1. What is Comet Academy
Comet Academy helps students learn more effectively through engaging practice and real-time feedback. Comet Academy serves grades 9 through 12 and focuses on AP courses.
2. Forward and definitions
At Comet Academy, Inc. (“us,” “we,” or “comet academy”), we take the security and privacy of user data extremely seriously. We are committed to complying with the student data privacy laws that apply to your use of the Platform and helping our customers comply with FERPA, COPPA, and other regulatory requirements. Read more below and in our Terms of Use.
We use the term “User Information” in this policy to refer to information that personally identifies a user of Comet Academy Platform and other information we receive or create in the course of a User’s usage of the Platform about a User that is linked to information that personally identifies a User.
3. Data we collect
When you register for, and use the Platform, you may provide us with three types of User Information:
Personal data
For the general purposes of authentication and roster management, we collect information that is used to identify individual Users (the “Personal Data”). Personal Data does not include Data that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person.
The Personal Data that we collect from Users includes:
- email address
As a general matter, we do not request nor collect any of the following information from Users:
- first name and last name
- age
- school identification code
- physical address
- telephone number
- photograph or physical likeness
- date or place of birth
- social security number
- dates of attendance in school
- grade level
- grades or test scores
- disciplinary records
- medical or health records
We collect Personal Data in different ways. For example, we collect Personal Data when Users register for an Comet Academy account and when a User responds to Comet Academy emails or surveys. We also receive Personal Data from other sources (“Integrated Services”), such as identity verification services, like Google and Facebook, contingent on Users granting such Integrated Services to share Personal Data with us.
You have the right to decline to share certain elements of Personal Data that we ask you to provide, but must note that doing so may limit your use of certain features and functionality of the Platform. You may edit account information and submissions at any time by accessing your account through the Platform.
Device data
Like most web-based services, we (or our service providers) may automatically receive and log information on our server logs from your browser or your device when you use our website (“Device Data”). For example, this could include cookies, your web browser type, your IP address, and your device’s operating system, among others. If you use Comet Academy on different devices, we may link the information we collect from those different devices to help us provide a consistent service across your different devices.
We take measures to ensure that our cookies do not collect personally identifiable or sensitive information. The aggregate information we collect is analyzed and may be combined with similar aggregate information of other users.
Usage data
User interactions with our Platform generate data we refer to as “Usage Data”. Usage Data for Student Users may include, for example, the lessons a student chooses to complete and how they performed on those lessons, when a student starts and stops a lesson, and student responses in the lesson.
4. How we use data
Personal data
We and our third-party software vendors (“Service Providers”) use Personal Data to: (i) provide the Platform, ii) comply with applicable laws, and (iii) promote our products, systems, and tools. Examples of how we may use Personal Data include:
- To authenticate a user’s identity;
- To customize the features that we make available to you;
- To respond to inquiries, send service notices and provide customer support;
- To communicate regarding a payment, and provide related customer service;
- For regulatory purposes and compliance with industry standards;
- To send communications about new features and products;
We do not use Personal Data for maintenance, testing, or improvement of the Platform.
Device data
We use cookies in order to permit you to remain logged in as a User for the duration of your sessions. We use other Device Data to improve the product, deliver a consistent and enjoyable experience, debug, provide customer support, and for aggregate analysis.
Usage data
We use Usage Data to test and improve our product. We also use aggregate Usage Data to develop new products, improve or modify our Platform, conduct aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of, our business.
5. How we share data
We do not disclose, share, rent, or sell any User Information to any third parties for commercial uses, such as targeted advertising.
6. Security
All User Information is securely encrypted within our database, which has daily backups and is protected by SSH (Secure Shell) and a firewall. All actions that involve the digital transmission of User Information are handled by a 256-bit SSL (Secure Sockets Layer) encryption.
7. Data ownership and control
Any and all student data provided to Comet Academy, or to which Comet Academy has been granted access, are and shall remain the sole property of the educational agency that provided or granted access to such records.
10. Data breaches
Within 48 hours of learning about a data breach, or longer reasonable time as may be required by the legitimate needs of applicable law enforcement or as to take measures necessary to determine the scope of the breach and restore reasonable integrity of its systems, we will notify all Users and district administrators whose information may have been improperly disclosed, via email communication to the email address on file for each User. This email notification will describe the nature of the data breach, the date of the breach, the types of information that were subject to the breach, and steps that are being taken to protect their Comet Academy accounts going forward.
11. Notice of changes
If we are going to make any changes to this Privacy Policy that would change our practices around what data we collect, how we collect that data, or that would lessen the previously noted protections around student data privacy in a material way, we will notify all users at least 30 calendar days in advance of making such a change. We will provide notification via the emails associated with the profiles of our users.
12. Contacting us
If you have any questions or comments about this Privacy Policy, please contact us via [email protected]