AOPS ACADEMY VIRTUAL CAMPUS PRIVACY POLICY - EFFECTIVE August 6, 2020

This Privacy Policy applies to all users. Please click here for our specific information practices with regards to children under 13 (also provided at the end of this policy).

High Performance Learning, LLC, doing business as AoPS Academy ("Academy", "we" or "us"), is committed to protecting the privacy of student records and other personal information obtained through its web site at virtual.aopsacademy.org and affiliated web sites that link to this Privacy Policy (collectively, the "Sites" and individually a "Site"), and all associated products and services provided on and through the Sites, including registration for classes and workshops ("Classes"), book sales, and certain email publications prepared and delivered by us to users. The foregoing items are referred to collectively in this Privacy Policy as the "Services".

This Privacy Policy provides an overview of the terms and conditions surrounding the use of this information and discloses our information gathering and dissemination practices in connection with the Services. It does not apply to personal information that may be acquired by Academy in other ways.

AoPS Incorporated ("AoPS"), a California corporation provides online educational tools, content, testing and assignments as part of the Services (the "AoPS Services"). You agree that AoPS's handling of your personal information in connection with the AoPS Services is subject to the AoPS Privacy Policy located here, and not this Privacy Policy. AoPS also provides online educational tools, content, testing and assignments via its Beast Academy Online learning system as part of the Services ("Beast Academy Services"). You agree that AoPS's handling of your personal information in connection with the Beast Academy Services is subject to the Beast Academy Privacy Policy located here, and not this Privacy Policy. You also acknowledge and agree that AoPS will provide data regarding your use of AoPS Services and Beast Academy Services to us.

Information Collected

In order to apply for and use our Services, Users provide name, email address, phone number, physical address, gender, date of birth, school, test scores, course information, and other academic history. You may voluntarily provide additional personal information, or we may ask for additional personal information, in connection with the purchase and use of Services.

In some cases, users will purchase access to the Services by entering a credit card or PayPal information. Academy may arrange for the collection of financial information such as your payment method (valid credit card number, type, expiration date or other financial information).

The Services may contain collaboration tools to allow for communications between the instructor and student, and between students. These tools may enable users to see other users' personal information including account/student name, and other information. Any additional personal information that you communicate with other users of the Services through collaboration or communication tools is your own choice and the privacy of such information cannot be guaranteed. Information shared through collaboration tools should be considered public information.

Cookies

A "cookie" is a small piece of data placed on your computer by the Site. Within your web browser, cookies placed by our Site can only be accessed by our Site. We use cookies to maintain session and preference information to improve the use of the Sites. We do not use cookies to target advertisements to specific users. You may set your web browser to decline our cookies; however this will render large portions of our Sites unusable.

We may also allow cookies to be placed on your computer by third parties for the purpose of website analytics. This allows the third parties to collect data about your use of our Sites. The data collected by these cookies may include information such as your IP address or mobile identifier, the type of computer operating system, the web browser, the frequency with which the user visits various parts of our Sites or applications, and information regarding the online or mobile service provider. This data is not used to target advertisements to specific users. We don't share the data that a third party collects with anyone besides that third party. The third parties are required to not share any personally identifiable information they may collect with anyone other than us (except as may be required by law). We use the data that is collected in the following ways:

• to report, in aggregate, how our visitors find and use our Sites;
• to understand overall visitor behavior; and
• to inform how we update and improve our Sites.

Academy also gathers information about its users collectively and automatically logs IP addresses, session sources, and other data that track access to the Site. We analyze these logs to better understand aggregate behavior and to monitor Services performance. The logs are analyzed to ascertain the overall aggregate trends they reveal about our users, but not as a means of tracking the behavior of individual users outside our Site. This information is used for the purposes of maintaining and improving the Services, and expanding its capabilities.

Use and Disclosure of Collected Information

We do not use or share your personal information with others except as indicated in this Privacy Policy.

Academy will use your personal information to provide the Services to you, alert you of new Services features and enhancements, respond to your support issues, and/or notify you of upgrade opportunities, promotions, and special offers. You agree that we may communicate with you via email and other electronic communication tools for any purpose relating to the Site or the Services. We may share your email address with a third party (ActiveCampaign, LLC) for sending email correspondence and will not share this information with any other third party, except as may be required by law.

We will share payment information with our credit card payment processor. We will store all of this information on our server, except for your credit card information; however, the credit card information may be retained by our credit card processor for the purpose of processing additional transactions, refunds, and/or chargebacks. We will not use this information for any purpose other than to process your purchase, and will not share this information with any other third party, except as described above or as may be required by law.

We may access and copy student information for the purposes of backup, internal maintenance, improvement of the Services, and technical support. We take the utmost efforts to not divulge student information to unauthorized individuals. We strive to ascertain whether authorized persons are able to access the information correctly and to inform these authorized persons how to access the information.

Academy may aggregate information to enhance our Services, perform educational research, and to develop new Services. We may disclose aggregated and statistical information to third parties that does not identify a specific user.

Academy may also disclose personal information:

• When we have your permission to do so; or
• To AoPS; or
• To companies other than AoPS who work for Academy to provide one or more parts of the Services or that provide related administrative functions (such as support Services, web analytics, and fraud detection). These third parties may have access to your personal information; if they do, this access is only so that they may perform these tasks on our behalf and they are obligated not to disclose or use it for any other purpose; or
• When we believe in good faith that disclosure is reasonably necessary to (1) comply with a legal process or law, or to respond to a government request for information, (2) enforce the terms of use or other agreements, (3) respond to claims that any content on the Site or Services violates the rights of third parties, or that otherwise arise from your use of the Services, or (4) protect the rights, property, or personal safety of Academy, its users, or the public.

Opt-Out

We provide you the opportunity to opt-out of receiving certain communications from us, by contacting customer support. In addition, all marketing e-mails from Academy will provide you with the opportunity to unsubscribe from future marketing mailings. Even if you opt out of such mailings, however, we reserve the right to send you e-mail and other communications to disclose maintenance and other service-related issues.

Access to Account

If you are a registered user of the Services, you can change your account information through the account profile component of the Services. You may need to supply certain information so that we can try to verify that you have authority to modify this information.

Third-Party Sites

The Site and Services may contain links and/or other connections to other sites, web services, and information. We have no responsibility for the privacy practices of other web sites and services.

The fact that we may link to a website or present an advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites or services. These other websites or services may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit and services you use.

Legal Requirements

We intend to protect your privacy to the fullest extent possible as described in this policy while also fulfilling our responsibility to uphold all applicable laws and regulations. Due to potential legal requirements and other possible circumstances, we cannot ensure that all of your private communications and other personally identifiable information will never be disclosed or accessed in ways not otherwise described in this policy. We may be compelled under law to disclose information to government or third parties under certain circumstances or third parties may unlawfully intercept or access transmissions or private communications. Further, we can, and you hereby authorize us to, disclose any information to law enforcement or other government officials that we, in our sole discretion, believe necessary or appropriate in compliance with the law and/or government requests.

United States

The Services are hosted in the United States. If you are accessing the Site or Services from outside the United States, please be advised that through your continued use of the Site or Services, which is governed by U.S. law and this Privacy Policy, you are transferring your personal information to the United States and you consent to that transfer.

Security

We implement commercially reasonable security methods to protect the information we collect from you. While the security of your personal information is of the utmost importance to us, we cannot absolutely guarantee the security of any information you choose to disclose.

Changes

Academy posts any changes to this Privacy Policy on the Site. Your continued use of the Site and Services constitutes your agreement to this Privacy Policy and any future revisions.

Contact Information

Questions or comments about this Privacy Policy may be sent to:
High Performance Learning, LLC dba AoPS Academy
10865 Rancho Bernardo Rd Ste 100
San Diego, CA 92127
privacy@aopsacademy.org

Effective date and notice of future changes

This Privacy Policy is effective August 6, 2020. This Privacy Policy may be updated from time to time as necessary.

COPPA Policy

The federal Children's Online Privacy Protection Act (COPPA) requires that we inform you of our practices with regards to our collection, use, or disclosure of personal information from children under the age of 13, and to obtain verifiable parental consent prior to collecting, using, or disclosing any such information. If we discover we have collected information from a child in a manner inconsistent with COPPA's requirements, we will either seek the parent's consent for that collection or delete the information. We won't require a child to disclose more information than is reasonably necessary to participate in an activity.

1. Information we collect and share

When we use the term "children" or "child", it refers to individuals under the age of 13. We may collect and share the following personal information with verifiable parental consent (where necessary under COPPA) from children:

(a) Children may provide us their email address during registration or as part of receiving our services. We may use this email address to communicate directly with the child. If the child joins one of our email lists, their email address will be shared with the third party (ActiveCampaign, LLC) we use to manage our email lists. We will not otherwise share an email address with a third party except when required by law.

(b) A username used to uniquely identify each child is created during registration. This username may be disclosed on our Sites, for example in our message boards or any other part of the Sites on which the child may participate. Other members of the Sites may use the child's username to directly contact the child (for example, by private message).

(c) The child's real name will only be used for internal purposes, or will be disclosed only to third parties to whom the child's parent has given specific authorization.

(d) Other non-identifying data may be collected in the course of a child's participation on the Sites; for example, online homework submissions, etc. These data may be combined or associated with the child's username, and may be publicly available on the Sites, at the child's or parent's discretion.

(e) Children using our Sites may have the opportunity to post personal information about themselves (for example, in a message board post or on a blog). Such information may be publicly displayed on the Site alongside the child's username. We strongly discourage users from sharing personal information, but we cannot prevent it in every instance. This policy addresses how parents can delete information posted by their children in item #2 below.

(f) Children using our Sites may take video-based classes. In video-based classes, video and audio of students are streamed to class participants via a third party, Zoom Video Communications, Inc. Zoom Video Communications, Inc. only collects user data required to provide its services and has a privacy policy available here. We create recordings of each video-based class that contain audio from student participants. Consent to gather audio recording is gathered before a student enters a video-based class. Recordings are only made available to students enrolled in the class and employees of AoPS Academy and AoPS Incorporated. Recordings are automatically deleted 7 days after the class.

(g) When children use our Sites, certain information may automatically be collected by third parties: IP address or mobile identifier, the type of computer operating system, the web browser, the frequency with which the user visits various parts of our Sites or applications, and information regarding the online or mobile service provider. This information is collected using technologies such as cookies, which are described above.

This data is primarily collected and shared with third parties for internal purposes, in order to:

• report, in aggregate, how our visitors find and use our Sites;
• understand overall visitor behavior; and
• inform how we update and improve our Sites.

The third-party operators who may collect information for these purposes on our Sites and applications are Alphabet Inc., Microsoft, Facebook, Amazon.com, Inc., and Hotjar. This information is not used to target advertising to specific users. For any questions about how we or any third-party uses your data, please do not hesitate to contact us. Our contact information is provided below in item #3.

(h) We may disclose a child’s personal information if permitted or required by law, for example, in response to a court order or a subpoena.

(i) We generally do not collect personal information from a child until we have received verifiable parental consent in accordance with COPPA. There are limited instances where we may collect information without parental consent in compliance with COPPA, including:

• An email address is collected from a child at the time of registration, solely to contact the child's parent in order to obtain the necessary parental consent;
• To protect the security or integrity of our Sites, applications, and other technology; and
• A username is selected by the child; however, this username cannot be used to contact the child, nor be used for the purposes listed in sections (c) and (d) of above, unless and until we receive verifiable parental consent.

2. Parental rights and responsibilities

1. At any time, a parent can review or ask us to delete a child's personal information, or can refuse to permit its further collection or use, by contacting us by any of the means listed in item #3 below.
2. Parents may also access their child’s personal information by logging onto their account and can delete their child’s personal information. Parents will need their child’s username and password, and our login page explains how parents can recover a username or password if they cannot recall this information.

3. Contact information

Questions or comments about this policy, or requests pursuant to item #2 above, may be sent to:

High Performance Learning, LLC dba AoPS Academy
10865 Rancho Bernardo Rd Ste 100
San Diego, CA 92127
privacy@aopsacademy.org

This COPPA Policy is current as of August 6, 2020. We may change this COPPA Policy from time to time, so please be sure to review periodically. This policy will be available at our website at https://aopsacademy.org/legal/privacy.