Privacy Policy - Lincoln Empowered

Organization: Lincoln Learning Solutions
Contact Email: privacy@lincolnlearningsolutions.org
Business Address: 2139 Brodhead Rd, Aliquippa, PA, 15001
Product Name: Lincoln Empowered
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 (‘Lincoln Learning’, 'the company', 'we', ‘our’ 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 Empowered ('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.

• Data you provide to us: We collect information created or uploaded to the product by users through their use of our Products and Services. This may include student records uploaded by teachers or administrators and any information entered into the product by users. For example, teacher’s names and email addresses used when registering accounts, and other rostering information.
• Data from third party sources: We allow teachers and administrators to add information about students and classes directly into the product manually or via third party tools used by schools. The data collected from these tools, including information provided by teachers, administrators, and all student records, is used solely for the purpose of delivering and supporting the service.

Data collected automatically: When you use our services, we may use cookies and similar technologies that collect certain technical and usage information to deliver the services and better understand how you use the product. For more information on cookies and similar technologies, please see the Cookies and Similar Technologies section below. 

 

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:

• Service delivery and App Functionality (such as provide, operate, support, secure, and improve the service, including reviewing user-created content only when necessary for support, security, compliance, or at the direction of the school or authorized administrator)
• Account Management
• Product Personalization
• Analytics for research and product improvement
• Security and Compliance with applicable laws
• Send communications and help you use the service better

Lincoln Empowered is a curriculum and course solution for K–12 education available through learning management systems. The product is available through a school’s learning management system, directly from Lincoln Learning through an instance of the Agilix Buzz learning management system, or from other vendors.

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 Empowered. Lincoln Empowered does not process interactive or social data from these features, and any information shared within those external tools is subject to the privacy policies of the respective platform provider or the School. Outside of teachers assigning content and viewing student usage and progression, there are no social features or public posting functions through Lincoln Empowered.

Lincoln Learning retains personal information only for as long as reasonably necessary to provide services, fulfill contractual and legal obligations, resolve disputes, maintain security, and comply with applicable record retention requirements. 

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.

• 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
• HubSpot (https://legal.hubspot.com/privacy-policy): CRM storing client data for onboarding and client success
• Sprig (https://sprig.com/privacy-policy): Survey platform for clients and end users
• Clever (https://www.clever.com/trust/privacy/policy): SSO & User and enrollment synchronization platform
• ClassLink (https://www.classlink.com/company/privacy): SSO & User and enrollment synchronization platform
• SAP Business One (https://www.sap.com/about/legal/privacy.html): ERP storing client data for invoicing

For the avoidance of doubt, we never sell personal data from our service and we do not share data with third parties for their own marketing, advertising purposes, or creating advertising profiles.

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. 

YOUR CHOICES

To use our Products and Services, users are required to create an account. During the account creation process, we will collect certain information to establish and manage your account effectively. Your account enables you to personalize your experience, monitor your activities, and access, manage, and control both your personal data and any information you provide to us. Please note that when an educational institution administers the services for student users, certain account controls may be accessible only to account administrators.

When student data is provided to us through a third party learning management system, access, modification, or deletion of that data may be managed through those tools. We recommend contacting the school or district that administers your student’s data for any such requests.

We do not contact users of the Lincoln Empowered app for our own direct marketing and our service is free from any advertising including any contextual or personalized advertising. However, we may contact administrators, teachers and account administrator users directly to provide guidance on how to better utilize the product and to provide product guidance, onboarding assistance, service-related communications, updates, training resources, and information relevant to use of the product and related educational services. 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 Product or Services. When you choose 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. 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 

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 Empowered 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 what your username and password are so you can automatically log in.

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 Empowered 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 Empowered curriculum for homeschool, 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 Empowered.
• Right to Deletion: The right to request the deletion of Personal Information collected from or about you, subject to Lincoln Empowered’s right to retain data for legal, archival, or internal business purposes permitted by law.
• Right to Opt-Out of Sale or Sharing: Lincoln Empowered does not sell student data or share it for cross-contextual behavioral advertising. However, users maintain the right to opt-out of any future activities that may constitute a “sale” or “sharing” under 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 Empowered, 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 Empowered as a Data Controller: When you register for and use our products directly as an individual consumer, Lincoln Empowered acts as the Data Controller. This means we determine how and why your personal information is collected and processed.
• Lincoln Empowered 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 Empowered 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 13 years of age and under, 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 

 We may use algorithms or automated means to provide information and content to our users, including minors. Use of these automated means includes, but is not limited to, promoting, ranking, or filtering information or content. Lincoln Learning uses automated system logic to deliver educational content based on course enrollment, grade level, and assigned coursework established by the school or district. This logic may filter or sequence lessons, assessments, and progress indicators to support instruction. The system relies only on limited information necessary to provide the service, such as course enrollment and course progress, and does not use student data for advertising or commercial profiling.

CHANGES TO THIS PRIVACY POLICY

Lincoln Learning reviews and updates its privacy policy as needed to reflect changes in our products, services, or applicable laws. When we make changes 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) 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