Thinking Habitats, LCC

Privacy Policy

Effective Date: December 01, 2025
Last Updated: December 01, 2025

1. Purpose and Scope

This Privacy Policy, together with any documents it may incorporate by reference, including without limitation the Thinking Habitats Terms of Service Policy (the “Agreement”), describes how Thinking Habitats, LLC and our affiliates, including Thinking Habitats Foundation, (collectively, “Thinking Habitats,” “we,” “us,” or “our”) is committed to protecting the privacy of all users of our educational platform, THINKING PRO, and any related websites, applications, software, and services (collectively, the “Service”). Capitalized terms not otherwise defined in this Privacy Policy have the meanings given to them in the Agreement.

More specifically, this Privacy Policy describes how we collect, use, store, and share personal information of the following categories of users:

1. Schools, teachers, and instructional coaches who use the Service in an educational or institutional capacity;
2. Students whose accounts are created through a school, teacher, or approved third-party identity provider; and
3. Parents and individual users who participate in the Service directly through Thinking Habitats.
4. All visitors and other individuals who access or interact with the Service, including those who browse our website(s) without creating an account or otherwise registering.

By accessing or using our Service, or by otherwise giving us your personal information, you agree to this Privacy Policy, which we may update from time to time. You consent to our collecting, using, and sharing your personal information as described here. If we update this Privacy Policy, your continued use of the Website after we post the changes means you accept them. Please check this page periodically for updates. If you do not agree with this Privacy Policy, you must not access or use any portion of our Service.

2. Account Provisioning and Roles

2.1. Schools, Teachers, and Coaches

Accounts for schools, teachers, and instructional coaches are created and provisioned by Thinking Habitats at the request of the participating school or district. Educators and coaches do not create their own accounts.

2.2. Students

Student accounts are created in one of two ways:

• Automatically, when the student signs in using an approved third-party identity provider (such as Google Workspace for Education, Microsoft 365, or Clever).
• Manually, by Thinking Habitats through the secure upload of a school-provided roster file.

Students cannot self-register.

2.3. Parents and Individual Users

For programs or pilots offered directly to families or individual users, Thinking Habitats creates accounts for the parent or individual participant and, where applicable, for the associated student learner. Parents and guardians may request changes to their or their child’s account information by contacting Thinking Habitats at legal@thinkinghabitats.com.

3. Information We Collect

3.1. Information Provided by Schools or Users

We collect the following categories of information, depending on the user role:

• School or district contact information (including name, address, and administrator contact details);
• Teacher and coach information (including name, email addresses, and role designations;
• Student identifiers (including name, class enrollment, grade level, and school email address);
• Parent or individual information (including user names, email addresses, and any enrollment information needed to administer the Service);
• Information provided by you in connection with the Service, including online forms, account information, order history, user reviews, survey responses, and communications with our online support team;
• Communication and engagement preferences;
• Information required to process job applications and evaluate employee candidates; and
• Payment information to complete your orders and/or payment transactions.
  • We use Stripe, Inc. and its affiliates ("Stripe") to process online payments. We do not store your full card number or CVC/CVV. We may keep limited card details and Stripe tokens to complete charges, process refunds, and prevent fraud. To learn more about Stripe’s processing, please visit https://stripe.com/privacy. To manage the personal information collected and stored by Stripe, contact Stripe or visit https://support.stripe.com.
  • If you pay by check, direct bank transfer (such as ACH or wire), or any other type of payment sent directly to us, we may collect the information on the instrument or transfer and related remittance details. We process these through our bank and keep necessary records for accounting, compliance, and fraud prevention.  

3.2. Information Collected Automatically

When users interact with the Service, we automatically collect usage and technical data, including:

• Log and activity data (including assignments completed, progress metrics, and time spent within lessons);
• Device and browser information (including IP address, operating system, and general location at the city or region level); and
• Cookies or similar technologies necessary for authentication, session continuity, security, content personalization, data aggregation, and analytics, as described below.
  • Cookies are text files that websites store on a visitor's device to uniquely identify the visitor's browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising. These may be “persistent” cookies, which will be stored for a set period, or “session” cookies, which are temporary and last only for your browser session.
  • Web beacons, also known as pixel tags or clear GIFs, are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
  • Analytics Services. We may use third-party analytics services, including Google Analytics, to gather information about our website visits. These third parties may collect personal information as outlined in this Privacy Policy. To learn more about Google Analytics, please visit https://policies.google.com/ and https://policies.google.com/technologies/partner-sites.
  • Your browser may give you the ability to control cookies or other tracking technologies or to reject cookies. If you reject our cookies or other similar tracking technologies, you may still use the Website, but you may be limited in the use of some of the features.
  • For more information about cookies, please visit www.allaboutcookies.org. To control flash cookies, which we may use on certain websites from time to time, you can go here.

3.3. Information Collected from Third-Party Sources

We may receive personal information from other sources, including:

• Third-party accounts that you use to sign up, log in, or link to the Service. If you access the Service through such third-party accounts, we will collect personal information you have consented to share and you agree to comply with the policies of such third-party. To learn more or to limit or control the information shared through these third-party accounts, please visit the policies and controls through your account with them.
• Data providers, such as information services and data licensors, that provide demographic and other information.
• Our analytics and advertising partners, including online advertising networks and analytics providers.
• Business partners, such as joint education and platform partners.
• Other individuals who refer their friends or other contacts to us and share their contact information. Please do not refer someone to us or share their contact information with us unless you have their permission to do so.

The Service may enable you to connect your account with third-party cloud storage services—such as Google Drive, Google Classroom, or other comparable platforms (collectively, “External Repositories”)—to upload, access, or submit content including assignments, presentations, or other instructional materials. External Repositories are operated by independent third parties that are not owned or controlled by Thinking Habitats. Your use of any External Repository is subject to the terms of service and privacy policy of the applicable provider (for example, Google LLC). Thinking Habitats is not responsible for the security, availability, or integrity of data stored in, or transmitted through, such services. Disconnecting or revoking access to an External Repository may disable certain features and may result in the unavailability or deletion of related files within the Service.

4. How We Use Personal Information

We use personal information for the following purposes or as otherwise described at the time we collect it:

1. Service Delivery. We may use your personal information to:
   1. Provide, administer, improve, and support the Service;
   2. Establish and maintain the your accounts and data on the Service;
   3. Communicate with schools, educators, parents, and individual users regarding Service operation, updates, and training;
   4. Protect users and promote safe use of the Service;
   5. Understand your needs and interests, and personalize your experience with the Service and our communications; and
   6. Provide support for the Service and respond to your requests, questions and feedback.
2. Research and Development. Evaluate and improve the effectiveness of the Service through educational research and development using data that has been reasonably de-identified and aggregated.
3. Marketing and Advertising. We and our third-party advertising partners may collect and use your personal information for direct marketing and interest-based advertising purposes.
4. Legal and Business Compliance. We may use your personal information to:
1. Comply with applicable laws and regulations, lawful requests, and legal process;
2. Protect our, your, or others’ rights, privacy, safety, or property;
3. Audit our internal processes for compliance with legal and contractual requirements and internal policies;
4. Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred;
5. Enforce any policies that govern the Service; and
6. Prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

5. Educational Privacy and Children’s Data

When we provide the Service to schools, our collection, use, and disclosure of personal information that can be linked to an identifiable student, including education records as defined by Family Educational Rights and Privacy Act (FERPA) and any information classified as sensitive or otherwise protected under applicable law (“Student Data”) is governed by our agreements with those schools and by applicable federal and state privacy laws regarding Student Data.

• Student Data remains under the ownership and control of the school. Thinking Habitats acts as a service provider and school official, as that term is used under FERPA, with a legitimate educational interest.
• Thinking Habitats processes Student Data only on documented instructions from the school and for the limited purposes described within this Privacy Policy.
• Instructional coaches affiliated with Thinking Habitats may view Student Data only to support teachers in using the Service effectively. All such access is strictly role-based and logged.
• Student Data is never used for targeted advertising or marketing purposes. We do not “sell,” as that term is defined under the Student Online Personal Protection Act (SOPPA), Student Data.

We also take measures to protect the privacy of personal information collected from children under the age of 13 (“Children’s Data”), which may, depending on the circumstances, also be considered Student Data.

For direct-to-family programs, Thinking Habitats creates the child’s account with the verifiable consent of a parent or legal guardian. We obtain verifiable parental consent prior to collecting, using, or disclosing Children’s Data, and we only do collect, use, and disclose Children’s Data as reasonably necessary and consistently with this Privacy Policy. We do not use Children’s Data for any form of marketing. Parents and guardians may review, delete, and restrict further use of their child’s personal information by contacting us at legal@thinkinghabitats.com.

For school-based programs, accounts for students—including children under 13—are created by Thinking Habitats upon the request or authorization of the school or teacher. We rely on the school to provide consent on behalf of parents for students’ use of the Service. We provide the school with the information necessary to fulfill parental notice and consent obligations. Eligible students, and parents if information concerns Children’s Data, may contact the student’s school directly or us at legal@thinkinghabitats.com to request access to, correction of, or deletion of Student Data. Thinking Habitats promptly complies with all verified school-directed requests as reasonably necessary and required under applicable law.

6. How We Disclose and Share Personal Information

In connection with one or more of the purposes outlined within this Privacy Policy, Thinking Habitats may disclose or share your personal information as follows:

• With our subsidiaries and affiliates for purposes consistent with this Privacy Policy and other business and operational purposes;
• With contracted service providers who operate on our behalf or help us operate the Service or our business, including without limitation to support hosting, security, analytics, or technical operations, under strict confidentiality and data-protection terms;
• With other business partners and companies with whom we partner to offer the Service and carry out other related activities;
• With other users of the Service who may be able to view the limited personal information you choose to publicly provide or post on the Service’s features;
• At the direction of the school or parent, such as enabling third-party authentication or integration services;
• As required by law, to comply with legal obligations or to protect rights, property, or safety; and
• In the event of a business transaction, such as a merger or acquisition.

We may also aggregate or de-identify personal information so that it will no longer be considered “personal information” and disclose and use such aggregated or de-identified information for purposes consistent with those described in this Privacy Policy.

7. Data Retention and Deletion

We retain personal information only for as long as reasonably necessary to fulfill the purposes outlined in this Privacy Policy, or as required by law or contract. When accounts are closed or agreements expire, Student Data and related personal information are deleted or de-identified according to our standard retention schedule or at the written request of the student, school, or parent.

8. Security

Thinking Habitats employs reasonable administrative, technical, and physical safeguards designed to protect information against unauthorized access, disclosure, or loss. These measures include encryption, access controls, monitoring, and secure data-storage practices. However, no system can guarantee absolute security.

9. Your Choices

You have the following choices with respect to your personal information:

• Access or Update Your Information. If you have registered for an account with us, you may review and update certain account information by logging into the account. If your account is controlled by your school, you or your parent should contact the school directly to request management of your account or data. We will comply with verified school-directed requests as reasonably necessary.
• Opt Out of Marketing Communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at legal@thinkinghabitats.com. You may continue to receive service-related and other non-marketing emails. Please see our Terms of Service for more details.
• Refuse Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser's settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Service. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.
  • Opt Out of Analytics Data Collection. We may use third-party analytics services, such as Google Analytics, to help us understand user activity and patterns on the website portions of the Service. You can learn more about how Google protects your data here (https://policies.google.com/).
• You can prevent the use of Google Analytics relating to your use of our Service by downloading and installing a browser plugin available here.
• Limit Information Disclosure Through Third-party Platforms. If you choose to connect to the Service through a third-party account, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.
• Declining to Provide Information. You may choose to not provide personal information to us in connection with our Service. However, if you do not provide certain information requested, we may not be able to provide the Service to you.

If you are located in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, you have certain rights under applicable data protection laws, including the General Data Protection Regulation (“GDPR”).

Depending on your location and subject to applicable exceptions, these rights may include: (1) the right to access your personal data and receive a copy; (2) the right to correct inaccurate or incomplete personal data; (3) the right to delete your personal data; (4) the right to restrict the processing of your personal data; (5) the right to object to our processing of your personal data, including for direct marketing; (6) the right to data portability, allowing you to obtain and reuse your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller; and (7) the right to withdraw consent at any time where our processing is based on your consent, without affecting the lawfulness of processing before withdrawal. If you want to assert any of your applicable rights, please contact us at legal@thinkinghabitats.com. Any such communication must be in writing.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal data that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal data that we hold about you, or we may have destroyed, erased, or made your personal data anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal data, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

10. Research and Development

As a federally supported research and development organization, Thinking Habitats uses de-identified and aggregated data to evaluate curriculum effectiveness, improve instructional design, and measure learning outcomes. All research activities are conducted in compliance with FERPA, Children’s Online Privacy Protection Act (COPPA), and applicable federal grant-management standards.

11. Linked Websites

The Service may contain links to websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or other online services that are not associated with us. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. When you interact with these third parties and choose to use their service, you are providing your information to them. Your use of these services is subject to the privacy policies of those providers. You expressly relieve Company from any and all liability arising from your use of any third-party website, or from the content of any third-party website.

12. Learning Analytics, Data Modeling, and Machine Learning

Thinking Habitats applies learning analytics, gamification, and adaptive methods to enhance instructional design and student engagement. Interactive videos and other digital features may adjust pacing, feedback, and difficulty according to each learner’s responses and progress. These adaptive processes are primarily rule-based, following defined instructional frameworks and evidence-based learning principles.

Thinking Habitats also conducts data modeling to evaluate curriculum effectiveness, analyze learning patterns across schools and districts, and optimize the THINKING PRO program for diverse learner populations. These activities use de-identified or aggregated data and follow recognized educational research standards, consistent with FERPA’s studies exception and other applicable regulations.

Where expressly authorized by a school, parent, or guardian through written or documented consent, machine-learning techniques may be used to further personalize instruction or analyze program impact. Any processing of identifiable Student Data in connection with machine-learning activities is conducted solely for authorized educational purposes and in compliance with FERPA, COPPA, and all relevant state student-data-privacy laws.

Whenever feasible, Thinking Habitats performs analyses using de-identified or aggregated information to prevent the disclosure of personally identifiable data. Thinking Habitats does not engage in behavioral profiling or targeted advertising and does not use analytics or machine-learning results to make automated decisions about grading, assessment, or student eligibility.

13. International Data Transfers

Thinking Habitats is based in the United States. Personal information may be transferred to and processed in the United States or other jurisdictions where its service providers operate, under safeguards consistent with applicable data-protection laws.

If you are located in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, and have certain rights under the GDPR, note that such transfers will be subject to appropriate additional safeguards under standard data protection clauses adopted by the EU Commission or adopted by a supervisory authority and approved by the EU Commission.

14. Do Not Track

Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

15. Updates to This Privacy Policy

We may update or modify this Privacy Policy periodically. Material updates will be communicated through reasonable means, such as email notice or in-product notification. Unless otherwise specified, updates take effect on the date shown above (“Effective Date”). Your continued use of the Service after the Effective Date constitutes acceptance of the revised Privacy Policy.

16. Contact Information

For questions or concerns about this Privacy Policy, please contact: