1. About This Policy

Red Comet is an online school operated by Jupiter Education Services LLC. This Privacy Policy explains how Red Comet collects, uses, shares, and protects information. It applies to everyone who interacts with Red Comet — students, parents and legal guardians, and visitors to our websites — and to any kind of enrollment, including full-time students working toward a Red Comet diploma, students whose tuition is funded through the Alternate Learning Education (ALE) program in Washington State and the Texas Education Freedom Accounts (TEFA) program, private-pay students, students of partner schools, student-athletes seeking NCAA-approved credit, and families who take individual courses through our catalog, in every state where we operate. This is the single privacy policy for the company and replaces any earlier version.

2. Information We Collect

We collect only the information we need to educate students and operate our school and services:

• Student information: name, date of birth, grade level, contact details, enrollment and academic records (courses, assignments, grades, and attendance shown by platform login activity), transcripts and credentials, and immunization records or a valid exemption. If a family chooses to provide an IEP or Section 504 plan, we collect it to determine platform-based supports​ we can reasonably provide.
• Parent and guardian information: name, contact details, relationship to the student, and — for private-pay enrollments — payment information.
• Program information:
  • For ALE participants in Washington, the information needed to administer the program, such as eligibility, enrollment, transcripts/grade reports and student progress, exchanged with the Office of Superintendent of Instruction (OSPI) and the district through which the program is offered.
  • For TEFA participants in Texas, the information needed to administer the program, such as eligibility, enrollment, transcripts/grade reports and tuition acceptance, exchanged with the Texas Comptroller of Public Accounts and Odyssey.
  • For NCAA participants, the information needed to administer the program, such as eligibility, enrollment, and transcripts, exchanged with the NCAA.
• Website and technical information: IP address, device and browser type, and usage information that may be collected through cookies and similar technologies when you visit our websites.

3. How We Collect Information

We collect information directly from you when you communicate with us, when you register on our registration platform or website, from the student's use of our learning platform, from a prior school when you authorize the transfer of the student's records, from the district and OSPI for ALE administration, from the Texas Comptroller and Odyssey for TEFA administration, from the NCAA platform and automatically through cookies and analytics on our websites.

4. How We Use Information

We use the information we collect to:

• provide and administer instruction and the student's program of study;
• provide platform-based accommodations;              
• maintain student records and issue progress reports, transcripts, credentials, and diplomas;
• communicate with students and families and with the student’s school;
• process payments and, for TEFA students, administer the program with the Comptroller and Odyssey;
• upload required transcript or grade information for the ALE, TEFA and NCAA programs and to the student’s school (if not enrolled full time in Red Comet or registered at/transferring to another school);
• comply with our legal, accreditation, and program obligations, including records-retention and audit requirements;
• protect the safety of students, including meeting mandatory reporting duties; and
• operate, secure, support, and improve our platform and services.

5. How We Share Information — and the Limits

We treat student information as confidential and share it only as described here.

• We do not sell student information. We never sell, rent, or trade student information.
• We do not use student information for advertising. We do not share student information — including in aggregated or de-identified form — with advertisers, sponsors, or data brokers, and we do not use student information for third-party or targeted advertising.
• Service providers. We share limited information with vendors that help us operate — for example, our learning-management platform, assessment providers, and payment processors — under contracts that require them to safeguard the information and use it only to provide services to Red Comet.
• For students participating in TEFA, we share the information necessary to administer the program with the Texas Comptroller and Odyssey; for students participating in ALE, we share the information necessary to administer the program with OSPI; for students participating in NCAA, we share the information necessary to issue NCAA credits.
• Legal and safety. We disclose information when required by law — for example, in response to a subpoena or a program audit — to meet mandatory child-abuse reporting obligations under state laws, or to protect the safety of any person.
• With your consent. Any sharing not described above happens only with the consent of the parent or guardian (or the eligible student) and usually upon request.
• Business transfers. If Red Comet is involved in a merger, acquisition, financing, reorganization, or sale of assets, student and family information may be transferred to a successor only if that successor agrees in writing to protect the information under this Policy and applicable law, and — for TEFA participants — consistent with the confidentiality and non-distribution requirements of Texas Education Code §§29.365 and 29.369. We do not treat student information as a freely transferable commercial asset, and we will provide any notice the law requires.

6. Student Records and Confidentiality

Red Comet handles student educational information consistent with applicable state and federal law and, for TEFA students, with the confidentiality requirements that apply to program participants, including Texas Education Code §29.369. We do not sell or distribute information about a participating child except as needed to administer the program or with your consent.

Red Comet is a private school that does not receive federal financial assistance, so it is not directly regulated by the federal Family Educational Rights and Privacy Act (FERPA). We nonetheless maintain confidentiality practices consistent with FERPA-level protections and with applicable state student-privacy laws.

7. Children's Privacy

Red Comet serves K–12 students, including children under 13. We collect and use a child's information only for legitimate educational purposes, under the authorization of the enrolling parent or guardian (and, where applicable, as a school-authorized service). We do not condition a child's participation on disclosing more information than is reasonably necessary, and we never use a child's information for advertising. A parent or guardian may review the child's information, ask us to correct it, or ask us to stop further collection by contacting us; some requests may end the child's ability to use the platform.

8. Data Retention

We keep student and program records for as long as we need them to provide our services and as required by our accreditor, the ALE and TEFA program's audit and retention requirements, and applicable law. When records are no longer needed, we archive them securely.

9. How We Protect Information

We maintain reasonable administrative, technical, and physical safeguards designed to protect information against loss, misuse, and unauthorized access. Access to student records is limited to authorized personnel, including staff who have completed background checks where required. We use secure methods of data transmission when transmitting data to outside agencies. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. Your Rights and Choices

A parent or guardian (or an eligible student) may ask to review the student's records, request a correction of information that is inaccurate, and ask questions about how we handle information, by contacting us using the details below. You can also control cookies through your browser settings.

11. State Privacy Rights

Because Red Comet serves students in multiple states, additional privacy rights may apply depending on where you live. We honor the student-data- privacy and consumer-privacy laws that apply to us in the states where our students reside, and we will provide any additional notices or rights those laws require.

12. Cookies and Analytics

Our websites use cookies and similar technologies to make the site work, remember your preferences, and understand how the site is used. You can set your browser to refuse cookies, though some parts of the site may not function properly if you do.

13. Changes to This Policy

We may update this Policy from time to time. Your continued use of our services after an update means you accept the updated Policy.