NEUROLUTION CONSORTIUM
TARGETED COGNITIVE INTERVENTION ™ WEB-BASED DELIVERY PLATFORM
PRIVACY POLICY
The Neurolution™ Consortium is a collaboration comprising non-profit schools (“Neurolution” “we” “us”) dedicated to improving academic and cognitive outcomes for students with language-based learning difficulties through data-informed instruction. Neurolution makes powerful solutions available to educators to address major challenges, including: (1) a powerful data environment that enables schools to understand each student’s learning profile, and (2) a unique approach to combining academic and cognitive interventions to promote student learning.
Neurolution collects information about users of its website and about users of its cognitive intervention solutions, which include software and web-based curriculum, learning tools, and outcome data analysis tools. Neurolution’s primary tool to deliver its cognitive intervention solution is the Targeted Cognitive Intervention™ Delivery Platform (“TCI Delivery Platform”), as it may be modified over time. The TCI Delivery Platform is a required tool for student participation in Neurolution’s cognitive function and learning outcomes curriculum (“TCI Curriculum”).
This TCI Curriculum Privacy Policy addresses data collected by Neurolution through implementation of the TCI Curriculum. Our Website Privacy Policy is located here.
Other than Neurolution and its members, only students (“Students”) and school administrators, who may include teachers or other educators, (“Administrators”) who are authorized by their school, can become registered users (“you” or “User”) of the TCI Delivery Platform. Each school will collect parental consent prior to Student use of the TCI Delivery Platform and will send us the applicable information, as indicated below, for us to enable Administrator and Student access through the authorized school account.
Each User of the TCI Delivery Platform (including each Administrator and each Student) must agree to this Privacy Policy as a condition to using the TCI Delivery Platform and accessing the resources made available through the TCI Curriculum. Your use of the TCI Delivery Platform indicates your agreement with this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the TCI Delivery Platform. We encourage you to print out this Privacy Policy for your records and if you are a Student, to discuss this Privacy Policy with your parent or legal guardian.
Each Administrator agrees to this Privacy Policy in their individual capacity and on behalf of their school.
We may modify this policy from time to time. We will notify you if our modifications change the way in which we use or store your information.
This Privacy Policy is to inform you of the information we gather through the TCI Delivery Platform, how we use that information, and the choices you have relating to your information. This Privacy Policy is organized as follows:
· Information we collect
· Information use
· Information sharing
· Information security
· Opting-out/Correcting Personal Information
· Contact Us
We take protecting User privacy seriously. Neurolution has implemented steps so that the operation of the TCI Delivery Platform complies with federal regulations regarding online privacy, most notably the Children's Online Privacy Protection Act (COPPA), the Family Educational Rights and Privacy Act (FERPA), and the Protection of Pupil Rights Amendment (PPRA).
All Information that Neurolution receives in connection with the TCI Delivery Platform is subject to this Privacy Policy.
Information We Collect
Registration
To authorize access to the TCI Delivery Platform, the User’s school provides us with the following information about each User (“Registration Information”).
From or For All Users:
Name
Email Address
School Affiliation
Role at your school (such as student, teacher, or administrator)
In addition, we may collect the following information about each Student from the school or from the Student:
From or For Students:
Birth Date
Grade
Gender (optional)
Information that can identify who you are, such as name and email address, is “Personal Information.” All together, we refer to your Personal Information and any other information that we collect about you from your use of the TCI Platform as “Information.”
Educational Records
If the Student’s school has received parental consent through a Consent Form ( a sample of which may be requested by contacting info@neurolution.org), Neurolution may receive certain educational records from the Student’s school that are necessary or helpful in implementing the TCI Curriculum. These records may include certain demographic and diagnostic data that we use to inform assignments.
Participation Data
Neurolution collects information directly from a Student in the form of the interactions that are made when using the TCI Delivery Platform, which include, but are not limited to, the Student’s access times, performance, and user habits for the TCI Delivery Platform.
Cookies
The TCI Delivery Platform does not use cookies. Some of our content providers may use cookies. Disabling cookies may prevent access to that content.
Information Use
Neurolution uses anonymized individual and aggregate usage information to enhance the TCI Delivery Platform, the TCI Curriculum, and our services. We will analyze this information and consider it when we are designing new or improved features for the TCI Curriculum and the TCI Delivery Platform, and for general purposes related to Neurolution’s charitable mission.
Neurolution uses Information collected from Administrators to administer the TCI Delivery Platform on behalf of the Student. Neurolution uses Educational Records and Participation Data, which may be in combination with other Information, to inform assignments under the TCI Curriculum, to assess Students’ progress, and to evaluate the curriculum’s efficacy. In addition, Neurolution may use Information, including Personal Information, from Students and Administrators (i) to provide notices or deliver reports relating to the Student, (ii) to provide information relating to the TCI Delivery Platform, and (iii) to administer assessment tools and surveys required by the TCI Delivery Platform.
Information Sharing
Except as described in this Privacy Policy, Neurolution does not share Personal Information, except that any Information may be shared among the members of Neurolution subject to compliance with this Privacy Policy, applicable law, and any restrictions imposed by a member. All Personal Information is collected and stored solely for the purpose of operating the TCI Delivery Platform and as set forth in this Privacy Policy. All outcome reports and research studies are issued using de-identified data. Personal Information is not included.
The TCI Delivery Platform incorporates some components and services provided through Neurolution’s third party vendors. To the extent any Personal Information is shared with any third party vendors, those vendors are required to protect that Personal Information in a manner compliant with this Privacy Policy.
Because participating schools administer the TCI Curriculum and the implementation of the TCI Delivery Platform, Administrators designated by the school are able to view a Student’s Information, including Personal Information. The TCI Delivery Platform generates reports and assessments, which are available to Administrators and, upon request, the Student’s Parent. Neurolution is not responsible for the security and sharing practices of any school or Administrator.
Neurolution (including each of its members) may use or share anonymized aggregated information for cognitive research and for development of learning tools and assessments. We may share anonymized aggregated information with our subscriber schools, our contracted business partners, and unaffiliated outside parties. This information is valuable for planning and assessing educational services to benefit students. From time to time, we may share aggregated information in connection with scholarly publications or presentations.
In limited circumstances, we may be required to share Information, which includes Personal Information, with third parties as follows:
· Law Enforcement Officials and as Required by Law. We may release any or all of your Information to third parties when we determine, in our judgment, that it is necessary to (a) comply with the law, regulation, legal process, or enforceable governmental request; (b) enforce or apply the terms of any of our policies or user agreements; or (c) protect the rights, property or safety of us, our employees, our users, or others.
· Reorganization: We may decide, for strategic or other reasons, to reorganize our consortium, have one or more members leave or join our consortium, combine our consortium or a member of our consortium with another entity, or modify the way in which our consortium members collaborate. Any such transaction may involve the disclosure of Information, including Personal Information, to third parties or members who are leaving or joining our consortium, or who are otherwise participating in our efforts to pursue our mission. In such cases, we will take reasonable measures to protect the Personal Information we disclose, for example, by requiring the recipient of the Personal Information to sign a non-disclosure agreement limiting the use and protecting the confidentiality of the Personal Information.
· Asset Management: We may disseminate the TCI Delivery Platform to or for the benefit of third parties as part of a licensing strategy. We may transfer the ownership or operation of the TCI Delivery Platform or TCI Curriculum to another organization, whether voluntarily or through insolvency or bankruptcy proceedings. If such a transfer occurs, the successor organization will acquire our rights to use your Personal Information, but the successor organization’s use of your Personal Information will still be subject to this Privacy Policy and the privacy preferences you have expressed to us.
Information Security
Personal Information relating to a User is stored separately from other Information about the User.
Significant data segregation and controls exist to ensure data access is limited as appropriate.
One or more of the Neurolution members host, or have engaged third party service providers to host, all Information collected through the TCI Delivery Platform. As of the date of this Privacy Policy, the TCI Delivery Platform is hosted on Amazon Web Services, or such other service as we determine from time to time, for data processing and report storage. Neurolution and its members have implemented reasonable physical and digital security measures to prevent unauthorized access to transmitted and stored Information. However, no data transmissions over the internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any Information you transmit to us and you do so at your own risk. We may change our hosting, storage and security procedures at any time without notice to you.
Neurolution does not control or influence the practices used by any school or Administrator to protect your Information.
If you have specific questions regarding our data security measures, please contact info@neurolution.org.
Opting-out/Correcting Personal Information
At any time, a Parent may review their Student’s Information, may correct any Personal Information, may revoke consent to allow the Student to use the TCI Delivery Platform, or refuse to allow Neurolution to further use or collect the Student’s Personal Information. All Information will be retained subject to this Privacy Policy except that Personal Information will be removed if requested. However, if any consent is revoked or any information is required to be removed, the Student will not be able to use the TCI Delivery Platform. We will not release any Personal Information of children under the age of 13 to persons claiming to be those children's parents without verification that the child's parent is requesting the information.
Any User, or any parent or legal guardian of a Student, may request Neurolution to correct or remove such User’s Personal Information; however, removal of Personal Information revokes the User’s access to the TCI Delivery Platform.
If interested in more information about access to, removal of, or correction of Personal Information, or for any other questions, please email us at tci@carrollschool.org.
Contact Us
If you have any questions about our privacy or security measures, please contact: tci@carrollschool.org
Version: October, 2021