This Privacy Statement provides information on how LEAN Frog Digital LLC, doing business as K12 BLOOM, protects student educational records and personal information (referred to collectively as “Customer Data”) provided by our K12 institutional customers (educational institutions) to process their behalf when their staff, parents/guardians, and students use our products, including mobile services. It also outlines how LEAN Frog Digital LLC, dba K12 BLOOM, collects and protects personal information (referred to as “Personal Information”) when you visit our products or websites, including https://www.k12bloom.com, https://www.gotchas.com, https://www.bloombucks.com, and https://leanfrogdigital.com (collectively the “K12 BLOOM Products”).

Our practices are designed to comply with US federal regulations, including the Family Educational Rights and Privacy Act (FERPA) and the Children’s Online Privacy Protection Act (COPPA). How we use the information may differ based on our relationship with you and our contractual obligations to our customers. Below, we’ve detailed the different relationships we may have with you. References to “us,” “we,” “our,” or “K12 BLOOM” in this Privacy Statement refer to LEAN Frog Digital LLC and its affiliates.

1. Customer Data: K12BLOOM receives customer data from its customers and their authorized users (staff, faculty, parents/guardians, and students) and processes that customer data on behalf of the customer as a data processor. The customer strictly controls K12BLOOM’s processing through contractual obligations, including data privacy agreements. The customer restricts and controls user access to these K12BLOOM products and services.

2. Collected Data: In some instances, K12BLOOM collects personal information directly from a user of its publicly accessible websites or online services. For Collected Data, K12BLOOM acts as a data controller, serving both as collector and processor of an individual’s Personal Information. The collection and processing of personal information by any particular K12BLOOM website or service are consented to beforehand and subject to the Terms of Use or Service (TOU or TOS). You should not access or use a particular website or product if you do not agree with the TOU or TOS.

3. Transaction Data: Transaction Data, also known as transaction data or metadata, is created using K12BLOOM products and services. This K12BLOOM proprietary data is normally found in application access and end-user usage monitoring logs, network access logs, web usage tools, communication logs, identity and access management logs, and database management system tables. This K12BLOOM proprietary data can be used to determine the health of the system, in incident investigation, for security information and event management (SIEM), or for troubleshooting a customer-identified issue within a customer’s implementation of a product. K12BLOOM retains control and ownership of the Transactional Data.

K12BLOOM customers are mainly K12 schools and districts. The makeup of Customer Data processed by K12BLOOM can vary by K12BLOOM service and a customer’s product configuration. K12BLOOM provides a full spectrum of education-related services for customers to choose from. These include K-12 education technology products, and administration products. Customers may have one or more of these K12BLOOM products and services. Depending on the product or service, Customers may provide student data, and employee data for K12BLOOM processing. The mix of data provided by each customer may also vary based on how the customer configures the K12BLOOM product or service for Customer Data collection (potential variations are discussed in more detail below). For this reason, it is impossible for K12BLOOM to fully document the data that it will process for each customer until after the customer has fully implemented and configured the K12BLOOM product and service. The configuration may also be dynamic in that the school or district may change its data collection configuration over time. If you have questions about which data is being collected by a customer connected to you, you should direct those questions directly to the K12BLOOM customer that controls your data. The customer’s privacy policy may be another good source of information.

When does a customer’s privacy policy govern?  K12BLOOM’s Privacy Statement does not supersede the terms of any consent form, privacy notice or privacy statement from your school, school district or higher education institution, or stated alternatively, the terms of any agreements between you and your school or school district, or higher education institution (our customers).

Who Owns Student Data Provided to K12BLOOM by Customers for Processing? Student data is synonymous with Customer Data under this Privacy Statement. Accordingly, all Customer Data is owned, and thereby controlled, by our customers (school, school districts or higher education institutions). If required under applicable law, our customers are responsible for obtaining consent for K12BLOOM to process Customer Data. For Customer Data processing under FERPA, the Family Educational Rights and Privacy Act, a United States federal law governing access to educational information and records, the customer designates K12BLOOM as a “school official” with a legitimate educational purpose. Our customers license K12BLOOM Products and purchase certain professional services for the purpose of providing, maintaining, and supporting student data for those legitimate educational purposes. K12BLOOM will only process student data for the purposes of providing access to the K12BLOOM Products and professional services that our customers (school or school districts) have contracted with us to provide, and we will process such student data according to instructions and the terms of our contract and data privacy agreements with our customers. 

Many school districts are also obligated to parents to post information about the data that it collects. It bears mentioning again that K12BLOOM processes the Customer Data under strict contractual obligations and privacy agreements signed with the customer. K12BLOOM does not use or disclose Customer Data except as authorized and required by our customers and as provided for in our agreements with our customers. Because K12BLOOM does not own or control Customer Data, any request for access, review, correction, or deletion of Customer Data must come directly from our customers. With our customer’s consent, K12BLOOM may receive information from affiliates in our K12BLOOM Group of companies, or third parties and combine that information with Customer Data.

Although most K12BLOOM on-line services and products are used by customers for Customer Data collection, K12BLOOM websites and some K12BLOOM products and services collect data directly from users of our website or those products and services. In these situations, K12BLOOM is a “data controller” because K12BLOOM determines the purposes for which and the manner in which personal information is processed. Because K12BLOOM is the collector and controls the configuration of these products and services, K12BLOOM can provide more detail on the data collection. These websites, products and services are further detailed below.

We also collect device and usage information when you access and use the K12BLOOM Products, including information that your browser or the mobile app sends when you are using our products. This data may include your unique device identifier, IP address, your browser type and configuration, the date and time of your use of the product or service and cookie data. Learn more about our use of cookies in our Cookie Statement.

Transaction Data is not Customer Data, nor is it Collected Data. It is a different K12BLOOM category of data. Transaction Data may contain copied elements from Customer Data or Collected Data. For example, the logging of a user session may contain a unique id that identifies the user. The unique id is necessary for monitoring the health and security of K12BLOOM applications.

The monitoring of K12BLOOM systems and applications is a part of our standard business operations to protect Customer Data and Collected Data; comply with laws; be able to provide customer support, and monitor events related to Customer Data or Collected Data. The monitoring of events is essential in preventing data-related incidents and determining if a data-related incident has occurred or is occurring that requires immediate attention by K12BLOOM’s Incident Response Team. System and application events are monitored by the creation of artifacts or metadata about our systems, applications and their use. We call this “Transaction Data”. Transaction Data is vital to our ability to improve our products; trouble shoot customer support questions; analyze the health and performance of our products; and maintain security of Customer Data and Collected data, and privacy investigations. Transaction Data may either contain personal information along with application data that does not directly or indirectly relate to a person; or application data without any personal information at all.

The storage and maintenance of Transaction Data is separate from the storage and maintenance of Customer Data and Collected Data with clear boundaries between the three types of data. In fact, Transaction Data is temporary. This means Transaction Data is permanently deleted on a regular rolling basis over time. This occurs regardless of whether Transaction Data contains any personal information or not. This is an implementation of the data minimization principle. Transaction Data which contains no personal information or Transaction Data containing even one element of personal information are all treated the same. Except for Service Providers acting as data subprocessors supporting our applications who are granted secure access to Transaction Data, K12BLOOM does not share, disclose, sell or transfer such Transaction Data. Additionally, K12BLOOM treats all Transaction Data as K12BLOOM Restricted Information – meaning confidential and secured – and at the same level as Customer Data and Collected Data.

K12BLOOM does work with various data subprocessors to support the operability of our products. In order for these vendors to service us as captured in our agreements with them, they do create metadata within their systems. In these cases, K12BLOOM binds these vendors to privacy requirements to ensure any metadata is properly deleted as required by law.

K12BLOOM respects our customers’ privacy and data security requirements. Transaction Data is one way we fulfill that promise to our customers – educational institutions and individuals. Transaction Data provides us with the ability to service our customers properly.

Whether K12BLOOM is a collector or processor or your data, K12BLOOM is committed to protecting your personal information. K12BLOOM uses commercially reasonable physical, administrative, and technical safeguards to preserve the confidentiality, integrity, and availability of your personal information. As customers provide K12BLOOM with Customer Data to process, K12BLOOM makes commercially reasonable efforts to ensure the security of our systems. Please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, administrative, and technical safeguards.

Regardless of whether the data is Customer Data or Collected Data, both are covered under K12BLOOM’s privacy program. K12BLOOM supports privacy rights and has developed and implemented policies, processes, procedures, and technologies for the collection, processing, use, and protection of your data, whether it is collected by a customer or us.

How is your personal information protected? K12BLOOM employs a variety of physical, administrative, and technological safeguards designed to protect your data against loss, misuse, and unauthorized access or disclosure. We strive to continuously maintain reasonable physical, administrative, and technical security measures. Our security measures consider the type and sensitivity of the data being collected, used, and stored, as well as the current state of technology and threats to data. K12BLOOM also endeavors to align its privacy and security operations to best practices and relevant international regulations.

Under the Family Educational Rights and Privacy Act (FERPA), K12BLOOM acts as a “school official” with “legitimate educational interests” and contractually relies on educational institutions to obtain parental consent, if required.

More generally, K12BLOOM has processes and procedures in place to protect the personal information of children under 13, as detailed below. We do not use such information for any purpose other than to provide our services and for the specific uses set forth below, in accordance with contractual agreements with our customers and our Terms of Service for each K12 Bloom software product.

K12 BLOOM retains information collected on behalf of our customers for as long as necessary to fulfill the purposes for which it was collected, in accordance with applicable US federal regulations, including the Family Educational Rights and Privacy Act (FERPA). Under FERPA, educational records are generally retained as long as required to support the educational institution’s academic and administrative needs, but they must be kept for at least five years after the student’s last date of attendance. For data collected directly by K12 BLOOM, such as through our websites, we retain personal information as long as necessary to provide the services requested and for other essential purposes, such as complying with our legal obligations, resolving disputes, and enforcing our agreements.

Once the retention period has expired, K12 BLOOM securely deletes or anonymizes the data, following industry best practices and legal requirements. We review our data retention policies periodically to ensure compliance with all relevant laws and regulations.

Consent to Collect, Use, or Disclose Personally Identifiable Information from Children Under 13. Children under 13 may only use K12BLOOM’s Products with the prior consent of a parent or educational institution acting on behalf of the child’s parent. We will not collect, use, or disclose any personally identifiable information from children under 13 without such consent. Educational institutions may consent to the collection, use, or disclosure of personally identifiable information from children under 13 by agreeing to purchase our products.

Personal Information from Children Under 13 Provided to K12BLOOM. K12BLOOM products may collect the following categories of personal information from children under 13, with the appropriate consent:

• Information provided via customers or through use of K12BLOOM’s Products, assessment data, conduct or behavior data, demographic data, enrollment data, contact information, course schedule data, online communications, student identifiers (e.g., school ID number), academic or extracurricular program membership, student-generated content, transcript data, college interests, college application list, college scholarships, career interests, and post-secondary planning data; and
• Usage, browser and device information. K12BLOOM does not allow personal information from children under 13 to be made publicly available via its Products. K12BLOOM does not share personal information from children under 13 with third parties unless consented to under our customer agreements or necessary under the law.
• Service providers, partners, and product integrations. Our service providers help us with things like data security, cloud hosting, information technology, customer support, usage and analytics, email delivery, application performance monitoring, and user identity and authentication. In addition, some of our Products may support partnerships and integrations that offer certain features to users, like CommonApp, Gallup, and McGraw-Hill Education, at the election of educational institutions (see further detail in Section IV).
• Administrative and legal reasons. When reasonably necessary to meet and comply with any applicable law, regulation, legal process or enforceable governmental request; enforce applicable Terms of Service, including investigation of potential violations; detect, prevent, or otherwise address fraud, security or technical issues; or protect against harm to the rights, property or safety of K12BLOOM, our users or the public as required or permitted by law.
• Business transitions. In the event that K12BLOOM goes through a business transition such as a merger, acquisition by another company, sale of all or a portion of its assets, bankruptcy, or other corporate change (including during the course of any due diligence process), this personal information may shared or transferred based on consent of our customers.

Our customers, educational institutions, may share personal information of students with educators as needed for educational purposes. K12BLOOM does not control and is not responsible for this type of sharing. If you are a parent and have questions about this, please contact your child’s educational institution.

K12BLOOM does not share personally identifiable information from children under 13 for advertising or marketing purposes.

Parental Rights. For K12BLOOM Products provided to educational institutions, the collection, maintenance, and use of personal information from children under 13 is controlled by the educational institution that contracts with K12BLOOM for use of its Products. If you are a parent and have questions regarding personally identifiable information collected from your child as part of their educational institution’s use of K12BLOOM’s Products, including your rights to review, delete, and refuse further collection of such information from your child, please contact your child’s educational institution. K12BLOOM cannot delete such information unless authorized by your child’s educational institution.

K12 BLOOM is committed to respecting the rights of data subjects, particularly students, parents, and educational staff, in accordance with applicable US federal and state laws. The rights outlined below apply to individuals whose personal data is processed by K12 BLOOM as part of our educational software services.

1. Access to Personal Data. Individuals have the right to request access to the personal data that K12 BLOOM processes on behalf of their educational institution. This includes the right to know what data has been collected, how it is being used, and with whom it has been shared. To exercise this right, data subjects should contact their educational institution, which acts as the data controller. K12 BLOOM will work with the institution to fulfill access requests in compliance with FERPA and other relevant laws.
2. Correction of Inaccurate Data. If any of the personal data processed by K12 BLOOM is inaccurate or incomplete, data subjects have the right to request corrections. These requests should be directed to the educational institution, which will instruct K12 BLOOM on the necessary updates. K12 BLOOM will promptly make the corrections as directed by the institution.
3. Deletion of Personal Data. Data subjects have the right to request the deletion of their personal data under certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected. Deletion requests should be submitted to the educational institution. K12 BLOOM will carry out the deletion as directed, in accordance with the institution’s policies and applicable legal requirements, including FERPA.
4. Consent Withdrawal. For data collected based on consent, individuals (or their parents/guardians in the case of minors) have the right to withdraw their consent at any time. If consent is withdrawn, K12 BLOOM will cease processing the data and, if required, delete it, subject to the educational institution’s instructions and legal obligations.
5. Data Portability. Data subjects may request a copy of their personal data in a commonly used, machine-readable format. This right applies only to data that K12 BLOOM processes on behalf of an educational institution and is subject to the institution’s policies. Requests for data portability should be made through the educational institution.
6. Right to Object or Restrict Processing. In certain situations, data subjects may have the right to object to or request the restriction of the processing of their personal data. Such requests should be directed to the educational institution, which will determine whether the request can be accommodated under applicable laws. K12 BLOOM will comply with the institution’s instructions regarding any restrictions or objections.
7. Handling of Requests. All requests related to data subject rights must be made through the educational institution, which acts as the data controller. K12 BLOOM will cooperate fully with the institution to ensure that requests are handled in a timely and compliant manner. K12 BLOOM does not directly respond to data subject requests without the explicit direction of the educational institution.
8. Compliance with US Laws. K12 BLOOM adheres to US federal and state laws, including FERPA and COPPA, in processing all requests related to data subject rights. We work closely with educational institutions to ensure that all personal data is handled in accordance with legal requirements and best practices.

We keep information collected on behalf of our Customers for as long as necessary to fulfill the purpose for which it was collected, pursuant to contractual terms or as otherwise required by applicable law. We dispose of information that is not held pursuant to contractual terms within a commercially reasonable time period or at the request of a customer using reasonable measures to protect against unauthorized access to or use of information.

To comply with K12BLOOM’s obligations under applicable data protection laws and to our customers, we provide a list of significant third-party suppliers that enable us to provide our products and services and operate our business. These third-party suppliers perform the functions described below and are considered subprocessors under applicable data protection laws (“Subprocessors”). We require our Subprocessors to implement proper security measures to safeguard and to respect the privacy rights attendant to Customer Data and Collected Data. 

Below is a brief privacy-related description of each of our product suites and associated products. Please note that a customer may purchase a license to access one or more products individually or as a suite across our entire product portfolio.

1. K12 BLOOM

   This suite of solutions includes K12 BLOOM Behavior Management, Behavior Intervention (Bloom Bucks), and Student Support Services Module.

   1. Behavior Management

      This application process inputs from teachers, principals, and educational institution administrators to track student behavior data (positive and negative behavior), automate the office referral process, standardize behavior inputs to each educational institution’s individual student code of conduct, standardize consequences and restorative school discipline practices, map educational institution behavior to state requirements, sync behavior into the educational institution’s student information system, and provide data dashboards and reporting.

      To exercise your privacy rights under state, federal, provincial or country privacy legislation related to this application and the Customer Data it processes on behalf of your educational institution, please contact your educational institution. As a data processor for our customers, K12BLOOM will take direction from our customers on exercising those privacy rights. Direction from our customers can be submitted through the K12BLOOM support system. To help protect the security of your Personal Information, K12BLOOM will always work with your educational institution to verify your identity.

   2. Behavior Intervention (Bloom Bucks)

      Behavior Intervention (Bloom Bucks) is an application designed to incentivize positive behavior among students. It allows educational institutions to set behavioral goals, track student progress, and award Bloom Bucks points that students can redeem for various rewards. The system is integrated with the institution’s student information system and provides reporting tools for administrators.

      As with our other products, K12 BLOOM acts as a data processor for Behavior Intervention (Bloom Bucks) and follows the direction of the educational institution regarding data handling and privacy rights. To exercise your privacy rights, please contact your educational institution, which will direct K12 BLOOM on how to proceed. All data processing is performed under strict contractual obligations to ensure the protection of student data.

   3. Social Support Module

      This application processes inputs from teachers and others at the educational institution to automate student social support referrals, manage student support cases, and provide data dashboards and reporting.

      To exercise your privacy rights under state, federal, provincial or country privacy legislation related to this application and the Customer Data it processes on behalf of your educational institution, please contact your educational institution. As a data processor for our customers, K12BLOOM will take direction from our customers on exercising those privacy rights. Direction from our customers can be submitted through the K12BLOOM support system. To help protect the security of your Personal Information, K12BLOOM will always work with

For users of our publicly accessible Websites, we offer details on how K12BLOOM collects and uses information from or about you. In this relationship, K12BLOOM acts as a data collector (controller). This is because we collect aggregated information about your browser until and if you consent to provide us personal information about you when you wish to engage with K12BLOOM directly to receive information about our webinars, white papers and product information.

Information You Provide: You may voluntarily provide us information when you complete a form or survey on our Websites or subscribe to our blogs or newsletters. This may include some or all the following categories of information: name and role; job title; signature; profession; social media account name; username; telephone number; street address; and email address. You may also provide information when you register for an account through a Website to log in to a K12BLOOM Product, or submit a resume or other information through the Careers link.

From the moment you first interact with one of our Websites, we may collect personal information. Sometimes we collect personal information automatically when you interact with our Websites and sometimes we collect the personal information directly from you. At times, we may collect personal information about you from other sources and third parties, even before our first direct interaction.

Note that if you use a K12BLOOM application website to access a service or product, you may need to log in to make use of the functionality of the product.

Our Websites may offer publicly accessible community forums. You should be aware that any information you provide in these areas is public and may be read, collected, and used by others who access them and may remain on the public forum indefinitely. To request removal of your personal information from our community forums, please contact [email protected]. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. We encourage all users to exercise caution when providing personal information in community forums. If you provide information when you communicate through our K12BLOOM community forums, we may link this information with your personal information.

Information We Collect Automatically. We collect information about the pages your device’s browser visits and how your browser accesses and uses the Websites using cookies, tracking technologies and other third-party analytics tools. Specifically, we and our service providers use cookies and similar technologies such as local storage (HTML5), web beacons, JavaScript, and eTags on our Websites. This includes information about the devices you use to access the Websites including, but not limited to, unique device identifiers, IP address, operating system, browser, and cookies. Depending on your device settings, we may also collect information about your approximate geographical location. You can learn about our use of cookies, and set your preferences, in our Cookie Statement.

Information We Receive From Third Parties. K12BLOOM works with third-party ad publishers to re-publish K12BLOOM content on paid media platforms. We may receive personal information about users from these publishers, which we may use to provide user-requested information or to contact users regarding K12BLOOM Products. We may also supplement the information we collect from you with information from the K12BLOOM Group affiliates and other third parties that we use to promote the K12BLOOM Products. For example, we may receive information from a third party about how well an online marketing or email campaign performed, or from conference and trade show organizers.

How We Use Your Information

In addition to the uses described above, we may collect and use your personal information for the following purposes:

1. Product Improvements, Analytics and Requested Communications. We may use your information collected to provide and improve our Websites and K12BLOOM Products by using third-party analytics tools to help us understand how our Websites are used, analyze usage information for sales and marketing purposes, and to communicate with you in any manner that you have requested. We also use the information collected to communicate with you in any manner that you have requested.
2. Marketing. We conduct marketing to promote the K12BLOOM Products, but do not use or disclose student information (whether personal information or otherwise) provided by customers into our platforms for targeting of advertisements to students. When we conduct (or sponsor) events, conferences, and webinars, we will collect information about attendees, such as the session they attend and their contact information to provide them information about K12BLOOM Products and other K12BLOOM information. Marketing Preferences and Opt-Out Our marketing emails include an “unsubscribe” link so that you can change your preferences and opt-out of receiving marketing emails or communications from K12BLOOM. You can also send us email at [email protected] to unsubscribe. Please note that even if you opt-out of marketing emails, we may still need to contact you with important information about your K12BLOOM account.
3. Interest-based Advertising. We use third party advertising tools to collect information about your device browser’s visits to the Websites to provide targeted advertisements to you based on your browsing history on other websites or on other devices you may use. If you would prefer to not receive personalized ads based on your browser or device usage, you may generally express your opt-out preference to no longer receive tailored advertisements. Please note that you will continue to receive advertisements, but they will no longer be tailored to your interests.

Please note that we do not use student data for targeted advertising purposes, for example, by inhibiting these third-party advertising networks from collecting information for targeted advertising purposes when a student logs into the service through their student account. We do not provide any student data to any third parties for marketing purposes not related to legitimate educational interests.

To learn more or opt-out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit: 

• Digital Advertising Alliance (DAA)’s self-regulatory opt-out page (http://optout.aboutads.info/) and mobile application-based “AppChoices” download page (https://youradchoices.com/appchoices). 
• European Interactive Digital Advertising Alliance (EDAA)’s consumer opt-out page (http://youronlinechoices.eu), if you’re located in the EU 
• Network Advertising Initiative (NAI)’s self-regulatory opt-out page (http://optout.networkadvertising.org/). 

K12 BLOOM is committed to safeguarding the personal and educational data we process. We only share data with third parties in ways that comply with US laws, including the Family Educational Rights and Privacy Act (FERPA) and the Children’s Online Privacy Protection Act (COPPA). Below, we detail the circumstances under which we may share data and the strict controls we have in place to protect it.

1. Service Providers. We engage certain trusted service providers to perform functions and provide services that are essential to our operations and the delivery of our products. These providers may include cloud storage services, data analytics services, customer support services, and IT infrastructure services. All service providers are contractually bound to protect the confidentiality and security of data and are prohibited from using it for any purpose other than the services they are providing to us. They must comply with our privacy and security requirements, as well as any applicable US federal and state laws, including FERPA and COPPA.
2. Educational Partners.  With the explicit permission of our educational institution customers, K12 BLOOM may share data with selected educational partners to enhance the functionality of our products or to integrate with additional educational tools and platforms. Such sharing is done solely for legitimate educational purposes, and any partner accessing data is required to adhere to strict data protection and privacy standards.
3. Other Types of Disclosures. K12 BLOOM may disclose data when legally required to do so, such as in response to court orders, subpoenas, or other legal processes, or when necessary to comply with applicable laws. We may also disclose data to protect the rights, property, or safety of K12 BLOOM, our users, or the public, including enforcing our Terms of Service or investigating potential violations.
4. Data Aggregation and Anonymization. K12 BLOOM may use aggregated, de-identified, or anonymized data for internal purposes, such as improving our products or conducting research and analysis. Such data cannot be linked back to any individual and does not include any personally identifiable information. K12 BLOOM does not sell, rent, or otherwise provide access to student personal information for marketing or advertising purposes.
5. Business Transfers. In the event of a merger, acquisition, reorganization, or sale of all or a portion of our assets, K12 BLOOM reserves the right to transfer or assign the data we have collected, subject to the applicable privacy laws. In any such event, we will ensure that the new entity adheres to the same stringent data protection and privacy standards as K12 BLOOM.

K12 BLOOM takes the privacy of children under 13 very seriously and complies with the Children’s Online Privacy Protection Act (COPPA). Our products are only deployed in school districts that have their own consent agreements in place for students and parents, ensuring that the collection and use of student data are fully authorized.

1. Consent Requirements. For products that are directly used by students, K12 BLOOM systems utilize student birthdates to determine if a student is under 13 years of age. Access to the system is automatically denied unless a valid consent form is on file. This consent can either be provided by the school district, as part of their COPPA compliance procedures, or directly through our system, where parents or guardians are prompted to provide consent before any access is granted. This consent status is clearly noted within the system prior to allowing access to ensure compliance with COPPA.
2. Data Collection and Use. For students under 13, once consent is obtained, K12 BLOOM may collect personal information such as assessment data, behavior data, and other educational records necessary to provide our services. This data is only used for educational purposes as defined by the consent agreement and is protected under the same rigorous security measures we apply to all personal information.
3. Parental Rights. Parents or guardians have the right to review, correct, or request the deletion of their child’s personal information collected through K12 BLOOM products. Requests can be made directly through the educational institution or via our system where consent was originally provided. K12 BLOOM does not share, sell, or use student information for any marketing or advertising purposes.
4. Access Denial. If no consent form is on file, access to the product is denied to students under 13 years of age. This ensures that K12 BLOOM adheres strictly to COPPA requirements and protects the privacy of young users.Products. 

California law requires us to disclose the following information with respect to our privacy practices. If you are a California resident, this section applies to you in addition to the rest of the Privacy Statement.

Categories of Personal Information K12BLOOM Collects and Purposes for Collection and Use

The types of personal information we collect depends on which K12BLOOM Product(s) and/or Websites you utilize but can include:

• Basic identifying information (e.g., name, address, email, phone number)
• Demographic data (e.g., age, date of birth, gender)
• Device information and other unique identifiers (e.g., device ID, IP address, cookies)
• Network activity
• User-generated content, including student-generated content

Depending on the K12BLOOM Product(s) and/or Websites you utilize, we may collect personal information through the following means:

• Directly from you (e.g., upon creating an account)
• Automated data collection technologies (e.g., cookies, pixels)
• Other sources (e.g., data analytics providers)

K12BLOOM collects and uses personal information for various purposes, including the following:

• Administration of K12BLOOM Products
• Improvement of K12BLOOM Products
• Communications with you
• Legal obligations
• Security, fraud prevention, and troubleshooting

K12BLOOM does not share personal information with third parties unless necessary for the above-listed purposes. K12BLOOM may disclose personal information to the following categories of third parties:

• Service providers and partners. Our service providers help us provide services to our customers via our K12BLOOM Products. These service providers support activities such as data security, cloud hosting, information technology, customer support, usage and analytics, email delivery, application performance monitoring, error and crash reporting, and user identity and authentication. In addition, we engage in product partnerships and integrations that offer certain features to users as requested by our customers. Under data privacy agreements, these third parties may require access to your personal information.
• Administrative and legal reasons. We may share personal information with third parties based on a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable law, regulation, legal process or enforceable governmental request; enforce applicable Terms of Service, including investigation of potential violations; detect, prevent, or otherwise address fraud, security or technical issues; or protect against harm to the rights, property or safety of K12BLOOM, our users or the public as required or permitted by law.

Exercising California Privacy Rights

Subject to certain limitations, including that K12BLOOM cannot delete Customer Data where it is acting as a data processor under legal agreements with the data controller (our customers), California residents have the right to request access to the categories and specific pieces of personal information we collect, use, and disclose; the right to request deletion of their personal information; and the right to opt out of any sales of personal information that may be occurring. These rights may be exercised via our K12BLOOM Products or by contacting your respective educational institutions who are licensed to the applicable K12BLOOM Product(s).

Access to Data and Deletion Requests

For Collected Data where K12BLOOM is not acting as a data processor, but collects personal information directly from a user, you may submit a request for a copy of the information collected about you in the last 12-months, or request deletion of information, by contacting us at [email protected].

Our Websites may provide links to third-party websites or resources. The information practices of those websites are not covered by this Privacy Statement or any other policies or terms applicable to the K12BLOOM Products or Websites. We recommend that you review the terms of use and privacy policies of any linked third-party website before providing any personal information.

In the event that K12BLOOM is acquired by or merged with a third-party entity, we reserve the right, in any of these circumstances, to transfer or assign the personal information our Customers have provided to us from our Users as part of such merger, acquisition, sale, or other change of control to the new data processor. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your personal information is treated, transferred, or used. Nevertheless, in such a circumstance, K12BLOOM would request that all applicable data privacy standards no less stringent than our own shield the personal information already in our possession. In the event that information is shared in any manner, notice will be posted on our site.

We may update this Privacy Statement and its last updated date to reflect changes to our data governance practices. If we propose to make any material changes, we will notify you by means of a notice on our public facing webpage page prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. 

If you have any questions or concerns about your privacy or this Privacy Statement, please Contact us at [email protected].

You may also write to us at:

LEAN Frog Digital, LLC dba K12BLOOM
4920 Corporate Drive NW, Suite B Huntsville, Alabama 35805
ATTN: Privacy