Privacy Policy
Last updated: July 14, 2026
Welcome to the website of LearningClues, Inc. (“LearningClues”, “Company”, “we”, “us” and/or “our”) (learningclues.com) (the “Site”).
If you are unable to access this Policy due to a disability or impairment, please contact us using the contact details in the Contact LearningClues Section and we will arrange to supply you with the information you need in an alternative format that you can access.
This Privacy Policy (“Policy”) sets forth LearningClues’s practices with respect to information including “personal data”, “personal information”, and “personally identifiable information” as these terms are defined under applicable data protection laws (“Personal Data”), that is collected, used and shared by LearningClues in the usual course of business, including when you:
visit, interact with or use our Site; visit our social media pages; visit our offices; submit a job application; receive online advertisements or communications from us, including emails, phone calls and texts; or register for, attend and/or otherwise take part in our contests, events, tutorials or webinars (we collectively refer to all of these activities as our “Marketing Activities”);
purchase or use any LearningClues services as an authorized end user (for example, as a student, instructor, or administrator, or as an authorized team member of one of our Institutional Customers) (herein referred to as “Service Users”) (we collectively refer to these activities as the “Services” in this Policy), specifically where we act as a data controller of your Personal Data (unless otherwise noted).
For clarity, our Services are intended for use by our Institutional Customers (colleges, universities, and workforce training organizations) and their students, instructors, and administrators. As a result, for much of the Personal Data we process through the Services, we act as a processor or service provider on behalf of our Institutional Customers. For more information, see Section 2 below.
“You” may, depending on the context, be a visitor to our Site, offices or social media pages; a recipient of our communications or online advertisements; a job applicant; or a Service User.
We may provide additional “just-in-time” disclosures or additional information about our data processing practices. These notices may supplement this Policy or clarify LearningClues’s privacy practices in the circumstances described or may provide you with additional choices about how LearningClues processes your Personal Data.
This Policy does not apply to any third-party websites, services or applications, even if they are accessible through or are necessary for the use of our Services.
When you access or use our Services or engage with our Marketing Activities, you acknowledge that you have read this Policy and understand its content. Your use of our Services and interaction through our Marketing Activities and any dispute over privacy is subject to this Policy, the Terms of Service at learningclues.com/legal/tos, the End User License Agreement at learningclues.com/legal/eula, and any applicable service terms (including any applicable limitations on damages and the resolution of disputes).
We recommend that you read this Policy in full to ensure you are fully informed. However, to make it easier for you to review those parts of this Policy which apply to you, we have divided up the document into the following sections:
About LearningClues
LearningClues enhances course preparation and student learning by indexing course materials made available by the instructor in the course Learning Management System (LMS) and from class recordings available from most class capture vendors. It offers a virtual teaching assistant that answers student queries 24/7 based solely on course content. LearningClues uses AI to create concept maps of course learning objectives and spaced repetition reviews that use adaptive learning methods to track student proficiency per concept. Dashboards allow both students and instructors to monitor student progress on a concept level. You can find out more about LearningClues and our Services at learningclues.com.
Subject to Section 2 below, if you are located in the European Economic Area (“EEA”), United Kingdom (“UK”) or Switzerland, the controller (or processor where applicable) of your Personal Data that LearningClues processes for the purposes described in this Policy is LearningClues, Inc.
Information We Process on Behalf of Our Customers
Our Services are intended for use by our Institutional Customers. As a result, for much of the Personal Data we process through the Services, we act as a processor or service provider on behalf of our Institutional Customers. This means that it is our Institutional Customers that control what Personal Data we collect through the Services and how we use it. Where our activities as a processor or service provider are clear and consistent across our customer base, we have described those activities herein in the interests of transparency. However, if you are a Service User, and have privacy related questions or concerns about the privacy practices of or the choices the relevant Institutional Customer has made regarding your information via the Services, you should contact the relevant institution directly or review their privacy notices.
We are not responsible for the privacy or data security practices of our Institutional Customers, which may differ from those set forth in this Policy.
FERPA Notice for Institutional and Student Data
LearningClues provides its Services to accredited colleges, universities, and workforce training organizations (our “Institutional Customers”). In connection with the Services, LearningClues may receive, access, or process personally identifiable information from education records, as defined under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g; 34 C.F.R. Part 99) (“FERPA”), on behalf of our Institutional Customers.
Where LearningClues processes FERPA-protected education records, we do so as a “school official” with a “legitimate educational interest,” acting under the direct control of the Institutional Customer with respect to the use and maintenance of such records, consistent with 34 C.F.R. § 99.31(a)(1). LearningClues:
uses education records solely to provide, maintain, and improve the contracted Services on behalf of the Institutional Customer, and for no other purpose;
does not disclose, sell, rent, or share education records with third parties except as directed or authorized by the Institutional Customer, as required to provide the Services (including to subprocessors, as described in the “Artificial Intelligence and Machine Learning” section below), or as required by law;
maintains education records under the direct control of the Institutional Customer, including with respect to use, retention, and destruction, in accordance with our agreement with that Institutional Customer;
implements administrative, technical, and physical safeguards designed to protect education records against unauthorized access, use, or disclosure, as described in the “Security” section below; and
will notify the applicable Institutional Customer promptly upon discovery of any unauthorized access to or disclosure of education records.
Because LearningClues acts as a service provider to Institutional Customers with respect to education records, students, parents, and eligible individuals seeking to exercise rights under FERPA (including rights to inspect, review, or request correction of education records) should direct those requests to their educational institution, which remains the record custodian. LearningClues will cooperate with and support our Institutional Customers in responding to such requests as required under our agreements and applicable law.
For more information about how a specific Institutional Customer uses LearningClues’ Services or maintains education records, please contact that institution directly.
Artificial Intelligence and Machine Learning
LearningClues’ Services use artificial intelligence and machine learning technologies, including generative AI models provided by third-party subprocessors (currently, Microsoft Azure OpenAI Service), to power features such as automated question generation, adaptive learning recommendations, and instructional feedback (collectively, “AI Features”).
No Training on Institutional or Student Data. LearningClues does not use Institutional Data, student records, course materials, or other Customer Data processed through the Services to train, fine-tune, or otherwise improve any underlying AI or machine learning model — whether our own or those of our third-party subprocessors — and does not permit our subprocessors to do so. Institutional Data and Customer Data submitted to or generated by the AI Features are used solely to provide the contracted functionality of the Services to the applicable Institutional Customer and are not used for LearningClues’ or any third party’s independent model training, marketing, or advertising purposes.
Third-Party AI Subprocessors. Where AI Features rely on third-party infrastructure, that data is transmitted under contractual terms that prohibit the subprocessor from using the data to train its own models and require the subprocessor to maintain confidentiality and security protections consistent with LearningClues’ obligations to its Institutional Customers.
Human Oversight. AI Features are designed to support, and not replace, the professional judgment of instructors and institutions. LearningClues does not use AI Features to make automated decisions producing legal or similarly significant effects concerning individuals without human involvement.
Learn More. For more information about LearningClues’ approach to responsible AI governance, see our Responsible AI Policy, available upon request through our Trust Center at trust.learningclues.com.
The Personal Data We Collect
The Personal Data we collect depends on the context of your interactions with LearningClues and the choices you make (including your privacy and browser settings), the Services you use, your location and applicable law, but can include the following:
Personal Data That You Provide to LearningClues: We collect different types of Personal Data that you voluntarily submit through the Site. We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, respond to one of our surveys, register for access to the Services or use certain Services. Wherever LearningClues collects Personal Data, we make an effort to provide a link to this Privacy Policy.
The Personal Data we collect may include:
Marketing information (Identifiers) – such as your business contact information (name, job title, organization, phone number, email address, country/state of residence, mailing address) and contact preferences;
Online content (Internet activity information) – which includes Personal Data disclosed by you on message boards, chat features, blogs and other services or platforms to which you are able to post information and materials, including third party services and platforms;
Applicant information (Employment and Education information) – if you apply for a job with LearningClues (such as your resume, desired pay, education and work history, whether you are over the age of 18, and visa status). You also may choose to provide your gender, ethnicity, veteran status, disability status, and links to your website, blog, portfolio, or LinkedIn profile;
Services account registration data (Customer Records) – such as your email, username or account name and hashed password when you sign up or register for an account with us and the unique Service user ID assigned to you in our systems;
Services management data (Customer Records) – data LearningClues needs in order to provide its educational technology services to institutions, such as enrollment, role, and course information (an individual’s name, role (e.g., student/instructor/administrator), course or section enrollment, email address);
Troubleshooting and support data – which is data you provide or we otherwise access in connection with support queries we receive from you. This may include, for example, contact or authentication data, the content of your chats and other communications with LearningClues, the product or service you are using related to your help inquiry and related crash analytics.
If you communicate directly with us, we may collect and maintain an archive of our communications with you (including their content). We may also record or monitor our telephone or other communications with you, to the extent permitted by applicable law.
Providing your Personal Data is optional, but it may be necessary for certain Services, such as in relation to Services account registration and management data. In such cases, if you do not provide your Personal Data, LearningClues may not be able to provide you with the requested Services.
Personal Data we collect automatically: When you use or interact with the Services and Marketing Activities, we automatically collect or receive certain information through our Services (for example in log files) and through other technologies (such as cookies) about your device and usage of the Services. In some countries, including countries in the EU and UK, this information is considered Personal Data.
The categories of Personal Data we automatically collect and have collected in the last 12 months include your device’s IP address, the domain name of the website from which your device linked to our Services and Marketing Activities, and your browsing habits on and usage of the Services and Marketing Activities through your device:
• Commercial Information – Information about the products or services you purchased, looked at or searched for, and any related use histories or tendencies;
• Online Identifiers and Inferences – Details about your computers, devices, applications, and networks, including internet protocol (IP) address, URLs or domain names of websites you visit, information about applications installed on your device, traffic data, cookie identifiers, mobile carrier, mobile device ID, advertising identifiers;
• In relation to the Services: performance information, data relating to your interaction with the Services (e.g., time of access, features used, length of use, OS version, browser information), device IDs and characteristics, crash logs, and other aggregate or statistical information.
We use tracking technologies to collect this information, including cookies, web beacons, pixels and clear gifs. For more information, please see our Cookie Manager.
Information on Behalf of Our Institutional Customers: We may collect and process Personal Data about individuals at the direction of our Institutional Customers (“Customer Data”). Customer Data has historically included name, email address, institution name, role and enrollment information (e.g., student, instructor, administrator; course or section enrollment), IP address, device IDs, among other information. Our processing of Customer Data is governed by the terms of our service agreements with our Institutional Customer, and not this Privacy Policy (see also Section 3, “FERPA Notice for Institutional and Student Data,” above). We are not responsible for how our Institutional Customers treat the Personal Data we collect on their behalf, and we recommend you review their separate privacy policies.
LearningClues acknowledges that you may have rights in connection with Customer Data. If your information has been processed by LearningClues on behalf of an Institutional Customer and you wish to exercise any rights you have with such Personal Data, please inquire with our Institutional Customer directly. If you wish to make your request directly to LearningClues, please provide the name of the LearningClues Institutional Customer on whose behalf LearningClues processed your information. We will refer your request to that Institutional Customer and will support them to the extent required by applicable law in responding to your request.
Information From Third-Party Services: We may receive information about you from other sources, including through third-party services that you may connect to LearningClues (such as API integrations, including your institution’s Learning Management System) and organizations that supplement information directly provided by you. For example, if you access our Services through a third-party application, such as your institution’s single sign-on, we may collect information about you from that third-party application that you have made available. Information we collect through integrations and other connected third-party services may include your name, email address, logging information, etc. This information allows us to provide you with the LearningClues Services and to enhance our ability to provide you with information about our business and products.
Information from Other Sources:
We may obtain Personal Data about you from other sources. The categories of other sources from which we collect and have collected Personal Data from in the last 12 months include:
Social networks when you interact with our Services and Marketing Activities or grant permission to us to access your information;
Partners with which we offer co-branded services or engage in joint marketing activities;
Third parties that have indicated that they have your consent or are otherwise legally permitted or required to disclose your Personal Data to LearningClues;
Other individuals at your institution, or individuals who may refer LearningClues to you, for the purpose of learning more about our Services;
Background screening providers that LearningClues uses in the event you are selected to join our team via our careers and recruitment process. We conduct background screenings through a third-party service provider and verify information from your job application that relates to your past education, employment, credit and/or criminal history, as allowed by applicable law;
Recruitment agencies, who may share your Personal Data with us for purposes of helping to identify and select candidates; and
Publicly available sources such as data in the public domain.
Aggregated Personal Data: In an ongoing effort to better understand and serve our prospects and Service Users, LearningClues often conducts research on its customer demographics, interests and behavior based on Personal Data and other information provided to us. As it relates to our Services, we may also use machine learning and performance metrics for the purposes of providing and improving LearningClues’s products and services, consistent with Section 4, “Artificial Intelligence and Machine Learning,” above. This information may be compiled and analyzed on an aggregate basis. This aggregate information does not identify you personally. LearningClues may also disclose such aggregated information in order to describe and promote our Services to current and prospective business partners, and to other third parties for other lawful purposes.
Our Use of Your Personal Data and Our Legal Basis for Processing
We may use your Personal Data, and may have done so over the preceding 12 months, for the following purposes and in reliance on the legal bases described in this Privacy Policy or disclosed explicitly to you in our Services or other contracts:
To communicate, including…
With you, our customers, partners and other third parties (e.g., through email) about the Services, including to communicate changes and revisions to our policies, technical notices, security alerts, support, renewal notices, for account verification and other administrative messages in reliance on our legitimate interests in administering our Services;
To ask you to participate in surveys or solicit feedback on our Services in reliance on our legitimate interests;
If you fill out a web form or request support, or if you contact us by other means, including via a phone call, we use your data to perform our contract with you or, if we do not have a contract directly with you, in reliance on our legitimate interests in fulfilling your requests and communicating with you;
With you about promotions, upcoming events, and news about products and services offered by LearningClues (e.g., marketing newsletters, telemarketing calls, SMS, emails or push notifications) and, in some cases, our selected partners, all in accordance with your marketing preferences as necessary for our legitimate interest in conducting direct marketing, or to the extent you have provided your prior consent;
To conduct marketing research, advertise to you, provide personalized information about us on and off our websites, and to provide other personalized content based on your activities and interests to the extent it is necessary for our legitimate interest in advertising our Services, or where necessary, to the extent that you have provided your prior consent. Generally, LearningClues does not rely on consent as a legal basis for processing your Personal Data, other than sending direct marketing communications to you via email.
To process job applications, including…
To evaluate your application, make hiring decisions, and evaluate your authorization to work, if applicable;
To communicate with you and inform you of current and future career opportunities (unless you tell us that you do not want us to keep your details for such purposes);
To manage and improve our recruiting and hiring processes, such as soliciting feedback via candidate surveys, or to conduct reference and background checks where required or permitted by applicable local law;
To provide and improve our products and services, including…
Operating, maintaining and providing to you the features and functionality of the Services, as necessary to perform our contract with you;
Using a person’s IP address and other online identifiers to generate aggregate, non-identifying information about how our Services are used in reliance on our legitimate interests and as necessary to perform our contract with you;
To monitor and improve marketing campaigns and make relevant suggestions to users in reliance on our legitimate interests and, where applicable, with your consent, which can be withdrawn at any time;
To understand you and your preferences to enhance your user experience in reliance on our legitimate interest in personalizing and improving the Services and as necessary to perform our contract with you.
To fix problems and protect the Services, you, ourselves, other customers and the public generally and to comply with applicable laws, including…
To troubleshoot and diagnose product problems and to provide other customer support, in reliance on our legitimate interests and, where applicable, to perform our contract with you in accordance with the applicable terms;
To ensure the safety and security of our Services in reliance on our legitimate interests, including verifying accounts and activity, investigating suspicious activity, detecting and preventing fraud and other illegal activities and to protect the rights and interests of us, users, and other customers’ users, third parties, and the public;
To enforce our terms and conditions or protect our business in our legitimate interests;
To comply with our legal obligations under applicable laws, including FERPA, when cooperating with public and government authorities, courts or regulators, to the extent this requires the processing or disclosure of Personal Data.
For other legitimate business purposes in reliance on our legitimate interests, such as to update, expand, and analyze our records, data analysis, developing new products, enhancing, improving or modifying our Services, identifying usage trends, and operating and expanding our business activities.
If LearningClues intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.
Our Disclosure of Your Personal Data
LearningClues is not in the business of selling your information for monetary consideration. We consider this information to be a vital part of our relationship with you and we only share it where reasonably necessary to provide our services to you or enhance our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you. The types of entities to whom we disclose and have disclosed information within the last 12 months include:
Affiliates: We may share all categories of your Personal Data with our affiliates for internal business purposes. For example, for customer support, marketing, or technical operations.
Third-party service providers: Our service providers may process all categories of your information in connection with their work on our behalf and are contractually prohibited from retaining, using, or disclosing your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other commercial purposes. If you do not want us to use your Personal Data for marketing purposes, you can opt out by contacting us at privacy@learningclues.com.
Vendors, Agents, Consultants and Related Third Parties: LearningClues, like many businesses, sometimes hires other companies to perform certain business-related functions. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
Partners: LearningClues may share business contact information, marketing information, troubleshooting and support data with business partners of ours (including referral partners, resellers, and managed service providers), for the purpose of assisting with sales, marketing and support activities.
Merger or acquisition: We may share all categories of your information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
Legal Requirements: LearningClues may disclose any categories of your Personal Data if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation or other legal process, protect and defend the rights or property of LearningClues, act in urgent circumstances to protect the personal safety of users of the Services or the public, or protect against legal liability.
Consent: To any other person you have consented to us sharing Personal Data.
Without limiting the foregoing, we may share aggregated information which does not identify you or de-identified information with other parties or affiliates except as prohibited by applicable law.
Cookies and Other Tracking Technologies
We may, and we may allow third-party service providers to, use cookies or other tracking technologies to automatically collect information from your computer or mobile device about your browsing activities over time and across different websites following your use of the Site, your interaction with our Marketing Activities, as well as in connection with the Services.
For example, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze your use of the Services and Marketing Activities, compile statistical reports on the service’s activity, and provide other services relating to your activities and internet usage.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Site. For more information, and to manage how LearningClues collects and stores non-essential cookies, please see our Cookie Manager.
Security
LearningClues takes reasonable administrative, physical and electronic measures designed to protect your Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. Therefore, we cannot guarantee the security of your Personal Data. Please keep this in mind when disclosing any Personal Data to LearningClues via the Internet.
Retention
We may retain your Personal Data for as long as necessary for the purposes it was collected, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types in the context of different services, actual retention periods can vary. We determine the appropriate retention period for Personal Data based on the amount, nature and sensitivity of your Personal Data processed, the potential risk of harm from unauthorized use or disclosure of your Personal Data and whether we can achieve the purposes of the processing through other means, as well as applicable legal requirements (such as applicable statutes of limitation and, for education records, the retention terms of our agreement with the applicable Institutional Customer). After expiry of the applicable retention periods, your Personal Data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of that data. For further information on applicable data retention periods, please see the section entitled Contact LearningClues.
Transfers of Your Personal Data
Personal Data we collect may be stored and processed in your region, in the United States, Canada, the United Kingdom or any other country where we or our affiliates, subsidiaries or service providers maintain facilities. We maintain primary data hosting centers in the United States. We take steps designed to ensure that the data we collect under this Privacy Policy is processed as described in this Privacy Policy and according to applicable law wherever the data is located.
Therefore, we may transfer Personal Data from the European Economic Area (EEA), UK and Switzerland (collectively, “Europe”) to other countries that may not have the same level of data protection that applies in your jurisdiction. In these cases, we use a variety of legal mechanisms to ensure that the recipient of your Personal Data offers an adequate level of protection, including entering into the standard contractual clauses for the transfer of European data approved by the European Commission, or where required, we will ask you for your prior consent.
Additional Disclosures for U.S. Residents
This section describes how LearningClues collects, uses and discloses your Personal Data pursuant to the following U.S. state privacy laws: the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (CCPA); the Virginia Consumer Data Protection Act (VCDPA); the Colorado Privacy Act (CPA); the Connecticut Data Privacy Act (CDPA); and the Utah Consumer Privacy Act (UCPA).
This section applies only if you live in the US states of California, Colorado, Connecticut, Virginia, Utah or any other US state that has enacted similar privacy laws. This section also describes the rights you have with regard to your Personal Data, which apply when these laws take effect in these states. This section does not apply to any of our employees, owners, directors, officers, or contractors.
Categories, Sources, and Use of Personal Data we collect: The categories of Personal Data we collect and the sources from which we collect it are described in detail in the section entitled The Personal Data We Collect. The business and commercial purposes for which we collect this information are described in the section entitled Our Use of Your Personal Data.
In addition, and specifically with respect to job applicants, LearningClues may collect Personal Data that contains characteristics which may be protected classifications under California or Federal Law solely to the extent such characteristics are voluntarily disclosed to us, and Personal Data which includes sensitive Personal Data as defined under the CCPA. We do not collect or process sensitive Personal Data for the purpose of inferring characteristics about individuals.
Sale or Disclosure of Personal Data: This section only applies where LearningClues is acting as a business, and not a service provider, under applicable US data protection laws. While LearningClues does not sell Personal Data in exchange for monetary consideration, we may share Personal Data for cross-context behavioral advertising purposes and for other benefits as defined by certain state privacy laws. You have a right to direct LearningClues not to sell or share your Personal Data. We do not have actual knowledge that we have sold or shared Personal Data of individuals under the age of 16 for targeted advertising or cross-context behavioral advertising purposes.
Your Privacy Rights and Choices
LearningClues provides ways for you to access and delete your Personal Data as well as exercise other rights that give you certain control over your Personal Data.
All Users. You can always unsubscribe from our commercial or promotional emails by clicking unsubscribe in those messages. You may exercise choice regarding the use of cookies as described in our Cookie Manager.
EEA, UK and Switzerland Residents and Visitors. If you are a resident of or visitor from the EEA, UK or Switzerland, where we are acting as a data controller, you may access, correct, update and delete your Personal Data, object to or restrict processing, or request portability, by emailing us at privacy@learningclues.com. If we have collected and processed your Personal Data with your consent, you can withdraw your consent at any time for future processing. You have the right to complain to a data protection authority about our collection and use of your Personal Data. LearningClues does not engage in any automated decision making with your Personal Data.
US Privacy Rights. Subject to certain limitations under applicable law, you have the right to know what Personal Data we have collected, used, disclosed or sold about you; the right to access a copy of that Personal Data; the right to request deletion; the right to correct inaccurate Personal Data; and the right to opt out of the sale or sharing of your Personal Data. You can exercise these rights by emailing us at privacy@learningclues.com. Please note that if your information has been processed by LearningClues on behalf of an Institutional Customer, we will refer your request to that Institutional Customer and support them as required by applicable law.
California’s Shine the Light law. If you are a California resident, you are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of Personal Data to third parties for their direct marketing purposes in the preceding calendar year. To request the above information, please email us at privacy@learningclues.com or write to us at Box 1078, Leland, MI 49654-1078 with a reference to “CA Disclosure Information” and include your name, street address, city, state, and ZIP code.
Children's Personal Data
Our Marketing Activities are not intended for individuals under the age of 16, and LearningClues does not knowingly collect Personal Data from children under the age of 16 through our Marketing Activities in a manner that is not permitted by the U.S. Children’s Online Privacy Protection Act (“COPPA”) or other applicable laws. Where LearningClues provides the Services to an Institutional Customer whose students may be under the age of 16 (for example, in a dual-enrollment or workforce-training program serving high-school-age learners), LearningClues processes the Personal Data of those students at the direction of, and under the consent or authorization obtained by, the Institutional Customer acting in its capacity as the student’s educational institution, consistent with FERPA and applicable state student-data-privacy laws, and consistent with COPPA’s provisions permitting schools to consent on behalf of parents for education records used solely for a school-authorized educational purpose. We encourage parents and legal guardians to direct questions about a specific institution’s use of the Services to that institution. If you have reason to believe that a child has provided Personal Data to LearningClues other than as described above, please contact us at privacy@learningclues.com.
We do not knowingly “sell” or “share” as those terms are defined under US data protection laws, the Personal Data of minors under 16 years old who are U.S. residents.
Links to Third-Party Web Sites
The Site and Services may contain links to other web sites, resources or services not operated or controlled by LearningClues (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The privacy practices of these websites and services will be governed by their own policies. We make no representation or warranty as to the privacy policies of any third parties, including the providers of third-party applications.
Changes to LearningClues's Privacy Policy
The Services and our business may change from time to time. As a result, at times it may be necessary for LearningClues to make changes to this Privacy Policy. LearningClues reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you use our Sites or our Services or engage with our Marketing Activities. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy. We encourage you to review this Policy frequently to be informed of how LearningClues is protecting your Personal Data.
Contact LearningClues
Please feel free to contact us if you have any questions or concerns about LearningClues’s Privacy Policy or our privacy practices, including if you need to access this Policy in an alternative format, or if you wish to lodge a complaint about our privacy practices.
You may contact us as follows: privacy@learningclues.com, by using the Your Privacy Choices form, or by registered mail at Box 1078, Leland, MI 49654-1078.
The data controller of your Personal Data is LearningClues, Inc.
Social Media and Technology Integrations
The information collected and stored by third parties, whether through our Services and Marketing Activities, or another party’s service or device, remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. LearningClues is not responsible for and makes no representations regarding the privacy practices of third parties. You should carefully read their own privacy policies before providing any information to such parties.