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: September 30, 2026

DRAFT

This privacy policy should be considered a DRAFT policy.

INTRODUCTION

At Lincoln Learning Solutions (“Lincoln Learning,” “we,” “our,” or “us”), we respect your privacy and are committed to protecting it as described in this Privacy Policy (“Policy”).

This Policy describes the types of information we may collect from you or that you may provide when using Lincoln AI and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Policy covers two products under the Lincoln AI umbrella: Linc Coach and Lincoln Learning Assistant

“Lincoln AI” refers collectively to our AI-enabled educational products and services, including Linc Coach or Learning Coach (“Coach”), which is offered directly to parents and guardians for student use at home, and Lincoln Learning Assistant (“Assistant”), which is offered through schools and other educational institutions.

Your use of Lincoln AI and any information you provide through the Services are subject to this Privacy Policy and our applicable Terms of Service. 

DATA COLLECTION

For purposes of this Privacy Policy, “Personal Information” means information that identifies, relates to, describes, or could reasonably be linked with an individual or household, directly or indirectly. The Personal Information Lincoln Learning collects depends on whether Lincoln AI is used through Coach or Assistant and the features that are enabled.

Lincoln Learning limits the collection of Personal Information to information reasonably necessary to provide, operate, secure, support, and improve Lincoln AI and to fulfill applicable legal and contractual obligations.

Information You or an Authorized User Provide

We collect information provided by users, parents or guardians, educators, administrators, and authorized educational organizations when using Lincoln AI. Depending on the Service and deployment model, this may include:

• • Account and Contact Information: Name, email address, unique user or account identifiers, and other information necessary to create, authenticate, and manage an account.
  • Parent or Guardian Information: For Coach, information provided by a parent or guardian to establish and manage their account and their child's account.
  • Student Information: Student identifiers, grade level, and, for Coach where required for age assurance and account administration, birth month and year.
  • Educational Information: Course, class, enrollment, assignment, curriculum, and other educational information necessary to provide appropriate learning support.
  • AI Interaction Data: Prompts submitted to Lincoln AI, AI-generated responses, conversation history, and conversational context.
  • User-Provided Educational Content: Files, documents, or other educational materials uploaded or submitted for learning support, where those features are available.

Information Provided by Schools and Authorized Educational Services

When Assistant is provided through a school, district, consortium, intermediate unit, or other authorized educational organization, Lincoln Learning may receive student, educator, class, course, enrollment, rostering, and account information from the educational organization or through systems it authorizes, such as learning management systems, identity providers, and rostering services.

Lincoln Learning uses this information only as necessary to provide, administer, support, personalize, and secure Assistant in accordance with the educational organization's instructions and applicable agreements.

Information Collected Automatically

• When Lincoln AI is used, we may automatically collect limited technical, diagnostic, usage, and security information necessary to operate, secure, support, and improve the Services. This may include:
• device and browser information;
• IP address and related network information;
• application and feature interactions;
• search and usage activity used to support authorized educator usage dashboards;
• authentication and security events;
• diagnostic and crash information; and
• cookie and similar technology information as described in the Cookies section of this Policy.
• Lincoln Learning does not collect precise geolocation information. Approximate location may be derived from IP or network information for security, diagnostics, or service operation where applicable.

Safety and Alert Information

Lincoln AI includes automated safety and acceptable-use features designed to identify certain content that may indicate a potential safety concern or violation of acceptable-use standards. When designated criteria are detected, Lincoln AI may generate and retain a safety or acceptable-use alert record.

Depending on the nature of the detection, this record may include the applicable alert category or classification, severity level, alert status, relevant session or interaction information, the content or portion of the interaction associated with the alert, timestamps, and information regarding the review or resolution status of the alert.

Safety and alert information is used to provide the safety functionality of Lincoln AI, notify appropriate authorized adults, support review and follow-up, maintain an appropriate record of alert status and resolution, and support security, compliance, and service administration.

For Assistant, safety and alert information is made available only to authorized personnel designated by the applicable school or educational organization, such as authorized teachers, administrators, counselors, or other designated personnel. For Coach, applicable alerts may be made available to the parent or guardian responsible for the student's account.

Safety alerts are generated automatically and are intended to support human review. An alert does not constitute a clinical assessment, diagnosis, determination of intent, disciplinary determination, or substitute for professional or emergency response. Authorized adults are responsible for reviewing the circumstances and determining the appropriate response.

Safety and alert information is retained only as reasonably necessary to provide the applicable safety functionality and in accordance with Lincoln Learning's retention practices, contractual obligations, and applicable law.

Voice and Speech-to-Text Information

Where speech-to-text functionality is available, audio is processed for the purpose of converting speech to text and providing the requested functionality. As described further in this Policy, Lincoln Learning does not retain the audio after transcription is completed.

Lincoln Learning does not collect more Personal Information from students or children than is reasonably necessary to provide the applicable Service.

PERSONAL INFORMATION THAT WE COLLECT

 

HOW WE USE YOUR DATA

We limit the data we process and collect from users of the product and students to only what is required to deliver the services. We use the collected data for the following purposes:

• Provide, operate, maintain, and support Lincoln AI.
• Authenticate users and manage accounts.
• Generate educational responses and maintain appropriate conversational context.
• Personalize educational support based on authorized educational information and prior interactions where applicable.
• Provide automated safety and acceptable-use detection features.
• Troubleshoot, secure, and protect Lincoln AI.
• Conduct internal analytics, research, and product improvement using information as permitted by this Policy and applicable agreements.
• Communicate with authorized adults regarding accounts, service operation, support, safety, or product information.
• Comply with applicable laws and contractual obligations

Lincoln Learning does not use student Personal Information for advertising, commercial profiling, or training of artificial intelligence models.

This Policy covers two products under the Lincoln AI umbrella: Linc Coach and Lincoln Learning Assistant. Both products are subject to the privacy protections described in this Policy, with additional practices applicable to each deployment model as described below.

Privacy Protections for Lincoln AI products:

• Safety and Acceptable-Use Alerts: Lincoln AI includes automated features designed to identify certain content that may indicate a potential safety concern or violation of acceptable-use standards. When designated criteria are detected, Lincoln AI may generate an alert for an authorized teacher, school administrator, counselor, parent, guardian, or other designated responsible adult, depending on how the Service is deployed. Alerts are generated automatically to support human review and do not constitute a clinical assessment, diagnosis, determination of intent, or substitute for professional or emergency response.
• Learning-Focused Support: Lincoln AI is designed to support the learning process by providing guidance, explanations, prompts, and instructional assistance intended to help students develop understanding and problem-solving skills rather than providing answers or simply completing work on their behalf.
• Student Data Is Not Used to Train AI Models: Lincoln Learning does not use student Personal Information or student interactions to train any artificial intelligence models. Student chat history with AI features is only stored to personalize the educational content provided to students. Student interactions with Lincoln AI are stored using a unique user identifier rather than the student's account name. Conversation content may nevertheless contain Personal Information entered by the user. Access to conversation data is restricted and used only for authorized purposes described in this Policy.
• Voice data is not retained: Where speech-to-text functionality is available, audio is processed for transcription and is not retained by Lincoln Learning after transcription is completed.

For Home Use: Linc Coach is a standalone solution using proprietary artificial intelligence models trained on Lincoln Learning curriculum content to provide learning support and assistance to students. Linc Coach is offered directly to parents and guardians for use by their children at home. Parents and guardians retain full control over the features that their child can access.

For School Use: Lincoln Learning Assistant is a chatbot-like solution embedded in the Lincoln Learning curriculum using proprietary artificial intelligence models trained on Lincoln Learning Curriculum content currently available, integrated within a school’s LMS. Schools control whether Assistant is enabled and may manage access at the organizational, class, course, or student level, depending on available functionality. Lincoln Learning processes student information on behalf of the educational organization and in accordance with applicable agreements and law. In addition, Where parental opt-out is offered or required, authorized administrators may disable Assistant access for an individual student.

Additional interactive and social features that may be offered within a learning management system, such as discussion boards and chats, are not part of Lincoln AI. Lincoln AI does not process interactive or social data from external LMS features, and any information shared within those external tools is subject to the privacy policies of the respective platform provider or the School.

Lincoln AI can function within a learning management system (LMS) or as a standalone coach to provide support and guidance to students as they engage in learning activities. Student interactions and transcripts with Lincoln AI are stored using a unique user identifier rather than the student's account name. Users can upload content for learning feedback or support from the product however, user content is not available to share with users through the application. There are no interactions between users within Lincoln AI.

DATA RETENTION

Lincoln Learning retains Personal Information only for as long as reasonably necessary to provide Lincoln AI, maintain account and safety functionality, satisfy contractual and legal obligations, resolve disputes, and protect the security and integrity of the Services. Retention periods may vary based on the type of information and whether Lincoln AI is provided through a school or directly to a parent or guardian. For school-managed accounts, retention and deletion may also be governed by Lincoln Learning's agreement with the educational organization. When information is no longer required, Lincoln Learning deletes or de-identifies it in accordance with applicable requirements and established retention practices.

HOW WE SHARE YOUR PERSONAL INFORMATION

This section describes how and the purpose for which we disclose or share your data with third-parties. As part of providing our services, we may share data with third party sub processors who process information to help us provide our services. This includes processing data for product functionality, internal analytics, research, and product improvement purposes.

We establish contractual limitations with third party sub processors that restrict the extent and purposes for which they may process any personal information we disclose to them. These third parties are permitted to process personal information solely on our behalf and in accordance with our instructions. Third-parties with access to information are required to provide the same security protections as the company.

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, AI processing provider
• Postmark (https://www.activecampaign.com/legal/privacy-policy): Multi Factor Authentication Notifications
• Stripe (https://stripe.com/privacy): Payment Processing 

For the avoidance of doubt, Lincoln Learning does not sell Personal Information, use student Personal Information for targeted or cross-context behavioral advertising, or disclose student Personal Information to third parties for their own marketing purposes.

In the event of a merger, acquisition, or bankruptcy, user information may be transferred to a third-party successor. Throughout any such transition, Schools retain full ownership and control of their information, including all student records. Users will be notified if their information is transferred to a third party due to a change in ownership or insolvency. Furthermore, where permitted by applicable law and contractual obligations, schools or authorized users may request deletion of information before transfer. Any third-party successor is contractually obligated to adhere to the same privacy protections and data usage practices established in this policy.

We may disclose information, including personal information, if we have a good faith belief that doing so is necessary to comply with the law, such as complying with a subpoena or other legal obligation. Where legally permitted and appropriate, Lincoln Learning will notify the affected customer or educational organization of a government or legal request involving information processed on its behalf

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 student’s account effectively. This information may include, but is not limited to, your name, email address, and a password of your choice.

Lincoln AI is available either through a school or educational institution or, in the case of Coach, through direct sign-up by a parent or guardian. In the case of school-based users, an authorized school representative provides Lincoln Learning with the information needed to register and create accounts. As mentioned above, account administrators retain granular controls for activating Lincoln AI features for different students, schools, or classes.

For direct sign-ups by parents or guardians, information is provided by the parent or guardian who then retains oversight over their student’s account and associated user data.

We do not contact student or child users of the Lincoln AI applications for our own direct marketing and our service is free from any advertising including any contextual or personalized advertising. We may contact administrators, teachers, parents, guardians, and account administrators to provide account information, product guidance, service updates, training resources, support, and other information relevant to their use of Lincoln AI. You can stop receiving email communications from us by clicking “unsubscribe” in such communications or contacting us directly. We make every effort to promptly process all unsubscribe requests.

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 Lincoln AI products used by schools. When a school chooses to log in to our services using third-party authentication, such as through learning management systems 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 user ID. When Assistant is accessed through an authorized third-party identity provider or LMS, Lincoln Learning receives the information necessary to authenticate the user and provide the Service as authorized by the educational organization. When Coach is set up by parents at home, parents must provide the account information for their student.

SECURITY

We are dedicated to safeguarding the security of information obtained through the services, including personal information. When we collect information from you, we implement reasonable and appropriate administrative and technical safeguards to help protect it from unauthorized access, use, or disclosure. For example, all data is encrypted during transmission and at rest.

Lincoln Learning maintains policies, procedures, and technical safeguards designed to identify, investigate, respond to, and remediate suspected or confirmed security incidents involving personal information.

In the event of a confirmed unauthorized access to, acquisition of, disclosure of, or loss of personal information that materially impacts the confidentiality, integrity, or availability of data under our control (“Security Incident”), Lincoln Learning will notify affected educational institutions, customers, or users, as applicable, without unreasonable delay and in accordance with applicable law, contractual obligations, and the nature and scope of the incident.

Where Lincoln AI is provided through a school, district, consortium, intermediate unit, or other educational partner, Lincoln Learning will coordinate notification and response efforts with the educational organization, including providing available information regarding the nature of the incident, categories of information involved, remediation steps taken, and recommended actions where appropriate.

Lincoln Learning maintains an incident response process designed to support timely escalation, investigation, communication, and remediation of high-priority security incidents in accordance with applicable policies, contractual obligations, and service commitments. Lincoln Learning will take commercially reasonable steps to investigate, contain, mitigate, and remediate confirmed security incidents and to reduce the likelihood of recurrence.

COOKIES

Our Product may use cookies or similar technologies to help you personalize your online experience. A cookie is a text file that is placed on your device browser that stores preferences to facilitate and enhance your experience. For example, if you register with our Product or Services, a cookie helps our product to recall your specific information on subsequent visits. For clarity, we do not use third-party cookies on our service for personalized advertising or to track users and display personalized advertisements on other third-party websites or services. You can find a list of the types of first and third party cookies we use below:

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.

Preference cookies: Also known as “functionality cookies,” these cookies allow a website to remember choices you have made in the past, like what language you prefer, or authentication state or other preferences that allow you to remain signed in where supported.

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.

Because Lincoln Learning does not sell personal information or engage in cross-context behavioral advertising, we currently do not respond to Global Privacy Control (GPC) browser signals.

YOUR PRIVACY RIGHTS

This section provides additional disclosures and describes the rights afforded to residents of United States jurisdictions with applicable comprehensive privacy laws, including but not limited to California, Virginia, Colorado, Connecticut, and Utah. For the purposes of this section, “Personal Information” shall have the meaning ascribed to such term (or similar terms such as “Personal Data”) under the applicable state law of the user’s residence.

Lincoln AI may be provided through schools, districts, educational partners, or directly to parents/guardians for homeschool or individual educational use. Data rights and account controls may differ depending on the deployment model. Lincoln Learning primarily serves as a Service Provider or Processor to educational institutions (each, a “School”). In such instances, the School remains the primary Data Controller with respect to student and parent information. If your Personal Information was collected on behalf of a School, Lincoln Learning will coordinate with the School to respond to any verified requests. However, if you are a direct purchaser of the Lincoln AI services for home use, you may exercise your data rights by submitting a request via email to privacy@lincolnlearningsolutions.org.

Subject to statutory exceptions and the verification requirements detailed below, residents of applicable states may exercise the following rights:

• Right to Know and Access: The right to confirm whether Lincoln Learning is processing your Personal Information and to obtain a copy of such data in a portable, readily usable format.
• Right to Correction: The right to request the rectification of inaccurate or incomplete Personal Information maintained by Lincoln AI.
• Right to Deletion: The right to request the deletion of Personal Information collected from or about you, subject to Lincoln Learning's right and obligation to retain certain information as permitted or required by applicable law, contractual obligations, security requirements, or educational record requirements.
• Right to Opt-Out of Sale or Sharing: Lincoln Learning does not sell Personal Information or share Personal Information for cross-context behavioral advertising. If these practices materially change, Lincoln Learning will provide any notice and choices required by applicable law.
• Right to Non-Discrimination: We shall not deny services or provide a different level of quality should you choose to exercise your privacy rights.

To exercise these rights, you or your Authorized Agent must submit a verifiable request via:

• Email: privacy@lincolnlearningsolutions.org 
• School Coordination: If you are a student or parent, please submit your request to your School administrator.

Verification Process: Lincoln Learning reserves the right to verify your identity before fulfilling any request. Verification may require the provision of specific data points to be matched against our existing records. If an Authorized Agent is utilized, Lincoln Learning may require proof of a valid power of attorney or written, signed authorization from the consumer. We will only utilize Personal Information provided in a verification request to confirm the requestor's identity or authority.

Lincoln Learning may be unable to process a request if the identity of the requestor cannot be verified to a degree of certainty required by law. Please note that certain data is exempt from these requests if its retention is required to comply with the Family Educational Rights and Privacy Act (FERPA) or other legal obligations.

GDPR

If you are located in the European Economic Area (EEA), the UK, or Switzerland, you have specific rights under the General Data Protection Regulation (GDPR). Depending on how you access Lincoln AI, Lincoln Learning may act as either a Data Controller or a Data Processor for the personal information we collect through our services.

How we handle your data depends on how you access our services:

• Lincoln Learning as a Data Controller: When you register for and use our products directly as an individual consumer, Lincoln Learning acts as the Data Controller. This means Lincoln Learning determines how and why your personal information is collected and processed.
• Lincoln Learning as a Data Processor (School Use): When our curriculum and services are used within a school or educational institution, the school acts as the Data Controller. In these instances, Lincoln Learning operates strictly as a Data Processor, handling student and educator data solely on behalf of, and according to the instructions of, the school. If you use our services through a school, please contact your institution directly to exercise your privacy rights.

To use your data legally, we rely on the following Legal Bases:

• Performance of a Contract: We process your personal information to provide our educational curriculum and services. This processing is necessary to fulfill our agreement with you or your school.
• Legitimate Interests: We may process data to improve our services and ensure platform security, provided these interests do not override your fundamental privacy rights.
• Consent: Where required by law, including for certain optional features or children’s privacy requirements, we rely on consent to process personal information.

You have the following rights regarding your personal information:

• Right of Access and Portability: You may request a copy of the personal data you provided to us in a structured, machine-readable format.
• Right to Rectification: You can update or correct inaccurate information directly within your account settings.
• Right to Erasure (“Right to be Forgotten”): Subject to applicable law, contractual obligations, and educational record requirements, users may request deletion of personal information. Where self-service deletion tools are available, deletion may be permanent and irreversible.
• Right to Restrict or Object to Processing: You can limit how we use your data by adjusting your device permissions or stopping the use of specific features.
• Right to Withdraw Consent: If we rely on your consent to process data, you can withdraw it at any time via your app settings.

To submit a request or ask questions about your data, please contact our Privacy Team at: privacy@lincolnlearningsolutions.org. 

If you believe we have not addressed your concerns adequately, you have the right to lodge a complaint with your local Data Protection Authority. You can find a list of EEA authorities here. 

CHILDREN'S PRIVACY NOTICE

We comply with the U.S. Children’s Online Privacy Protection Act and Family Educational Rights and Privacy Act, and describe our practices regarding the personal information of all students under the age of 13 below. Our service is designed to be used by teachers, administrators, and students in an education context. As part of our services, we may process student records and data from children under 13 years of age, as provided to us by schools and teachers.

When we provide services on behalf of a school, the school provides consent for Lincoln Learning to collect and process information from students under the age of 13 as permitted by the Children’s Online Privacy Protection Act. As described in the notice we provide to schools, we collect, maintain, use and share student records only for authorized educational purposes. Student records that we process on behalf of schools will remain under the control of the respective school. To request access to, modification of, or deletion of student records, please contact the school that maintains those records directly. Where services are provided through a district, school, intermediate unit, consortium, or authorized educational partner, Lincoln Learning relies on the contracting educational organization or its authorized partner to provide required notices and obtain required consents.

When we provide services on behalf of a parent to a child under the age of 13, we will first obtain verifiable parental consent in accordance with the Children’s Online Privacy Protection Act. We collect personal information from children under 13 only to the extent necessary to provide the service requested. We use, maintain, and share this information strictly for the purpose for which consent was given. Parents have the right to review their child’s personal information, request that it be deleted, and refuse to permit its further collection or use.

We are committed to protecting the privacy and data of students and children and do not require more information about students or children than is reasonably necessary to provide the service. In addition:

• We collect, maintain, use and share student records only for an authorized educational purpose.
• We do not use or disclose student records for targeted advertising or any other commercial purposes unrelated to education.

We do not build a personal profile of a student other than to deliver our service.

ALGORITHMIC CONTENT

Lincoln AI uses artificial intelligence and automated systems to provide educational assistance to students. These systems may process student prompts, conversation context, authorized curriculum and course information, and other information described in this Privacy Policy to generate educational responses, explanations, guidance, and other learning support.

Lincoln AI may use prior interactions and authorized educational context to maintain conversational continuity and personalize educational assistance. Lincoln AI also uses automated systems to identify certain content that may indicate a potential safety concern or violation of acceptable-use standards. When designated criteria are detected, the system may generate an alert for an authorized adult as described in the Safety and Acceptable-Use Alerts section of this Policy.

AI-generated responses and automated safety detections may require human review and validation. Automated systems are intended to support students and responsible adults and do not independently make clinical, disciplinary, or other high-impact decisions about students. Safety alerts are provided to support human review and assessment.

Lincoln Learning does not use student Personal Information for targeted advertising or commercial profiling. Student Personal Information and student interactions are not used to train artificial intelligence models 

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.

If a material change requires additional notice or consent under applicable law or contractual obligations, Lincoln Learning will provide such notice or obtain consent as required before the change applies.

HOW TO CONTACT US

If you have questions on concerns regarding this Privacy Policy, please contact us using the means described in this section.

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