Privacy Policy

Effective date: 9/21/2016 Last updated: 7/21/2026

WIN ELEMENTS LLC ("WIN ELEMENTS," "we," "us," or "our") operates Sleedu Professional Development (the "Service"), which trains teachers and school leaders to use available technologies — including third-party open-source learning management software and plugins hosted on Sleedu.com and its subdomains (the "Website") — to implement education-related strategies and resources that support students. WIN ELEMENTS LLC also operates a separate e-commerce website, winelements.com, hosted on separate servers.

Please read this Privacy Policy carefully before using the Service.

We are committed to protecting student privacy. We understand that privacy is extremely important to the users of our Website — including teachers, students, and child users — and we are committed to protecting your personal information and complying with applicable legal requirements, including the Children's Online Privacy Protection Act ("COPPA") and the Family Educational Rights and Privacy Act ("FERPA").

We are a proud signatory of the Student Privacy Pledge. We use students' and users' data from our Service only to support instruction and learning opportunities and to develop and improve our products and services intended for educational use. In addition, we host our online store on a separate server at winelements.com to further protect student privacy.

This Privacy Policy explains how we collect, use, protect, and otherwise handle Personally Identifiable Information ("PII") in connection with the Website. PII, as described in U.S. privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context.

BY REGISTERING FOR, ACCESSING, BROWSING, OR USING THE WEBSITE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY AND OUR TERMS OF SERVICE.

WHEN YOU REGISTER FOR OUR SERVICE, YOU WILL BE ASKED TO READ AND AGREE TO OUR TERMS OF SERVICE, WHICH ALSO REFERENCE THIS PRIVACY POLICY. BY AGREEING TO OUR TERMS OF SERVICE, YOU ALSO AGREE TO THIS PRIVACY POLICY.

IF YOU ARE A PARENT OR LEGAL GUARDIAN AND YOU CONSENT TO YOUR CHILD REGISTERING WITH THE WEBSITE, YOU AGREE TO BE BOUND BY OUR TERMS OF SERVICE AND THIS PRIVACY POLICY WITH RESPECT TO YOUR CHILD'S USE OF THE WEBSITE.

IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR THE TERMS OF SERVICE, YOU DO NOT HAVE PERMISSION TO ACCESS THE SERVICE.

This Privacy Policy is subject to change by us at our sole discretion at any time (see Section 17).

1. What personal information do we collect from Students and Child Users?

We collect your name, email address, username, password, avatar, and user-generated content, only for purposes authorized by the educational institution or agency, teacher, or parent/student. Once a user is enrolled in a course, we track and retain records of the user's interactions with course activities — this is the primary function of our Service as an online learning management system. The teacher of a course may view their students' data only to better serve students' learning.

2. What personal information do we collect from Teacher Users?

We collect your name, email address, username, password, avatar, and user-generated content. When a teacher signs up for a paid Teacher Account on winelements.com, a third-party payment service — PayPal or Stripe — collects and processes your billing address and credit-card information. We do not store or process payment card information on our servers.

3. How do we collect your information?

3.1 From you. When you create an account as a student or teacher, we ask for your name, username, password, and email address in order to create your account. You may also upload an avatar to your user profile.

3.2 Sign-in with third-party accounts. If your school uses single sign-on, you may log in with a third-party account (such as a Google account provided by your school). In that case, we receive basic profile information from the identity provider — such as your name and email address — solely to create and authenticate your account. We do not receive your password for that third-party account.

3.3 Information collected automatically. To provide a personalized learning experience, we automatically collect certain types of usage information from your browser or device, such as log files, Internet Protocol (IP) address, device or browser type, Internet service provider (ISP), and the dates and times you visit the Website. We may use cookies — small text files containing a string of alphanumeric characters — to record current session information. Cookies are used to track logins and sessions and to collect anonymous traffic data. We may also use Google Analytics to help us measure traffic and usage trends for the Service. We collect information about how you use the Service (such as the pages you view, the activities you use, and other interactions) and your usage of the Service over time. We may collect log-file information from your browser or mobile device each time you access the Service.

We do not allow any third-party advertising networks to collect information about the users of the Website.

We use a limited number of third-party service providers — for example, YouTube to host videos and Google Analytics to understand Website usage.

4. How do we use your information?

4.1 Students and other users. Students and other users access the Website using personally identifiable information (such as username, email, and password). We strictly maintain the confidentiality of student data, and we do not use student data for any purpose other than providing the Service.

4.2 Information collected automatically. We use data collected through cookies, log files, and device identifiers to: (1) remember information so that a user's progress in activities is saved and the user can continue where they left off; (2) record a user's achievements and other records as they interact with the Service; (3) diagnose and fix technological problems; and (4) help users access information more efficiently.

4.3 De-identified information. We may use de-identified information to improve our educational products for adaptive-learning purposes and to customize users' learning experiences.

5. How do we protect your information?

When you interact with the Service, the information you supply is encrypted in transit using SSL/TLS technology. Your personal information is contained behind secured networks and is accessible only by a limited number of persons who have special access rights to those systems and who are required to keep the information confidential. We implement a variety of security measures when a user enters, submits, or accesses their information in order to maintain the safety of your personal information.

All payment transactions are processed through a gateway provider (including, but not limited to, Stripe and PayPal) and are not stored or processed on our servers.

6. How do we share or transfer data?

We protect the information you provide to us. We do not rent or sell personal information that we collect from users to third parties, and we do not use student personal information for targeted advertising.

7. Do we use cookies?

Yes. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your web browser (if you allow) that enable the site's or provider's systems to recognize your browser and capture and remember certain information.

On the Website, we use cookies to track logins and sessions, save your progress, understand your preferences based on previous or current site activity, and compile aggregate data about site traffic and interactions so that we can offer better experiences and tools in the future. On our online store (winelements.com), cookies are also used for functions such as remembering the items in your shopping cart. We may use trusted third-party services that track this information on our behalf.

You can choose to have your computer warn you each time a cookie is being sent, or you can turn off all cookies, through your browser settings. Each browser is a little different, so consult your browser's Help menu for the correct way to modify your cookie settings. If you turn cookies off, some features of the Service will be disabled and may not function properly.

8. Third-party disclosure

We do not sell, trade, or otherwise transfer your personally identifiable information to outside parties without providing you advance notice. We may release information when its release is appropriate to comply with the law, to enforce our site policies, or to protect our or others' rights, property, or safety.

Excluding third-party links provided by our users, we make reasonable efforts to ensure that any third parties we work with adhere to the Student Privacy Pledge principles, including security and data-retention principles. Our online store is hosted on a separate server, and students under 13 years of age do not have permission to use our online store.

8.1 Third-party links. Occasionally, at our discretion, we may include or offer third-party products or services on the Website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of linked sites. We nevertheless make reasonable efforts to ensure that third parties we choose to work with adhere to the Pledge principles.

9. California Online Privacy Protection Act (CalOPPA)

CalOPPA requires commercial websites and online services that collect personally identifiable information from California consumers to post a conspicuous privacy policy stating exactly what information is collected and with whom it is shared.

In accordance with CalOPPA, we agree to the following:

  • Users can visit our site anonymously (browsing without an account).
  • A link to this Privacy Policy is available on our homepage, or at a minimum on the first significant page after entering the Website.
  • Our Privacy Policy link includes the word "Privacy" and can easily be found on the pages specified above.
  • You will be notified of any Privacy Policy changes on this Privacy Policy page.
  • You can change your personal information by logging into your account.

10. COPPA (Children's Online Privacy Protection Act)

COPPA puts parents in control of the collection of personal information from children under 13 years of age. The Federal Trade Commission enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.

We do not market to children under 13 years of age. Children under 13 may use the Service only with the consent of a parent or legal guardian, or where a teacher or school has obtained verifiable parental consent on the school's behalf, as described in our Terms of Service.

With respect to Child Users, we: collect only the information described in Section 1; use it solely to provide the Service; do not use it for targeted advertising; and do not require a child to disclose more information than is reasonably necessary to participate in the Service.

Parents and legal guardians may review their child's personal information, direct us to delete it, and refuse to allow any further collection or use of it, by contacting us at hello@winelements.com or through the child's school.

11. FERPA (Family Educational Rights and Privacy Act)

Where we receive student education records from a school or district, we act as a "school official" with a legitimate educational interest under FERPA. We use education records solely to provide the Service on the school's behalf, we do not disclose them except as directed by the school or as permitted by law, and access to such records remains under the control of the school or district. Students and parents should direct requests to inspect or amend education records to their school or district.

12. Fair Information Practices

The Fair Information Practice Principles form the backbone of privacy law in the United States, and the concepts they include have played a significant role in the development of data-protection laws around the globe.

In line with the Fair Information Practices, should a data breach occur we will take the following responsive action:

  • We will notify affected users via email within 7 business days.
  • We will notify users via in-site notification within 7 business days.

We also agree to the Individual Redress Principle, which requires that individuals have enforceable rights against data collectors and processors who fail to adhere to the law, and recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

13. CAN-SPAM Act

The CAN-SPAM Act sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to stop receiving emails, and spells out penalties for violations.

We collect your email address in order to send information and respond to inquiries and other requests or questions.

To be in accordance with CAN-SPAM, we agree to the following:

  • We will not use false or misleading subjects or email addresses.
  • We will identify any advertising message as an advertisement in a reasonable way.
  • We will monitor any third-party email marketing service we use for compliance.
  • We will honor opt-out and unsubscribe requests promptly.
  • We will allow users to unsubscribe via the link at the bottom of each email.

If at any time you would like to unsubscribe from future emails, follow the instructions at the bottom of any email from us, or email us at hello@winelements.com, and we will promptly remove you from all correspondence.

14. E-commerce / online store on a separate server (winelements.com)

To protect our students' privacy and our users' payment information, we host our e-commerce store on a separate server at winelements.com.

14.1 Payment. All payments on our online store are processed and completed by secured PayPal and/or Stripe payment services. You can learn how PayPal and Stripe protect customers on their respective sites.

14.2 Age of consent. Only users who are 18 or older may create an account on our online store. If you are younger than 18, you do not have permission to access or use winelements.com.

14.3 Placement-targeted advertising (winelements.com only). We use Google placement-targeted ads only on our online store, which is hosted on a separate server. Google may use information (not including your name, address, email address, or telephone number) about your visits to that and other websites to provide advertisements about goods and services of interest to you. For more information about this practice and your choices about not having this information used by Google, see Google's advertising policies.

NO ADVERTISING IS SERVED ON SLEEDU.COM OR ITS SUBDOMAINS, AND WE DO NOT USE ANY PERSONALLY IDENTIFIABLE INFORMATION IN STUDENT RECORDS FOR TARGETED ADVERTISING.

15. Change of business, including a merger or acquisition

In the event that WIN ELEMENTS LLC (including its services, such as Sleedu.com and winelements.com) is acquired by or merged with another company, or undergoes any other change of control, we may transfer or assign the information we have collected from users as part of that transaction. We will only enter into such a transaction with a successor whose practices are consistent with the Student Privacy Pledge principles, or we will give users the choice of whether their information is transferred to the successor entity.

16. Data access, correction, and retention

16.1 Access and correction. Students, their parents, or their authorized guardians may review, make changes to, or correct a student's personally identifiable information using the student's login information, or by contacting us.

16.2 Retention and deletion. We will not retain students' personal information for longer than necessary to deliver the Service or for the educational purposes for which it was provided. Users may request deletion of their accounts at any time by contacting us at hello@winelements.com.

17. Notice and choice; changes to this Privacy Policy

We reserve the right, at our sole discretion, to modify, change, add, or remove portions of this Privacy Policy at any time. What constitutes a material change will be determined at our sole discretion. Please check this Privacy Policy periodically for changes. We will announce changes on our Website and make reasonable efforts to notify users by email at the address associated with their account. By continuing to access or use our Service after revisions become effective, you agree to be bound by the revised Privacy Policy. If you do not agree to the revised Privacy Policy, you are no longer authorized to use the Service.

18. Contact us

If you have any questions regarding this Privacy Policy, you may contact us at hello@winelements.com.

If you are unable to reach us, you may contact our Registered Agent:

California Registered Agent Inc 1267 Willis Street STE 200 Redding, CA 96001 Tel: (530) 232-5985 http://www.californiaregisteredagents.net agent@californiaregisteredagents.net

Last modified: Tuesday, 21 July 2026, 3:46 PM