Privacy Policy

This Privacy Policy explains what information Elevate Edwards collects about students and their parents or guardians, how we use that information, how we protect it, and the rights that parents and guardians have over their child’s data. Elevate Edwards is a free K–5 summer learning program operated at Edwards Elementary in Edwards, Colorado. Because all students in our program are under the age of 13, we comply with the Children’s Online Privacy Protection Act (COPPA). Because we may exchange educational records with the student’s school, we also operate in alignment with the Family Educational Rights and Privacy Act (FERPA).

1. Who we are

Elevate Edwards is operated by Vail Performance Academy. Inquiries about this policy or your child’s information should be directed to:

• Email: samuel.bennett@vailperformanceacademy.com
• Mailing address: Edwards, Colorado 81632
• Program location: Edwards Elementary, Edwards, Colorado

2. Information we collect

From parents and guardians

When you register your child, we collect from you:

• Your full name, relationship to the student, email address, mobile phone, and mailing address.
• Preferred contact method and language.
• Emergency contacts and authorized pickup persons.
• Your typed signature and the timestamp of your consent.

From students

With your verifiable parental consent, we collect from or about your child:

• Identifying information: full legal name, preferred name, date of birth, grade, and current school.
• Health and safety information you choose to provide: allergies, medical conditions, medications taken during program hours, and pediatrician contact.
• Program participation data: daily attendance, arrival and departure method, and instructor observations.
• Learning data generated as your child uses our platforms: questions attempted and answered, time on task, skills mastered, mastery scores, XP earned, and other performance metrics produced by Math Academy, IXL/Reading Academy, Math Facts, and Reading Facts.
• Photographs and recordings, only if you grant photo/media permission on the registration form.

From your child’s school (only with your consent)

If you grant permission on the registration form, we may receive from Edwards Elementary:

• Prior academic records, including grades and standardized assessment results.
• Individualized Education Program (IEP) or 504 Plan information, where applicable, so staff can support your child appropriately.

3. How we collect information

We collect information in three ways:

• Directly from you through the online registration form.
• Directly from your child as they participate in the program (instructor observations, daily attendance).
• Automatically through the learning platforms your child uses during program hours (Math Academy, IXL/Reading Academy, Math Facts, and Reading Facts). Each platform records performance data as your child completes lessons.

We do not collect information about your child outside of program activities. We do not track your child across other websites or services.

4. How we use information

We use the information we collect for the following purposes only:

• To deliver the program safely (emergency contact, allergies, medical needs, authorized pickup).
• To communicate with you about your child’s participation, attendance, and progress.
• To tailor instruction to your child’s individual mastery level.
• To provide your child with motivation through earned incentives (game time, attendance bonus).
• To generate reports to you about your child’s growth in the program.
• To improve the program by reviewing what worked and what didn’t, in aggregate.
• To measure and report the overall effectiveness of the program (see Section 5 below).

5. Aggregate and de-identified use of student data

We may use information about your child in aggregate or de-identified form to evaluate and communicate the effectiveness of Elevate Edwards. This is a routine and expected practice for educational programs that aim to demonstrate impact and improve over time. Specifically, we may use aggregate or de-identified data to:

• Measure program-level outcomes such as average mastery growth, attendance, and learning velocity.
• Compare cohort performance over time and across grade levels.
• Report outcomes to families, school partners, funders, grant makers, investors, researchers, and the general public.
• Apply for grants or funding to continue and expand the program.
• Present results at conferences or in publications.
• Inform the design of future iterations of the program and of Vail Performance Academy.
• Support research on educational outcomes, including potential partnerships with academic researchers.

Two firm commitments: “Aggregate” means combined with the data of other students such that no individual student can be identified. “De-identified” means we have removed direct identifiers (name, school, date of birth) and applied reasonable techniques to prevent re-identification through indirect identifiers, in accordance with FERPA’s de-identification standards.

We will never identify your child by name, photograph, or other personally identifiable detail in any external communication, marketing material, public report, conference presentation, or social media post without your separate, written consent given on the registration form (photo/media release) or obtained later.

6. Third-party platforms and service providers

Elevate Edwards uses the following third parties. Each is an independent organization with its own privacy practices. We have reviewed each and selected them because their practices are consistent with COPPA and student-data privacy norms. By enrolling your child, you are consenting to your child’s use of these services. We encourage you to review each provider’s own privacy policy.

• Math Academy (mathacademy.com) — adaptive math curriculum and assessment.
• IXL Learning (ixl.com) — platform used to deliver our Reading Academy curriculum.
• Math Facts and Reading Facts — internal practice tools built and operated by Elevate Edwards. Data stays with us; we do not share it with outside parties except as described in this policy.
• Jotform (jotform.com) — used to host the registration form and store submissions. Form data is encrypted in transit and at rest.
• Squarespace (squarespace.com) — hosts our public website. No student data is stored on Squarespace.

Each provider above acts as a data processor on our behalf for the data we collect through them. We do not authorize any of these providers to use your child’s data for advertising or to sell it to third parties.

7. Disclosures to schools (FERPA)

We do not disclose personally identifiable information about your child to Edwards Elementary or any other school unless you have given written consent on the registration form. If you grant that consent:

• We may receive your child’s prior academic records from Edwards Elementary so our instructors can tailor the program to your child’s needs.
• We may share your child’s progress data — attendance, mastery, instructor notes, XP totals — with Edwards Elementary at the end of the program so the school has visibility into your child’s summer learning.

You can revoke this consent at any time by contacting us at the address in Section 1. Revocation applies to future disclosures only.

8. Your child’s privacy and your rights under COPPA

Because every student in our program is under 13, COPPA applies to all data we collect about them. As a parent or legal guardian, you have the following rights, and we will respond to any request within 30 days:

• Right to review. You can ask us to provide you with a description of the specific types of personal information we have collected from your child.
• Right to delete. You can ask us to delete your child’s personal information from our records.
• Right to refuse further collection. You can ask us to stop collecting further personal information from your child. Doing so may end your child’s participation in the program.
• Right to revoke consent. You can revoke any consent you have given at any time. Revocation applies prospectively.

To exercise any of these rights, email samuel.bennett@vailperformanceacademy.com with the subject line “COPPA Request.” We may ask you to verify your identity (typically a copy of a photo ID) before we act on a request, to ensure we are responding to the actual parent or guardian.

9. Your rights under FERPA

FERPA gives parents and eligible students specific rights regarding education records. To the extent Elevate Edwards holds education records covered by FERPA, you have the right to:

• Inspect and review your child’s records held by Elevate Edwards.
• Request that records you believe are inaccurate or misleading be amended.
• Consent in writing before we disclose personally identifiable information from those records, except where FERPA authorizes disclosure without consent.
• File a complaint with the U.S. Department of Education concerning alleged failures by Elevate Edwards to comply with FERPA. The office that administers FERPA is the Student Privacy Policy Office, U.S. Department of Education, 400 Maryland Avenue SW, Washington, DC 20202.

10. How we protect information

We take the security of student and family data seriously. Our safeguards include:

• All data transmitted to and from our forms and platforms is encrypted in transit using TLS.
• Submission data stored in Jotform is encrypted at rest.
• Access to identifiable student data is limited to Elevate Edwards staff who need it to run the program.
• Staff receive training on student-data privacy and on this policy before working with students.
• We review our third-party providers periodically to confirm their practices remain consistent with this policy.

In the unlikely event of a data breach affecting your child’s information, we will notify affected families as required by applicable law and explain the steps we are taking in response.

11. How long we keep information

We retain identifiable information only as long as needed for the purposes described in this policy:

• Active program data is retained during your child’s participation in Elevate Edwards.
• After the program ends, identifiable data is retained for up to three years for outcomes reporting, follow-up communication with families, and longitudinal analysis. After that period it is either deleted or fully de-identified.
• Aggregate and de-identified outcomes data may be retained indefinitely, because by definition it can no longer be traced to your child.
• Signed consent records (registration form PDFs) are retained for at least three years after the program ends, consistent with COPPA recordkeeping expectations.

You can request earlier deletion of your child’s identifiable data at any time (see Section 8).

12. Children’s interactions with our platforms

Math Academy, IXL/Reading Academy, Math Facts, and Reading Facts are educational platforms only. They do not contain advertising, social features, chat with strangers, or open user-generated content visible to other students. Your child cannot publicly post information through any platform we use. Communication during the program day is limited to your child, program staff, and the curriculum itself.

13. Changes to this policy

We may update this policy occasionally to reflect changes in our practices, the platforms we use, or applicable law. If we make material changes — for example, adding a new platform that collects student data, or expanding how we use aggregate data — we will notify you by email at the address you provided at registration, and we will obtain new parental consent where required. The current version of this policy will always be posted on our website with the effective date at the top.

14. Contact us

If you have any questions, concerns, or requests related to this policy or to your child’s information, contact us:

• Email: samuel.bennett@vailperformanceacademy.com
• Subject line for privacy requests: “COPPA Request” or “FERPA Request” as appropriate.
• Location: Edwards, Colorado 81632

We will acknowledge your message within five business days and respond substantively within 30 days.

Learning Assist OS — Chrome Extension Privacy Policy

Operator: Vail Performance Academy / Elevate Edwards — samuel.bennett@vailperformanceacademy.com
Effective Date: June 12, 2026

What the extension does

Learning Assist OS is a Chrome browser extension that displays a tutoring overlay on supported learning platforms (Math Academy, IXL, Khan Academy, Synthesis, Canvas, Schoology). When a student requests help, it reads the visible problem text and returns a hint calibrated to their grade level — without revealing the answer.

Data stored on the student’s device (never transmitted)

• Student first name — used only within the extension UI
• Exact grade level — used to compute the anonymized grade band sent to our server
• Preferred language (English or Spanish)
• A device-bound session token (random, not linked to any account)
• Behavioral usage history (help types used, ratings given) — used for on-device personalization only

All of the above is stored in Chrome’s local extension storage (chrome.storage.local) and never leaves the device.

Data transmitted when a student requests help

What is never transmitted: student name, student ID, device identifier, exact grade, or behavioral usage history.

Third-party services used by the extension

OpenAI — Problem text, grade band, and language are forwarded to OpenAI’s API to generate hints. No student name or identifier is included. OpenAI does not use API-submitted content to train its models by default (OpenAI API data usage policy). A Data Processing Addendum (DPA) covering this API usage is in place.

Vercel — The extension’s backend runs on Vercel’s serverless platform. Vercel receives standard server logs (IP addresses, timestamps, request metadata). No student name or identifier appears in these logs. (Vercel Privacy Policy)

COPPA compliance

No personally identifiable information about a child is ever transmitted to our server or to any third-party service. The extension does not collect a child’s name, email, phone number, geolocation, photo, or persistent identifier externally. Data stored locally on the device is controlled entirely by the device and can be cleared by uninstalling the extension or clearing Chrome’s local storage.

Parental rights

Because no personally identifiable student information is transmitted externally, there is no external record to review or delete. Local device data (name, grade, language preference) can be removed at any time by uninstalling the extension. For any questions, contact samuel.bennett@vailperformanceacademy.com.