Privacy of Personal Information Provided on Behalf of Children
Triumph Learning, LLC (“Triumph Learning”) understands that users of our educational products who are under 13 years of age (“Children”) need special safeguards and privacy protection, and it is the intent of Triumph Learning to fully comply with the Children's Online Privacy Protection Act (“COPPA”). Triumph Learning does not collect personal information directly from Children online at any point. Triumph Learning only receives personal information about Children directly from school administrators and/or teachers when they set up one of our learning programs.
In furtherance of our commitment to protect the privacy of Children and other students, Triumph Learning has made the K-12 School Service Provider Pledge to Safeguard Student Privacy, whereby we have committed to:
- Not collect, maintain, use or share student personal information beyond that needed for authorized educational/school purposes, or as authorized by the parent/student.
- Not sell student personal information.
- Not use or disclose student information collected through an educational/school service (whether personal information or otherwise) for behavioral targeting of advertisements to students.
- Not build a personal profile of a student other than for supporting authorized educational/school purposes or as authorized by the parent/student.
- Not make material changes to our privacy policies without first providing prominent notice to the account holder(s) (i.e., the educational institution/agency) and allowing them choices before data is used in any manner inconsistent with terms they were initially provided; and not make material changes to other policies or practices governing the use of student personal information that are inconsistent with contractual requirements.
- Not knowingly retain student personal information beyond the time period required to support the authorized educational/school purposes, or as authorized by the parent/student.
- Collect, use, share, and retain student personal information only for purposes for which we were authorized by the educational institution/agency, teacher or the parent/student.
- Disclose clearly in contracts or privacy policies, including in a manner easy for parents and teachers to understand, what types of student personal information we collect, if any, and the purposes for which the information we maintain is used or shared with third parties.
- Support access to and correction of student personally identifiable information by the student or their authorized parent, either by assisting the educational institution in meeting its requirements.
- Maintain a comprehensive security program that is reasonably designed to protect the security, privacy, confidentiality, and integrity of student personal information against risks – such as unauthorized access or use, or unintended or inappropriate disclosure – through the use of administrative, technological, and physical safeguards appropriate to the sensitivity of the information.
- Require that our vendors with whom student personal information is shared in order to deliver the educational service, if any, are obligated to implement these same commitments for the given student personal information.
- Allow a successor entity to maintain the student personal information, in the case of our merger or acquisition by another entity, provided the successor entity is subject to these same commitments for the previously collected student personal information.
Parents or legal guardians should contact their Child’s school to review any personal information regarding their Children that the school’s administrators or teachers have provided to Triumph Learning. Parents or legal guardians can request that their Children’s school not provide any personal information to Triumph Learning. Please be aware that, depending on the school’s policies, if a parent or legal guardian makes such a request, their Children may no longer be eligible to be enrolled in or utilize our learning programs. Therefore, such a request by a parent or legal guardian could potentially terminate their Children’s participation in and their use of our learning programs.
For information on COPPA and the use of Children’s personal information, please contact:
Triumph Learning, LLC
136 Madison Avenue, 7th Floor
New York, NY 10016