Student Data Privacy

Student Data Privacy Addendum

Effective Date: April 13, 2026

This Student Data Privacy Addendum supplements The Critical Thinking Child, LLC’s (“CTC”) general Privacy Policy and applies specifically when The Critical Thinking Child, LLC provides services to school districts, schools, and educational institutions (“Educational Partners”).

Scope

When CTC works with Educational Partners, CTC may receive, process, or store student data belonging to K–12 students, including students under the age of 13, solely for the purpose of delivering educational services under a contract with the Educational Partner. In this capacity, CTC acts as a “school official” with a legitimate educational interest under the Family Educational Rights and Privacy Act (FERPA) and as an “operator” under applicable state student online personal protection laws, including the Illinois Student Online Personal Protection Act (SOPPA).

Compliance

The Critical Thinking Child, LLC complies with all applicable federal, state, and local student data privacy laws in the jurisdictions where CTC provides services, including but not limited to:

  • FERPA — the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g)
  • COPPA — the Children’s Online Privacy Protection Act (15 U.S.C. § 6501) when applicable
  • PPRA — the Protection of Pupil Rights Amendment (20 U.S.C. § 1232h)
  • State student online privacy and pupil record laws, including the Illinois Student Online Personal Protection Act (SOPPA, 105 ILCS 85/), the California Student Online Personal Information Protection Act (SOPIPA) and Cal. Educ. Code § 49073.1, the New York Education Law § 2-d and its implementing regulations, and similar laws in Colorado, Connecticut, Virginia, Utah, Idaho, the District of Columbia, and other jurisdictions in which CTC operates

CTC’s compliance obligations are fulfilled under the terms of each individual contract with an Educational Partner, and the specific requirements of each state’s law apply when CTC serves students in that state.

Student Data We Collect

When delivering services under an Educational Partner contract, CTC may collect the following student data: name, grade level, school, classroom, teacher, username, password, language, student-generated content (including practice responses and assessment answers), student grades, student test scores, and IP addresses. CTC does not collect student date of birth, gender, race, or ethnicity except where expressly required by the Educational Partner’s contract and authorized in writing.

How Student Data Is Used

Student data is used only for the purpose of providing the educational services described in the contract with the Educational Partner. Specifically, student data is used to deliver personalized learning content, track student progress, generate reports for authorized school personnel, match students with appropriate curriculum, and administer assessments.

What The Critical Thinking Child, LLC Will Never Do With Student Data

CTC will never:

  • Sell, rent, or lease student data
  • Use student data for targeted advertising or marketing
  • Use student data to build personal profiles of students for non-educational purposes
  • Use student data to train, fine-tune, or improve artificial intelligence models
  • Disclose student data to any third party except as authorized by the Educational Partner or required by law

The marketing, advertising, and third-party commission provisions contained in CTC’s general Privacy Policy do not apply to student data collected under an Educational Partner contract.

Third-Party Platforms

The Critical Thinking Child, LLC uses licensed third-party educational platforms to deliver services to students. The specific platforms used under any given Educational Partner contract are disclosed directly to that Educational Partner through the applicable vendor agreement and data sharing documentation. CTC selects platforms that comply with applicable student data privacy laws, including FERPA, SOPPA, and COPPA where applicable.

Parent and Guardian Rights

Parents and legal guardians of students whose data is processed by The Critical Thinking Child, LLC under an Educational Partner contract have the right to:

  • Review the student data CTC holds about their child
  • Request correction of inaccurate student data
  • Request deletion of student data (subject to the terms of the Educational Partner contract)
  • Receive notice of any data breach involving their child’s student data

To exercise these rights, contact the Educational Partner (typically the school district) directly, or contact The Critical Thinking Child, LLC at the email below.

For jurisdictions requiring a Parent’s Bill of Rights (including New York Education Law § 2-d), CTC will provide a jurisdiction-specific Parent’s Bill of Rights upon request from the Educational Partner or parent.

Data Retention and Deletion

CTC retains student data only for as long as necessary to provide services under the Educational Partner contract, or as required by the contract, whichever is shorter. Upon contract termination, student data will be deleted or returned to the Educational Partner as specified in the contract.

Data Security

The Critical Thinking Child, LLC and its third-party platforms use commercially reasonable security measures to protect student data, including encryption in transit and at rest, access controls, and regular security reviews.

Contact

For questions about this Student Data Privacy Addendum, or to exercise any of the rights described above, please contact:

The Critical Thinking Child, LLC

P.O. Box 199323

Chicago, IL 60619

Email: info@criticalthinkingchild.com

Relationship to General Privacy Policy

This Student Data Privacy Addendum takes precedence over The Critical Thinking Child, LLC’s general Privacy Policy with respect to student data collected under an Educational Partner contract. All other provisions of the general Privacy Policy remain in effect for non-student users, website visitors, newsletter subscribers, and retail customers.v