Privacy Center

This Data Protection Agreement (“DPA”) becomes effective as of the Effective Date of the Terms of Service (the “Agreement”) and is entered into by and between Education Advanced and the Customer.

1. United States. With respect to Users in the United States, the following provisions shall apply:
2. Definitions.
   Capitalized words used in this Data Protection Addendum that are not expressly defined in this Data Protection Addendum have the meaning set forth in the Agreement.
   
   1. “Data Protection Legislation” means applicable federal, state, local, and municipal laws and regulations in the United States that relate to the privacy, data protection or data security of Personal Data.
   2. “Personal Data” means information about a specific individual that is provided, submitted, or otherwise made available to Education Advanced by or on behalf of Customer or any User in connection with any of the Service that constitutes “personal data”, “personal information”, “personally identifiable information” or similar term under applicable law.
   3. "Process” shall have the same meaning as set out in the applicable Data Protection Legislation or if no such meaning or concept exists, it shall be the means by which Education Advanced collects, uses, stores, discloses, or transfers Personal Data.
3. Compliance with Laws; Roles.Each Party shall comply with all Data Protection Legislation applicable to itin its respective Processing of Personal Data under the Agreement. For purposesof this Agreement and as between the Parties, Customer is the controller of thePersonal Data and Education Advanced is the processor of such data.
4. Notices and Consents. Customer shall provide all notices and obtain all such consents required under applicable Data Protection Legislation (including, without limitation, consents required under the Family Education Rights and Privacy Act, 20 U.S.C. § 1232g and its implementing regulations, 34 C.F.R. Part 99 (together, “FERPA”))from the Users to allow Education Advanced to Process the Personal Data to provide the Services and as otherwise described in the Agreement, including in this Data Protection Addendum (the “Notices and Consents”). Customer represents and warrants that it has obtained and will maintain the Notices andConsents for all Users through the entire term of the Agreement.
5. Details of Processing.
   Personal Data will be Processed for the purposes set forth in the Agreement and any applicable Sales Order.
6. Education Advanced Obligations.‍
   1. Education Advanced shall implement and maintain reasonable administrative, technical and organizational measures that are designed to preserve the confidentiality and availability of Personal Data Processed by Education Advanced via the Services. Education Advanced’s technical and organizational measures, as set forth in Education Advanced’s Information Security Overview, are available upon request and may be updated from time to time. Customer has reviewed such measures and agrees that the measures are appropriate taking into account the state of the art, the costs of implementation, nature, scope, context and purposes of the processing of Personal Data hereunder.
   2. Education Advanced shall take reasonable steps to ensure that any employees who have access to the Personal Data are trained on applicable Data Protection Legislation and to ensure that employees do not disclose Personal Data for reasons other than those necessary for their Processing of the Personal Data.
   3. Education Advanced engages certain third-party entities to Process the Personal Data on Education Advanced’s behalf ("Sub-processors"). Information about Sub-processors, including their functions and locations, is available at: https://www.educationadvanced.com/privacycenter/ (as may be updated by Education Advanced from time to time) or such other website address as Education Advanced may provide to Customer from time to time (the “Sub-processor Site”).Education Advanced shall enter into an agreement with each Sub-processor containing terms that offer substantially
   4. similar levels of data protection obligations and protection for Personal Data as those set out in this Section. Customer consents to Education Advanced engaging the Sub-processors for the purposes set forth in the Agreement and this DPA.
   5. If Education Advanced becomes aware of a confirmed breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to the Personal Data (a “Security Incident”), Education Advanced shall inform Customer, within a reasonable amount of time, taking into account the timeframes required by Data Protection Legislation, with respect to the Security Incident. Education Advanced will provide reasonable information, cooperation, and updates of material developments to enable Customer to fulfill any data breach reporting obligations it may have under Data Protection Legislation. However, Education Advanced provision of information and cooperation shall be at Customer’s cost and expense to the extent any Security Incidents were caused by Customer or its Users or Data Subjects (as defined below). Education Advanced may take such other measures as it deems appropriate to mitigate the effects of the Security Incident.

1. Data Subject Inquiries. Customer shall be solely responsible for responding to and fulfilling any inquiries from Users and other data subjects, including parents and legal guardians of Users where the User is a student of Customer (collectively, “Data Subjects”) regarding their Personal Data in connection with the Processing under the Agreement, including any requests to exercise their rights under applicable Data Protection Legislation, and Customer shall handle all Data Subject inquiries in accordance with applicable Data Protection Legislation. Customer understands that Education Advanced is not required to take any action in response to any requests from Data Subjects except to notify such Data Subjects to contact Customer. To the extent Customer cannot obtain a copy of, delete or amend the Personal Data directly within the Services, Customer may contact Education Advanced and Education Advanced, with Customer’s express written permission and provided Customer has obtained the appropriate consent from the applicable Data Subject, will provide a copy of, delete or amend such Data Subject’s Personal Data in accordance with Customer’s instructions. To the extent legally permitted, Customer shall be responsible for reasonable costs arising out of Education Advanced’s provision of assistance with Customer’s Data Subject requests. Customer shall indemnify, defend, and hold harmless Education Advanced and its affiliates, subsidiaries, successors and assigns (and the officers, directors, employees, sublicensees, customers, and agents of Education Advanced and its affiliates, subsidiaries, successors, and assigns), from and against any and all losses, demands, liabilities, damages, fines, settlements, expenses, and costs (including without limitation reasonable attorneys’ fees and costs), arising from, in connection with, Education Advanced complying with Customer’s instructions under this Agreement.
2. Authorized Disclosure of Personal Data.
   1. Customer acknowledges and agrees that, at Customer’s request and reasonable cost,Education Advanced may provide Personal Data to third-parties or other entities to whom Customer requests Education Advanced provide Personal Data (e.g.,State Board of Education). Customer shall make such a request to disclosePersonal Data in writing (“Authorization”). Customer acknowledges and agrees that each Authorization will result in Customer electing, in its sole discretion, to transfer the Personal Data to the recipients that Customer selects.
   2. The entities identified in Section 8(a) are collectively defined as “Recipients.”
   3. Customer acknowledges that Customer Data may contain Personal Data and may be subject to Data Protection Legislation. Customer will hold Education Advanced harmless, and not liable in any way, for Education Advanced’s disclosure of Personal Data to the Recipients in accordance with an Authorization.
   4. Education Advanced makes no warranty (a) that the use of the Personal Data by the Recipient is valid or in compliance with applicable Data Protection Legislation and Customer’s organization’s policies or (b) that Personal Data will remain secure upon transfer to the Recipient, and disclaims any responsibility for the transfer. Customer acknowledges that the Personal Data will be provided on an “as is”, “as available” basis.
3. Data Retention. EducationAdvanced will delete Personal Data within a reasonable amount of time after the termination or expiration of the Agreement, except that Education Advanced may retain Personal Data as required by applicable legal requirements or as agreed by Customer. For the avoidance of doubt, the foregoing shall not apply toAnonymized Data (as defined below).
4. Education Advanced Data. Customer acknowledges and agrees that Education Advanced may create and derive performance, system, and operational data, aggregated data, anonymized data and de-identified data from Processing related to the Agreement, including in connection with the Services (collectively, “Anonymized Data”). In generating such data, Education Advanced shall (a) take reasonable measures to ensure that such data cannot be associated with a Data Subject and (b) not attempt to reidentify such data, except as permitted under Data ProtectionLegislation.
5. Education Records. As applicable, to the extent Education Advanced has access to “Education Records”and “Personally Identifiable Information” (as those terms are defined in FERPA)in connection with its provision of the Products that is not otherwise permitted under FERPA: (a) Customer agrees that Education Advanced has met the criteria for being a “School Official” with “Legitimate Educational Interests” (as those terms are used in FERPA) in such Education Records and Personally IdentifiableInformation; and (b) Education Advanced agrees that such Education Records andPersonally Identifiable Information will be used only for authorized purposes under the Agreement, and it will not redisclose such Education Records orPersonally Identifiable Information except with Authorization from Customer and where such redisclosure is otherwise permitted under FERPA.
6. Compliance; Audits.
   1. Taking into account the nature of the Processing of Personal Data byEducation Advanced and the information available to Education Advanced, where required by applicable law, Education Advanced shall provide such information and assistance to Customer as Customer may reasonably request (insofar as such information is available to Education Advanced and the sharing thereof does not compromise the security, confidentiality, integrity or availability of any dataProcessed by Education Advanced) to help Customer meet its obligations underData Protection Legislation, including in relation to the security of PersonalData, the reporting and investigation of Security Incidents, the demonstration of Customer’s compliance with such obligations and the performance of any data protection assessments.
   2. Subject to Section 12(c) below, where required by applicable law, Education Advanced shall make available to Customer such information as Customer may reasonably request for Education Advanced to demonstrate compliance with Data ProtectionLegislation and this DPA. Without limitation of the foregoing, Customer may conduct (in accordance with this Agreement), at its sole cost and expense, andEducation Advanced will reasonably cooperate with, reasonable audits (including inspections, manual reviews, automated scans and other technical and operational testing that Customer is entitled to perform under Data ProtectionLegislation), in each case, whereby Customer or a qualified and independent auditor appointed by Customer using an appropriate and accepted audit control standard or framework may audit Education Advanced’s technical and organizational measures in support of such compliance and the auditor’s report is provided to Customer and Education Advanced upon Customer’s request.
   3. Customer shall give EducationAdvanced reasonable advance notice of any such audits. Education Advanced need not cooperate with any audit (a) performed by any individual or entity who hasnot entered into a non-disclosure agreement with Education Advanced on terms acceptable to Education Advanced in respect of information obtained in relation to the audit; (b) conducted outside of Education Advanced’s normal business hours at the relevant site; or (c) on more than one occasion in any calendar year during the term of the Agreement, except for any additional audits thatCustomer is required to perform under Data Protection Legislation. The audit must be conducted in accordance with Education Advanced’s safety, security orother relevant policies, must not impact the security, confidentiality ,integrity or availability of any data Processed by Education Advanced and must not unreasonably interfere with Education Advanced’s business activities.Customer shall not conduct any scans or technical or operational testing of Education Advanced’s applications, websites, services, networks or systems without Education Advanced’s prior approval (which shall not be unreasonably withheld).
7. State Specific Privacy Addenda. If applicable, the Parties agree to the State Specific Data Protection Addenda for the applicable state(s).
8. Updates to this DPA. Notwithstanding anything to the contrary in the Agreement, Education Advanced reserves the right to modify this DPA from time to time in its sole discretion and without Customer’s prior consent except where required by applicable law (“UpdatedDPA”). Customer agrees that any Updated DPA will be effective immediately upon Education Advanced emailing the Updated DPA to Customer, unless EducationAdvanced is required by applicable law to obtain Customer’s consent, in which case, such Updated DPA will be effective immediately upon the provision of such consent. Education Advanced will also endeavor to notify Customer of any material revision to this DPA at least ten (10) days prior to such revision coming into effect, using Customer’s email address as set forth in the most recently executed Sales Order.

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State Specific Agenda

Capitalized words used in this State Specific Data Protection Addendum but not defined herein have the meanings given to them in the Data Protection Addendum or in the Agreement.

CALIFORNIA

With respect to Pupil Records (as defined in Cal. Educ. Code § 49073.1) that Education Advanced processes on behalf of a Customer in California, the following provisions shall apply to the extent required by applicable law:

1. Pupil Records that Education Advanced processes on behalf of Customer are the property of and under the control of Customer, except a User may retain possession and control of User-Generated Content where the User opens a personal account.
2. Education Advanced shall limit its use of Pupil Records to those purposes specified in the Agreement, the Data Protection Addendum, and the Privacy Policy.
3. Procedures for the review and correction of Pupil Records shall be in accordance with the Data Protection Addendum.
4. Education Advanced shall implement, maintain, and use reasonable measures to ensure the security and confidentiality of Pupil Records as specified in the Data Protection Addendum.
5. Procedures for notification in the event of unauthorized disclosure of Pupil Records shall be in accordance with the terms of the Data Protection Addendum.
6. Education Advanced certifies that retention of Pupil Records shall be limited in accordance with the terms of the Data Protection Addendum.
7. Education Advanced’s and Customer’s access to and use of Education Records and Personally Identifiable Information (as defined in FERPA) shall be subject to the terms of the Data Protection Addendum.
8. Education Advanced shall not use Personal Data in Pupil Records to engage in targeted advertising.

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COLORADO

With respect to Student Personally Identifiable Information (as defined in Colo. Rev. Stat. Ann. § 22-16-103) that Education Advanced processes on behalf of a Customer in Colorado, the following provisions shall apply to the extent required by applicable law:

1. Education Advanced shall comply in all material respects with the requirements of Colo. Rev. Stat. § 22-16-108 with regard to the provision of clear information regarding collection, use, and disclosure of Student Personally Identifiable Information, as specified in the Data Protection Addendum and Privacy Policy.
2. Education Advanced shall comply in all material respects with Colo. Rev. Stat. § 22-16-109 with regard to the collection, use, and disclosure of Student Personally Identifiable Information, as specified in the Data Protection Addendum and Privacy Policy.
3. Education Advanced shall comply in all material respects with the requirements of Colo. Rev. Stat. § 22-16-110 with regard to data security and retention of Student Personally identifiable information, as specified in the Data Protection Addendum and Privacy Policy.
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CONNECTICUT

With respect to Student Information, Student Records, and Student-generated Content (as those terms are defined in Conn. Gen. Stat. § 10-234aa) (collectively, “CT Student Data”) that Education Advanced processes on behalf of a Customer in Connecticut, the following provisions shall apply to the extent required by applicable law:

1. CT Student Data that EducationAdvanced processes on behalf of Customer are Customer Data and under thecontrol of Customer.
2. Education Advanced retention ofCT Student Data shall be in accordance with the Data Protection Addendum andPrivacy Policy.
3. EducationAdvanced shall limit its use of CT Student Data to those purposes specified in the Agreement, Data Protection Addendum, and Privacy Policy.
4. Procedures for the review and correction of CT Student Data shall be in accordance with the Privacy Policy.
5. Education Advanced shall implement, maintain, and use reasonable measures to ensure the security and confidentiality of CT Student Data as specified in the Data Protection Addendum.
6. Procedures for notification in the event of unauthorized disclosure of CT Student Data shall be in accordance with the terms of the Data Protection Addendum.
7. Education Advanced and Customeraccess to and use of Education Records and Personally Identifiable Information(as defined in FERPA) shall be subject to the terms of the Data ProtectionAddendum.
8. Laws of the state ofConnecticut shall govern rights and duties with regard to CT Student Data, as specified in the Agreement.
9. In the event that any provision or the application of the Agreement or Data Protection Addendum is held invalid by a court of competent jurisdiction, severability of terms shall be in accordance with the Agreement.
   

DISTRICT OF COLUMBIA

With respect to Personally Identifiable Student Information (as defined in D.C. Code § 38-831.01(14)) that Education Advanced processes on behalf of a Customer in the District of Columbia, the following provisions shall apply to the extent required by applicable law:

1. [Procedures for notification in the event of unauthorized disclosure of Personally Identifiable Student Information shall be in accordance with the terms of the Data Protection Addendum.]
2. Personally Identifiable Student Information that Education Advanced processes on behalf of Customer are Customer Data and under the control of Customer.
3. [Retention of Personally Identifiable Student Information shall be limited in accordance with the terms of the Data Protection Addendum.]
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IDAHO

With respect to Student Data (as defined in Idaho Code Ann. § 33-133) that Education Advanced processes on behalf of a Customer in Idaho, the following provisions shall apply to the extent required by applicable law:

1. Education Advanced is permitted to use De-Identified Data, which may include Aggregated Data, as disclosed in the Data Protection Addendum and Privacy Policy, as applicable.
2. Education Advanced is permitted to use Student Data for secondary uses with consent of a student’s parent or guardian and as disclosed in accordance with the Data Protection Addendum and Privacy Policy, as applicable.
3. Education Advanced is permitted to use Student Data for secondary uses with consent of a student’s parent or guardian and as disclosed in accordance with the Data Protection Addendum and Privacy Policy, as applicable.
   

ILLINOIS

With respect to Covered Information (as defined in 105 Ill. Comp. Stat. Ann § 85/5) that Education Advanced processes on behalf of a Customer in Illinois, the following provisions shall apply to the extent required by applicable law:

1. The types of Covered Information for which Education Advanced may act as a processor on behalf of Customer under the Agreement are specified in the Data Protection Addendum and Privacy Policy, as applicable.
2. The Services provided to Customer by Education Advanced are specified in the Agreement.
3. Education Advanced and Customer access to and use and disclosure of Education Records and Personally Identifiable Information (as defined in FERPA) shall be subject to FERPA, in accordance with the terms of the Data Protection Addendum.
4. Procedures in the event of a security breach shall be in accordance with the terms of the Data Protection Addendum; provided that, if the security breach is attributed to Education Advanced, any costs and expenses incurred by the Customer in investigating and remediating the breach will be allocated between Education Advanced and the Customer.
5. Education Advanced’s retention of Covered Information shall be in accordance with the Data Protection Addendum and Privacy Policy, as applicable.
6. Education Advanced agrees that Customer may publish a mutually agreed upon redacted copy of the Agreement and Data Protection Addendum on its website and/or make the documents available for inspection by the general public at its administrative office, as applicable.
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LOUISIANA

With respect to Personally Identifiable Information (as defined in La. Stat. Ann. § 17:3914(B)(1)) that Education Advanced processes on behalf of a Customer in Louisiana, the following provisions shall apply to the extent required by applicable law:  

1. Education Advanced shall limit access to Personally Identifiable Information it processes on behalf of Customer in accordance with the DPA and any notice of children’s privacy practices.
2. Education Advanced shall comply with the standards governing the privacy and security of Personally Identifiable Information as set forth in the DPA and any notice of children’s privacy practices.
3. Privacy and security audits performed by Customer’s superintendent shall be completed in accordance with the DPA.
4. Procedures for unauthorized disclosure of Personally Identifiable Information shall be in accordance with the terms of the DPA.
5. Education Advanced’s retention of Personally Identifiable Information shall be limited in accordance with the terms of the Agreement, DPA, and any notice of children’s privacy practices, as applicable.
6. Education Advanced’s disposal of Personally Identifiable Information shall be done in accordance with the terms of the Agreement, DPA, and any notice of children’s privacy practices, as applicable.
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MINNESOTA

With respect to Educational Data (as defined in Minn. Stat. § 13.32) that Education Advanced processes on behalf of a Customer in Minnesota, the following provisions shall apply to the extent required by applicable law:

1. Education Advanced shall limit access to Educational Data it processes on behalf of Customer in accordance with the DPA and any notice of children’s privacy practices.
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MONTANA

With respect to Pupil Records (as defined in Mont. Code Ann § 20-7-1324(6)) that Education Advanced processes on behalf of a Customer in Montana, the following provisions shall apply to the extent required by applicable law:

1. Pupil Records that Education Advanced processes on behalf of Customer are the property of and under the control of Customer, except an Authorized User may retain possession and control of Authorized User-Generated Content where the Authorized User opens a personal account.
2. Education Advanced shall limit its use of Pupil Records to those purposes specified in the Agreement, the DPA, and any notice of children’s privacy practices.
3. Procedures for the review and correction of Pupil Records shall be in accordance with the DPA.
4. Education Advanced shall implement, maintain, and use reasonable measures to ensure the security and confidentiality of Pupil Records as specified in the DPA.
5. Procedures for notification in the event of unauthorized disclosure of Pupil Records shall be in accordance with the terms of the DPA.
6. Education Advanced certifies that retention of Pupil Records shall be limited in accordance with the terms of the DPA.
7. Education Advanced’s and Customer’s access to and use of Education Records and Personally Identifiable Information (as defined in FERPA) shall be subject to the terms of the DPA.
8. Education Advanced shall not use Personal Data in Pupil Records to engage in targeted advertising.
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NEW YORK

With respect to personally identifiable information (as defined in N.Y. Comp. Codes R. & Regs. tit. 8, § 121.1(m)) (“NY PII”) that Education Advanced processes on behalf of a Customer in New York, the following provisions shall apply to the extent required by applicable law (for the avoidance of doubt, NY PII is a subset of Personal Data as defined in the Agreement):  

1. Education Advanced certifies that its technologies, safeguards and practices align with the NIST Cybersecurity Framework.
2. Education Advanced shall comply in all material respects with Customer’s data security and privacy policy and applicable state and federal laws.
3. Education Advanced shall limit access to NY PII it processes on behalf of Customer in accordance with the Data Protection Addendum and Privacy Policy.
4. Education Advanced shall limit its use of NY PII to those purposes specified in the Agreement, Data Protection Addendum, and Privacy Policy.
5. Education Advanced shall not disclose NY PII except in accordance with the Data Protection Addendum and Privacy Policy.
6. Education Advanced shall implement, maintain, and use reasonable measures that are designed to ensure the security and confidentiality of NY PII as specified in the Data Protection Addendum.
7. Education Advanced shall use encryption to protect electronic NY PII in transit or in storage.
8. Education Advanced shall not sell NY PII and shall limit its use and disclosure of NY PII in accordance with the Data Protection Addendum and Privacy Policy.
9. Data Security and Privacy Plan
   1. Education Advanced will implement applicable data security and privacy requirements as specified in the Data Protection Addendum
   2. Education Advanced shall implement, maintain, and use reasonable measures that are designed to ensure the security and confidentiality of NY PII as specified in the Data Protection Addendum.
   3. A parent’s bill of rights is incorporated as part of this addendum, and Education Advanced shall comply in all material respects with its terms.
   4. Education Advanced shall train its officers and employees on applicable laws prior to granting access to User data as specified in the Data Protection Addendum.
   5. Education Advanced shall require that Sub-processors protect NY PII and manage breaches and unauthorized disclosure as specified in the Data Protection Addendum.
   6. Education Advanced shall manage data security and privacy incidents as specified in the Data Protection Addendum. Procedures for notification in the event of breaches and unauthorized disclosures shall be in accordance with the terms of the Data Protection Addendum.
   7. Education Advanced retention of NY PII shall be limited in accordance with the Data Protection Addendum.
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OHIO

With respect to Education Records (as defined in Ohio Rev. Code § 3319.325(A)) that Education Advanced processes on behalf of a Customer in Ohio, the following provisions shall apply to the extent required by applicable law:

1. Education Advanced shall limit access to Education Records it processes on behalf of Customer in accordance with the DPA and Privacy Policy, as applicable.
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UTAH

With respect to Student Data (as defined in Utah Code Ann. § 53E-9-301(17)) that Education Advanced processes on behalf of a Customer in Utah, the following provisions shall apply to the extent required by applicable law:

1. Education Advanced shall limit its collection, use, storage, and sharing of Student Data to those purposes specified in the Agreement, Data Protection Addendum, and Privacy Policy, as applicable.
2. Processing of Student Data by Sub-processors shall be in accordance with the Data Protection Addendum and Privacy Policy, as applicable.
3. Education Advanced’s retention of Student Data shall be limited in accordance with the terms of the Agreement, Data Protection Addendum, and Privacy Policy, as applicable.
4. Education Advanced shall not use Student Data for purposes other than those specified in the Agreement and Data Protection Addendum and except as permitted by Utah Code Ann. § 53E-9-309(4) or as requested by the Customer.
5. Education Advanced agrees that, at Customer’s request, Customer or Customer’s designee may conduct an audit of Education Advanced, in accordance with reasonable and mutually agreed-upon procedures, to verify compliance with the Agreement and Data Processing Agreement to the extent required by Utah Code Ann. § 53E-9-309.
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VIRGINIA

With respect to Student Personal Information (as defined in Va. Code Ann. § 22.1-289.01) that Education Advanced processes on behalf of a Customer in Virginia, the following provisions shall apply to the extent required by applicable law:

1. The types of Student Personal Information for which Education Advanced may act as a processor on behalf of Customer shall be specified in the Data Protection Addendum and Privacy Policy, as applicable.
2. Privacy of Student Personal Information processed by Education Advanced on behalf of Customer shall be subject to the Data Protection Addendum and Privacy Policy, as applicable, and notification of material changes shall be in accordance with the Data Protection Addendum.
3. Education Advanced shall maintain reasonable measures to ensure the security, privacy, confidentiality, and integrity of Student Personal Information as specified in the Data Protection Addendum.
4. Procedures for access to and the review and correction of Student Personal Information shall be in accordance with the Data Protection Addendum and Privacy Policy, as applicable.
5. Education Advanced shall not collect, maintain, use, or share Student Personal Information except for purposes specified in the Agreement, Data Protection Addendum, and/or Privacy Policy, except with consent of the Customer or student’s parent or legal guardian, as applicable.
6. Education Advanced shall require that its Sub-processors of Student Personal Information on behalf of Customer comply with Education Advanced’s policies and security measures in accordance with the Data Protection Addendum.
7. Education Advanced’s retention of Student Personal Information shall be limited in accordance with the terms of the Data Protection Addendum and Privacy Policy, as applicable.
8. Education Advanced shall not use Student Personal Information to engage in targeted advertising to students.
9. Education Advanced shall not use Student Personal Information to create a personal profile of a student, except for the purposes specified in the Agreement, Data Protection Addendum, and Privacy Policy, as applicable.
10. Education Advanced shall not knowingly sell Student Personal Information except the extent that Education Advanced is sold to or acquired by a successor entity that purchases, merges with, or otherwise acquires Education Advanced.

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