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PRIVACY POLICY AND TERMS OF USE

Last Modified May 1, 2025

 

Thank you for visiting the website of ICL Academy, LLC (ICL). We take the protection of your personal data very seriously and strictly observe the appropriate laws and regulations. We would like to take this opportunity to inform you about the steps taken by ICL to ensure the protection of your data as well as how your data may be processed and the purpose of doing so. 

This privacy policy ("Policy") describes how Website Operator ("Website Operator", "we", "us" or "our") collects, protects and uses the personally identifiable information ("Personal Information") you ("User", "you" or "your") may provide on the www.iclacademy.org website and any of its products or services (collectively, "Website" or "Services"). It also describes the choices available to you regarding our use of your Personal Information and how you can access and update this information. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

Broadly speaking, we use personal information for purposes of administering our school and business activities, providing customer service and making available other items and services to our students and prospective students.

ICL Academy will not obtain personally-identifying information about you when you visit our site, unless you choose to provide such information to us, nor will such information be sold or otherwise transferred to unaffiliated third parties without the approval of the user at the time of collection.

We may disclose information when legally compelled to do so, in other words, when we, in good faith, believe that the law requires it or for the protection of our legal rights.

 
AUTOMATIC COLLECTION OF INFORMATION

When you visit the Website our servers automatically record information that your browser sends. This data may include information such as your device's IP address, browser type and version, operating system type and version, language preferences or the webpage you were visiting before you came to our Website, pages of our Website that you visit, the time spent on those pages, information you search for on our Website, access times and dates, and other statistics.

 
COLLECTION OF PERSONAL INFORMATION

You can visit the Website without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the Website's features, you will be asked to provide certain Personal Information (for example, your name and e-mail address). We receive and store any information you knowingly provide to us when you create an account, or fill any online forms on the Website. When required, this information may include your email address, name, or other Personal Information. You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of some of the Website's features. Users who are uncertain about what information is mandatory are welcome to contact us.

 
USE AND PROCESSING OF COLLECTED INFORMATION

Any of the information we collect from you may be used to personalize your experience; improve our Website; improve customer service and respond to queries and emails of our customers; send newsletters; send notification emails such as password reminders, updates, etc; run and operate our Website and Services. Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding Website usage. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system.

We may process Personal Information related to you if one of the following applies: (i) You have given your consent for one or more specific purposes. Note that under some legislations we may be allowed to process information until you object to such processing (by opting out), without having to rely on consent or any other of the following legal bases below. This, however, does not apply, whenever the processing of Personal Information is subject to European data protection law; (ii) Provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) Processing is necessary for compliance with a legal obligation to which you are subject; (iv) Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (v) Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

 
EMAIL POLICIES

We are committed to keeping your e-mail address confidential. We do not sell, rent, or lease our subscription lists to third parties, and we will not provide your personal information to any third party individual, government agency, or company at any time unless strictly compelled to do so by law.

We will use your e-mail address solely to provide timely information about ICL Academy.

We will maintain the information you send via e-mail in accordance with applicable federal law.

 
INFORMATION TRANSFER AND STORAGE

Depending on your location, data transfers may involve transferring and storing your information in a country other than your own. You are entitled to learn about the legal basis of information transfers to a country outside the United States, European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us to safeguard your information. If any such transfer takes place, you can find out more by checking the relevant sections of this document or inquire with us using the information provided in the contact section.

Like most standard website servers we use website statistic packages such as Google Analytics to analyze trends in how our website is accessed and utilized. Information monitored includes internet protocol (IP) addresses, geographic location of visitors (country, city), browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, time spent on pages, and keywords used to find our site via search engines. This information is anonymous and cannot be directly linked to individual users. We may use it to identify high-use or low-use areas of the site, pinpoint problem areas of the site, analyze broad demographic trends in our visitors, and make decisions about how to make it easier for people to find and navigate our website.

 
THE RIGHTS OF USERS

You may exercise certain rights regarding your information processed by us. In particular, you have the right to do the following: (i) you have the right to withdraw consent where you have previously given your consent to the processing of your information; (ii) you have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent; (iii) you have the right to learn if information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing; (iv) you have the right to verify the accuracy of your information and ask for it to be updated or corrected; (v) you have the right, under certain circumstances, to restrict the processing of your information, in which case, we will not process your information for any purpose other than storing it; (vi) you have the right, under certain circumstances, to obtain the erasure of your Personal Information from us; (vii) you have the right to receive your information in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.

 
THE RIGHT TO OBJECT TO PROCESSING

Where Personal Information is processed for the public interest, in the exercise of an official authority vested in us or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection. You must know that, however, should your Personal Information be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn, whether we are processing Personal Information for direct marketing purposes, you may refer to the relevant sections of this document.

​HOW TO EXERCISE THESE RIGHTS

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible.

 
PRIVACY OF CHILDREN

We do not knowingly collect any Personal Information from children under the age of 13. If you are under the age of 13, please do not submit any Personal Information through our Website or Service. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through our Website or Service without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to us through our Website or Service, please contact us. You must also be at least 16 years of age to consent to the processing of your Personal Information in your country (in some countries we may allow your parent or guardian to do so on your behalf).

 
STUDENT DATA PRIVACY

ICL Academy is an education company that provides various management services and curriculum content (“Services”) to our customers, including private schools and special programs that wish to provide students and their families with an exceptional online school option.

ICL Academy uses industry best practices to protect the privacy of all of our students and families. When our Services are used as part of a school’s educational mission or a family enrolls their student in ICL Academy, the personal information related to the student users (“School Users”) that is (i) provided to ICL Academy by a parent, student, or school, or (ii) collected by ICL Academy during the provision of our services to a student or school, may include information protected by similar student data privacy laws. We call this information “Student Records.”

 
STUDENT RECORDS

Our collection and use of Student Records is governed by our contracts with schools, by our Privacy Policy, and by applicable privacy laws. For example, we work with schools to help protect personal information from the student’s educational record and to protect the personal information of students under 13 consistent with the Children’s Online Privacy Protection Act (“COPPA”).

We collect, maintain, use, and share Student Records only for authorized educational use and as described in our Privacy Policy, or as directed by the school, the School User, and/or the student’s parent or legal guardian.

Depending on the features and account controls applicable to the School User accounts, we may share usernames and account information with other users on the Website, such as teachers, learning coaches, or school administrators.

In the ICL Academy education management system, access to student information and data is controlled by a central team of administrators using a complex system of roles and permissions. Only users who have permissions will be permitted to access student data. Data points and reports will be assigned to roles, including vendors with whom ICL Academy has contracted to provide a service. Access to reports and all student data will be controlled by these roles. Only users with the correct roles will meet the requirements to access the data.

The education management system contains personally identifiable information that is maintained and accessible by third parties (such as service providers, content partners, or vendors). These third parties are provided access to the minimum amount of information required to allow them to perform the tasks for which they have been engaged or contracted. Such third parties have agreed to maintain the confidentiality of such information and to use or disclose it only for the work they are performing for us, or as permitted by law.

  • We do not disclose Student Records for targeted advertising purposes. We do use certain marketing technologies for the purpose of retargeting, analytics, and attribution activities.
     

  • We do not build a personal profile of a School User other than in furtherance of an educational purpose or as authorized by a parent or guardian.
     

  • We maintain a comprehensive data security program designed to protect the types of Student Records we maintain.
     

  • We will never sell Student Records.
     

 
PRIVACY IN LIVE CLASSES AND MESSAGE BOARDS

​Many of our students participate in ICL Live classes and use online message boards as part of their educational experience in ICL Academy. It’s important to understand that any information students share during a live class or in an ICL Academy online message board is available to all other individuals who have access to the class and/or message board. Therefore, ICL Academy cannot guarantee the privacy of the information that students provide in these situations.

 
CHILDREN’S GUIDELINES

  • Children may not provide personally identifiable information without prior parental consent or parental notification, which will include an opportunity for the parent to prevent the use of the information and participation in the activity.
     

  • Children may not publicly post or otherwise distribute personally identifiable contact information without prior parental consent.

 
CHILDREN UNDER 13

ICL Academy is concerned about the safety and privacy of children online. We take reasonable efforts to comply with the Children’s Online Privacy Protection Act of 1998 (COPPA), as well as state-specific laws that provide privacy protections for K–12 students.

The Websites are not intended to solicit information of any kind from children under the age of 13, and we do not and will not knowingly contact or collect personally identifiable information from children under 13. The only personal information we receive about children under the age of 13 is information provided by the parent or legal guardian or information provided by the child as part of that child’s participation in a course or courses as part of that child’s K–12 education program. By enrolling a child in such course or courses, a parent is consenting to the collection of that information.

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It is possible that by fraud or deception by others we may receive information pertaining to children under the age of 13. If we are notified of the receipt of information under such circumstances, once verified, we will promptly obtain parental or guardian consent, and in the absence of such consent, will delete the information. If you want to notify us that we have inadvertently received information for a child under the age of 13, please do so by emailing us at finance@iclacademy.org.

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You can request to review, edit, or prohibit personally identifiable information of a child under the age of 13 from being used by ICL Academy, its affiliates, schools, and vendors acting on behalf of ICL Academy by making a request in writing to finance@iclacademy.org. Please note that if you make a request to prohibit personally identifiable information from being used by ICL Academy, its affiliates, schools, and vendors acting on behalf of ICL Academy, it will not be possible for your child to participate in an ICL Academy program.

 

ONLINE SERVICES AND ACCOUNTS

Students are required to use various online accounts and services to complete assignments and participate in various School activities. The Children’s Online Privacy Protection Act (COPPA) requires that children thirteen (13) years of age or under must have verifiable Parent/Guardian consent to use such services. COPPA allows schools to gather consent from Parents/Guardians on behalf of their students, thus eliminating the need for Parents/Guardians to provide consent and establish accounts individually with each service provider. Parent/Guardian agrees that signing this Agreement constitutes Parent’s/Guardian’s consent for ICL Academy to establish such accounts and to provide personal identifying information for Student (consisting of first name, last name, email address, class year and username) to such service providers. 

If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to individual rights and your Personal Information, you may send an email to finance@iclacademy.org or:

ICL Academy, LLC

Chief Financial Officer

3705 W. Pico Blvd #564

Los Angeles, CA 90019

 
NEWSLETTERS

We offer electronic newsletters to which you may voluntarily subscribe at any time. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transactional emails.

 

​COOKIES

The Website uses "cookies" to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. We may use cookies to collect, store, and track information for statistical purposes to operate our Website and Services. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the features of the Website and Services. To learn more about cookies and how to manage them, visit internetcookies.org

 
DO NOT TRACK SIGNALS

Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. Our Website does not track its visitors over time and across third party websites. However, some third party sites may keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.

 
LINKS TO OTHER WEBSITES

Our Website contains links to other websites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other websites or third-parties. We encourage you to be aware when you leave our Website and to read the privacy statements of each and every website that may collect Personal Information.

 
INFORMATION SECURITY

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and our Website cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third-party, despite best efforts.

 
DATA BREACH

In the event we become aware that the security of the Website has been compromised or users Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will send you an email.

​CHANGES AND AMENDMENTS

We may update this Privacy Policy from time to time in our discretion and will notify you of any material changes to the way in which we treat Personal Information. When changes are made, we will revise the updated date at the bottom of this page. We may also provide notice to you in other ways in our discretion, such as through contact information you have provided. Any updated version of this Privacy Policy will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified. Your continued use of the Website or Services after the effective date of the revised Privacy Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Data in a manner materially different than what was stated at the time your Personal Data was collected. Policy was created with WebsitePolicies.

 
TERMS AND CONDITIONS OF USE

By accessing this website, you are agreeing to be bound by these web site Terms and Conditions of Use, all applicable laws and regulations, and agree that you are responsible for compliance with any applicable local laws. If you do not agree with any of these terms, you are prohibited from using or accessing this site. The materials contained in this web site are protected by applicable copyright and trade mark law.

 
INTELLECTUAL PROPERTY RIGHTS

All copyrights, trademarks, patents and other intellectual property rights in and on our website and all content and software located on the site shall remain the sole property of ICL Academy or its licensors. The use of our trademarks, content and intellectual property is forbidden without the express written consent from ICL Academy.

You must not:

  • Republish material from our website without prior written consent.

  • Sell or rent material from our website.

  • Reproduce, duplicate, create derivative, copy or otherwise exploit material on our website for any purpose.

  • Redistribute any content from our website, including onto another website.

Acceptable Use

You agree to use our website only for lawful purposes, and in a way that does not infringe the rights of, restrict or inhibit anyone else’s use and enjoyment of the website. Prohibited behavior includes harassing or causing distress or inconvenience to any other user, transmitting obscene or offensive content or disrupting the normal flow of dialogue within our website.

You must not use our website to send unsolicited commercial communications. You must not use the content on our website for any marketing related purpose without our express written consent.

 
NOTICE OF CERTAIN MARKETING PRACTICES

Last Modified September 1, 2025

 
CRITELLI CONSULTING

We work with a company called Critelli Consulting, which assists us in advertising our products and/or services. One of the products that we may purchase from Critelli Consulting is a retargeting product, which enables Critelli Consulting to show you advertisements for our Site when you visit other sites in the Critelli Consulting network or in third-party networks. 

Critelli Consulting is able to do this through the use of cookies that are provided by Critelli Consulting through its third-party partners (“Advertising Cookies”). The sole use of the Advertising Cookies is to show you advertisements for our Site; they are not being used to target you in any other way. Moreover, Critelli Consulting does not link or otherwise connect the information in the Advertising Cookies to any Personal Information that you may have provided.

If you have any questions regarding Critelli Consulting and/or the Advertising Cookies, you are encouraged to contact Critelli Consulting at jmcritelli6@gmail.com. 

 
ANALYTICS

We use Google Analytics to analyze activity on our site and to understand how users use our site in order to enhance the user experience on our Site. If you wish to opt-out of Google Analytics tracking, go to https://tools.google.com/dlpage/gaoptout?hl=en-GB.


 

ACCEPTANCE OF THIS POLICY

You acknowledge that you have read this Policy and agree to all its terms and conditions. By using the Website or its Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to use or access the Website and its Services.

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CONTACTING US

If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to individual rights and your Personal Information, you may send an email to finance@iclacademy.org or:

ICL Academy, LLC

Chief Financial Officer

3705 W. Pico Blvd #564

Los Angeles, CA 90019

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