Coach Digital Compass and Catch Up with Coach Privacy Policy
PRIVACY POLICY
Effective Date: March 6, 2025

EPS Operations, LLC (“EPS,” “we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains our practices in connection with personal information we receive through certain software applications and the accompanying services provided to educational institutions and educators by EPS (the “Services”). This Privacy Policy applies to coachdigital.com, compass.coachdigital.com, catchupcoach.coachdigital.com, and any other website operated by EPS that links to or displays this Privacy Policy (collectively, “Website(s)”).

Please Note: This Privacy Policy does not apply to EPS’ e-commerce website or services.

While this Privacy Policy describes how we treat personal information, please be aware that additional terms and conditions may apply to the Website you are visiting and any products we offer. For example, the EPS End User License Agreement may apply depending on which Website you are using.

1. STUDENT INFORMATION

We provide Services that schools and parents use for educational purposes. When we act as a vendor to educational agencies and institutions, we do so in accordance with, including but not limited to, the Family Educational Rights and Privacy Act (“FERPA”), the Children’s Internet Protection Act (“CIPA”) and other individual state laws, such as New York Education Law 2-d (“Ed Data Law 2d”), Student Online Personal Protection Act of 2019 (“SOPPA”) in Illinois, the Minnesota Government Data Practices Act - Chapter 13, and The Student Online Personal Information Protection Act (“SOPIPA”) in California. We may collect the following information from students: name, email address, username, assigned ID number, school enrollment, district ID, state ID, grade level, homeroom, scheduled courses, course performance sources, the names of the students’ teachers, any student work that is submitted to our Websites or Services, and information regarding how each student uses our Websites or Services, including the information described in Section 3 below (collectively “Student Information”).

Some of our Services collect Student Information from children under the age of thirteen, when the students interact with those Services. When we collect information from children under the age of thirteen, we do so in compliance with the Children’s Online Privacy Protection Act (“COPPA”) of 1998.

We only use Student Information as we are authorized to by the applicable educational institution or agency or a parent/guardian. When we collect Student Information, we take additional steps to protect students’ privacy, including:

• Notifying educational institutions or parents about our information practices with regard to our privacy practices with regard to children;
• In accordance with applicable law, obtaining consent from educational institutions or parents for the collection of personal information from children, or for sending information about our Services directly to children; and
• Limiting our collection of personal information from children to no more than is reasonably necessary to participate in the Services.

Educational institutions retain ownership of all Student Information provided through our Services.

2. WHAT PERSONAL INFORMATION WE COLLECT

In addition to the Student Information described above, we may collect and process the following personal information about parents or educators when they use our Services (“Parent and Educator Information”):

(a) Information and identifiers about parents and educators. This includes name, and email address. If a parent or educator registers for an account on a Website, we will collect information about their account, including their username and their assigned ID number to use our Services.

(b) Education information of parents and educators. We collect information regarding the school a parent or educator is affiliated with, the local district ID, the state ID, and whether you are a parent or educator.

(c) Our interactions with parents and educators. We may keep a record of any interactions and correspondence between us such as calls made to our customer support services, online chat conversations with our customer support services, and any interactions parents or educators may have with our representatives.

(d) Information relating to parents’ and educators’ use of our Services or Websites, including their internet and network activity. When parents or educators access our Services or Website, we will automatically collect information that is necessary for us to provide the Websites or Services, including an IP address, which is a number assigned to your device when you connect to the internet. In addition, our web servers may log the type of browser, type of computer, device ID, and geolocation.

3. OUR USE OF COOKIES AND OTHER SIMILAR TECHNOLOGIES

We use cookies and similar technologies to support the functionality and security of our Services. We only use session cookies, which are temporary and required for users to access and navigate our platform. These cookies help maintain user sessions and ensure the secure operation of our Services.

We do not use cookies for advertising, behavioral tracking, or cross-site tracking. Any third parties that process data on our behalf must follow the same restrictions and may not use Student Information for behavioral advertising or profile building.

4. SOURCES OF INFORMATION.

EPS collects the information described above from educators, parents, students, educational institutions we work with, our service providers and suppliers, data analytics providers, and our affiliates.

5. USE OF PERSONAL INFORMATION.

In accordance with our contractual obligations and applicable laws regarding Student Information, EPS only uses Student Information:

• To provide and improve our Websites and Services;
• As authorized by any applicable educational institution or agency;
• To enforce legal obligations related to the Websites or Services;
• In the event of a sale, merger, or re-organization provided the information is used for the same purposes as set out in this Privacy Policy; and
• To comply with law.

For Parent and Educator Information and any other non-Student Information, EPS may use that personal information for the purposes described below. EPS may also use Student Information and Parent and Educator Information for any additional purpose that a parent or educator consents to or that EPS notifies you of at the time of collection. EPS does not sell any personal information of students, parents, or educators to third parties. Please note personal information will be collected, transferred to, and stored by us in the United States.

(a) To provide our Services. To enable the purchase of our Services, to supply or distribute Services and Websites, to set up or verify an account, to provide customer service, and to enable us to identify a user of our Services or Websites.

(b) To communicate effectively with our customers and conduct our business. To provide our customers with administrative emails, to correspond with users when they register to receive information, and to inform our customers of changes to this Privacy Policy, our Services, or applicable terms and conditions.

(c) To monitor certain activities. We monitor the use of our Services and Websites, including users’ movements around the Websites, the date and time of your visit, details of the information collected through cookies, and other tracking methodologies. We sometimes monitor activities as part of our compliance procedures, to secure our Websites, and to combat fraud. We may also collect limited geolocation data based on a user’s IP address.

(d) To comply with our legal obligations and enforce our rights. To comply with our regulatory requirements, conduct audits, communicate with regulators, protect EPS’ or a third party’s rights, and enforce our contracts, which may include disclosing your personal information to third parties, the court service, attorneys, regulators, or law enforcement agencies in connection with inquiries, proceedings, or investigations by such parties anywhere in the world or where compelled to do so.

(e) In connection with a sale, merger, or reorganization of our business. If we undergo a sale, merger, or reorganization, we may need to transfer personal information to a third party or its advisors as part of any due diligence process for the purpose of analyzing the proposed sale, merger, or reorganization or after the sale, merger, or reorganization for the same purposes as set out in this Privacy Policy.

6. WITH WHOM THE PERSONAL INFORMATION MAY BE SHARED.

If a student, parent, or educator uses our Services in connection with a particular educational institution or agency, we will provide the Parent and Educator Information and Student Information to the associated educational institution or agency. We may also disclose Parent and Educator Information and Student Information as described in the below table. Each category of third party receives only the information necessary to perform its specific function and no additional data. Except as described in this Privacy Policy, EPS will not knowingly disclose or authorize the disclosure of Student Information to any third party unless: (1) we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may have breached the terms and conditions of a Website, or who may be causing injury to or interference with (either intentionally or unintentionally) EPS’ rights or property, other Website users, or anyone else who could be harmed by such activities; (2) we believe in good faith that the law requires it; or (3) a parent or educator has consented to the disclosure. We require all third parties that we share Student Information with to respect the security of Student Information and to treat it in accordance with the law and this Privacy Policy. Third parties engaged by EPS provide essential services (e.g., hosting, authentication, analytics, customer support) and are contractually required to comply with applicable laws, this Privacy Policy, and EPS’s agreements with educational institutions.

Categories of Personal Information	Categories of Services Providers and Third Parties with whom Personal Information is Shared
Student Information	Entities that we are required to share with pursuant to law or for legal proceedings; service providers; our affiliates; and prospective purchasers of our business. We only share Student Information as authorized by an educational institution or agency or a parent/guardian or by applicable law.
Information and identifiers about Parents and Educators.	Entities that we are required to share with pursuant to law or for legal proceedings; service providers; our affiliates; and prospective purchasers of our business.
Education information of Parents and Educators.	Entities that we are required to share with pursuant to law or for legal proceedings; service providers; our affiliates; and prospective purchasers of our business.
Our interactions with Parents and Educators.	Entities that we are required to share with pursuant to law or for legal proceedings; service providers; our affiliates; and prospective purchasers of our business.
Information relating to Parents’ and Educators’ use of our Services or Websites.	Entities that we are required to share with pursuant to law or for legal proceedings; service providers; our affiliates; our customers; and prospective purchasers of our business.
Information collected from cookies and other similar technologies.	Entities that we are required to share with pursuant to law and for legal proceedings and service providers.

EPS provides its Services to and on behalf of educational institutions. As such, decisions regarding third-party data sharing—including opt-out requests—must be made by the educational institution that provides access to our Services. If you have concerns about third-party data sharing, please contact your educational institution.

7. RETENTION PERIODS.

Our retention periods for personal information are based on business needs and legal requirements. We retain personal information for as long as necessary to provide Services to the educational institution or agency associated with the account or to comply with legal requirements. Personal information will be removed upon request from the educational institution at the conclusion of the contract, pursuant to our contractual obligations and applicable laws.

8. DATA ACCESS AND MANAGEMENT.

EPS provides its Services to and on behalf of educational institutions, and as such, requests related to Student Information—including access, modification, or deletion—must be submitted by the educational institution that provides access to our Services. EPS does not claim ownership of Student Information and only processes it at the direction of the institution, in accordance with contractual agreements and applicable laws such as FERPA.

Educational institutions may submit requests related to Student Information by:

• Calling us at 800-225-5750; or
• Emailing us at Support@epslearning.com.

EPS cannot process requests for Student Information directly from students, parents, or other individuals. To verify a requestor’s authority, we may require confirmation from the requesting institution. We will respond to most verified requests within one month, or as required by law or contractual agreements.

9. LINKS TO OTHER WEBSITES.

Users may be linked or directed to other third-party websites that are beyond EPS’ control while using our Websites or Services. Each of these third parties may have a privacy policy different from that of EPS. EPS is not responsible for any actions or policies of such third parties. Users should review the applicable privacy policies of these third-party websites before providing personal information to those third parties.

10. SECURITY.

Our security is designed to protect the personal information we collect and hold. Our security measures include encryption, access controls, and regular security assessments to safeguard personal information. All confidential and sensitive information is encrypted while in transit and at rest using industry-standard encryption protocols. We apply a least-privileged access model, ensuring that individuals only receive the minimum access necessary to perform their job functions.

To enhance account security using custom authentication, we require users to create passwords that are at least eight characters long. We recommend using a mix of letters and numbers to improve security. Some institutions using our platform may enable multi-factor authentication (MFA) through third-party authentication providers such as Clever or ClassLink.

11. ADVERTISEMENTS.

We do not display advertisements or use personal information for advertising. Third parties providing services to EPS are contractually prohibited from advertising-related tracking.

12. CHANGES TO THESE TERMS.

We may change this Privacy Policy to reflect changes to our informational practices. If we make material changes, we will notify you at least 14 days prior to the change taking effect by posting the revised policy on this page or by email.

13. CONTACTING EPS.

Any questions or concerns regarding this Privacy Policy or updates regarding communication preferences can be submitted to us at: