of their personal information by Empower, but it is the school’s responsibility to provide notice to students that Empower is among the school’s vendors to whom educational records may be disclosed by the school and establish a method for making the user registration information anonymous if a user so requests.

Regardless of how User information is obtained, Empower makes every effort to ensure that it is collected and stored consistent with FERPA’s policies. Empower encourages Licensee’s to employ policies and procedures that explicitly address student privacy concerns in connection with third party learning management systems hosted outside their educational institution, such as, notifying students & parents that the school/district/class uses third party platforms, educating students and instructors on school policies with regard to the use of such systems and how to use the features of Empower platforms to protect student data; and providing students and instructors with student identification numbers that are not highly sensitive (cannot be the used as the sole basis to access sensitive campus student information or educational records) in order to facilitate an anonymous experience within the Empower environment.

We believe the above information appropriately addresses questions posed by adopting institutions on how Empower addresses the FERPA guidelines on management of student consent and personally identifiable information. The following details more specific privacy policies for our end users.

Summary of Key Points

• We collect Personal Data from Teachers and Parents when a Teacher or Parent accesses and takes actions on our Sites, Apps or Services, such as when a Teacher or Parent creates an Account. We also collect Personal Data from Teachers when a Teacher creates and posts content to his or her Profile and/or Newsfeed and interacts with other users, including with Students.

• We collect Personal Data about Students that is provided to us by Teachers or Schools, such as their names, student assessment responses and other evidence of learning. If a Teacher creates an Account on behalf of the Student, we collect limited Personal Data about the Student from the Teacher to establish the Account.

• We use the Personal Data we collect to provide Teachers, Parents and Students with the LMS Services. For instance, we use Personal Data to enable Teachers to edit and manage their Accounts, Profiles and/or Newsfeeds, to enable Teachers to load and share content including Resource Pins and Educational Materials (both as defined below), and to enable Teachers to connect with their Students, Parents, and other Teachers. We also use Personal Data to enable Teachers, Parents and Students to access and view assessment responses, evidence of learning, Resources Pins, Educational Materials, as well as all other features of the Services.

• We share Teacher Personal Data with other Teachers through a Teacher’s Profile and/or Newsfeed, depending on the Newsfeed privacy settings. We share Teacher Personal Data with Students and Parents but limited to only the Teacher’s name and School.

• We share Student Personal Data only in limited ways. We share Student Personal Data only with that Student’s Parent(s) and their Teacher(s) as expressly described in this Privacy Policy and our COPPA Privacy Policy.

• We also share Personal Data of all users of the Sites, Apps, and Services with third parties but only for the express purpose of helping us to provide the Services.

• We use cookies and other tracking and analytic technologies on our Sites and in our Services to track the use of our Sites and Services and to enhance the functionality of our Sites and Services.

• We do not host third party advertisements on our Sites, Apps or Services. We do not provide Personal Data to third parties for their own marketing purposes.

• For more information about your choices regarding your Personal Data, including how to access or modify your Personal Data, please see the section title “Your Choices Regarding Your Data.”

What Information Do We Collect About You?

We may collect Personal Data from end users affiliated with a particular school or other educational institution or organization (“School”) who are teachers or administrators (“Teachers”), students, which may include children under the age of 13 (“Students”), and parents or legal guardians of Students (“Parents”) as each uses our Sites, Apps and Services (any individual end user in one of these groups or all three collectively may be referred to as “you”). “Personal Data” means data that allows someone to identify or contact you, including, for example, your name or email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. We may also collect Anonymous Data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. To the extent that Anonymous Data is linked with your Personal Data, we will treat it as Personal Data.

We collect Personal Data and Anonymous Data that Teachers, Parents and Students provide to us directly. We may also collect Personal Data or Anonymous Data automatically, through technologies used on the Sites, in the Apps and in the Services, as described below.

Information we collect directly from you

Information we collect from Teachers and Parents:

• Certain areas and features of our Sites, Apps, and Services may require you to register for an account through which you can log in to access the Services (“Account”). If you register for an Account as a Teacher or Parent, we will collect your (1) email address and/or username and (2) a password.

• We may collect and retain information on your behalf, such as files and messages that you store and/or share using your Account.

• If you participate in one of our surveys, we may collect additional profile information.

• If you choose to provide it, we may collect any feedback, testimonials or comments you may provide to us about your use of the Sites, Apps or Services.

• If you contact us via email to provide comments, feedback, or to request support for the Services, we may collect other types of Personal Data, such as your operating system and version, as applicable, your IP address, and other requested information.

• We may also collect Personal Data at other points in our Sites that state that Personal Data is being collected.

Information we collect only from Teachers:

• If you choose to post messages or other content on the Sites, Apps or Services using your Account or Profile, such as through the newsfeed function on your Account (“Newsfeed”), the information contained in your posting will be stored on our servers and will be viewable by all other users unless you choose to make your Newsfeed private through the privacy settings on your Account.

• If you choose to provide them, any learning assessments, links or references to external educational and learning resources (“Resource Pins”), curriculum maps, student scores or other academic or educational resources or materials (“Educational Materials”) that you choose to upload to your Account.

• If you make a purchase on our Sites or Apps or through our Services, we will collect all information needed to complete the transaction, including but not limited to your e-mail address and password, credit card information, and name on your credit card. For more information about payment processing, please see below.

• If you choose to provide it, the name or other select Profile information to identify another Teacher whose Newsfeeds you wish to follow and about whom you wish to receive updates and other information on the Sites, Apps or Services (“Follow”).

Information we collect from Students:

• We may collect a Student’s name, assessment information, and other information as directed by the Student’s Teacher or School. We limit the information we collect about Students to only that information necessary to provide the Service. We do not use the Student’s Personal Data for our own commercial purposes.

• We collect Student assessment responses and may archive evidence of learning.

Information We Collect Automatically

• We may automatically collect the following information about your use of our Sites, Apps, or Services through our servers and in log files: domain name; browser type and operating system; web pages viewed; links clicked; the length of time spent on our Sites or Apps; the length of time our Services are used; the referring URL, or the webpage that led a user to our Sites; language information; device name and model; operating system type, name, and version; and activities within our Sites and Apps. We use this information to analyze trends, administer the Sites, track users’ movements around the Sites, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. We do not link this automatically-collected data to Personal Data.

• We may also collect IP address, device identifier or a similar unique identifier from users of our Apps and Sites; we only use such identifiers to support the internal operations of our Sites and Apps in the same manner as described above.

• We may also collect non-personal information from your mobile device if you have downloaded our Apps. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include how you use the Apps and information about the type of device you use. In addition, in the event our Apps crash on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our Apps. This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual.

Information We Receive from Third Parties

In some cases, the Services may allow you to set up an Account and/or sign in using your Google Plus ID or your Clever ID. If your school chooses to use this option, if available, we will receive information for the sole purpose of setting up your Account and/or enabling you to sign in to your existing Account.

How We Use Your Information

General Use

We use the information that we gather about you for the following purposes:

• To provide you with our Services, as applicable to Teachers, Students and Parents;

• To facilitate creation of your Account on our Sites or Apps;

• To identify you as a user in our system;

• To provide improved administration of our Sites, Apps and Services;

• To send you a welcome email to verify ownership of the email address provided when your Account was created;

• To send you administrative notifications via email, text or other digital means;

• To respond to inquiries that you send to us, including your customer service requests, and for other customer service purposes; and

• To provide Students, Parents and Teachers with information and reports about Student performance and use of the Sites, Apps, and Services.

If you are a Teacher, we also use the information that we gather about you for the following additional purposes:

• To tailor the content and information that we may send or display to you, to offer personalized help and instructions, and to otherwise personalize your experiences while using the Sites, Apps, or Services;

• To enable you to create and post content to your Profile through your Account, load and share Resource Pins and other Educational Materials, enable you to Follow other users and to enable you to post and share content on your Newsfeed; and

• To send you news and newsletters, special offers, and promotions from Empower Learning, LLC, or to otherwise contact you with information we think may be of interest related to Empower Learning, LLC products and services. You are able to change your preferences under your Profile settings if you wish to opt out of these types of emails. We will not send marketing or promotional materials to Student users.

Aggregated or Anonymous Data

We may aggregate or anonymize data we collect to create Anonymous Data. Anonymous Data does not identify you individually. We may use this Anonymous Data for our own purposes, such as to better understand how users access and use our Sites, Apps, and Services in order to improve our Sites, Apps, and Services and respond to user desires and preferences, and for other research and analytical purposes. We also may disclose Anonymous Data to third parties in order to meet these purposes.

How We Share Your Information

We do not sell your personal information. We will disclose the Personal Data that we collect from you only as described in this Privacy Policy.

We may disclose Personal Data as follows:

• Teacher Data. If you are a Teacher, we will share the Educational Materials, Resource Pins and other information that you load through your Account with the other Teachers, Students and Parents that you have allowed to receive it. We will share any information that you post on your Profile with other users in the educational system. We will share any information that you post to your Newsfeed based on the privacy settings you have selected.

• Student Data. We will disclose Personal Data of Students: (1) to each Student’s Teacher(s) and their Parent(s); (2) as directed by the Student’s Teacher(s) or school; and (3) as further described in our COPPA Privacy Policy. The Student’s Teacher(s) may share the Student’s scores, academic progress data or other academic information (“Academic Data”) with other Teachers.

• Third Party Service Providers. We may disclose Personal Data to third-party vendors, service providers, contractors or agents who perform functions on our behalf and/or at the request of a school or district customer in order to: provide you with the Services that we offer you through our Sites and Apps; conduct quality assurance testing; facilitate creation of accounts; provide technical support; and/or provide other services to us. These third party service providers are required not to use your Personal Data other than to provide the services requested by the Company. We will not disclose Personal Data to third parties for any purposes not described in this Privacy Policy.

• Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the Personal Data we have collected to the other company. We will notify your school via email and/or a prominent notice on our Sites of any change in ownership or uses of your Personal Data, as well as any choices you may have regarding your Personal Data.

• In Response to Legal Process. We may disclose Personal Data in order to comply with applicable law, a judicial proceeding, court order, or other legal process.

• To Protect Us and Others. We may disclose Personal Data where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Privacy Policy, or as evidence in litigation in which Empower Learning, LLC is involved.

• No Disclosure to Third Party Companies for Marketing. As stated above, we will not disclose your Personal Data to any third party company for the third party company’s own direct marketing purposes.

• Disclosure to Other Third Parties Only With Consent. Beyond the disclosures described in this Privacy Policy, Empower Learning, LLC will not disclose your Personal Data to any other third party without your consent to do so.

Public Comments

If you make any comments to a Newsfeed, Educational Materials, Resource Pins or other items or forums associated with the Sites or Apps that are publicly viewable by the Empower Learning, LLC community, you should be aware that any Personal Data you submit there can be read, collected, or used by other users, and could be used to send you unsolicited messages. We are not responsible for Personal Data that you choose to submit in these blogs and forums.

Our Use of Cookies and Other Tracking Mechanisms

Cookies. We use cookies to track information about your use of our Sites, Apps, or Services. “Cookies” are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them). Some Cookies allow us to make it easier for you to navigate our Sites and Services, while others are used to enable a faster log-in process or to allow us to track your activities but only as those activities relate to your use of our Sites and Service.

Third-Party Analytics. We may also use third party analytics tools and technologies, such as Google Analytics, to track and analyze data from our Sites, Apps, or Services. Google Analytics uses Cookies to collect information such as how often users visit the Sites, what pages they visit, and what other sites they used prior to coming to the Sites. We use the data collected by such third party analytics tools only to help us administer and improve the quality of our Sites, Apps, and Services and to analyze usage. These third parties are not permitted to use the information collected on our behalf, except to help us conduct and improve our business. Google Analytics collects only the IP address assigned to you on the date you visit the Sites, rather than your name or other personally identifying information. Although Google Analytics plants a persistent Cookie on your web browser to identify you as a unique user the next time you visit the Sites, the Cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Sites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. For more information on Google’s privacy practices, please click here. For information about how to opt out of Google Analytics, please click here.

Teacher Profiles

• If you are a Teacher, the Personal Data you provide on your Profile, including your profile photo, is made public by default on the Sites, Apps and Services and is viewable by other Teachers.

• Once displayed publicly, the information you post in your Profile and Newsfeed(s) can be collected and used by others. We cannot control who reads your Newsfeed, postings or what other users may do with the information that you voluntarily post, so it is very important that you exercise caution with respect to any Personal Data that you include in your posts. Once you have posted information publicly, while you will still be able to edit and delete it on the Sites or App, you will not be able to edit or delete such information cached, collected, and stored elsewhere by others (e.g., search engines).

Third-Party Links

Our Sites, Apps, and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Privacy Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

Security of Your Personal Information

We have implemented a variety of security measures to protect the personal information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We protect your login information and the transmission of data using Secure Socket Layer (SSL) technology.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Your Choices Regarding Your Personal Data

You have several choices regarding our use of your information on our Services:

Accessing and Deleting Your Personal Information

• You may edit or delete any of the non-required information from your Personal Data through the profile page in your Account on our Sites or Apps.

• You may request deletion of your Personal Data or your entire Account by contacting your school administration who is responsible for your educational and student information system. If your account was set up directly through the Empower Learning Application, you may contact us directly.

• Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Sites or Apps for a period of time.

Disabling Cookies.

Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Sites who disable cookies will be able to browse certain areas of the Sites, but some features may not be available to you.

Changes to This Privacy Policy

This Privacy Policy is current as of the Last Updated Date set forth above. We may update this Privacy Policy from time to time to reflect changes in our information processing practices. If we make any material changes to this Privacy Policy, we will notify you at the email address that we have on file for you in advance of the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

COPPA Privacy Policy

Empower Learning, LLC, values the privacy of children and of all of its users. This COPPA Privacy Policy ("COPPA Policy") is designed to comply with the Children's Online Privacy Protection Act ("COPPA") and contains important information about how we collect, use, and disclose the personal information we collect from children under thirteen years old who use our Learning Management System known as Empower. This COPPA Policy also explains how a parent or guardian (“parent” or “you”) can restrict the collection, use and/or disclosure of your Child’s (as defined below) information and how you can request deletion of your Child’s information. The Empower Learning, LLC Services is an educational tool and resource that educator end users (“Educators”) can use as part of their learning environment to identify levels of student understanding around their instruction on a real-time basis as well as personalized learning needs. To use the Services, Teachers may collect personal information from their students, including children who are under 13 years old (“Students”). For the purposes of this Policy, "Child" or "Children" means a Student under 13 years old.

When an “Educator” uses our Services in the classroom or an educational setting, such as to sign Students up for the Services, or to assign response activities to Students and track their progress, the School is required to provide consent to the collection and use of personal information from and about Children as required under applicable laws, including but not limited to COPPA and Family Educational Rights and Privacy Act (“FERPA”). They are also responsible for providing parents with notice about how personal information from their Child(ren) is collected and used by us.

Children's personal information will be handled only as described in this COPPA Policy. Any personal information we collect about other users (e.g., Students over 13 years old, Teachers, and parents) will be treated in accordance with the Empower Learning, LLC Privacy Policy ("Privacy Policy").

What Information Do We Collect About Children? We may collect information about Children directly from Children and/or their Teachers, as well as automatically through a Child's use of our Sites, Apps, and/or Services. We will not require a Child to disclose more information than is reasonably necessary to use our Services. Further, as explained below, we will not collect a Child’s name, contact information, or other personal information directly unless a Teacher or School requests it. We provide Teachers and Schools with a notice regarding our privacy practices.

Information We Collect Directly. Empower Learning, LLC does not require Children to submit name, contact information, or other personal information to us to register for our Sites, Apps or Services. To log on to the Services, Children are prompted to enter either a unique and anonymous user ID, which will be provided to the Student by the school or district, and/or a unique and anonymous student ID generated either by the School or by Empower Learning, LLC.

We may collect a Child's name and other limited personal information directly from a Child's Teacher or School. Through our Services, Teachers can create assessments and track their Students’ learning progress. In doing so, Teachers may require the Child’s personal information in order to track and archive evidence of learning. Teachers are responsible for ensuring that their collection and use of personal information from Children complies with applicable laws, including COPPA and FERPA. If you are a parent and you have questions about your Child's Teacher's use of our Services and any information collected, you should discuss your questions with your child's Teacher or School.

A Teacher has the option of creating an account on behalf of their Students which allows those Students to view their learning progress and access learning resources provided by their Teacher. If a Teacher chooses to register a Child for an account, Empower Learning, LLC will generate a user name and temporary password and provide directly to the Teacher who may then share with the Child. The only information we collect directly from the Child is a permanent password for their account.

We collect information about Children's performance and activities on our Sites, Apps, and Services, including the assessments taken, questions answered, and other evidence of learning. This information is made available to Teachers in personally identifiable form; we do not use this information in personally identifiable form for our own commercial purposes. If we analyze or use any activity data for our own commercial purposes, we will de-identify and/or aggregate such information.

Parents can tell us to stop collecting personal information from their Child(ren); however, in such cases the Child(ren) will not be able to use our Services, as they are intended to be controlled by a Teacher. If you direct us to stop collecting and using your Child's personal information, we must disable his or her use of our Services to ensure that no information is collected via the Teacher's use of Empower Learning, LLC as a classroom tool.

Information We Collect Automatically. We may automatically collect the following information about a Child’s use of our Sites, Apps, or Services through our servers and in log files: domain name; browser type and operating system; web pages viewed; links clicked; the length of time spent on our Sites or Apps; the length of time our Services are used; the referring URL, or the webpage that led a user to our Site; language information; device name and model; operating system type, name, and version; and activities within our Sites and Apps. We use this information to analyze trends, administer the Sites, track users’ movements around the Sites, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. Except as noted in this COPPA Policy, we do not link this automatically-collected data to a Child’s personal information.

We may also collect IP address, device identifier or a similar unique identifier from users of our Apps and Sites; we only use such identifiers to support the internal operations of our Sites and Apps in the same manner as described above.

We may also collect information from any mobile devices that a Child uses if the Child has downloaded one or more of our Apps to the device. This information is generally used to help us deliver the most relevant information to the Child. Examples of information that may be collected and used include how the Child uses the App(s) and information about the type of device the Child is using. In addition, in the event our App(s) crash on a mobile device, we will receive information about the mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our App(s). This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual.

How We Use Children’s Information

We use the personal information that we collect from Children for the following general purposes:

• To provide our Services;

• To respond to customer service and technical support issues and requests;

• To identify the Child as a user in our system;

• To provide improved administration of our Site, App and Services; and

• To tailor the content and information that we may display to Children, to offer personalized help and instructions, and to otherwise personalize a Child’s experiences while using the Sites, Apps, or Services.

As Requested by Teachers. When a Teacher or School provides a Child’s name and other personal information, we use that personal information for the following additional purposes:

• To provide Children and Teachers with information and reports about a Child’s performance and use of the Sites, Apps, and Services;

• If requested, to facilitate creation of a Child’s account;

• We do not use or disclose this personal information for our own commercial purposes.

Unique Identifiers. As noted, with the exception of unique identifiers (e.g., IP address and device identifiers), our Sites, Apps, and Services will not collect personal information from Children. We only collect and use unique identifiers as necessary to operate our Sites, Apps, and Services, including to maintain or analyze their functioning; perform network communications; authenticate users or personalize content; and protect the security or integrity of users and our Site, App, and Services. We never use unique identifiers to track users across third party apps or websites.

Aggregate or De-identified Information. We may use aggregate or de-identified information about Children for research, analysis, and similar purposes. When we do so, we strip out names, email, contact information, and other personal identifiers. For example, we may use aggregate or de-identified information for one or more of the following purposes, among other purposes:

• To better understand how users access and use our Sites, Apps, and Services;

• To improve our Sites, Apps, and Services and respond to user desires and preferences; and

• For other research and analytical purposes.

How We Share Children’s Information

We do not sell Children's personal information, and a Child may not make his or her personal information public through our services (though Teachers may choose to share a Child’s information and responses with the Child’s classmates or with other Teachers). We will disclose the personal information that we collect from Children only as described in this COPPA Policy. We may disclose Children’s personal information as follows:

• Parents, Teachers and Classmates. We will disclose Children’s personal information: (1) to each Child’s Teacher(s) and parent(s); and (2) as directed by the Child’s Teacher(s) or School.

• Third Party Service Providers. We may disclose a Child’s personal information to third-party vendors, service providers, contractors or agents who perform functions on our behalf and/or at the request of a school or district customer in order to: provide the Child and the Child’s Teacher with the Services that we offer through our Sites and Apps; conduct quality assurance testing; facilitate creation of accounts; provide technical support; and/or provide other services to us. These third party service providers are required not to use personal information other than to provide the services requested by Company. We will not disclose Personal Data to third parties for any purposes not described in this COPPA Policy.

• In Response to Legal Process. We may disclose personal information that we have collected from Children in order to comply with applicable law, a judicial proceeding, court order, or other legal process.

• To Protect Us and Others. We may disclose personal information that we have collected from Children where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service, our Empower Learning, LLC Privacy Policy or this COPPA Policy, or as evidence in litigation in which Empower Learning, LLC is involved.

• No Disclosure to Third Party Companies for Marketing. As stated above, we will not disclose personal information that we have collected from Children to any third party company for the third party company’s own direct marketing purposes.

• Disclosure to Other Third Parties Only With Consent. Beyond the disclosures described in this Privacy Policy, Empower Learning, LLC will not disclose your Personal Data to any other third party without a Teacher or School’s consent to do so.

Our Use of Cookies and Other Tracking Mechanisms

Cookies. We use cookies to track information about a Child’s use of our Sites, Apps, or Services. “Cookies” are alphanumeric identifiers that we transfer to a computer’s hard drive through a web browser for record-keeping purposes. We may use both session Cookies (which expire once a user closes a web browser) and persistent Cookies (which stay on a computer until a user deletes them). Some Cookies allow us to make it easier for a Child to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track a Child’s activities, but only as those activities relate to a Child’s use of our Sites and Service.

Third-Party Analytics. We may also use third party analytics tools and technologies, such as Google Analytics, to track and analyze data from our Sites, Apps, or Services. Google Analytics uses Cookies to collect information such as how often users visit the Sites, what pages they visit, and what other sites they used prior to coming to the Sites. We use the data collected by such third party analytics tools only to help us administer and improve the quality of our Sites, Apps, and Services and to analyze Sites and Apps usage. These third parties are not permitted to use the information collected on our behalf, except to help us conduct and improve our business. Google Analytics collects only the IP address assigned to a user on the date the user visits the Sites, rather than a user’s name or other personally identifying information. Although Google Analytics plants a persistent Cookie on a user’s web browser to identify the user as a unique user the next time the user visits the Sites, the Cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about a user’s visits to the Sites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. For more information on Google’s privacy practices, please click here. For information about how to opt out of Google Analytics, please click here.

Third-Party Links

Teachers may provide Children with links to third-party educational and learning resources located on third party websites. Any access to and use of such linked websites is not governed by this COPPA Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

Your Rights to Review, Delete, and Control Our Use of Children’s Personal Information

Parents and Teachers have a right to review the information we have collected about their Child(ren) and Students, respectively, and to delete it, and to tell us to stop using it. To exercise these rights, you may contact us at. You will be required to authenticate yourself as the Child's parent or Teacher to receive information about that Child. Please note that we cannot delete copies of information that a Child's Teacher has already collected and/or copied, and copies of information that you have deleted may remain viewable in cached and archived pages of the Sites or Apps for a period of time.

Additional Choices Regarding Children’s Personal
 Information

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Sites who disable cookies will be able to browse certain areas of the Site, but some features may not be available to you.

Applications. You can stop all collection of information by the App(s) by uninstalling the App(s). You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

Changes to this COPPA Policy

This COPPA Policy is current as of the Last Updated date set forth above. We may change this COPPA Policy from time to time, so please be sure to check back periodically. If we make any changes to this COPPA Policy that materially affect our practices with regard to the personal information we have previously collected from a Child, we will provide you with notice in advance of such change becoming effective by emailing you at the address we have on file for you and by highlighting the change on our Site.

Contact Us

If you have questions about the privacy aspects of our Services, please contact us at:

Empower Learning, LLC

Attn: Legal

317 W. 4th Street

Greenville, Ohio 45331

john@empowerlearning.net