Privacy Policy

Last Modified: June 9, 2025

CommonLit, Inc. and our subsidiaries and affiliates ("CommonLit," "we", "us" or "our") is a non-profit organization that delivers high-quality, free instructional materials to support literacy development for students in grades 3-12. This Privacy Policy describes our practices regarding personal information we collect through our learning platform (the "Platform"), websites ("Sites") and any other interactive features or services owned or controlled by CommonLit that post a link to this Privacy Policy (collectively with the Platform and Sites, the “Service”) as well as any other personal information we collect offline and combine with personal information we collect through the Service.

Users of the Service include:

representatives (including teachers, tutors and other administrative users) authorized or approved to use the Service by our district, school, university and other institutional customers (“School Officials”),
students authorized by our institutional customers to access and use the Service (“Students”), and
Site visitors

(collectively, referred to as “users” or “you”).

CommonLit may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.

While this Privacy Policy applies to personal information that we process in connection with providing the Services to our school, district and other institutional customers, our relationship with those customers is typically governed by a separate agreement. In such circumstances, the relevant agreement may place obligations or restrictions on our collection, use, disclosure and other processing of your personal information and explain any rights their users may have to such personal information (including any rights under FERPA). To the extent there is any conflict between this Privacy Policy and a relevant customer agreement, the customer agreement shall control our processing of your personal information. If you have questions with respect to personal information that we process in the context of an agreement or relationship with a school or district, you should direct them to the relevant school or district.

Note about FERPA: Certain personal information processed on behalf of our customers may be subject to the Family Educational Rights and Privacy Act ("FERPA"), meaning we will only use personal information that is considered to be “personally identifiable information” maintained as part of “education records” (as both are defined under FERPA) for legitimate educational interests, which include providing the Services to our customers.

Note about European Users: Please see the below Notice to European Users for additional information for individuals located in the European Economic Area and United Kingdom (which we refer to as “Europe”, and “European” should be understood accordingly).

Note about Children: As required by applicable law and our Terms of Service, children under the age of 13 in the U.S. (and a higher age if required by the applicable law in another country) may only use our Service with the express prior consent of a parent or legal guardian unless (and where permitted by applicable law) a school, district, or other institutional customer consents on behalf of a parent or legal guardian in connection with the use of the Services for educational purposes.

Personal information we collect

Information you provide to us.

Personal information you may provide to us through the Service or otherwise includes:

Contact data, such as your first and last name, email address, and organization name.
Demographic data, such as your city, state, country of residence, and postal code.
Account data, such as the username and password that you may set to establish an online account on the Service, biographical details, grade level and any other information that you add to your account profile.
Student data, such as assessments and other data related to a Student’s performance and progress with our educational materials and other interactions with the Service.
School Official data, such as notes and feedback regarding Students and posts and other content that School Officials may choose to make available, including to other School Officials, through interactive features and other communicatory functionality within the Service.
Communications data based on our exchanges with you, including when you contact us through the Service or otherwise.
Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers, transaction history and payment information such as payment card information or bank account number.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Note that a Student’s data, including a Student’s account data, will only be visible to the Student’s School Officials and Students cannot share data with other Students through the Platform.

Third-party sources.

We may combine personal information we receive from you with personal information that we obtain from other sources, such as:

Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
Data providers, such as information services and data licensors.
Partners, such as marketing partners and event co-sponsors.
Other users of the Service, such as when our institutional customers provide information concerning School Officials and/or Students and when School Officials share information concerning Students.
Business transaction partners. We may receive personal information in connection with an actual or prospective business transaction. For example, we may receive your personal information from an entity we acquire or are acquired by, a successor, or assignee or any party involved in a business transaction such as a merger, acquisition, sale of assets, or similar transaction, and/or in the context of an insolvency, bankruptcy, or receivership.
Third-party services, such as third-party platforms and services such as Google or Clever that you use to log into, or otherwise link to, your Service account. This data may include your username and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.

Automatic data collection.

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Location data when you authorize the Service to access your device’s location.
Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

For more information concerning our automatic collection of data, please see the Tracking technologies section below.

Tracking Technologies

Cookies and other technologies. Some of the automatic collection described above is facilitated by the following technologies:

Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
Session-replay technologies, such as those provided by PostHog, that employ software code to record users’ interactions with the Services in a manner that allows us to watch video replays of those user sessions. The replays include users’ clicks, mobile app touches, mouse movements, scrolls and keystrokes/key touches during those sessions. These replays help us diagnose usability problems and identify areas for improvement. You can learn more about PostHog at https://posthog.com/privacy.

For information concerning your choices with respect to the use of tracking technologies, see the Your choices section, below.

Note that we do not use third party cookies or any other third-party tracking technologies within the Platform for tracking our Student or School Official users, including tracking such users across apps.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations.

We may use your personal information to:

provide the Service, including establishing and maintaining your user profile on the Service and allowing Students and School Officials to engage with our educational products and services;
enable security features of the Service;
communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
communicate with you about events or contests in which you participate; and
provide support for the Service, and respond to your requests, questions and feedback.

Service personalization, which may include using your personal information to:

understand your needs and interests;
personalize your experience with the Service and our Service-related communications; and
remember your selections and preferences as you navigate webpages.

Service improvement and analytics

We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

Marketing

We, or our service providers on our behalf, may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

Compliance and protection

We may use your personal information to:

comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the terms and conditions that govern the Service; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Data sharing in the context of corporate events

We may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information , below.

To create aggregated, de-identified and/or anonymized data

We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you and we will not attempt to reidentify any such data. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Further uses

In some cases, we may use your personal information for further uses, in which case we will ask for your consent to use of your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.

Note that we will not use Student data to advertise or market to Students or their parents. Additionally, with respect to our Student and School Official users of the Platform, we will not share their personal information with third parties to allow those third parties to advertise or market their own products or services to such users, display targeted advertisements to such users, sell the personal information of such users, or profile such users for any commercial purposes. We will not mine Student data for any purposes other than those agreed to by our relevant school or district customer. Data mining or scanning of Student content for the purpose of advertising or marketing to Students or their parents is prohibited.

Retention

Upon termination of your account, CommonLit will take commercially reasonable steps to delete any personal information from its live databases in a reasonable amount of time not to exceed ninety (90) days. You understand and agree that CommonLit may continue to have personal information in archive files or similar databases. You further agree that CommonLit has no obligation to delete aggregated, anonymized or de-identified information. CommonLit may retain and use aggregated, anonymized or de-identified information for any purpose that is consistent with laws and regulations.

Even if your account is closed, information may remain in backup or archive records and we may retain certain data relevant to preventing fraud or future abuse or for legitimate business purposes, such as analysis of aggregated, anonymized or de-identified data, account recovery or if required by law. All retained data will continue to be subject to the applicable privacy policy for the Service. Also, if you have posted content on or through the Services, such as in community forums, we may not be able to delete it.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

Service providers

Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).

Payment processors

Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy.

Third parties designated by you

We may share your personal information with third parties where you have instructed us or provided your consent to do so.

Linked third-party services

If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.

Professional advisors

Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities, academic integrity investigations and similar disclosures

Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above. For example, we may provide information in response to a request from, or as otherwise authorized by, an academic institution connected to an investigation into academic integrity.

Business transferees

We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in CommonLit, financing of CommonLit, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of CommonLit as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Customers and other users of the Service

As the Service has interactive components, certain of your personal information will be shared with our institutional customers and other users of the Service. For example, School Officials and their Students may share information. However, as noted, a Student’s data, including a Student’s account data, will only be visible to the Student’s School Officials and Students cannot share data with other Students through the Platform. If School Officials share information in community forums with other School Officials, that information may be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.

Testimonials

We display personal testimonials of satisfied adult users on our Service in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us via email by clicking here.

Your choices

Access or update your information.

If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

Opt-out of 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. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Cookies and other technologies.

Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. 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. You can also configure your device to prevent images from loading to prevent web beacons from functioning.

Blocking images/clear gifs:

Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

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” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information.

We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Linked third-party platforms.

If you choose to connect to the Service through your social media account or other third-party platform, 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.

Close your account.

If you wish to close your account with the Service, please send your request via email by clicking here and we will remove your personal information and account, if applicable, from the active databases for the Service you request. Please let us know which Service you wish to close and, if applicable, send your request using an email account that you have registered with CommonLit under your name. You typically will receive a response to a request sent to this account within five business days of our receiving it. Requests to change your email preferences or unsubscribe from all emails may not be made through this email address, but rather must be submitted through one of the channels set out in the previous section. If you are a Student and your account is through a school or institution, we may not be able to service your request to close your account and recommend that you please contact the relevant school or institution.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We take data security seriously. We employ technical, organizational and physical safeguards designed to protect the personal information we collect. Such measures vary depending on the sensitivity of the information at issue. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

For more information on how we transfer personal information from the European Economic Area and United Kingdom, please see the European Notice.

Children

Protecting the privacy of young children is especially important to CommonLit. For that reason, we created certain features designed to help protect personal information relating to children who are less than 13 years of age, or higher age if required by applicable law (“Child Users”). CommonLit does not knowingly permit Child Users to use our Services without prior, express consent from a parent or legal guardian, except through agreements with schools or districts or as otherwise permitted under the Children’s Online Privacy Protection Rule (COPPA) and FERPA. If we learn that personal information of a Child User has been collected on our Service without prior parental consent, then we will take appropriate steps to delete this information. If you are a parent or guardian (“Parent”) and discover that your child under the age of 13 (or a higher age if required by applicable law) has a registered account with our Services without your consent, please contact your child’s school and alert CommonLit at security@commonlit.org and request that we delete that child’s personal information from our systems.

How does a child register and use the services?

Child Users cannot obtain a user account without first receiving a prompt from their school.

What children’s information is visible to others?

No Child User’s profile is made available or visible to the public through CommonLit. If a teacher or other School Official utilizes certain features on a device in the classroom, other Students may be able to view information that is displayed by the teacher in the classroom, but Students can’t view each other’s individual Child User profiles.

Parents: To review your Child User’s data you must request the information from your child’s teacher.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

How to contact us

Email: help@commonlit.org
Mail: P.O. Box 15189 Washington, DC 20003

Notice to European Users

Where this Notice to European users applies. The information provided in this Notice to European Users applies only to individuals in Europe.

Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” as defined in the “GDPR” (i.e., the General Data Protection Regulation 2016/679 (“EU GDPR”) and the EU GDPR as it forms part of the law of the United Kingdom (“UK GDPR”)) Under the GDPR, “personal data” means information about individuals from which they are either directly identified or can be identified.

Controller. CommonLit is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of the GDPR, except that where we provide the Services to our school, district and other institutional customers, we typically act as a processor on behalf of our customer, in which case this Privacy Policy does not apply to our processing of such personal information. See the ‘How to contact us’ section above for our contact details. If you have questions concerning your personal information that we process on behalf of one of our customers, please reach out to the relevant customer.

Representatives. We have appointed the following representatives in the EEA/UK as required by the GDPR – you can also contact them directly should you wish:

Commonlit, Inc. takes the protection of personal data seriously, and has appointed DataRep as their Data Protection Representative in the European Union and Switzerland so that you can contact them directly in your home country. DataRep has locations in each of the 27 EU countries, the UK, and Norway & Iceland in the European Economic Area (EEA) and Switzerland, so that Commonlit's customers can always raise the questions they want with them.

If you want to raise a question to Commonlit, Inc., or otherwise exercise your rights in respect of your personal data, you may do so by:

sending an email to DataRep at commonlit@datarep.com,
contacting us on our online webform a https://www.datarep.com/data-request, or
mailing your inquiry to DataRep at the most convenient address below:

Country	Address
Austria	DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria
Belgium	DataRep, Rue des Colonies 11, Brussels, 1000
Bulgaria	DataRep, 132 Mimi Balkanska Str., Sofia, 1540, Bulgaria
Croatia	DataRep, Ground & 9th Floor, Hoto Tower, Savska cesta 32, Zagreb, 10000, Croatia
Cyprus	DataRep, Victory House, 205 Archbishop Makarios Avenue, Limassol, 3030, Cyprus
Czech Republic	DataRep, Platan Office, 28. Října 205/45, Floor 3&4, Ostrava, 70200, Czech Republic
Denmark	DataRep, Lautruphøj 1-3, Ballerup, 2750, Denmark
Estonia	DataRep, 2nd Floor, Tornimae 5, Tallinn, 10145, Estonia
Finland	DataRep, Luna House, 5.krs, Mannerheimintie 12 B, Helsinki, 00100, Finland
France	DataRep, 72 rue de Lessard, Rauen, 76100, France
Germany	DataRep, 3rd and 4th floor, Altmarkt 10 B/D, Dresden, 01067, Germany
Greece	DataRep, lppodamias Sq. 8, 4th floor, Piraeus, Attica, Greece
Hungary	DataRep, President Centre, Kálmán Imre utca 1, Budapest, 1054, Hungary
Iceland	DataRep, Laugavegur 13, 101 Reykjavik, Iceland
Ireland	DataRep, The Cube, Monahan Road, Cork, T12 HlXY, Republic of Ireland
Italy	DataRep, Viale Giorgio Ribotta 11, Piano 1, Rome, Lazio, 00144, Italy
Latvia	DataRep, 4th & 5th floors, 14 Terbatas Street, Riga, LV-1011, Latvia
Liechtenstein	DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria
Lithuania	DataRep, 44A Gedimino Avenue, 01110 Vilnius, Lithuania
Luxembourg	DataRep, BPM 335368, Banzelt 4 A, 6921, Roodt-sur-Syre, Luxembourg
Malta	DataRep, Tower Business Centre, 2nd floor, Tower Street, Swatar, BKR4013, Malta
Netherlands	DataRep, Cuserstraat 93, Floor 2 and 3, Amsterdam, 1081 CN, Netherlands
Norway	DataRep, C.J. Hambros Plass 2c, Oslo, 0164, Norway
Poland	DataRep, Budynek Fronton ul Kamienna 21, Krakow, 31-403, Poland
Portugal	DataRep, Torre de Monsanto, Rua Afonso Praça 30, 7th floor, Alges, Lisbon, 1495-061, Portugal
Romania	DataRep, 15 Piaţa Charles de Gaulle, nr. 1-T, Bucureşti, Sectorul 1, 011857, Romania
Slovakia	DataRep, Apollo Business Centre II, Block E / 9th floor, 4D Prievozska, Bratislava, 821 09, Slovakia
Slovenia	DataRep, Trg. Republike 3, Floor 3, Ljubljana, 1000, Slovenia
Spain	DataRep, Calle de Manzanares 4, Madrid, 28005, Spain
Sweden	DataRep, S:t Johannesgatan 2, 4th floor, Malmo, SE - 211 46, Sweden
Switzerland	DataRep, Leutschenbachstrasse 95, ZURICH, 8050, Switzerland
United Kingdom	DataRep, 107-111 Fleet Street, London, EC4A 2AB, United Kingdom

PLEASE NOTE: when mailing inquiries, it is ESSENTIAL that you mark your letters for 'DataRep' and not 'Commonlit, Inc.', or your inquiry may not reach us. Please refer clearly to Commonlit, Inc. in your correspondence. On receiving your correspondence, CommonLit, Inc. is likely to request evidence of your identity, to ensure your personal data and information connected with it is not provided to anyone other than you.

If you have any concerns over how DataRep will handle the personal data we will require to undertake our services, please refer to our privacy notice at www.datarep.com/privacy-policy

Our legal bases for processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

Where we need to perform a contract, we are about to enter into or have entered into with you (“Contractual Necessity”).
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests ”). More detail about the specific legitimate interests pursued in respect of each purpose we use your personal information for is set out in the table below.
Where we need to comply with a legal or regulatory obligation (“ Compliance with Law ”)
Where we have your specific consent to carry out the processing for the purpose in question (“Consent”).

We have set out below the legal bases we rely on in respect of the relevant purposes for which we use your personal information – for more information on these purposes and the data types involved, see ‘How we use your personal information’.

Purpose	Categories of personal information involved	Legal basis
Service delivery and operations	Contact data Account data School Official data Communications data Transactional data	Contractual Necessity
Service personalization	Demographic data Account data School Official data Location data	Legitimate Interests. We have legitimate interest in understanding what may be of interest to our users, improving our users’ experience, delivering relevant content to our users, and measuring and understanding the effectiveness of the content we serve to users.
Service improvement and analytics	Demographic data Account data School Official data Communications data Marketing data Device data Online activity data Communication interaction data	Legitimate Interests. We have a legitimate interest in understanding how our Service and Platform are being used and who uses our Service and Platform in order to identify patterns and trends to improve the Services. ‍ Consent, in respect of any optional cookies used for this purpose.
Marketing	Contact data Demographic data Account data Marketing data Device data Online activity data	Legitimate Interests. We have a legitimate interest in promoting our Platform and business and sending marketing communications for that purpose. ‍ Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to send marketing communications.
Compliance and protection	Any and all data types relevant in the circumstances	Compliance with Law Legitimate Interests. Where Compliance with Law is not applicable, we have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We may also have a legitimate interest in ensuring the protection, maintenance, and enforcement of our rights, property, and/or safety.
Data sharing in the context of corporate events	Any and all data types relevant in the circumstances	Legitimate Interests. We have a legitimate interest in sharing personal information in the context of certain corporate events to ensure the continuity of the Service and the ongoing operation of our business.
To create aggregated, de-identified and/or anonymized data	Any and all data types relevant in the circumstances	Legitimate Interests. We have legitimate interest in taking steps to ensure that our Service and how we use personal information is as un-privacy intrusive as possible.
Further uses	Any and all data types relevant in the circumstances	The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the personal information was collected. Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.

Retention

We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for compliance and protection purposes.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information, we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Other info

No sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service, or otherwise to us. If you provide us with any sensitive personal information to us when you use the Service, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Service.

No Automated Decision-Making and Profiling. As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects.

Your rights

General.

European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information where there is no lawful reason for us continuing to store or process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be described to you, if applicable, at the time of your request;
Portability. Port a machine-readable copy of your personal information to you or a third party of your choice, in certain circumstances. Note that this right only applies to automated information for which you initially provided consent for us to use or where we used the information to perform a contract with you.
Restrict. Restrict the processing of your personal information, if, (i) you want us to establish the personal information’s accuracy; (ii) where our use of the personal information is unlawful but you do not want us to erase it; (iii) where you need us to hold the personal information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use it.
Object. Object to our processing of your personal information where we are relying on Legitimate Interests (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedom – you also have the right to object where we are processing your personal information for direct marketing purposes.
Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent.

Exercising These Rights.

You may submit these requests by email to help@commonlit.org or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions.

Your Right to Lodge a Complaint with your Supervisory Authority.

In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en
For users in the UK – the contact information for the UK data protection regulator can be found here: https://ico.org.uk/make-a-complaint/

Data Processing outside Europe

We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.

It is important to note that that the US is not the subject of an ‘adequacy decision’ under the GDPR – basically, this means that the U.S. legal regime is not considered by relevant European bodies to provide an adequate level of protection for personal information, which is equivalent to that provided by relevant European laws.

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:

Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time).
Transfers to territories without an adequacy decision.
- We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S., see above).
- However, in these cases:
  - we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorise for this purpose; or
  - in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.