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COPPA Privacy Policy

Children’s Online Privacy Protection Act

Last Modified January 23, 2024

Graduation Alliance, Inc (“Graduation Alliance,” “we,” or “us”) values the privacy of children and of all of its users. This COPPA Privacy Policy (“COPPA Policy”) is designed to comply with the Children’s Online Privacy Protection Act (“COPPA”) and contains important information about how we collect, use, share, and protect the personal information we collect from children under thirteen years old that we may gather from the technology, software, systems, and websites that support our operations (collectively referred to as the “Site”) or that is provided to us by you or third parties.

Who Will Collect Information About Children?

Graduation Alliance collects personal information made available to Graduation Alliance by contracting educational agencies and institutions, such as student names, student identification numbers, e-mail addresses, GPA, grades, courses taken, standardized test scores, and related information.

Graduation Alliance operates in compliance with federal and state school privacy laws, including The Family Educational Rights and Privacy Act of 1974 (20 U.S.C. § 1232g; 34 CFR Part 99) (“FERPA”). FERPA is a federal law that protects the privacy of student educational records, and applies to all schools receiving federal funding. With certain exceptions, this law prohibits schools from releasing personal information of students under the age of 18 without parental consent. By designating Graduation Alliance as a “school official” and/or a designated contractor with a “legitimate educational interest,” educational agencies and institutions are permitted to share personal information with Graduation Alliance without express, parental consent under the exception provided by 34 CFR § 99.31(a)(1). You may find out more information about FERPA at http://www.ed.gov/policy/gen/guid/fpco/ferpa/index.html.

The classification as a “school official,” or as a contracted company with a “legitimate educational interest” is described by the Family Policy Compliance Office (“FPCO”). The FPCO’s FERPA policy and advisory materials on this issue can be found at https://www2.ed.gov/policy/gen/guid/fpco/ferpa/index.html.

Graduation Alliance will handle children’s personal information as described in this COPPA Policy. Any personal information we collect about other users (e.g., teens and adults) will be treated in accordance with the Graduation Alliance Privacy Policy (“Privacy Policy”). The use of our Site and any dispute over privacy, is subject to this COPPA Policy, the Privacy Policy, and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. Our Terms of Service and Privacy Policy are incorporated by reference into this COPPA Policy. Graduation Alliance operates the Site and Services and will collect children’s personal information as described in this COPPA Policy and our Privacy Policy. We can be contacted at:

10 W Broadway 7th Floor Salt Lake City, UT 84101 privacy@graduationalliance.com

Even if Graduation Alliance works in conjunction with an outside partner, the partner will not receive any individual personal information from users of the Site, including children. Graduation Alliance may provide partners with aggregate or de-identified information about users.

Your Personal Information

Graduation Alliance may use your personal information to:

  • Contact you about your or your children’s participation in a Graduation Alliance program and for other customer service purposes;
  • Provide you with resources, products, and services, including but not limited to support services related to your use of the Site, that you request from us;
  • Provide you with information about new products and services available through Graduation Alliance and resources and support services related to your use of the Site, if you choose to receive such information. If you have opted in to receive such information, you can request to opt out of receiving this information in the future by making a request in writing to privacy@graduationalliance.com;
  • Automatically fill out certain forms and surveys upon your instructions to do so;
  • Help diagnose problems with and administer our Site;
  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us; and
  • Comply with applicable legal requirements and industry standards.


We may aggregate your information with the information of other users for our own internal statistical, design, and/or operational purposes, such as to estimate our audience size, measure aggregate traffic patterns, and understand demographic, customer interest, and other trends among our guests and customers.This aggregate information generally will not personally identify you or be correlated to you individually for external purposes.

We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

What Information Do We Collect About Children and Why?

As described in further detail below, we collect some personal information from children so that we can track their progress through our programs. Data is retained for education purposes only.

How Information is Collected?

We may collect information about children directly from children, through our contracted educational agencies and institutions, as well as automatically through a child’s use of our Site and Services. We will not require a child to disclose more information than is reasonably necessary.

Student Records

Graduation Alliance only receives personal information about your children as set forth in the “Student Records” section above and/or directly from you when you enroll your children into a Graduation Alliance program. If your children are enrolled in a Graduation Alliance program, we will collect, use, and maintain personal information about your children solely (i) to provide Graduation Alliance programs to them and for other authorized educational purposes, and/or (ii) as otherwise authorized by you.

You can review certain personal information that Graduation Alliance has regarding your children by making such a request in writing to privacy@graduationalliance.com. Please be aware that some personal information relating to your children’s educational records may not be able to be disclosed by Graduation Alliance due to state and/or federal law. You can request that your children’s personal information not be used by Graduation Alliance and contractors and service providers acting on behalf of Graduation Alliance by making a request in writing to privacy@graduationalliance.com. Please be aware that if you make such a request, your children can no longer continue to be enrolled in a Graduation Alliance program or to use most features on our Site. Therefore, a request by you for Graduation Alliance and our contractors and service providers to no longer use your children’s personal information will terminate your children’s participation in the Graduation Alliance program in which they are enrolled.

Non-Personal and Aggregated Information Collected Automatically

Each time you visit our Site, we log non-personal information that your browser automatically transmits to us. We may also use third-party website analytics tools (such as Google Analytics) that collect information about user interactions with the Site.Such information may include your IP address, operating system and browser type, domain name, the name of the Web page from which you entered our website, which pages you visit on our website, and how much time you spend on each page. We use this information to monitor and improve our website and for internal analysis. In particular, we use IP addresses to analyze trends, administer the Site, and gather information for aggregate use. However, IP addresses are not linked to personal information.

Use of Cookies

Our Site may use “cookies” to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you. We use cookies to keep track of how you are using our Site and to tailor our content to your interests. Graduation Alliance cookies do not contain any personal information about students enrolled in Graduation Alliance’s educational programs. We will not share or sell non-aggregated information contained within cookies to any third party. The cookies we use are erased when you log off the Site or completely close your browser.

How We Use Children’s Information

We use personal information collected from children for the following purposes:


  • To provide our Services; and
  • To respond to customer service and technical support issues and requests.


How We Share Children’s Information

We do not sell children’s personal information, and a child may not make his or her personal information public through our services. In general, we may disclose the personal information that we collect about children to provide our Services, to comply with the law, and to protect Graduation Alliance and other users of our Services. For example, we may share children’s personal information as follows:

  • Service Providers. We may disclose the information we collect from children to third-party vendors, service providers, contractors, or agents who perform functions on our behalf.
  • Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the personal information we have collected from our users to the other company.
  • In Response to Legal Process. We also may disclose the personal information we collect in order to comply with the law, a judicial proceeding, court order, subpoena, or other legal process.
  • To Protect Us and Others. We also may disclose the personal information we collect where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service, Privacy Policy, or this COPPA Policy, or as evidence in litigation in which Graduation Alliance is involved.
  • With Parents. Parents may request information about the information we have collected from their child by contacting us at privacy@graduationalliance.com.
  • Aggregate and De-Identified Information. We may also use and share aggregate or de-identified information about users with third parties for marketing, research, or similar purposes.


Your Rights to Review, Delete, and Control Our Use of Children’s Personal Information

Parents have a right to review the information we have collected about their children and students, respectively, and to delete it, and to tell us to stop using it. To exercise these rights, you may contact us at privacy@graduationalliance.com. You will be required to authenticate yourself as the child’s parent to receive information about that child.

Changes to This COPPA Policy

This COPPA Policy is current as of the Effective Date set forth above. We may change this COPPA Policy from time to time, so please be sure to check back periodically. We will post any changes to this COPPA Policy on our Site, at Graduation Alliance.com.
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