Introduction
ALS Education Holdings, LLC d/b/a Second Mile Education, a Delaware limited liability company (“we,” “our,” or “us”), is committed to protecting the privacy of our students, parents, educators, and partners. This Privacy Policy (this “Policy”) outlines how we collect, use, disclose, and protect personally identifiable information (“PII”) in compliance with applicable federal, state and local laws and regulations, including, without limitation, the Family Educational Rights and Privacy Act, as amended (“FERPA”), and laws governing PII.
FERPA is a federal law that protects the privacy of student educational records and applies to all schools receiving federal funding. With certain exceptions, this law prohibits schools from releasing PII of students under the age of 18 without parental consent. By designating us as a “school official” and/or a designated contractor with a “legitimate educational interest,” educational agencies and institutions are permitted to share PII with us without express, parental consent under the exception provided by 34 CFR § 99.31(a)(1). You may find out more information about FERPA at http://www.ed.gov/policy/gen/guid/fpco/ferpa/index.html.
This Policy does not apply to information that we may collect from you outside of our Website, such as over the phone, by fax or through conventional mail. This Policy does not apply to the practices of companies that we do not own or control or to people the we do not employ or manage. By using our educational services, you acknowledge and agree to the terms of this Policy.
Information We Collect and How We Collect It
We collect and maintain various types of PII to effectively provide our educational services. This may include student information, including, without limitation, name, date of birth, student identification numbers, academic records, attendance records, disciplinary history, standardized test scores, and other PII as defined by various state education agencies. We further collect parent and/or guardian information, including name, contact information, and relationship to the student, as well as educator and staff information, including name, professional credentials, employment history, and contact information. Additionally, we may collect technology and usage data, including IP addresses, device identifiers, cookies, and analytics data when users interact with our digital platforms.
We use PII to deliver and improve educational programs and services, maintain student records as required by applicable laws, communicate with parents, students, and educators, ensure compliance with federal, state and local education laws, rules and regulations, conduct assessments, evaluations, and reporting for educational improvement, and enhance the security of our digital platforms. We do not sell PII. However, we may disclose PII in specific circumstances. These include sharing information with educational institutions and partners to facilitate educational services and student support programs while ensuring compliance with FERPA and state privacy guidelines. We may also share information with service providers to assist in managing our operations, such as data storage and IT services, provided they adhere to strict confidentiality agreements. Additionally, we may disclose information as required by law to comply with legal obligations, court orders, government requests, and state reporting requirements. In cases where explicit consent is necessary under FERPA, state policies, or other applicable laws, we will seek parental or student consent before disclosure.
As an educational management entity, we adhere to FERPA and various state regulations, ensuring the protection of student education records and PII. Parents and eligible students have rights under FERPA and applicable state guidelines, including the right to access their education records, request corrections if information is inaccurate, and consent to the disclosure of PII unless otherwise permitted under FERPA and state regulations. Parents and eligible students may also opt out of sharing directory information such as names and awards.
Our Commitment to Data Security
We implement industry-standard security measures to protect PII, including, without limitation, encryption of sensitive data, secure access controls, regular security audits, and employee training on data privacy and security practices in accordance with state guidelines. We retain student and related data for the periods necessary to fulfill educational and legal obligations in accordance with FERPA and various state retention policies. Once no longer needed, we securely dispose of records following state and federal guidelines. Parents and eligible students may exercise their FERPA and state privacy rights by submitting form requests to our designated privacy officer at Privacy@2ndMile.com.
Your Choices
We offer you the following choices about what information we collect from you and how we communicate with you:
Cookies. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If, however, you choose to decline cookies, you may not be able to fully experience the interactive features of our Website or have some of our services on the Website function properly.
Marketing Emails. If we have sent you a marketing email, you may choose not to receive additional marketing emails from us by following the unsubscribe instructions contained in each email.
Your State Privacy Rights
State consumer privacy laws may provide their residents with additional rights regarding our use of their PII.
California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah and Virginia provide (now or in the future) their state residents with rights to:
- Confirm whether we process their PII.
- Access and delete certain PII.
- Correct inaccuracies in their PII, taking into account the information’s nature processing purpose (excluding Iowa and Utah).
- Data portability.
- Opt-out of PII processing for:
- targeting advertising (excluding Iowa);
- sales; or
- profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
- Either limit (opt-out of) or require consent to process sensitive PII.
The exact scope of these rights may vary by state. To exercise any of these rights please contact us as provided below.
European Union
The General Data Protection Regulation (the “GDPR”) is legislation to protect individuals within the European Union, effective May 25, 2018. It is binding and applicable to all EU member countries, which means it does not require national governments to pass any additional legislation.
The GDPR applies to PII when the data controller (an organization that collects data from EU residents) or data processor (an organization that processes data on behalf of the data controller) or the data subject is based in the EU area. It also applies to organizations based outside of the EU in case they collect or process PII of EU residents. We remain compliant with the GDPR.
Children Under the Age of 13
Our Website is not directed to children under the age of 13 and does not permit registration by and will not knowingly collect or use PII from anyone under 13 years of age. We require users to be at least 13 years of age to use our Website. If we learn we have collected or received PII from a child under the age of 13, we will delete that information. If you believe we might have any information from or about a child under the age of 13, please contact us as provided below.
Links
Our Website may contain links to other websites, chat rooms or other resources that we provide for your convenience (“Linked Sites”). Linked Sites are not under our control, and we are not responsible for the content available on any Linked Site. Such links do not imply our endorsement of material on any Linked Site, and we expressly disclaim all liability with regard to your access to such Linked Sites. Access to any Linked Site is at your own risk.
Changes to Our Privacy Policy
We may update this Policy periodically to reflect changes in laws or our operational practices. Any updates will be posted on our website with the Effective Date. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you and for periodically visiting our Website and this Policy to check for any changes.
Enforcement
We are committed to ensuring the integrity and security of user information. We reserve the right to pursue all legal remedies available to us in the event that our security measures and/or this Policy are breached, including, without limitation, the pursuit of all criminal and civil law enforcement proceedings available as of the occurrence of any breach. Should you believe that your data has been released or used in a way that is contrary to your rights or this Policy, please contact us as provided below.
Contact Information
To ask questions or comment about this Policy, contact us at:
Second Mile Education
5850 TG Lee Blvd, Suite 345
Orlando, Florida 32822
or e-mail Privacy@2ndmile.com