Privacy Policy

Last Updated: October 22, 2025

We at SkilRedi, Inc. (“SkilRedi”) know you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our Privacy Policy.

By using or accessing the Site or Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.

Remember that your use of SkilRedi’s Site and Services is at all times subject to the SkilRedi Terms of Service, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service.

What does this privacy policy cover?

This Privacy Policy covers our treatment of personally identifiable information (“Personal Information”) that we gather when you are accessing or using our Services, or when someone is viewing or accessing the Services on your behalf, such as an administrator for an institution or other organization sponsoring your enrollment. We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information internally in connection with our Services, including to personalize, provide, and improve our Services, to allow you to set up a SkilRedi Account and profile, to contact you and allow other users to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some Personal Information with third parties, but only as described below.

In some cases, the Site and Services are integrated with services or content provided by third parties not affiliated with SkilRedi (“Third-Party Content”). Third-Party Content linked to or embedded on the Site is governed by the privacy policies of those third parties. Your use of Third-Party Content is subject to each third-party site’s privacy policy, which may be different from ours. We have no control over the information that is collected, stored, or used by Third-Party Content.

Certain SkilRedi products and services are intended to be used by children located in the United States under the age of 13, for educational purposes only. We presume that schools or other organizations act as agents on behalf of parents and that a school’s or organization’s authorization for the collection of students’ Personal Information is based upon the school obtaining all legally required consents. For information regarding our compliance with the Children’s Online Privacy Protection Act (COPPA), please see our COPPA Notice below.

Information you provide to us

We receive and store any information you knowingly provide to us. For example, through the registration process and/or through any courses you register for through our Site and Services, we may collect Personal Information such as your name, email address, highest level of education completed, birth year, gender, ethnicity, zip code, and country. Disclosing some of this information is optional. You may also choose to share additional information in the profile associated with your SkilRedi Account, but this is not required. Certain information may be required to register with us or to take advantage of some of our features.

We may communicate with you if you’ve provided us with the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers on behalf of other businesses or email you about your use of the Services. If you do not want to receive communications from us, please indicate your preference in your SkilRedi Account settings.

Information Collected Automatically

Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geolocation data, device identification, “cookie” information, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. In some jurisdictions, we are not permitted to send cookies to your browser without your prior expressed consent. In this case, we will seek such consent. This section assumes that either the use of cookies is not restricted by applicable law, or if it is restricted that the individual has explicitly consented to the use of the cookies. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features. If you click on a link to a third-party website or service, such third party may also transmit cookies to you. Again, this Privacy Policy does not cover the use of cookies by any third parties, and we aren’t responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honor “Do Not Track” requests you have set using your browser or device.

We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services – for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.

Information That’s Been De-Identified

We may de-identify your Personal Information so that you are not identified as an individual and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose de-aggregated usage or de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual.

How does SkilRedi use Personal Information collected?

We use information about you for the legitimate business purposes listed below:

To provide you with access to the Services. For example, your information will be used to set up and maintain your SkilRedi Account, host the Service, backup and restore the Service, provide customer service, and verify user information.

To ensure quality, maintain safety, and improve the Services. For example, by providing upgrades and new versions of our Services. Or, for example, by monitoring and analyzing how users interact with our Services so we can create new features that we think our users will enjoy or make our Services easier to use.

To protect the Services, our users, and the public. For example, by detecting security incidents; detecting and protecting against malicious, deceptive, fraudulent, or illegal activity; fighting spam; complying with our legal obligations; and protecting the rights and property of SkilRedi and others, which may result in us, for example, declining a transaction or terminating services or features.

To fix problems with the Services. For example, by monitoring, debugging, repairing, and preventing issues.

To support scientific research. For example, in the areas of cognitive science and education, utilizing user information to assist in conducting research about how learners access and master course materials online.

To customize the user experience. For example, to personalize your experience by serving you relevant notifications and advertisements for our Services and recommending content.

To communicate with you. For example, by emailing you to ask for your feedback, share tips for getting the most out of the Services, or keep you up to date on SkilRedi. If you don’t want to hear from us, you can opt out of marketing communications at any time. (If you opt out, we’ll still send you important updates and transactional information relating to your account including without limitation alerts highlighting updates to this privacy policy and our terms of service.)

As otherwise described to you at the time of collection, or with your consent.

Will SkilRedi share any of the Personal Information it receives?

We do not rent or sell your Personal Information in personally identifiable form to anyone, except as expressly provided below. We may share your Personal Information with third parties as described in this below:

Instructors:

Instructors receive your Personal Information when you enroll or participate in their courses or programs through the Site.

Third-Party Providers:

We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you, as described in more detail below:

• We utilize a third-party vendor to monitor and assess the integrity of your course activity, including when you participate in remote proctoring or other course facilitation processes;
• We utilize Qualtrics to provide user surveys throughout the courses to gather additional information about how users progress through the courses, allowing us to generate reporting metrics and evaluate course effectiveness;
• We utilize Amazon Web Services for service hosting;
• We use New Relic to monitor platform performance and user experience;
• We utilize Zendesk for customer support management; and
• We use YouTube, provided by Google, for video lectures throughout the Site and in the Services. By using Services that incorporate these video lectures, you must agree to be bound to the YouTube Terms of Service and Google Privacy Policy. We encourage you to review those third-party terms and policies prior to use.

Unless we tell you differently, these third-party providers do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. They are also required to handle Personal Information in a confidential manner and maintain reasonable security practices.

User Profiles and Submissions:

Certain user profile information, including your name, location, and any video or image content that such user has uploaded to the Services, may be displayed to other users to facilitate user interaction within the Services or address your request for our services. Please remember that any content you upload to your public user profile, along with any Personal Information or content that you voluntarily disclose online in a manner other users can view (on discussion boards, in messages and chat areas, etc.) becomes publicly available and can be collected and used by anyone. Your username may also be displayed to other users if and when you send messages or comments or upload images or videos through the Services and other users can contact you through messages and comments.

Employers and Sponsors:

We may share your Personal Information with employers, government programs, institutions, or other enterprises that sponsor your enrollment in a course for training or other educational purposes. If an entity pays for or otherwise sponsors your obtaining of a certificate or course participation, SkilRedi will share Personal Information with the entity as necessary to confirm your enrollment, participation, progress, and completion status in that course.

Business Transfers:

We may choose to buy or sell assets and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.

Legally Required Disclosures

We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law or court order; enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of SkilRedi, our employees, our users, or others.

Is Personal Information about me secure?

Your SkilRedi Account is protected by a password for your privacy and security. You must prevent unauthorized access to your SkilRedi Account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your SkilRedi Account.

We endeavor to protect the privacy of your SkilRedi Account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. We do use our commercially reasonable efforts to have safeguards in place to protect your Personal Information.

SkilRedi is a United States based company. The information about you that we process when you use the Services in your country may be used, stored, and/or accessed by individuals or organizations operating outside your country. By accessing or using our Services, you expressly consent to the transfer of your information outside of your country. Such countries may have laws which are different, and potentially not as protective, as the laws of your own country. Where required by applicable law, we will take additional safeguards with respect to your information in connection with such transfers.

If we learn of a security breach impacting our Site or Services involving your Personal Information, we may attempt to notify you electronically so that you may take appropriate protective steps. Additionally, we may post a notice on the homepage of the Site (SkilRedi.com), or elsewhere on the Site, and may send an email to you at the email address associated with your SkilRedi Account. Depending on where you are located, you may have a legal right to receive notice of a security breach involving your Personal Information in writing, in which case SkilRedi shall comply with such applicable law.

How long does SkilRedi retain my Personal Information?

SkilRedi will retain your Personal Information for as long as your SkilRedi Account is active, or as needed to: provide you with Services you have requested; maintain a record of your transactions for financial reporting, audit, and compliance purposes; or comply with our legal obligations, resolve disputes, enforce our agreements, and as otherwise permitted by applicable law.

Upon your request that SkilRedi deactivate your SkilRedi Account and delete your information (such deletion rights further described below), SkilRedi will, within 30 days of your request, follow the process described below in “Delete SkilRedi Account and Personal Information,” including, without limitation, archiving your course data (in a manner and to the extent permitted by applicable law).

What Personal Information can I access?

Through your account settings, you may access, and, in some cases, edit or delete certain information you have provided to us.

Please note that usernames cannot be changed. Usernames identify you in courses you are enrolled in and elsewhere on the Site. SkilRedi encourages you to use discretion in choosing your username. To protect your identity, you may consider not using your actual name or a name easily identifiable to you as your username. Your account dashboard lists all current and archived courses in which you have enrolled and includes links to any certificates you may have earned. You may download copies of your earned certificates directly from your SkilRedi Account. The information you can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information we have on file about you, please contact SkilRedi learner support at contact@skilredi.com.

What choices do I have?

You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.

You may be able to add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.

Under certain circumstances, by law, you have the right to request erasure of your personal data. This enables you to ask us to delete or remove personal data and to stop processing it, as further described below. To request the deletion of personal data, please refer to the information in the section below, and for further information and assistance please reach out to contact@skilredi.com.

Delete SkilRedi Account and Personal Information

To request deletion of your SkilRedi Account and Personal Information, you should click the button labeled “Delete my account” in your SkilRedi Account settings. Because this is a permanent action and cannot be reversed, SkilRedi may ask you to complete an authentication process that aims to confirm your authority to manage the SkilRedi Account affected by your request. With respect to your SkilRedi Account, SkilRedi will then permanently:

• Deactivate your SkilRedi Account;
• Remove the active profile;
• Retire your username, and;
• Remove you from SkilRedi email lists.

California Residents

The California Consumer Privacy Act (CCPA) provides California consumers with the right to request access to their personal data, additional details about our information practices and deletion of their personal information (subject to certain exceptions). California consumers also have the right to opt out of sales of personal information, if applicable. We describe how California consumers can exercise their rights under the CCPA below. Please note that you may designate an authorized agent to exercise these rights on your behalf by providing written materials demonstrating that you have granted the authorized agent power of attorney. Please note that if an authorized agent submits a request on your behalf, we may need to contact you to verify your identity and protect the security of your personal information. We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the consumer about whom we collected personal information. We will not discriminate against you if you choose to exercise your rights under the CCPA.

You may request, no more than twice in a twelve (12) month period, access to the specific pieces of personal data we have collected about you in the last twelve (12) months. You may also request additional details about our information practices, including the categories of personal information we have collected about you, the sources of such collection, the categories of personal information we share for a legitimate business or commercial purposes, and the categories of third parties with whom we share your personal information. You may make these requests by contacting using the contact information provided below in the “How to Contact Us” Section below. After submitting your request, please monitor your email for a verification email. We are required by law to verify your identity prior to granting access to your data in order to protect your privacy and security.

You may request, no more than twice in a twelve (12) month period, transportable copies of your personal information that we have collected about you in the last twelve (12) months. You may make these requests by contacting using the contact information provided below in the “How to Contact Us” Section. After submitting your request, please monitor your email for a verification email. We are required by law to verify your identity prior to granting access to your data in order to protect your privacy and security.

You may request that we delete the personal information we have collected about you. Please note that we may retain certain information as required or permitted by applicable law. You may make these requests by contacting us using the contact information provided below in the “How to Contact Us” Section below. After submitting your request, please monitor your email for a verification email. We are required by law to verify your identity prior to granting access to your data in order to protect your privacy and security.

California residents are entitled to ask us for a notice identifying the categories of personal information which we share with our affiliates and/or third parties for marketing purposes and providing contact information for such affiliates and/or third parties. If you are a California Resident and would like to exercise your rights under CCPA, please submit a written request using the information provided in the “How to Contract Us” section below. Our privacy team will examine your request and respond to you as quickly as possible.

The Family Educational Rights and Privacy Act (“FERPA”)

All capitalized terms used herein that are not otherwise defined shall have the meaning given to them in FERPA. During the course of offering certain Services, we may have access to Student Data. “Student Data” is any information that is directly related to an identifiable current or former student that is maintained by a school, school district, or related organization, or by us. Student Data may include “Educational Records” as defined by FERPA. We consider Student Data to be highly confidential and have access to Student Data only as requested by the Educational Organization as needed to perform the Services. For these purposes, SkilRedi is deemed a “School Official” with “legitimate educational interests.” The type of Student Data we collect will depend on how the Educational Organization uses the Services. Student Data that we access, if any, is owned and controlled by the Educational Organization, and we only use such Student Data to provide the Services or for other limited purposes permitted by our agreements with the Educational Organizations, such as to evaluate, improve and develop our products and Services. We may be required to share Student Data with law enforcement or other third parties when compelled to do so by a court order or other legal process, to comply with statutes or regulations, to enforce our Terms of Service, or if we believe in good faith that the disclosure is necessary to protect the rights, property or personal safety of our users. We do not rent or sell Student Data.

Under FERPA, SkilRedi meets the definition of a school official. As such, the Educational

Organization may act as a parent or guardian’s agent and can consent to collection of their students’ information on the parent or guardian’s behalf. Parents do have certain rights over minor children’s information. Parents may review their child’s Personal Information, direct their child’s school or district to delete it, and refuse to allow any further collection or use of the child’s Personal Information. Because the Student Data is entrusted to us under the direct control of the Educational Organization, if parents would like to exercise any of the above-mentioned rights, a parent should directly contact their child’s school or district.

COPAA Notice

When it comes to the collection of Personal Information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. If you are the parent or guardian and believe your child has provided us with Personal Information that you do not wish for us to have, please contact us at the address below to request deletion.

Will SkilRedi ever change this Privacy Policy?

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will use commercially reasonable efforts to alert you to changes by placing a notice on the Services, by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

How to contact us?

If you have any questions or concerns regarding our privacy policies, please send us a detailed message at contact@skilredi.com and we will try to resolve your concerns. You can also attempt to contact us via the postal service at PO Box 26601, 100 Orchard Park Drive, Greenville, SC 29616.

K-12 Student Data Privacy and Protection Addendum

Last Updated: October 23, 2026

This K-12 Student Data Privacy and Protection Addendum (“Addendum”) applies to the provision of the SkilRedi platform, digital learning content, simulations, assessments, workforce and career-readiness resources, and related educational services (“Services”) by SkilRedi, Inc. (“SkilRedi”) to any public or private school, school district, local educational agency, state educational agency, charter school, career and technical education program, or other K-12 educational organization (“Educational Organization”) in the United States.

This Addendum constitutes the agreement between SkilRedi and the Educational Organization concerning Student Data, and supplements SkilRedi’s Terms of Service (“Terms”) and Privacy Policy. Capitalized terms used but not defined in this Addendum shall have the terms ascribed to them in the Terms.

1. Purpose

SkilRedi provides technology-enabled educational and workforce-development Services designed to support teaching, learning, career exploration, career and technical education, workforce readiness, assessment, and related educational activities.

When SkilRedi receives or maintains Student Data on behalf of an Educational Organization, SkilRedi will process such Student Data solely for authorized educational purposes and in accordance with this Addendum, the Terms, Privacy Policy, and applicable law.

2. Applicable Student Privacy Laws

SkilRedi will provide the Services in a manner designed to comply with applicable federal and state laws governing the privacy, security, confidentiality, and protection of K-12 Student Data, including, as applicable:

• the Children’s Online Privacy Protection Act and Rule (“COPPA”), 15 U.S.C. §§ 6501-6506 and 16 C.F.R. Part 312;
• the Protection of Pupil Rights Amendment (“PPRA”), 20 U.S.C. § 1232h;
• applicable provisions of the Children’s Internet Protection Act (“CIPA”) to the extent relevant to the Services and the respective responsibilities of the parties;
• applicable state student privacy, student records, educational technology, data security, and data governance laws and regulations; and
• applicable legally binding requirements governing the Educational Organization’s use of Student Data.

Where applicable law provides protections for Student Data greater than those established by this Addendum, SkilRedi will comply with those requirements to the extent applicable to SkilRedi and the Services being provided.

3. Definition of Student Data

“Student Data” means personally identifiable information or other information relating to an identifiable K-12 student that is provided to SkilRedi by or on behalf of an Educational Organization, student, parent, or guardian, or that is generated through a student’s authorized use of the Services, and that is protected under applicable student privacy law.

Student Data may include, as applicable, student identifiers, account information, educational records, course or program participation, learning activities, assessment information, progress information, credentials, and other information necessary to provide the Services. A representative description of these categories, the purposes for which they are used, and applicable retention triggers is set forth in Exhibit A.

Student Data does not include information that has been lawfully de-identified or aggregated so that it cannot reasonably be used to identify an individual student.

4. Educational Purpose and Limited Use

SkilRedi will collect, access, use, maintain, and disclose Student Data only as reasonably necessary to:

1. provide and support the Services authorized by the Educational Organization;
2. administer student accounts and educational activities;
3. deliver instructional content, simulations, assessments, and career or workforce-development experiences;
4. provide authorized reporting, analytics, and program-support functions;
5. maintain, secure, troubleshoot, and improve the operation and effectiveness of the Services;
6. comply with applicable law; or
7. carry out other purposes specifically authorized by the Educational Organization and permitted by applicable law.

SkilRedi will not use Student Data for purposes materially unrelated to providing the authorized educational Services.

5. FERPA and School Official Status

To the extent an Educational Organization discloses education records to SkilRedi pursuant to FERPA’s school-official exception, SkilRedi shall be considered a School Official (as deinfed under FERPA) with a legitimate edicationsl interest and performing an institutional service or function for which the Educational Organization would otherwise use employees or other authorized parties.

For purposes of such Student Data, SkilRedi will:

1. remain under the direct control of the Educational Organization with respect to the use and maintenance of education records as required by FERPA;
2. use personally identifiable information from education records only for the purposes for which it was disclosed;
3. limit access to personnel and authorized service providers with a legitimate need for such access;
4. not redisclose personally identifiable information from education records except as authorized by the Educational Organization or as otherwise permitted or required by law; and
5. reasonably assist the Educational Organization in fulfilling applicable FERPA obligations associated with Student Data maintained through the Services.

6. COPPA and Students Under Age 13

When an Educational Organization authorizes SkilRedi to collect information from students under age 13 in connection with the Services, the Educational Organization shall be solely responsible for making all disclosures required for and obtain and maintain all required authorizations and consents from the students parents and guardians. SkilRedi shall rely all such authorizations or consents to the extent permitted by COPPA. SkilRedi shall use the information collected through the Services solely for the purpose of the Services and for the use and benefit of the Educational Organization.

SkilRedi will provide the Educational Organization with appropriate notice regarding the collection, use, and disclosure of children’s personal information as required by COPPA.

Where parental consent is required directly from a parent or guardian rather than through an Educational Organization, SkilRedi will obtain such consent as required by COPPA. If any parent or guardian does not provide such consent, SkilRedi will not collect or use information from the applicable student and such student shall not be permitted to use the Services.

SkilRedi will not condition a child’s participation in an educational activity on the disclosure of more personal information than is reasonably necessary for that activity.

7. Ownership and Control of Student Data

As between SkilRedi and the Educational Organization, SkilRedi does not acquire ownership of Student Data by providing the Services.

Student Data remains subject to the rights and control of the Educational Organization, student, parent, or guardian as established by applicable law.

Nothing in this Addendum transfers ownership of SkilRedi’s platform, software, curriculum, simulations, digital assets, methodologies, intellectual property, or other proprietary materials to the Educational Organization.

8. Prohibition on Sale and Advertising

SkilRedi will not:

1. sell Student Data;
2. rent or trade Student Data;
3. use Student Data for targeted advertising directed to a student;
4. use Student Data to create a commercial profile of a K-12 student except for an authorized educational purpose; or
5. disclose Student Data to third parties for their independent advertising or marketing purposes.

Nothing in this section prohibits communications concerning the Educational Organization’s authorized use of the Services or educational opportunities requested or authorized by the Educational Organization. The prohibitions in this Section 8 apply to advertising and profiling conducted on or off SkilRedi’s platform, and may not be waived by parental, student, or Educational Organization consent. For purposes of this Section 8, “targeted advertising” means advertising directed to a student based on the student’s personal information, behavior, or activity gathered over time and across services, and does not include contextual advertising based solely on the content of a single page or session, or adaptive or personalized learning features that adjust instructional content based on a student’s own performance within the Services.

9. Data Minimization

SkilRedi will seek to collect and maintain only Student Data reasonably necessary to provide, administer, support, secure, and improve the authorized Services or otherwise satisfy applicable legal or contractual obligations.

10. Security Safeguards

SkilRedi will maintain reasonable and appropriate administrative, technical, and organizational safeguards designed to protect Student Data against unauthorized access, use, disclosure, alteration, loss, or destruction.

Such safeguards will be reasonably appropriate to the nature and sensitivity of the Student Data maintained and may include, as appropriate:

• access controls;
• authentication;
• encryption of Student Data in transit and at rest using industry-standard algorithms;
• system monitoring and logging;
• vulnerability and security management;
• backup and recovery procedures;
• personnel confidentiality requirements; and
• reasonable security practices for service providers with access to Student Data.

11. Authorized Personnel

Access to identifiable Student Data will be limited to SkilRedi personnel and authorized service providers who reasonably require access to perform functions associated with the Services.

Persons authorized to access Student Data will be subject to appropriate confidentiality, privacy, and security obligations.

SkilRedi will provide privacy and security training to personnel, and will require subprocessors to provide equivalent training to their personnel, before such personnel are granted access to Student Data, and will designate one or more responsible individuals accountable for Student Data privacy and security compliance under this Addendum.

12. Service Providers and Subprocessors

SkilRedi may use hosting providers, cloud infrastructure providers, technology vendors, analytics providers, and other service providers reasonably necessary to provide or support the Services.

Where a service provider has access to protected Student Data, SkilRedi will require the service provider to maintain confidentiality and security protections appropriate to the information and to process Student Data only for authorized purposes.

SkilRedi remains responsible for its obligations under this Addendum with respect to Student Data processed by such service providers to the extent required by applicable law.

SkilRedi will maintain a current list of subprocessors with access to Student Data and will provide that list to the Educational Organization at least annually and upon reasonable written request. SkilRedi will require each subprocessor to comply with privacy, security, and data deletion obligations equivalent to those set forth in this Addendum.

13. Artificial Intelligence and Automated Technologies

To the extent SkilRedi uses artificial intelligence, machine learning, digital-twin technology, adaptive learning, or automated technologies in connection with the Services, identifiable Student Data will be used only for authorized educational and operational purposes consistent with this Addendum.

SkilRedi will not use identifiable K-12 Student Data to train a general-purpose artificial intelligence model for unrelated commercial purposes unless separately authorized by the Educational Organization and permitted by applicable law.

14. Security Incidents

SkilRedi will maintain procedures for identifying and responding to confirmed unauthorized access to or acquisition, use, or disclosure of protected Student Data.

Following confirmation of a security incident affecting Student Data, SkilRedi will notify the affected Educational Organization within three (3) business days of such confirmed determination, or within any shorter period required by applicable law.

The notification will provide information reasonably available to SkilRedi concerning the nature and scope of the incident and the steps being taken in response.

SkilRedi will reasonably cooperate with the Educational Organization in investigating and responding to the incident.

Where applicable law requires notice to parents or guardians of an affected student, SkilRedi will reasonably cooperate with the Educational Organization’s parent notification process, including by providing information reasonably necessary for the Educational Organization to prepare that notice.

15. Parent, Guardian, and Student Rights

SkilRedi will reasonably assist Educational Organizations in responding to legally valid requests from parents, guardians, or eligible students to access, inspect, correct, or delete Student Data maintained through the Services.

When SkilRedi maintains Student Data on behalf of an Educational Organization, requests concerning education records may be directed to the Educational Organization so that it can determine and exercise the rights applicable under FERPA and other law.

Nothing in this Addendum limits rights independently available to a parent, guardian, or student under applicable law.

Upon the Educational Organization’s request, SkilRedi will: (a) identify the Student Data it holds regarding the requesting student; (b) make commercially reasonable corrections to inaccurate Student Data as directed by the Educational Organization; and (c) complete such assistance within a reasonable time, and in any event within the timeframe reasonably specified by the Educational Organization to meet its own legal deadlines.

16. Educational Organization Access and Control

Upon reasonable request and subject to appropriate security procedures, the Educational Organization may access Student Data maintained by SkilRedi on its behalf as reasonably necessary to fulfill its educational, administrative, or legal responsibilities.

The Educational Organization may request correction, export, return, or deletion of Student Data where required by applicable law or the parties’ agreement.

17. Retention, Return, and Deletion

SkilRedi will retain identifiable Student Data only for as long as reasonably necessary to:

1. provide the Services;
2. satisfy the purposes for which the information was collected;
3. meet the Educational Organization’s documented requirements; or
4. comply with applicable legal obligations.

Following termination or expiration of the applicable Services, SkilRedi will, upon request of the Educational Organization and subject to applicable legal requirements, return, delete, destroy, or render de-identified Student Data within sixty (60) days of such request, except as provided in Section 29.

At the Educational Organization’s request at any time during the term of the applicable Services, SkilRedi will delete, destroy, transfer, or render de-identified the specified Student Data within the same sixty (60) day period described above, subject to Section 29. Upon written request, SkilRedi will provide written certification that the requested Student Data has been deleted or destroyed in accordance with this Section.

Nothing in this section requires deletion of information that SkilRedi is legally required to retain, provided that such retained information remains protected under this Addendum and is not used for another purpose.

18. De-Identified and Aggregated Data

SkilRedi may create and use aggregated or de-identified information for legitimate purposes including improving educational content and Services, evaluating educational and workforce-development programs, improving platform performance, research and program evaluation, measuring outcomes, developing educational and workforce insights, and supporting product and curriculum development.

Such information must be de-identified so that it cannot reasonably be used to identify an individual student.

SkilRedi will not attempt to re-identify properly de-identified Student Data except where necessary to test or validate de-identification processes or as otherwise permitted by applicable law.

19. Student Surveys and Sensitive Information

Where the Services are used to administer surveys, assessments, or activities involving information protected by PPRA or similar state laws, the Educational Organization will determine whether parental notice, consent, or an opportunity to opt out is required.

SkilRedi will reasonably cooperate with the Educational Organization in implementing requirements applicable to the Services.

20. State-Specific Student Privacy Requirements

SkilRedi recognizes that states may establish additional requirements governing K-12 Student Data.

When providing Services to an Educational Organization in a state with applicable student-data privacy requirements, SkilRedi will comply with those requirements to the extent they apply to SkilRedi and the Services.

If a state-specific legal requirement conflicts with this Addendum, the applicable state requirement will control to the extent of the conflict.

The parties may execute additional state-specific terms when reasonably necessary to satisfy mandatory requirements applicable to a particular Educational Organization.

21. Data Location and Cross-Border Processing

SkilRedi will maintain reasonable oversight of the systems and service providers used to process Student Data.

Where an Educational Organization is subject to a mandatory requirement concerning the geographic storage or processing of Student Data, the parties may establish appropriate requirements in the applicable agreement.

22. Legal Requests for Student Data

If SkilRedi receives a legally binding request for Student Data from a governmental or other third party, SkilRedi will, to the extent legally permitted, notify the Educational Organization before disclosure and will disclose only information legally required to be disclosed.

23. Changes Affecting Student Data

Unless required to maintain compliance with applicable law, SkilRedi will not materially change its practices concerning the collection, use, or disclosure of K-12 Student Data in a manner inconsistent with this Addendum without providing appropriate notice and obtaining any authorization required by applicable law.

24. Educational Organization Responsibilities

The Educational Organization remains responsible for fulfilling obligations imposed directly upon it by applicable law, including determining the educational purposes for which the Services are used and providing notices or obtaining consents that the law specifically requires the Educational Organization to provide or obtain.

25. Conflict with Other SkilRedi Policies

If this Addendum conflicts with SkilRedi’s generally applicable Privacy Policy or Terms of Service concerning the collection, use, disclosure, retention, or protection of K-12 Student Data, this Addendum will control with respect to such Student Data.

If a separately executed agreement between SkilRedi and an Educational Organization establishes additional or more specific student-data requirements, the executed agreement will control to the extent of the conflict.

26. Changes in Law

Federal and state student privacy requirements may change from time to time. SkilRedi may update this Addendum as reasonably necessary to address changes in applicable law, regulation, regulatory guidance, technology, or the Services.

Material changes affecting the rights or obligations of an Educational Organization concerning Student Data will be communicated as required by applicable law or agreement.

27. No Waiver of Statutory Rights

Nothing in this Addendum is intended to waive or limit any right or protection that cannot lawfully be waived under applicable federal or state law.

28 Limitation of Liability

Except for claims arising from SkilRedi’s gross negligence, willful misconduct, or failure to implement industry-standard data protections as required under this Addendum, SkilRedi’s aggregate liability to the Educational Organization arising out of or relating to this Addendum, whether in contract, tort, or otherwise, shall not exceed $5,000.00. IN NO EVENT SHALL SKILREDI BE LIABLE FOR ANY PUNITIVE, CONSEQUENTIAL, SPECIAL, AND/OR INDIRECT DAMAGES, INCLUDING, BUT NOT LIMITED TO, LOSS OF GOOD WILL, PROFITS OR BUSINESS. Nothing in this section limits any right or remedy that cannot be limited or waived as a matter of applicable law.

29 Disaster Recovery and Backup Data

Notwithstanding Section 17, Student Data retained solely within SkilRedi’s encrypted backup, snapshot, or disaster-recovery systems is not required to be actively deleted, provided that such retained data (a) is not accessible for operational or production use, (b) is not used for any purpose other than disaster recovery or business continuity, and (c) is purged in the ordinary course consistent with SkilRedi’s standard backup retention schedule, not to exceed [__] following the corresponding production deletion.

30 Audit Rights

Any audit or inspection right available to the Educational Organization under applicable law or this Addendum is limited to the Educational Organization’s own Student Data, and any such audit shall be conducted upon reasonable prior written notice, no more than once in any twelve-month period absent a confirmed security incident affecting the Educational Organization’s Student Data, during SkilRedi’s normal business hours, and subject to reasonable confidentiality protections for SkilRedi’s systems, other customers’ data, and proprietary information. Educational Organization and its auditors will maintain the confidentiality of any confidential information and trade secrets of SkilRedi may be accessed or learned during an audit conducted under this Addendum.

31 Governing Law and Venue

This Addendum shall be governed by the laws of the United States and the State of South Carolina, without regard to conflict-of-laws principles. The parties consent to the exclusive jurisdiction and venue of the state and federal courts located in South Carolina for any dispute arising out of or relating to this Addendum.

32 Successors;Change in Control

This Addendum shall be binding upon Educational Organization and SkilRedi and their respective successors. Neither party shall assign this Addendum without the prior written consent of the other party; provided that SkilRedi may assign this Addendum and its rights and obligations herein to a successor entity in connection with any sale of all or substantially all of the assets of SkilRedi relating to the Services, whether by sale of assets or securities, merger, acquisition, consolidation or other business reogranazation (“Change of Control”). In the event of any such Change of Control, Educational Organization consents to the transfer of any Student Date relating to the Services to the successor entity, including SkilRedi’s rights to use such Student Data as set forth in this Addendum, provided that such successor entity shall assume SkilRedi’s obligations under this Addendum and SkilRedi shall notify the Educational Organization within thirty (30) days of completion of the Change of Control transaction.

33 Cooperation with Public Disclosure Obligations

Where applicable law requires an Educational Organization to publicly post, publish, or otherwise disclose the existence, terms, or content of this Addendum, or to include SkilRedi on a public list of technology or service providers with access to Student Data, SkilRedi will reasonably cooperate with the Educational Organization in fulfilling that obligation, including by providing summary information about the categories of Student Data collected and the purposes for which it is used as required by applicable law.

34. Order of Precedence

With respect to K-12 Student Data, the following order of precedence will apply:

1. mandatory applicable federal or state law;
2. a separately executed agreement or data privacy agreement between SkilRedi and the Educational Organization;
3. this Addendum, including any exhibits;
4. SkilRedi’s Privacy Policy; and
5. SkilRedi’s generally applicable Terms of Service.

35. Contact

Questions regarding this Addendum, Student Data, or SkilRedi’s K-12 privacy practices may be directed to:

SkilRedi, Inc.
PO Box 26601
100 Orchard Park Drive
Greenville, South Carolina 29616
Email: contact@skilredi.com

ACCEPTANCE BY EDUCATIONAL ORGANIZATION

This Addendum may be incorporated by reference into an agreement for SkilRedi Services or executed separately by the parties.

SKILREDI, INC.

By: ______________________________

Name: ____________________________

Title: _____________________________

Date: _____________________________

EDUCATIONAL ORGANIZATION

Organization: ______________________

By: ______________________________

Name: ____________________________

Title: _____________________________

Date: _____________________________

EXHIBIT A: CATEGORIES OF STUDENT DATA, PURPOSES, AND RETENTION TRIGGERS

This Exhibit A provides a representative description of the categories of Student Data processed by SkilRedi under this Addendum, the purposes for which each category is used, and the retention trigger applicable under Section 17. This Exhibit may be updated by mutual written agreement to reflect the Services actually configured for the Educational Organization, and does not expand the categories, purposes, or retention terms otherwise permitted under this Addendum.

1. Category: Student identifiers and account information. Purpose: Administer student accounts and educational activities (Section 4(b)). Retention Trigger: deleted, destroyed, or de-identified within sixty (60) days of the Educational Organization’s request or termination of the applicable Services, subject to Section 2.
2. Category: Educational records (e.g., grades, coursework, and disciplinary records, as applicable). Purpose: Provide and support the authorized Services and fulfill SkilRedi’s school-official function (Sections 4(a) and 5). Retention Trigger: deleted, destroyed, or de-identified within sixty (60) days of the Educational Organization’s request or termination of the applicable Services, subject to Section 29.
3. Category: Course or program participation data. Purpose: Deliver instructional content, simulations, assessments, and career or workforce-development experiences (Section 4(c)). Retention Trigger: deleted, destroyed, or de-identified within sixty (60) days of the Educational Organization’s request or termination of the applicable Services, subject to Section 29.
4. Category: Learning activity and progress information. Purpose: Provide authorized reporting, analytics, and program-support functions (Section 4(d)). Retention Trigger: deleted, destroyed, or de-identified within sixty (60) days of the Educational Organization’s request or termination of the applicable Services, subject Section 29.
5. Category: Assessment information. Purpose: Deliver and score assessments and support authorized reporting (Sections 4(c)-(d)). Retention Trigger: deleted, destroyed, or de-identified within sixty (60) days of the Educational Organization’s request or termination of the applicable Services, subject to Section 29.
6. Category: Credentials and completion records. Purpose: Provide and support the authorized Services, including issuance of credentials (Section 4(a)). Retention Trigger: deleted, destroyed, or de-identified within sixty (60) days of the Educational Organization’s request or termination of the applicable Services, subject to Section 29.
7. Category: De-identified or aggregated data derived from the categories above. Purpose: improve educational content and Services, program evaluation, and research (Section 18). Retention Trigger: not subject to the same-record deletion trigger above; retained only in de-identified or aggregated form consistent with Section 18.
8. Storage location and encryption. Student Data is stored using industry-standard encryption in transit and at rest, consistent with Section 10. A description of SkilRedi’s specific storage locations, security architecture, and encryption implementation is available to the Educational Organization on request and may be incorporated into a separate data security and privacy plan or state-specific rider where required.