Privacy Policy - Lincoln AI

Organization: Lincoln Learning Solutions
Contact Email: privacy@lincolnlearningsolutions.org
Business Address: 2139 Brodhead Rd, Aliquippa, PA, 15001
Product Name: Lincoln AI
Product Type: Web App/service
Effective Date: March 30, 2026

DRAFT

This privacy policy should be considered a DRAFT policy.

INTRODUCTION

At Lincoln Learning Solutions ('the company', 'we', or 'us'), we respect your privacy and are committed to protecting it as described in this privacy policy ('Policy' or the 'Privacy Policy'). This policy describes the types of information we may collect from you or that you may provide when you use our product, Lincoln AI ('the product', 'the service', 'the website', 'the app', or 'product'), and our practices for collecting, using, maintaining, protecting, and disclosing that information. Your use of the Product and Services and any information you provide on the Services are subject to the terms of this Privacy Policy, which is incorporated into and subject to our Terms of Service.

DATA COLLECTION

For the purpose of this section, Personal Information is defined as information that identifies, relates to or could reasonably be linked with or describes an individual or household, either directly or indirectly. We collect Personal Information you provide to us, as well as Personal Information collected automatically and from third-party sources as described below.

We do not allow data to be automatically collected by third-parties for their own purposes.

Personal information of users is not collected by a third party. Aggregated or combined information, representing a non-identifying summary of data, is treated with the same level of confidentiality and protection as personally identifiable information (PII) on our platform. Our product includes features that allow users to create content in the product or upload content to the product. We may ask for additional details to verify the identity of users on our platform. User information does not have to be shared or revealed in order to participate in social interactions. All social interactions of users through the product are logged, including private and direct messages, for review or audit. We may combine, augment, or extend the data with collect with additional data from third-party sources.

PERSONAL INFORMATION THAT WE COLLECT

 

HOW WE USE YOUR DATA

Data collected by the product is limited to the purpose of providing the service as well as limited in use to the purposes outlined in this privacy policy or as otherwise described at the time we collect it.

Data collected by the product is used for the following purposes:

Third-party marketing: We do not use your information for the purposes tracking and displaying personalized advertising on other websites. You can choose to opt-out of or unsubscribe from first-party marketing or third-party marketing.

Advertising: You can choose to opt-out of these advertisements.

Analytics: We use collected data to analyze trends, track user engagement, and improve the performance and functionality of our services. This helps us understand how users interact with our platform and identify areas for enhancement.

Application and Platform Functionality: User data may be processed to support the proper functioning and performance of the application, including authentication, feature delivery, and maintaining the stability and security of the Service. We take reasonable measures to delete all personal information from a user's postings before they are made publicly visible.
Product Personalization: User data may be processed to personalize the Service, enabling adjustments to features, interface, and functionality in accordance with individual user preferences.

Account Management: User data may be processed to facilitate account management, including authentication, profile maintenance, password recovery, and the secure administration of user accounts. Personal Data that we collect will be deleted when it is no longer necessary to provide you with our services. We delete Personal Data upon account cancelation or termination. In some cases, we may retain Personal Data beyond the length of time that you have an account with us in order to resolve disputes, comply with legal and compliance obligations, or otherwise. Anonymized data, which is no longer attached to you personally, may be retained for longer periods of time.

HOW WE SHARE YOUR PERSONAL INFORMATION

This section describes how and for what purpose we disclose or share your data with third-parties. We share data with the following categories of third-parties: affiliates. Personal information is not sold, rented, or exchanged for anything of value to third parties.

Personal information is not shared with third parties for their own marketing purposes.

We share the following categories of information with third-parties: identifier data, usage data, user content data, diagnostic data. The purposes for sharing information include analytics, product personalization, app functionality, account management, security and compliance. We share data with third-parties for internal analytics, research, and product improvement purposes.

Contractual limits are imposed third-parties regarding the extent to which they can use personal information that we may disclose to them. Contractual limits do not prohibit third parties from reidentifying de-identified information. Third-parties with access to information are required to provide the same security protections as the company.
In the event of a merger, acquisition, or bankruptcy user information may be transferred to acquiring third party. Users are notified if their information is transferred to a third party in the event of the company's bankruptcy, merger, or acquisition. User information can be deleted prior to its transfer to a third party. Third-party successors are contractually required to use the same privacy practices as described in this policy.

Below is a list of our data sharing partners along with links to their privacy policies for your information.

• Google Cloud Provider (https://cloud.google.com/terms/cloud-privacy-notice): Infrastructure and cloud services hosting provider.

• Amazon Web Services (https://aws.amazon.com/privacy): Infrastructure and cloud services hosting provider.

• Agilix Labs (Agilix Buzz) (https://igs.agilixbuzz.com/privacy): Vendor Learning Management System (LMS)provider

• Instructure (Canvas) (https://www.instructure.com/policies/product-privacy-policy): Vendor Learning Management System (LMS) provider

• PowerSchool (Schoology) (https://www.powerschool.com/privacy): Vendor Learning Management System(LMS) provider

• Google for Education (https://edu.google.com/intl/ALL_us/our-values/privacy-security): Vendor Learning Management System (LMS) provider

• Creatium Inc. (https://www.creatium.com/privacy-policy): Data Processor

• Postmark (https://www.activecampaign.com/legal/privacy-policy): Multi Factor Authentication Notifications

• Stripe (https://stripe.com/privacy): Payment Processing

YOUR CHOICES

You have certain choices regarding how your Personal Information is collected, used, and shared. This section explains the options available to you and how you can manage your privacy preferences.

To use our Products and Services, you are required to create an account. During the account creation process, we will collect certain information to establish and manage your account effectively. This information may include, but is not limited to, your name, email address, and a password of your choice. Your account allows you to personalize your experience, track your activities, and access additional features. We are committed to protecting the privacy and security of your account information in accordance with this privacy policy.

Users have the ability to choose whether their data is shared with or sold to third parties, and such sharing occurs only with opt-in consent.

You have the option to opt-out of specific tracking activities related to targeted advertising, also referred to as interest-based advertising. According to the CCPA, this involves the 'sharing' of your personal information with advertising partners.

We understand the importance of safeguarding your data, and therefore, we provide methods to control and restrict access to it. Our platform is equipped with access control mechanisms, allowing you to define and manage permissions for your data. Users cannot interact with trusted users. Users cannot interact with untrusted users, including strangers and/or adults. Users have the ability to manage how their data is displayed or shared with others through account settings and privacy controls. These tools enable users to adjust preferences and determine the visibility of certain information. Users must opt-in to participate in third party marketing. Users must opt-in to participate in first party marketing.

OTHER SITES AND SERVICES

The Service may contain links to websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or other online services that are not associated with us. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions.

Third-party login is supported for authentication into our Product or Services. When you choose to log in to our services using third-party authentication, such as through social media accounts or other external identity providers, we collect certain information from your chosen third-party platform. This may include basic profile details, such as your name, email address, and profile picture. By opting for third-party login, you grant us permission to access and use this information for the purpose of creating and managing your account, as well as enhancing your overall experience with our services. We may also request additional permissions during the authentication process, depending on the requirements of the third-party provider. In the event that user information is shared with a third-party, that information is, or would be, shared in an anonymous or de-identified format.

SECURITY

Multi-factor account protection is available. Reasonable security practices are used to protect data. Employee or physical access to user information is limited. All data in transit is encrypted. All data is stored in an encrypted format. Users are provided notice in the event of a data breach. All social interactions of users through the product are logged, including private and direct messages, for review or audit.

COOKIES

Our Product may use cookies to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize our Product, or register with our Product or Services, a cookie help sour Product to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the Product, the information you previously provided can be retrieved, so you can easily use the features that you customized.

Necessary cookies: Enable the core operation of our Products and Services and cannot be switched off in our systems. They include cookies that we use to help control secure areas of our site and to make sure it is accessible to you. You can set your browser to block or alert you about these cookies, but some parts of the site will not work as a result.

Analytics cookies: These cookies allow us to collect information about patterns of behavior among people using the site. Analytics cookies allow us to count site visits and understand traffic sources so we can measure and improve the performance of our site. We never collect any information from analytics cookies that could be used to personally identify you.

YOUR PRIVACY RIGHTS

Except as otherwise provided, this section applies to residents of states where they have privacy laws applicable to us that grant their residents the rights described below.

For purposes of this section, “personal information” has the meaning given to “personal data”, “personal information” or similar terms under the applicable privacy laws of the state in which you reside. Please note that not all rights listed below may be afforded to all users and that if you are not a resident of the relevant states, you may not be able to exercise these rights. In addition, we may not be able to process your request if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to it.

In some cases, we may provide a different privacy notice to certain categories of residents of these states, such as job applicants, in which case that notice will apply with respect to the activities it describes instead of this section.

Verification: Upon receipt of your request, we will initiate the identity verification process to confirm that you are the individual for whom we hold information in our system. This verification procedure necessitates your cooperation in supplying relevant information, allowing us to compare it with the details you previously furnished. Depending on the nature of your request, we may request specific information to align with our existing records, or we may reach out to you using a previously provided communication method (such as phone or email). In certain situations, alternative verification methods may be employed based on the circumstances.

Any personal information disclosed in your request will solely be utilized for the purpose of confirming your identity or validating your authority to make the request. We will make every effort to minimize the need for additional information for verification purposes. However, should it be impossible to verify your identity with the existing information in our records, we may request additional details to ensure the security and prevent fraud. Any supplementary information you provide for verification will be promptly deleted upon the completion of the verification process.

Authorized Agents: Your authorized agent may be able to make a request on your behalf. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.

Access: You can request a copy of the personal information that we have collected about you.

Notice is provided if the context in which data is collected changes. Consent is obtained if the practices in which data is collected change. You have the right to request details on the personal information that we sold, shared, or disclosed to a third-party for a business purpose.

Notice is provided in the event the company receives a government or legal request for a user's information. Users can request for their data to be deleted from the product or service. Users can opt-out of targeted advertising from the product or service

We maintain secure processes that allow authorized personnel to access, review, modify, and delete information when appropriate (for example: to fulfill your requests or maintain data accuracy).

Lincoln Learning Solutions provides users with the ability to exercise their privacy rights in accordance with applicable laws and contractual agreements. Depending on how Lincoln AI solutions are deployed, users may access, review, update, correct, or request deletion of their personal information either directly through the product interface or by submitting a request to privacy@lincolnlearningsolutions.org. For users accessing the product through a school or district, students and parents may also exercise their rights by contacting their school or district administrator, and Lincoln Learning will work with authorized school officials to fulfill such requests in a timely manner. Educators and administrators may manage account information and user data through available administrative tools within the platform. Users may opt out of non-essential communications by following unsubscribe instructions included in those communications. Lincoln Learning does not use personal information for third-party or targeted advertising. Users or authorized representatives may also request access to or deletion of data when accounts are closed or services are discontinued, subject to applicable legal, contractual, and record retention requirements.

CHILDREN'S PRIVACY NOTICE

This product is intended for children under the age of 13. This product is intended for teens between the ages of 13 and 18. This product is intended for to be used by parents and guardians. Intended for students. This product is intended for to be used by teachers. We will obtain verifiable parental consent from a parent or guardian before collecting or processing personal information from children under the age of 13. Parental consent can be given for collecting and processing data without also consenting to sharing data with third parties. Parents can withdraw consent for the further collection of their child's information. If we find that we have collected a child's personal information without the appropriate consent, we will delete that personal information. We provide notice to parents or guardians of the methods to provide verifiable parental consent.

When our product or service is used by a school, we rely on the school to provide the requisite consent, on behalf of the parent, for our product or service to collect information from a student User under the age of 13 for educational purposes. The company provides direct notice to school representatives that describes all the personal information that is collected and how it will be used and disclosed. The company requires a school representative to acknowledge and agree that they have authority to authorize the collection of personal information from children on behalf of the school, along with their name and title at the school. Personal information collected by the company in providing services to a school is under the direct control of the school with regard to its use and maintenance. Opt-in consent is requested from users at the time personal information is collected. Processes to enter education records into the product are described. Managed accounts are available.

CHANGES TO THIS PRIVACY POLICY

Lincoln Learning Solutions reviews and updates its privacy policy as needed to reflect changes in our products, services, or applicable laws. When we make a material change to our privacy policy, we notify users by posting an updated version of the privacy policy on our website with a revised effective date. When required, we also provide direct notice via email to educators or administrators associated with the affected product.

In addition to modifying this Privacy Policy and updating the effective date, we will contact you (either through the product or otherwise) to gain your consent if we change or modify the practices in which data is collected.

HOW TO CONTACT US

If you have questions on concerns regarding this Privacy Policy, please contact us using the means described in this section. A grievance or remedy mechanism is available for users to file a complaint in the event their content or account is restricted or removed. Please use the information below to contact us.

Email: privacy@lincolnlearningsolutions.org
Address: 2139 Brodhead Rd, Aliquippa, PA, 15001