PRIVACY POLICY

Velocity Education Group

A Program of Prioleau Educational Services

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Effective Date: April 3, 2026

Last Updated: April 3, 2026

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INTRODUCTION

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Velocity Education Group ("VEG," "we," "us," or "our"), a program of Prioleau Educational Services, is a 501(c)(3) nonprofit organization dedicated to providing life-skills and social-emotional learning (SEL) curriculum to K-12 schools, with a particular focus on Title I schools. Our curriculum is delivered digitally through our learning platform at velocityedcourses.com, powered by Course Creator 360.

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We are committed to protecting the privacy of all users of our platform, including students, parents and guardians, teachers, and school administrators. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information in connection with our websites (velocityeducationgroup.com and velocityedcourses.com) and our digital learning platform.

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Because we serve students in grades 4 through 12, we take our obligations under the Family Educational Rights and Privacy Act (FERPA) and the Children's Online Privacy Protection Act (COPPA) seriously. We do not use student data for commercial purposes, and we never sell personal information to third parties.

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1. INFORMATION WE COLLECT

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We may collect the following categories of information in connection with our educational services:

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Student Information

- Student first and last name

- Student email address (where provided by the school or district)

- Grade level and age range

- Course enrollment and progress data

- Assessment scores and completion records

- Login credentials and usage activity on the platform

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School and District Information

- School name and district name

- School address and contact information

- Teacher and administrator names and email addresses

- Licensing and enrollment details

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Parent and Guardian Information

- Parent or guardian name and email address (when provided for account verification or consent purposes)

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Technical and Usage Information

- IP address and general location data

- Browser type and device information

- Pages visited and features used on our websites

- Date and time of access

- Cookies and similar tracking technologies (see Section 10)

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2. HOW WE COLLECT INFORMATION

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We collect information through the following means:

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- Directly from schools and districts when they enroll students in our curriculum and set up accounts on our platform.

- Directly from users when they create accounts, log in, complete coursework, or contact us.

- Automatically through cookies and similar technologies when users visit our websites or use our platform.

- From parents or guardians who contact us regarding their child's account.

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3. HOW WE USE INFORMATION

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We use the information we collect solely for educational and operational purposes, including:

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- Delivering and administering our life-skills and SEL curriculum

- Tracking student progress and course completion

- Generating reports for teachers, schools, and districts

- Communicating with schools, educators, and families about our programs

- Improving and developing our curriculum and platform

- Ensuring the security and integrity of our platform

- Complying with applicable laws and regulations

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We do not use student personal information for advertising, marketing to students, or any non-educational commercial purpose. We do not build profiles of students for purposes unrelated to their education.

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4. FERPA COMPLIANCE

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Velocity Education Group operates as a "school official" under the Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. Section 1232g, when we provide services to schools and districts. In this capacity:

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- We access student education records solely to provide our educational services as directed by the school or district.

- We are under the direct control of the school or district with respect to the use and maintenance of education records.

- We do not use student education records for any purpose other than the purpose for which the disclosure was made.

- We do not re-disclose student education records to third parties without authorization from the school or district, unless required by law.

- Schools and districts retain ownership and control of all student education records.

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Schools and districts that use our platform are responsible for providing any required notices to parents and obtaining any necessary consent under FERPA before sharing student information with us.

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5. COPPA COMPLIANCE

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Because our curriculum serves students in grades 4 through 12, some users of our platform may be under the age of 13. We comply with the Children's Online Privacy Protection Act (COPPA), 15 U.S.C. Sections 6501-6506, as follows:

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- We do not knowingly collect personal information from children under 13 without verifiable parental consent or authorization from the child's school or district.

- When schools and districts direct us to collect personal information from students under 13 in an educational context, the school or district acts as the parent's agent and provides consent on the parent's behalf, consistent with COPPA and FTC guidance.

- We collect only the minimum personal information necessary to provide our educational services to children under 13.

- Parents and guardians may review their child's personal information, request its deletion, and refuse to permit further collection by contacting us at the address provided in Section 12 of this policy.

- We do not condition a child's participation in our educational activities on the disclosure of more personal information than is reasonably necessary.

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6. DATA SHARING AND DISCLOSURE

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We share personal information only in the following limited circumstances:

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With Schools and Districts

We share student data, including course progress and completion records, with the school or district that enrolled the student. Schools and districts use this information for educational purposes, including grading, reporting, and program evaluation.

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With Service Providers

We may share information with a limited number of service providers who assist us in operating our platform and delivering our curriculum. These providers are contractually obligated to use the information solely on our behalf and in accordance with this Privacy Policy. Our primary platform provider is Course Creator 360 (a GoHighLevel white-label platform).

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As Required by Law

We may disclose information if required to do so by law, regulation, court order, or other governmental authority.

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We Do Not Sell Personal Information

We do not sell, rent, lease, or trade the personal information of any user, including students, to any third party for commercial purposes. We do not share student data with advertisers or data brokers.

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7. DATA SECURITY

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We implement reasonable administrative, technical, and physical safeguards to protect the personal information in our possession, including:

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- Encryption of data in transit using SSL/TLS protocols

- Secure login credentials and password protections

- Role-based access controls that limit data access to authorized personnel

- Regular review of our data security practices

- Use of a secure, hosted platform (Course Creator 360) with its own security measures

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While we strive to protect personal information, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security but are committed to promptly addressing any security incident in accordance with applicable law.

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8. PARENTAL AND GUARDIAN RIGHTS

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Parents and legal guardians of students using our platform have the following rights:

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- Right to Access: You may request to review the personal information we have collected about your child.

- Right to Correction: You may request that we correct any inaccurate personal information about your child.

- Right to Deletion: You may request that we delete your child's personal information, subject to any legal obligation to retain records.

- Right to Refuse Further Collection: You may refuse to permit further collection of your child's personal information.

- Right to Withdraw Consent: Where consent is required, you may withdraw consent at any time.

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To exercise any of these rights, please contact us using the information in Section 12 below, or contact your child's school or district, which may direct us on your behalf. We will respond to requests within a reasonable timeframe, and no later than required by applicable law.

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Schools and districts may also exercise rights with respect to student data on behalf of parents and students, consistent with FERPA.

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9. STATE STUDENT DATA PRIVACY LAW COMPLIANCE

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In addition to FERPA and COPPA, we are committed to complying with applicable state student data privacy laws, including but not limited to:

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- The Student Online Personal Protection Act (SOPPA) in Illinois

- The Student Privacy Act in California

- The Georgia Student Data Privacy, Accessibility, and Transparency Act

- Similar laws in any state where we provide services

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We enter into data privacy agreements with schools and districts as required by applicable state law. If you have questions about our compliance with any specific state student data privacy law, please contact us using the information in Section 12.

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10. COOKIES AND TRACKING TECHNOLOGIES

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Our websites and platform use cookies and similar technologies to facilitate functionality and improve user experience. The types of cookies we use include:

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Essential Cookies

These cookies are necessary for the operation of our platform. They enable core features such as login authentication, session management, and course navigation. These cookies cannot be disabled without affecting the functionality of the platform.

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Analytics Cookies

We may use analytics cookies to understand how visitors interact with our websites. This information helps us improve our websites and services. Analytics data is collected in aggregate form and does not identify individual students.

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We do not use cookies or tracking technologies to serve targeted advertising to any user, including students. We do not allow third-party advertising networks to collect information through our platform.

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You may manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of our platform.

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11. DATA RETENTION AND DELETION

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We retain student personal information only for as long as necessary to fulfill the educational purposes for which it was collected, or as required by law. Our data retention practices include:

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- Active student records are retained for the duration of the school or district's engagement with our platform.

- Upon termination of our relationship with a school or district, we will delete or de-identify student personal information within a reasonable timeframe, typically no more than 90 days, unless the school or district directs otherwise or retention is required by law.

- Schools and districts may request deletion of student data at any time by contacting us.

- Parents and guardians may request deletion of their child's data as described in Section 8.

- De-identified or aggregated data that cannot reasonably be used to identify an individual student may be retained for program evaluation and improvement purposes.

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12. CONTACT INFORMATION

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If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

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Velocity Education Group

A Program of Prioleau Educational Services

Attn: Privacy Inquiries

818 Bishops Run Lane

Mableton, GA 30126

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Phone: (704) 299-4874

Email: info@velocityedcourses.com

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You may also direct privacy inquiries to:

Marlo Prioleau, Director of Learning & Development

Email: info@velocityedcourses.com

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For concerns related to a specific student's data, we recommend first contacting the student's school or district, which can coordinate directly with us.

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13. CHANGES TO THIS PRIVACY POLICY

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We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or platform capabilities. When we make material changes, we will:

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- Update the "Last Updated" date at the top of this policy

- Post the revised policy on our websites

- Notify schools and districts of material changes via email when feasible

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We encourage you to review this Privacy Policy periodically. Continued use of our platform after changes are posted constitutes acceptance of the revised policy. If changes materially affect the collection or use of student personal information, we will obtain any additional consent required by law.

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14. GOVERNING LAW

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This Privacy Policy is governed by and construed in accordance with the laws of the State of Georgia, without regard to conflict of law principles, and applicable federal laws including FERPA and COPPA.

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15. ACCESSIBILITY

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We are committed to making this Privacy Policy accessible to all users. If you need this policy in an alternative format, please contact us using the information in Section 12.

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Velocity Education Group

A Program of Prioleau Educational Services

501(c)(3) Nonprofit Organization

velocityeducationgroup.com | velocityedcourses.com

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Copyright 2026 Prioleau Educational Services. All rights reserved.