STAGING ENVIRONMENT

Journey Tracker — Privacy Policy

Journey Tracker ("the Platform") is operated by Acton Academy. This policy explains how we collect, use, and protect personal information through the Platform, accessible at journey.actonacademy.org.

Acton Academy operates the Platform and is responsible for its data practices as described in this policy. Campuses are independently responsible for their own student enrollment and authorization and data privacy practices in accordance with applicable law. Acton Academy provides this policy and related notices to support Campus operations and to enable parents to understand and exercise their rights.

1. Information We Collect

We collect the following categories of personal information necessary to operate an educational progress-tracking platform:

  • Account information — Name, email address, date of birth, and other identifiers provided at enrollment
  • Educational content — Work products, submissions, and other content created or submitted by students and guides through the Platform
  • Usage data — Session activity, login records, and technical data used for platform operations and security

When you visit the Platform, we also collect technical and usage information that does not identify you personally, including information about your Internet service provider, the date and time you access the Platform, the internet address of websites from which you linked to our Platform, the type of device, browser and operating system you are using, and your movements and preferences on our Platform.

2. How We Use Information

We use collected information solely to operate the Platform and provide its educational features, authenticate users, maintain security, and comply with applicable legal obligations. We do not sell personal information, use it for targeted advertising, or use it for non-educational commercial purposes.

3. AI Processing

The Platform uses third-party AI service providers to deliver certain educational features. Student educational content may be transmitted to these providers solely to provide educational feedback and functionality.

  • AI providers act solely as service providers on our behalf and may not use student data for model training, advertising, profiling, or independent product development
  • All AI providers operate under written contract with appropriate data use restrictions
  • Data is transmitted over encrypted connections

4. Children Under 13 (COPPA)

Where the Platform is used by children under 13, Acton Academy collects and uses personal information solely for school-authorized educational purposes and not for advertising or non-educational commercial purposes. We collect date of birth to identify children under 13 and apply appropriate data handling practices. Campuses are responsible for their own student enrollment processes in accordance with applicable law. Acton Academy provides the notices and privacy information reasonably necessary for Campuses to evaluate and authorize use of the Platform for school-authorized educational purposes and for parents to understand and exercise their rights.

5. Parental Rights

Parents or legal guardians of children under 13 may exercise the following rights by contacting their Campus:

  • Review their child's personal information
  • Request corrections to their child's personal information
  • Request deletion of their child's personal information
  • Refuse further collection or use of their child's personal information

Parents may also contact Acton Academy directly at privacy@actonacademy.org for assistance. We may coordinate with the Campus as needed to verify authority and process requests.

We will respond to all requests within 30 days.

6. State Privacy Rights

Depending on your state of residence, including California, Colorado, Connecticut, Florida, Oregon, Texas, Utah, and Virginia, you may be entitled to the following privacy rights:

  • The right to know/access — You may have the right to request access to or know the specific pieces of personal information we have about you, the categories of personal information we have collected, the categories of sources from which that information was collected, and the purposes for collecting your personal information.

Acton Academy has collected the categories of personal information detailed in the section titled “Information We Collect” above.

Acton Academy has disclosed the categories of personal information detailed in the section titled “Data Sharing” below.

  • The right to correction — You may have the right to request that we correct the personal information that we have collected or maintain about you.
  • The right to data portability — You may have the right to request your personal information in a format that is portable and usable.
  • The right to deletion — You may have the right to request that we delete the personal information that we have collected or maintain about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your personal information was collected. If we deny your request for deletion, we will let you know the reason why.
  • The right to restrict or opt out of the sharing or sale of your personal information — You may have the right to restrict or opt out of the sharing or sale of your personal information. We do not sell data or share it for advertising or marketing purposes.
  • The right to equal service — If you choose to exercise any of these rights, we will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of the Platform.

You may request your right to know and your right to deletion free of charge up to two (2) times in any twelve (12) month period. We may require verification of your identity before further processing your request. In certain instances, we may be permitted by law to decline some or all of such request.

To exercise the rights described above, please contact us as follows:

Email: privacy@actonacademy.com (please use “Consumer Privacy” in the subject line)

Phone: [PHONE NUMBER]

Mail: PO Box 200282, Austin, TX 78720, USA

We may require verification of your identity before further processing your request. In certain instances, we may be permitted by law to decline some or all of such request.

7. For Residents of the EU, Switzerland, and the UK

The legal bases for our processing of personal information about you are as follows:

  • Contract — When you use the Platform, we collect personal information that is necessary for providing educational services to you.
  • Consent — We obtain consent to collect personal information for distinct purposes. You have the right to withdraw your consent at any time.
  • Legitimate Interest — We have a legitimate interest to collect personal information for certain purposes such as data analytics and the protection and administration of the Platform so that we can understand user preferences and improve the Platform, protect the Platform from information security threats, communicate administrative changes, and comply with laws that apply to us.

You have the following rights with respect to the personal information we hold about you:

  • Right of Access — The right to know what personal information we hold about you and ask for copies of that information.
  • Right of Correction — The right to have incomplete, incorrect, outdated, or unnecessary personal information corrected, deleted, or updated.
  • Right to Restriction of Processing — The right to request that we restrict the processing of personal information we hold about you in certain circumstances.
  • Right to Object — The right to object to the processing of personal information we hold about you.
  • Right of Erasure — The right to ask us to erase your personal information in certain circumstances.
  • Right to Data Portability — The right to ask that we transfer personal information you have given us to another organization, or to you, in certain circumstances, and/or the right to receive any personal information we hold about you in a structured and commonly used machine-readable format.

We do not engage in automated decision-making. Depending on where you live, you may have a right to withdraw consent and lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning personal information about you. We encourage you to first reach out to us at privacy@actonacademy.org so we have an opportunity to address your concerns directly before you do so.

To exercise any of the rights described above, please contact us at privacy@actonacademy.org. We seek to promptly respond to your inquiry.

8. Third-Party Websites

This Privacy Policy does not govern, and we are not responsible for, the privacy, information security, or other practices of any third parties, including any third party operating any site or service to which the Platform links. The inclusion of a link on the Platform does not imply our endorsement of the linked site or service.

9. Data Sharing

We may disclose personal information to the following categories of service providers, solely to operate and support the Platform for educational purposes:

  • Cloud hosting providers — to store and serve Platform data
  • Authentication and session management providers — to manage user access
  • Infrastructure security and monitoring providers — to protect and maintain Platform integrity
  • Customer support and email delivery providers — to communicate with users
  • AI processing providers — to deliver educational feedback features

All providers operate under written contractual restrictions and may only process data for the specific purposes for which they are engaged. We do not sell data or share it for advertising or marketing purposes.

We have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer:

  • Account information — Name, email address, date of birth, and other identifiers provided at enrollment
  • Educational content — Work products, submissions, and other content created or submitted by students and guides through the Platform
  • Usage data — Session activity, login records, and technical data used for platform operations and security

10. Data Security and Retention

We maintain a written information security program with reasonable administrative, technical, and physical safeguards, and we require service providers handling personal information to maintain equivalent protections. We restrict access to personal information to only those employees who need to know that information to provide services. While our security measures are intended to protect personal information, the complete security of any transmission over the public internet cannot be guaranteed.

Student educational records are retained only as long as reasonably necessary to preserve learner access to educational history, support active educational use of the Platform, and satisfy applicable legal obligations. Records are deleted upon verified request from an authorized parent, guardian, or Campus Owner, or when Acton Academy determines they are no longer necessary for the learner's educational access. Deletion requests are processed within a reasonable period except where retention is required by law.

11. Changes to This Policy

We may update this policy from time to time. Material changes will be posted on the Platform. Changes that expand the collection or use of children's personal information will require new authorization where required by law.

12. Contact

Acton Academy — Privacy
Email: privacy@actonacademy.org
PO Box 200282, Austin, TX 78720, USA