Last Updated: July 8th, 2026

Important, Read This First. This Notice governs only the S²TaR Center digital learning platform accessed through digital.simplesolutions.org (including access via single sign-on providers such as Clever and ClassLink). It does not apply to our marketing website at simplesolutions.org, which is covered by a separate privacy statement and may describe data practices (such as marketing analytics and advertising) that do not apply to the S²TaR Center. The S²TaR Center is an educational service provided to schools, districts, and other educational institutions (“Schools”) and is not used for advertising, marketing to students, or building student profiles for commercial purposes.

1. Our Role; School Authorization (FERPA “School Official”)

Schools control whether and how students and educators use the S²TaR Center. When a School authorizes Simple Solutions to provide the S²TaR Center to its students and educators:

• Simple Solutions acts as a “school official” with a “legitimate educational interest” under the Family Educational Rights and Privacy Act (“FERPA”), 20 U.S.C. § 1232g, and 34 C.F.R. Part 99;
• Simple Solutions acts as the School’s authorized agent/service provider for purposes of the Children’s Online Privacy Protection Act (“COPPA”), 15 U.S.C. §§ 6501–6506, and the FTC’s COPPA Rule, 16 C.F.R. Part 312, in reliance on the School’s consent on behalf of parents for the limited educational purpose of providing the S²TaR Center; and
• Simple Solutions acts as the School’s service provider / processor / school-official designee under applicable state student data privacy laws (such as California’s SOPIPA, New York Ed. Law § 2-d, Connecticut Public Act 16-189, Illinois SOPPA, Colorado HB 16-1423, and similar laws).

Simple Solutions processes Student Personal Information only on documented instructions from the School and only to provide, support, secure, and improve the S²TaR Center for that School.

2. Information We Collect Through the S²TaR Center

We collect only the information needed to provide the S²TaR Center. Specifically:

2.1 Information Provided by the School or SSO Provider

When a School (or its SSO provider such as Clever or ClassLink) provisions accounts, we may receive:

• Student first name, last name, and grade level;
• District-, school-, class-, and teacher-assignment information;
• A School-assigned student identifier (e.g., Clever ID, SIS ID); and
• For educators: name, role, school assignment, and work email.

We do not require or request student Social Security numbers, dates of birth (beyond grade/age band where strictly necessary), home addresses, telephone numbers, biometric identifiers, geolocation, religion, citizenship/immigration status, criminal history, medical/health records, disciplinary records, special education status, or socioeconomic information, and we ask Schools not to send any such data fields to the S²TaR Center.

2.2 Information Generated Through Use of the S²TaR Center

• Assignment, lesson, and assessment activity, responses, scores, progress, and time-on-task; and
• Educator interactions (assignments created, reports viewed).

2.3 Technical/Service Information

• Authentication tokens (e.g., from Clever/ClassLink), session identifiers, device/browser type, operating system, and timestamps; and
• Server logs needed for security, troubleshooting, and integrity of the service.

We do not use advertising cookies, cross-site tracking pixels, marketing analytics, fingerprinting, or any other technology to track students across services or build advertising profiles. (Any cookies/analytics described on our marketing site at simplesolutions.org do not apply to the S²TaR Center.)

3. How We Use Student Personal Information

We use Student Personal Information only to:

1. Provide, maintain, support, secure, and troubleshoot the S²TaR Center;
2. Authenticate users (including via Clever or ClassLink SSO);
3. Deliver assignments, instruction, assessments, and reports to authorized educators and administrators within the authorizing School;
4. Respond to authorized School, parent, or student requests;
5. Comply with our contractual obligations to the School and with applicable law; and
6. Maintain the integrity, security, and proper operation of the S²TaR Center (including detecting and preventing security incidents).

4. What We Do Not Do With Student Personal Information

Consistent with FERPA, COPPA, applicable state student data privacy laws, and our contracts with Schools, we do not:

• Sell, rent, share, or lease Student Personal Information;
• Use Student Personal Information for targeted advertising, behavioral advertising, or marketing of any kind;
• Build personal profiles of students for any purpose other than providing the S²TaR Center as authorized by the School;
• Use Student Personal Information to train, develop, improve, or evaluate any artificial intelligence, machine learning, or other model or algorithm, except (i) where strictly necessary to provide the S²TaR Center to the School and (ii) where any resulting model retains no Student Personal Information and cannot be reverse-engineered to identify any individual;
• Disclose Student Personal Information to data brokers or advertising networks;
• License, sell, or transfer de-identified or aggregated data derived from Student Personal Information to any third party without the School’s prior written consent; or
• Retain Student Personal Information beyond the period reasonably necessary to provide the S²TaR Center to the School.

5. Disclosure of Student Personal Information

We disclose Student Personal Information only to:

• The authorizing School and its authorized educators and administrators;
• Service providers / sub-processors that operate the S²TaR Center on our behalf under written contracts containing student-privacy and security obligations no less protective than those in this Notice (a current list of sub-processors is available upon request);
• As required by law, including in response to lawful subpoenas, court orders, or government requests, with notice to the affected School where legally permitted; and
• In connection with a corporate transaction (merger, acquisition, financing, reorganization, or sale of assets), provided the successor agrees in writing to be bound by privacy and security commitments no less protective than this Notice, and the School is given prior notice and a reasonable opportunity to delete or transfer Student Personal Information before the transaction closes.

6. Sub-Processors and Hosting

We engage a limited number of sub-processors to host, operate, and support the S²TaR Center on our behalf. Each sub-processor is bound by a written agreement requiring privacy and security protections no less protective than those set forth in this Notice, including compliance with FERPA, COPPA, and applicable state student data privacy laws, and the implementation of administrative, technical, and physical safeguards appropriate to the sensitivity of Student Personal Information.

Sub-processors are permitted to process Student Personal Information only to provide the S²TaR Center to the authorizing School and only in accordance with our documented instructions.

A current list of sub-processors used to operate the S²TaR Center is available to Schools upon request to privacy@simplesolutions.org.

7. Data Security

We maintain a written information security program with administrative, technical, and physical safeguards designed to protect Student Personal Information against unauthorized access, use, alteration, disclosure, loss, or destruction. Our safeguards are reasonably designed in light of the nature of the Student Personal Information we process and the risks associated with the S²TaR Center, and we periodically review and update them as needed.

We require our personnel and sub-processors with access to Student Personal Information to comply with confidentiality and information-security obligations consistent with this Notice and applicable law.

No information system can be guaranteed to be completely secure, but we work continuously to protect the information entrusted to us.

8. Security Incident Notification

If we confirm a security incident affecting Student Personal Information, we will notify the affected School without undue delay, and in any event within forty-eight (48) hours after discovery, and will reasonably cooperate with the School’s investigation, mitigation, regulatory notification, and individual-notification obligations.

9. Data Retention, Return, and Deletion

We retain Student Personal Information only for as long as needed to provide the S²TaR Center to the authorizing School (typically for the duration of the School’s subscription term and a short post-termination wind-down).

Upon expiration or termination of the School’s subscription, or upon the School’s earlier written request, Simple Solutions will, at the School’s election:

• Return Student Personal Information to the School in a commercially reasonable, machine-readable format within thirty (30) days; and/or
• Securely delete all Student Personal Information from production and non-production systems within thirty (30) days, subject to a short retention period for routine backup cycles after which such information will be overwritten or rendered unrecoverable.

10. Parent and Eligible Student Rights

Under FERPA, parents (and eligible students, generally those 18 or older or attending a postsecondary institution) generally have the right to:

• Inspect and review education records held by the School;
• Request correction of information believed to be inaccurate or misleading; and
• Consent to certain disclosures of personally identifiable information.

These rights are exercised through the School, which controls the education record. Because Simple Solutions acts only on behalf of the School, please direct FERPA requests to your School or district in the first instance. Simple Solutions will reasonably and promptly assist Schools in responding to such requests at no additional charge.

Parents and eligible students may also contact Simple Solutions directly at privacy@simplesolutions.org, and we will route the request to the appropriate School and assist as authorized.

11. Children Under 13 (COPPA)

The S²TaR Center is a school-provided educational service. We collect personal information from children under 13 only at the direction of, and under the authorization of, the School, which acts as the parent’s agent for purposes of COPPA solely to enable the educational use of the S²TaR Center. We use such information only to provide the S²TaR Center to the School and never for advertising, marketing, profiling, or any commercial purpose unrelated to the educational service.

Parents who wish to review, correct, or request deletion of their child’s information should contact the School (or contact us at privacy@simplesolutions.org and we will coordinate with the School).

12. State Student Data Privacy Laws

Simple Solutions complies with applicable state student data privacy laws, including but not limited to: California SOPIPA and AB 1584; New York Education Law § 2-d and Parents’ Bill of Rights; Connecticut Public Act 16-189; Illinois SOPPA; Colorado HB 16-1423; and similar laws. Where required by the School’s jurisdiction, Simple Solutions will enter into a state-specific data privacy agreement (including, where applicable, the NDPA standard contract) and will post or make available the disclosures required by such law.

13. Changes to This Notice

We may update this Notice from time to time to reflect changes in law, technology, or our practices. We will post the updated Notice at https://digital.simplesolutions.org/ and update the “Last Updated” date. For material changes affecting Student Personal Information, we will provide reasonable advance notice to Schools and will not apply the changes retroactively to previously collected Student Personal Information in a manner that is materially less protective without the School’s consent.

14. Contact Us

Questions, requests, or concerns about this Notice or the S²TaR Center’s privacy practices may be directed to:

Simple Solutions Learning, Inc.
Attn: Privacy Officer
24755 Highpoint Road
Beachwood, Ohio 44122
Email: privacy@simplesolutions.org
Phone: 877-382-7537