Privacy Policy

Last Updated: January 19, 2026
Company Name: Intelexia USA, LLC d/b/a PAF Reading Program (“Company,” “we,” “us,” or “our”)
Website: https://www.pafprogram.com/ 

  1. Introduction

We are committed to protecting the privacy of the users of this Website. We are also committed to the protection of all student and School data that is collected through our programs as we strive to offer unparalleled structured language program for teaching reading, spelling, and handwriting using multisensory techniques (the “Products” and/or “Services”). A “School” means any local education agency, school district, or independent school in which we have agreements to perform our Services and provide our Products in connection with our educational programs.   

This Privacy Policy describes how we collect, use, disclose, and protect personal information via the Website from:

  • Customers purchasing books and materials online and contacting us via email or the “Contact Us” form on the Website;
  • Teachers and Schools interested in implementing our reading programs or teacher trainings;
  • Students participating in programs using our materials via the School programs;

We are committed to protecting privacy and complying with applicable U.S. privacy laws, including the Children’s Online Privacy Protection Act (COPPA), Family Educational Rights and Privacy Act (FERPA) (when applicable through School agreements), and relevant state laws, including but not limited to the California Consumer Privacy Act (CCPA).

This Privacy Policy is incorporated into and is subject to our Terms of Use, which governs your use of the Website.

  1. Products and Services

Our Products/Services are designed for K–12 students, educators, and School staff who access and use them under authorization from their School. The School owns and controls all Student Data (as defined below), and the Company receives such data as a “school official” under Section 99.31 of the Family Educational Rights and Privacy Act of 1974 (“FERPA”) for the sole purpose of providing the Products.

We also rely on the School’s acknowledgment that it is acting as the parent’s agent and providing consent on the parent’s behalf for the processing of personal information of students under the age of 18 (“Child Users”) in accordance with the Children’s Online Privacy Protection Act (“COPPA”). In all cases, we provide our Products and Services exclusively for the benefit of the School for it to assist children and for no other commercial purpose.

We require all Schools to review this Privacy Policy and to make a copy available to parents or guardians where required to do so.

Our Approach to Student Data Privacy:


Users and visitors of the Website do not and should not disclose Student Data, nor is Student Data knowingly collected.  Student Data is only collected when Schools engage and enter into separate agreements with Company to use Company’s assessment tool and curriculum services.   

When providing our Products and Services to Schools and their Authorized School Users, the Company collects, receives, generates, or otherwise has access to “Student Data” only when engaged in the separate agreement with Schools mentioned above.  Student Data means information that directly relates to an identifiable student which is further defined and governed by the Assessment Tool Privacy Policy and additional agreements between Company and Schools. Users will have access to the Assessment Tool Privacy Policy once such user signs up for and engages with Company for such services. 

We treat all Student Data as confidential and use it solely for educational purposes in connection with providing our Products to, or on behalf of, the School as described in this Privacy Policy, the Privacy Policy of the assessment tools, and our Agreements. We are committed to protecting the security and confidentiality of Student Data and ensure that Schools retain control over how such data is used, accessed, shared, and retained.

Our collection and use of Student Data are governed by our Agreements with Schools, the Assessment Tool Privacy Policy, this Privacy Policy and all applicable laws, which may include the Family Educational Rights and Privacy Act (“FERPA”), the Children’s Online Privacy Protection Act (“COPPA”), the Protection of Pupil Rights Amendment (“PPRA”), and other relevant federal, state, and local privacy laws and regulations (“Applicable Laws”). As noted above, under FERPA, the Company receives Student Data as a “school official” under Section 99.31 for the purpose of providing its Products, and such data remains owned and controlled by the School.

  1. Notice at Collection (California Residents)

We collect the categories of personal information listed in Section 4 below for the purposes described in Sections 4 and 5. We do not collect additional categories or use the information for materially different purposes without notice. For details on your rights, including to opt out of sale or sharing, see Section 14 (“Your California Privacy Rights”)

  1. Information We Collect
  2. When you visit the Website we may collect information in the following categories:

Information You Provide Directly:

Type of Information

Collected From

Name, email, phone number, shipping address, address

Customers, teachers, School representatives

Billing, shipping address, payment details, such as a credit card number (processed by third-party payment processors)

Customers purchasing materials

School/organization name and role, School website

Teachers, administrators, School districts

Message content from “Contact Us,” email inquiries, form submissions or phone calls made to us

All users

Teacher and program feedback

Teachers, Schools

  1. When you participate in our programs 

Information You Provide Directly:

Type of Information

Collected From

Name, email, phone number, shipping address, address

Customers, teachers, School representatives

Billing, shipping address, payment details, such as a credit card number (processed by third-party payment processors)

Customers purchasing materials

School/organization name and role, School website

Teachers, administrators, School districts

Message content from “Contact Us,” email inquiries, form submissions or phone calls made to us

All users

Teacher and program feedback

Teachers, Schools

We will also collect Student Data (Educational Use)

When Schools and teachers use our educational programs and assessment tools:

  • We may collect student names or unique student ID, grade, age, reading progress and scores, assessment results.
  • The only student data that is stored will be anonymized or aggregated for analytics, reporting, or improvement of our services.
  • Personally identifiable student information is only collected with consent from a parent, legal guardian, or authorized School official (as permitted by FERPA/COPPA).

The collection of such data is governed by the Assessment Tool Privacy Policy. Users will have access to the Assessment Tool Privacy Policy once such user signs up for and engages with Company for such services.  

  1. Automatically Collected Information

We use cookies and analytics tools to collect:

  • IP address, browser type, device identifiers, pages visited, time spent on site;
  • Order history and site interaction;
  • Cookies may be functional, performance-related, or used for analytics.

Using automatic collection technologies helps us to improve our Services and to deliver a better and more personalized experience.

The technologies we use for this automatic data collection may include:

  • Cookies. A cookie is a small file placed on your device when you interact with the Services. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain features of the Services. 
  • Web Beacons. Some parts of the Services, and our emails, may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those parts or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity). 

You may disable cookies via browser settings.  See our Cookie Policy for more details on our use of cookies. 

We ask that you never send us, and that you do not disclose, any sensitive government identifiers, such as social security numbers. 

  1. How We Use Information

We use information that we collect about you or that you provide to us, including any personal data to:

  • Process and deliver book orders and educational materials and communicate with you regarding such orders, such as order confirm, status, shipping, etc.;
  • Communicate with customers, teachers, Schools, and parents;
  • Set up and manage School programs, trainings, and contracts;
  • Provide and improve our educational tools, products, services and Website;
  • Analyze student performance and program effectiveness (only in anonymous or aggregated form and only when users are using the assessment tool services  – not found on this Website);
  • Respond to questions, requests, or customer support inquiries;
  • Comply with legal obligations (tax, accounting, regulatory).

The usage information we collect, whether connected to your personal data or not, helps us improve our services and deliver a more personalized experience by enabling us to:

  • Store information about your preferences, allowing us to customize the services according to your individual needs and interests; 
  • Speed up your searches; 
  • Recognize you when you return to our services. 

We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, please email us at [email protected].  For more information, see Your Rights and Choices, below. 

  1. Legal Bases for Processing (If Applicable)

Where required by law (e.g., California or GDPR if expanded internationally), data may be processed based on:

  • Consent;
  • Performance of a contract;
  • Legitimate educational/business interests;
  • Compliance with legal obligations.
  1. How We Share Information

We do not sell personal information, including student data.

We may share information only with:

Recipient

Purpose

Service providers (payment processors, hosting, email, analytics, shipping, manufacturers, customer service)

To operate our website and fulfill orders, provide customer service

Schools, teachers, or districts

To provide program consultation, training, results or progress reports (FERPA-compliant). For research, reporting, product improvement. Unless you are logged into our services system, no individual Student Data will be collected or saved by or on this Website. 

   

Legal authorities

If required by law, court order, or to protect safety or rights

Successors in interest (e.g., merger, acquisition)

Provided they comply with same privacy protections

 

We may also share your personal information where we have a good faith belief that such disclosure is necessary in order to: i) protect, enforce, or defend our legal rights, privacy, safety, operations, or property of those of our parents, subsidiaries or affiliates or our (or their) employees, agents and contractors; ii) protect the rights, safety, privacy, security or property of users of the Website or others; (iii) protect against fraud or for risk management purposes; iv) enable us to pursue any remedies and damages that are threaten or in fact sustained by us; or v) to comply with any court order, law, or legal process, including to respond to any government or regulatory request. 

  1. Children’s Privacy (COPPA Compliance)
  • Our website is primarily intended for adults (teachers, parents, Schools).
  • We do not knowingly collect personal information directly from children under 18 without verifiable parental or School authorization.
  • Student Data is only collected through authorized Schools/teachers or with parental consent. Student Data is only collected when Schools engage and enter into separate agreements with Company to use Company’s assessment tool and curriculum services.
  • If we learn we have collected personal information from a child without proper consent, we will delete it promptly.

If you believe that someone under 18 has or may have provided us with personal information without proper consent, we ask that you contact us immediately at [email protected].

The Company relies on the School’s acknowledgment that it is acting as the parent’s agent and providing consent on the parent’s behalf for the processing of personal information of Child Users in compliance with all applicable provisions of COPPA. Where COPPA applies, we process this information solely for educational purposes—and not for any commercial purpose—under the direction and authorization of the School as an educational institution. If you are a parent or guardian and have questions about your child’s use of the Products or the personal information collected, please contact your child’s School directly.

Our Assessment Tool Privacy Policy governs how we collect and how we use, disclose and retain this data. Users will have access to the Assessment Tool Privacy Policy once such user signs up for and engages with Company for such services.

  1. Data Security and Location 

We use commercially reasonable technical, administrative, personnel, and physical safeguards to protect personal information that has been collected and is in our possession from being accidentally lost, or used or accessed in an unauthorized way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. Should there be any suspected data security breach, we will notify you and any applicable regulator of a suspected data breach where We are legally required to do so. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

Personal information is stored on secure servers located in the United States.  The Website is operated, managed, and controlled by us from the United States and is not intended to subject us to the laws or jurisdiction of any country other than the United States. If you access the Site from outside the United States, you acknowledge and consent to the processing of your personal information in the United States. Please note that United States data protection and related laws may differ from those in your country of residence. This processing may include the use of cookies and other tracking technologies as described above.

The safety and security of your information also depends on you. You should carefully decide what information you send to us via communications channels. Any transmission of personal data is at your own risk. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access. 

  1. Data Retention

With certain exceptions to comply with state and local laws, we retain personal information and School data only as long as necessary:

  • For order fulfillment, legal obligations, or active School programs;
  • If using our curriculum and assessment tool service, Student Data is retained only as required for educational services and is anonymized or deleted upon request or program end. To our knowledge, visiting and using this Website will not lead to collection of Student Data. Users will have access to the Assessment Tool Privacy Policy once such user signs up for and engages with Company for such services;
  • Aggregated/de-identified data may be retained for research or product improvement.

Even after we delete your personal information from our systems, certain information associated with your account may remain visible in limited situations – for example, if you have shared it on social media or through other unaffiliated services. We may also retain backup copies of your account information for a period of time after cancellation to help detect fraud, comply with legal obligations, or enforce our internal security policies. Additionally, due to caching and other technical processes, your account or related content may not become immediately inaccessible, and removal from other parts of the internet or search engine results may take some time.

  1. Your Rights and Choices

Depending on your jurisdiction, you may have the right to:

  • Access, correct, or delete your information;
  • Opt-out of marketing emails;
  • Request deletion or return of student data (via School or district authorization);
  • California residents (if applicable) may request disclosure of collected data categories and request deletion under the CCPA. See California Privacy Rights below. 

Important: The exact scope of these rights vary by state. There are also several exceptions where we may not have an obligation to fulfill your request. 

To exercise these rights, contact us at: [email protected]. If we deny your privacy request, you have the right to appeal our decision. To submit an appeal, please contact us at [email protected]. We will review and respond to your appeal within the time frame required by law.

Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to process your request to opt out from certain types of data processing. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law. 

  1. Third-Party Links

We use third-party services such as the examples below:

Service

Purpose

Stripe

Payment processing

Google Analytics

Website usage analytics

Vimeo

Video hosting and streaming

sbjs_migrations cookie

Marketing attribution tracking

These services have their own privacy policies; we are not responsible for their content or practices. The list above may change from time to time.  We will try to keep the list updated, but it may not be fully complete. 

Our Website may link to external websites. We are not responsible for their content or privacy practices and you access those websites at your own risk. We encourage you to review their privacy policies.  Once you leave the Website via a link or enable an unaffiliated service, you are subject to the privacy policies and terms of use of those unaffiliated services and websites.

  1. Changes to This Privacy Policy

We may update this Policy periodically. The “Last Updated” date above will indicate when this Policy was last revised.  If significant changes are made, we will post a notice on our website and notify our registered users. Continued use of our services after changes constitutes acceptance. If you do not wish to be bound by the terms of the revised Privacy Policy, you must discontinue your use of the Website. We may email or otherwise communicate reminders about this policy, but you should check our Website periodically to see the current policy and any changes we have made to it. 

  1. California Privacy Rights (CCPA / CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA). These apply to personal information we collect in our commercial activities (e.g., selling books, communicating with teachers/Schools). FERPA further governs student data collected for educational/School purposes.  

  1. Categories of Personal Information Collected

Category

Examples

Source

Shared With

Identifiers

Name, email, postal address, School, IP address

User-provided, website analytics

Service providers (hosting, delivery, email)

Commercial info

Purchase history, cart activity

Customer transactions

Payment processors, fulfillment

Internet/technical

IP address, site usage, cookies

Automatically via your device

Analytics providers

Professional info

Teacher, School name, role

Contact forms/emails

Internal team

Student data (de-identified for analytics)

Reading levels, scores

Teachers/Schools

Aggregated only (no personal IDs)

We do not “sell” personal information as defined by CCPA. We may “share” limited data for cross-context behavioral advertising (e.g., website analytics), and you may opt out.

The chart above identifies which categories of information we collected from our consumers within the last 12 months. See also Section 10 (above) to learn more about data retention.

  1. Rights of California Residents

You may request:

  • Right to Know / Access – What personal information we collect, use, or disclose and the sources from which we collected the personal information.
    • If we have collected, used or disclosed your personal information over the last 12 months, we will identify the categories of such data share with each category or third party recipient. 

 

  • Right to Delete – Request deletion of personal information, subject to legal/contractual obligations or certain exceptions: for example, we may need to retain your personal information to provide you with the Products/Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

 

  • Right to Correct – Request corrections to inaccurate data. We may require you to provide documentation, if needed, to confirm your identity and support your claim that the information is inaccurate. Unless an exception applies, we will correct personal information.

 

  • Right to Limit Use You have a right to limit use and disclosure of your personal information only to what is necessary to perform the Services or for the Products to function. We do not collect highly sensitive personal information about consumers or students.

 

  • Right to Opt-Out of Sale/Sharing – We do not sell data, but you may opt out of data sharing for analytics and other marketing. See “Opt-Out Policy” Section in this Privacy Policy.

 

  • Right to Non-Discrimination – We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA.

 

  • Right to Appeal – If we deny your privacy request, you have the right to appeal our decision. We will review and respond to your appeal within the time frame required by law.

To exercise any of these rights, contact us at:

Email: [email protected]
Phone:  1-800-674-3849

We will verify your request before processing it. To exercise the rights described above, you must send us a request with sufficient detail so we can properly understand, evaluate, and respond to it, including sufficient information to allow us to verify that you are the person about whom we have collected personal data. Each request that meets these criteria will be a “Valid Request.” If the request does not meet these criteria, we may not respond.  You do not need an account to submit a Valid Request.

 

We will work to respond to your Valid Request within 45 days of receipt. There is no charge associated with Valid Requests unless it is excessive, unfounded or repetitive. We will notify you if we believe a fee is required.

 

  1. Other State Law Privacy Rights 

Residents of Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, Nevada, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia may have similar rights to those described for California residents. We will honor applicable state privacy rights to the extent required by law. 

  1. Opt-Out Policy

You may opt out of the following:

  1. Marketing Communications
  • You can unsubscribe from marketing emails by contacting us directly at [email protected].
  1. Cookies & Analytics Tracking
  1. Sale or Sharing of Personal Information
  • We do not sell personal information.
  • Where “sharing” for targeted advertising may occur, you may opt out through your browser or by contacting us at [email protected]
  1. Student Information
  • Student performance data is only shared in aggregated or de-identified format unless a School/district authorizes otherwise.
  • Parents or Schools may request deletion or access through authorized School officials.  See “Data Processing Agreement (Education Use Addendum)” below. 
  1. Data Processing Agreement (Educational Use Addendum)

When we process student data on behalf of a School or teacher the following additional terms apply:

  1. Roles
  • The School/District is the “Data Controller” or FERPA “School Official.”
  • We act as a “Data Processor” or “School Service Provider.”
  1. Permitted Use

We process student information only to provide educational Products/Services, including assessments, progress tracking, reporting, and teacher dashboards. We do not sell, share, or use student data for advertising or unrelated purposes.

  1. Data Ownership
  • All student records and performance data remain the property of the School or parent (as applicable).
  • We claim no ownership over student personal data.
  • We only retain rights to aggregated or de-identified data.
  1. Data Security & Confidentiality
  • We maintain administrative, technical, and physical safeguards aligned with industry standards. For information about data security and safeguards thereof, see the “Data Security and Location” section of our main Privacy Policy. 

 

  • Employee access to student information is limited and monitored.
  1. De-Identified Data
  • We may use anonymized or aggregated student data to improve programs, publish academic insights, or measure efficacy — never in a way that identifies a student, teacher, or School.
  1. Data Retention & Deletion
  • For information about data security and safeguards thereof, see the “Data Retention” section of our main Privacy Policy.. 
  1. Subprocessors
  • We may share limited data with vendors (cloud hosting, analytics, LMS systems), but only under written agreements that protect student data.
  1. Contact Us

For questions or privacy requests, contact:

Intelexia USA, LLC – Privacy Officer

Email: [email protected]
Phone: 1-800-674-3849