Great Minds Digital Platform Privacy Policy

We're updating the Privacy Policy for the Great Minds digital platform, effective August 17, 2026 for existing users and immediately for new users. By continuing, you acknowledge these changes.

Updated and Effective: August 3, 2026

This Privacy Policy applies to the collection of information by Great Minds PBC ("Great Minds," "we," "us", and "our") from students, teachers, or other users authorized by Schools through the access-controlled, digital platform we provide, including through any related websites, software, applications, or interactive features or online services, and that post a link to or include this Privacy Policy (collectively, the "Digital Platform"). This Privacy Policy also applies to any information we collect offline in connection with the use of the Digital Platform, or any related services, including implementation support we provide to Schools.

Please review our Digital Platform Terms of Use, which also apply to your use of the Digital Platform.

For privacy practices relating to our public website (https://greatminds.org/), please refer to our website Privacy Policy.

OVERVIEW

Access to the Digital Platform is provided to users pursuant to agreements that Great Minds has with authorized representatives of schools, learning institutions, school districts, state or local boards of education or other educational organization customers (collectively, "Schools").

The Digital Platform is only made available to students, teachers, and others as authorized by the Schools. Schools may provide certain information to us about their students and teachers who are authorized to use the Digital Platform, such as when creating an account on a student's behalf. We may also disclose information to the Schools pursuant to our agreements with the Schools. When we provide access to The Digital Platform through a School agreement, we collect, process, disclose, and store student information in order to provide learning services through The Digital Platform and on behalf of Schools and only in the ways permitted by the applicable School agreement. To the extent there is any conflict between this Digital Platform Privacy Policy and an applicable School Contract, the School Contract controls.

In limited circumstances, we may directly interact with students, parents/legal guardians, and/or teachers, outside the scope of an applicable School agreement, in which case we will provide direct notice and obtain consent (opt in or opt out) as may be required by applicable law.

We set forth our overall privacy practices below for the Digital Platform, however please note that we have certain more restrictive privacy practices for users younger than the age of 13, which are set forth under the section titled "COPPA NOTICE - Information and Direct Notice for Parents/Guardians of Children". To the extent there is any conflict between our general privacy practices and the section titled for "COPPA NOTICE - Information and Direct Notice for Parents/Guardians of Children", the section directed to Children controls.

TABLE OF CONTENTS

Information We Collect
How Does Great Minds Use The Information Collected?
When Does Great Minds Share Information?
Data Requests
Data Retention
Security
Third Party Links or Content
Consent to Transfer of Data
Notice to California Residents
COPPA Notice
Contact Us

What Information Do We Collect?

We may collect information from you directly, automatically when you visit The Digital Platform, and sometimes from third parties, such as your School. Some of this information may be considered "personal information" under various applicable laws. We consider information that identifies you as a specific, identified individual (such as your name and email address) to be personal information. We will also treat additional information, including IP addresses and cookie identifiers, as "personal information" where required by applicable law. Note that we may de-identify personal information so that it is non-personal, such as aggregating or converting it to a code. We will treat de-identified information as non-personal to the fullest extent allowed by applicable law and agreements. If we combine non-personal information with personal information, then we will treat the combined information as personal information under this Privacy Policy.

Information We Receive from Schools

When we receive information from Schools, it may be through a third-party rostering program. We encourage you to read the privacy policies of the Schools and these third-party rostering programs, as those parties have their own policies. Please contact us as detailed below if you have questions about which entities may be involved in such rostering processes.

We may receive information about students from Schools, including:

Full Name
Email address
Student ID assigned by the School
Grade level, subject area, class sections, school, school district where a student is enrolled

We may receive information about teachers and other individuals authorized by Schools, including:

Full Name
Staff ID
Email address
School and/or School District of employment
Professional role within the applicable School
Grade levels, class sections, curriculum, and subject areas taught

Information collected directly from students

Depending on the applicable agreement with the School and the product or features used, Great Minds may collect information directly from students, including:

Student username and password (unique to our systems)
User-generated content, including text, and other responses to questions, prompts, assignments, suggestions, or other similar content
Data generated from student activity within The Digital Platform, including answers provided, errors, preferences, scores, assessment reports, timing information, progress within the system, and inferences made from this data about student knowledge.
Optional audio recordings to assist educators/teachers in the assessment of language fluency

When we collect information from students, we do not make that information publicly available.

Information collected directly from teachers or other users authorized by Schools:

Username and password (unique to our system)
Audio and visual recordings of in-classroom demonstrations to support implementation and improve our products and services for Schools (which may include audio and likeness of participating students).
Answers to surveys, questionnaires, and other feedback to support implementation and improve our products and services for Schools.
Records of interaction with customer support
Data generated from teacher or users authorized by School(s), including annotations, notes, and assessments.
Phone number if provided as part of a support service ticket

Information collected automatically through use of The Digital Platform

In addition to any personal information that you choose to submit to The Digital Platform, we and our third-party service providers may use a variety of technologies that automatically or passively collect certain information whenever you visit or interact with The Digital Platform ("Usage Information"). Usage Information may include the following, among other information:

Web browser type and version
Operating system
Referrer Domain
Language setting
All pages and activities viewed on The Digital Platform
Date and time of use
Length of stay on certain courses or pages
We also automatically collect your IP address or other unique identifier ("Device Identifier") for any computer, mobile phone or other device you may use to access The Digital Platform. A Device Identifier is a number that is automatically assigned to your device used to access The Digital Platform, and our servers identify your device by its Device Identifier. We may be able to collect or infer your approximate location through information we collect, such as IP address.

Any Usage Information, Device Identifier, or other persistent identifier we collect is used for the sole purposes of providing our Digital Platform to students, teachers, and their Schools and to support The Digital Platform's internal operations.

The technologies that may be used to collect Usage Information include the following:

Cookies. When you use our Digital Platform, Great Minds may store data in "cookies" or similar technology on your devices, which are data files placed on your computer or other device when you visit The Digital Platform or otherwise access our online content. Great Minds may use cookies for many purposes, including, without limitation, to remember you and your preferences, to collect information about how you use our Digital Platform, personalize content within The Digital Platform, and track the pages you've visited. We use both session and persistent cookies (which remain on your computer after the browser has been closed). This information allows us to customize your Great Minds experience so that your visit is as relevant and as valuable to you as possible.

For more information on cookies, visit www.allaboutcookies.org.

Pixels. We may use pixels (small graphic images or other web programming code, also known as "web beacons" or "1x1 GIFs" or "clear GIFs") and similar technologies on our Digital Platform. Pixels can recognize certain types of information on your computer such as cookies, the time and date a page is viewed, and a description of the page where the web beacon is placed. Pixels or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to The Digital Platform, to monitor how users navigate The Digital Platform, to count how many e-mails that were sent were actually opened or links were actually viewed and to improve your experience on The Digital Platform.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with The Digital Platform, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third party service provider, is active only while you are connected to The Digital Platform, and is deactivated or deleted thereafter.

In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.

How Does Great Minds Use Information Collected?

Allow students to access and use the service as designated by the School, including to set up an account
Help students reset their passwords
Investigate information security and information asset protection-related incidents
Except where prohibited by applicable law or School Contract, test, correct, improve, and/or further develop our content, products, features, applications and services
Analyze academic and learning outcomes and preferences
Provide insights and details on class and student performance to teachers or Schools
Personalize the teaching and learning resources available across The Digital Platform to improve student instruction and meet individual student needs
Communicate with and provide reports to you, your parents or legal guardians, teachers or School or school district administrators at the student, class, School, or district level, or as otherwise directed by the School, based on your use of and activities on The Digital Platform, including reminders and other informational messages
Request feedback on our product(s) and services
Provide technical support and process support tickets
Monitor the use of our products and services and perform such analyses as might be necessary or helpful in improving product performance, efficiency, and security
Where not prohibited, research on how students use The Digital Platform and analyze the educational effectiveness of our products and services to contribute to general knowledge about how students learn
Enforce our Terms of Use or the applicable School Contract
Use the information as may be required or permitted by legal, regulatory, industry self-regulatory, insurance, audit or security requirements.
For purposes disclosed at the time you provide your personal information or otherwise with your consent.

Great Minds does NOT use any information collected about students to advertise or market to students or their parents or legal guardians.

How Does Great Minds Share Information?

To And On Behalf Of Schools

As discussed above, we provide The Digital Platform to students, teachers or other authorized users through agreements with Schools. Accordingly, Schools (and those who obtain authorized access from the Schools) may have access to some or all of the information we collect via registration and The Digital Platform from students associated with that School.

Service Providers

In order to provide and support our products, Great Minds may contract with third parties and share information required to carry out these services with these third parties, called "service providers," or "subprocessors." These service providers/subprocessors provide support services, such as hosting The Digital Platform and operating their features, or performing other administrative services. In such cases, all third parties are required to abide by this policy. Great Minds takes reasonable steps to release personal information collected from students only to service providers and third parties who are capable of and have agreed to maintain the confidentiality and security of that information and to use that personal information only to provide the applicable service to us or on our behalf. For our current list of service providers/subprocessors that may process student personal information in the provision of services to us or on our behalf, please refer here.

Administrative and Legal Reasons

We may disclose personal information about students, teachers, or other authorized users to third parties when necessary to protect the security or integrity of The Digital Platform; take precautions against liability; respond to judicial process; or provide information to law enforcement agencies or for an investigation on a matter related to public safety. We may also disclose personal information in connection with a merger or the sale of Great Minds' assets or interest in The Digital Platform, or other similar change in ownership (including, during the course of any due diligence process), provided that any subsequent owner of such personal information has agreed to abide by Great Minds' then-current Digital Platform Privacy Policy.

Research, Product Improvement, and Statistical Purposes

Except where prohibited by applicable law or School Contract, Great Minds may use de-identified and aggregate data about students', teachers', and/or other authorized users' use of our Digital Platform for internal product development, research, program evaluation, or other legally permissible purposes. To de-identify data, we remove or obfuscate all direct and indirect personal identifiers as required by applicable law. These identifiers include, but are not limited to: student name, teacher name or ID, teacher email, and school/district-provided unique IDs. Great Minds agrees to restrict any third parties to whom it discloses such data from attempting to re-identify any de-identified data. We may store de-identified data indefinitely unless otherwise agreed pursuant to your School Contract.

Third-Party Analytics Services

We may work with analytics providers to provide us with information regarding the use of our Digital Platform. These third parties may set and access their own tracking technologies on your devices (including cookies and web beacons), and they may otherwise collect or have access to information about you, including Usage Information.

Data Requests

If you are a parent/guardian of a student or a student and would like to access or request deletion of any information collected by Great Minds as a result of your or your student's use of the Digital Platform, please contact your School.

If you are a teacher or other user authorized by the School and would like to access or request deletion of any information collected by Great Minds as a result of your use of the Digital Platform, please contact your School.

You may be able to review, modify, and delete certain information related to your use of our Digital Platform through your account. Schools may ask to review the information that Great Minds has collected and retained about a particular student, or request its deletion, by contacting us at privacy@greatminds.org. Information collected from students, teachers, and/or users authorized by the School will always be deleted within one year after the end of a paid term of use, or sooner if requested by the School.

Data Retention

Great Minds will retain personal information for as long as required by the applicable School Contract and in order to provide access to the Digital Platform and related services. Great Minds will otherwise retain personal information as required by applicable law. Great Minds may also delete personal information or other data when requested by a School and where required under the requesting School's School Contract. The School may request a copy of the data by contacting us at privacy@greatminds.org.

Unless otherwise prohibited by a School Agreement, Great Minds may retain aggregated, de-identified, or other non-personal information, including curriculum or other content submitted by users when using The Digital Platform as long as needed for our business purposes.

All information collected and stored by a School remains subject to that School's privacy practices.

Security

Great Minds takes commercially reasonable steps to help protect and secure personal information. We have implemented an information security program with numerous measures, including administrative, technical, and physical controls that are designed to reasonably safeguard personal information under our control against loss, misuse and unauthorized alteration. However, please remember that no data storage or data transmission over the Internet, or by other means, can be guaranteed to be 100% secure. Thus, while we strive to protect your personal information, Great Minds cannot ensure or warrant the security of any information you transmit to us. Therefore, each School and any user accessing The Digital Platform under the School's authorization understands, acknowledges, and agrees that you transmit personal information to The Digital Platform at your own risk, to the greatest extent permitted by law.

Third-Party Links or Content

The Digital Platform may contain links to other web sites or include other content hosted and served by third parties that Great Minds does not control. Likewise, our content, including some of our Digital Platform, may be provided through or be included on third parties' web pages and web sites that are not associated with Great Minds and over which we have no control. We may collect Usage Information through Great Minds content appearing on third-party sites. Great Minds is not responsible for the privacy practices of any third party.

Consent to Transfer of Data

If you access or otherwise use The Digital Platform outside of the United States, by using the Digital Platform and/or providing us with information, you acknowledge and agree that your personal information may be processed for the purposes identified in the Privacy Policy. In addition, your personal information may be processed in the country in which it was collected and in other countries, including the United States. By providing your information, you fully understand and unambiguously consent to this transfer, processing, and storage of your information in the United States and other jurisdictions, where laws regarding processing of personal information may be less stringent than the laws in your country, and where governments, courts or law enforcement or regulatory agencies in those other countries may be able to obtain compelled disclosure of that personal information through the laws of those countries.

Information for California Residents

Great Minds collects personal information from users of The Digital Platform as a service provider on behalf of and only in the ways permitted by the applicable School Contract. Great Minds does not sell personal information collected through the Digital Platform or share that information with third parties for their own direct marketing purposes.

If you are a California consumer and a teacher/administrator end user of our Digital Platform and would like to submit a request to access or delete information or other available privacy rights under the California Consumer Privacy Act (CCPA/CPRA) or other applicable state laws, please contact your School.

COPPA NOTICE - Information and Direct Notice for Parents/Guardians of Children

Great Minds acts as a service provider to Schools that authorize Great Minds to collect information from students, including users younger than the age of 13 ("Children" or "Child"), in accordance with the Children's Online Privacy Protection Act ("COPPA"). Great Minds does not otherwise knowingly collect information from Children through the Great Minds Learning Platform.

When a School provides access to The Digital Platform to students who are Children, the School represents that it has secured all necessary consent(s) from the parents/guardians of those Children or alternatively, is providing, and is authorized to provide, such consent(s) on the parents/guardians' behalf. Great Minds Learning Platform only collects personal information from Children in connection with a School Agreement, so that we can track their progress through our Digital Platform for the use and benefit of Schools, their students, and for no other commercial purpose. We limit the use of personal information about Children to the educational context authorized by the applicable School. To the extent there is any conflict between our general privacy practices listed above and this section titled for "COPPA NOTICE - Information and Direct Notice for Parents/Guardians of Children", this section controls.

Information We Collect about Children

We may receive information about Children from Schools, including:

Full Name
Email address
Student ID assigned by the School
Grade level, subject area, class, teacher name/identifier, school, school district where a child is enrolled

Depending on the applicable agreement with the School and the product or features used, Great Minds may collect information directly from Children, including:

Username and password (unique to our systems)
User-generated content, including text, and other responses to questions, prompts, assignments, suggestions, or other similar content
Data generated from student activity within The Digital Platform, including answers provided, errors, preferences, scores, assessment reports, timing information, progress within the system, and inferences made from this data about student knowledge.
Optional audio recordings to assist educators/teachers in the assessment of language fluency

We use procedures such as contractual restrictions and internal policies and procedures to ensure that any persistent identifiers relating to Children are not used or disclosed in order to contact an individual, to create a profile, or for any other purpose, except as permitted under COPPA to provide support for internal operations of the Digital Platform.

How Does Great Minds Use Information Collected from Children?

We limit the use of personal information about Children to the educational context authorized by the applicable School, and to support the internal operations of the Digital Platform and related services, including the following:

Allow Children to access and use the service as designated by the School, including to set up an account
Help reset passwords and authenticate users
Investigate information security and information asset protection-related incidents
Except where prohibited by applicable law or School Contract, test, correct and improve and further develop our content, features, applications, and services for the benefit of students, other authorized end users, and Schools.
Analyze academic and learning outcomes and preferences
Provide insights and details on class and Children's performance to teachers, authorized users, or Schools
Personalize the teaching and learning resources available across The Digital Platform to improve instruction and meet specific learning and developmental needs
Communicate with and provide reports to parents or legal guardians, teachers or School or school district administrators at the Child, class, School, or district level, or as otherwise directed by the School, based on Child's use of and activities on The Digital Platform, including reminders and other informational messages
Provide technical support and process support tickets submitted by teachers or other authorized end users
Monitor the use of our products and perform such analyses as might be necessary or helpful in improving product performance, efficiency, and security
Enforce our Terms of Service
Use the information as may be required or permitted by legal, regulatory, industry self-regulatory, insurance, audit or security requirements

Great Minds does NOT use any information collected about Children to advertise or market to children or their parents or legal guardians.

When We Disclose Information Collected from Children

To And On Behalf Of Schools

As discussed above, we provide The Digital Platform to Children through agreements with Schools and on behalf of those Schools. Accordingly, Schools (and those who obtain authorized access from the Schools) and may have access to all or some of the information we collect via registration and The Digital Platform from Children associated with that School.

Service Providers

In order to provide and support our products, Great Minds may contract with third parties and share information required to carry out these services via these third parties, called "service providers," or "subprocessors." These service providers provide support services, such as hosting The Digital Platform and operating their features, or performing other administrative services. In such cases, all third parties are required to abide by this policy. Great Minds takes reasonable steps to release personal information collected from Children only to service providers and third parties who are capable of and have agreed to maintain the confidentiality and security of that information and to use that personal information only to provide the applicable service to us or on our behalf. You may view a list of our current service providers/subprocessors here.

Administrative and Legal Reasons

We may disclose personal information about Children to third parties when necessary to protect the security or integrity of The Digital Platform; take precautions against liability; respond to judicial process; or provide information to law enforcement agencies or for an investigation on a matter related to public safety. We may also disclose personal information about Children in connection with a merger or the sale of Great Minds' assets or interest in The Digital Platform, or other similar change in ownership (including, during the course of any due diligence process), provided that any subsequent owner of Children's personal information has agreed to abide by Great Minds' then-current Digital Platform Privacy Policy.

With respect to Children, to the extent there is any collection of information through tracking technologies, it is used only for providing support for internal operations as needed to provide The Digital Platform. You may view a list of current service providers/subprocessors, including our third-party analytics services here.

How Long we Keep Children's Personal Information

All information collected and stored by a School remains subject to that School's privacy practices.

Rights Parents Have about their Children's Information

Parents have the right to review personal information collected about a Child, to request that deletion of personal information collected and retained about a Child User, and to request that the Platform make no further collection of personal information from a Child User. Please contact your Child's School to make any of these requests.

Contact Us

If you are the parent of a Child who uses our Digital Platform through their School and have questions about our privacy practices, please contact us.

Great Minds PBC is the operator of The Digital Platform and any questions regarding this Privacy Policy and the collection or use of personal information should be directed to:

Great Minds PBC
Attention: Privacy
55 M Street SE
Suite 301
Washington, DC 20003

You may also contact Great Minds at 202-223-1854 or privacy@greatminds.org.