Privacy Policy

Effective date: 9/21/2016    Last updated: 9/5/2026

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"), the Family Educational Rights and Privacy Act ("FERPA"), the California Student Online Personal Information Protection Act ("SOPIPA," Cal. Bus. & Prof. Code § 22584), and Cal. Ed. Code § 49073.1.

We use student and user data from our Service only to provide, maintain, secure, and support the Service for the school, district, teacher, or other education authority that authorized the user's account (the "Subscriber"). We do not use student data for advertising, for building non-educational profiles, or to train artificial intelligence or other automated models. 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 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. "Student Data" means PII about a Student, including educational records, that is created by, provided to, or collected through the Service, and has the same meaning as in Section 2.2 of our Terms of Service.

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 as described in Section 18. Changes to our Student Data practices are additionally subject to Section 6(j).

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

We collect your name, email address, username, password, avatar (if you choose to upload one), and user-generated content, only for purposes authorized by the Subscriber, teacher, or parent. Once a user is enrolled in a course, we track and retain records of the user's interactions with course activities (such as assignment submissions, quiz attempts, grades, forum posts, and completion status) — 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 support students' learning.

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

We collect your name, email address, username, password, avatar (if you choose to upload one), 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. Your Subscriber may create accounts on your behalf.

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 operate and secure the Service, we automatically collect certain usage information from your browser or device, such as log files, Internet Protocol (IP) address, device or browser type, and the dates and times you visit the Website. We use cookies — small text files containing a string of alphanumeric characters — to record current session information. Cookies are used to keep you logged in, save your progress, and maintain your session. We collect information about how you use the Service (such as the pages you view, the activities you use, and other interactions) so that a user's progress is saved and teachers can see course activity.

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

4. Service providers we use

We use a limited number of third-party service providers to operate the Service. Each is bound by written terms that restrict its use of the data it processes for us to providing its service to us. Our current providers are:

  • Cloud hosting: Amazon Web Services, United States data centers. Student Data is stored in the United States.
  • Single sign-on (where enabled by your Subscriber): Google identity services, receiving only name and email address as described in Section 3.2.
  • Transactional email: an email delivery provider used to send account, password, and course notification emails. It receives only the recipient's email address and the content of the notification.
  • Embedded video: videos embedded in courses may be hosted by YouTube. YouTube's own privacy policy governs data it collects when a video is played.
  • Web analytics: Google Analytics, used only to measure aggregate traffic and usage trends for the Service. It is not linked to individual user accounts and is not used for advertising.

We will update this list before adding a provider that processes Student Data.

5. How do we use your information?

5.1 Students and other users

Students and other users access the Website using PII (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, maintaining, securing, and supporting the Service for the Subscriber.

5.2 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; (4) detect and prevent unauthorized access; and (5) help users access information more efficiently.

5.3 No model training

We do not use Student Data, user-generated content, or any other information from the Service to train, fine-tune, test, or improve artificial intelligence, machine learning, or other automated models, whether ours or a third party's.

6. Student Data commitments

This Section 6 applies to all Student Data and mirrors Section 2.2 of our Terms of Service.

(a) Ownership and control. Student Data is and remains the property of, and under the control of, the Subscriber and, where applicable, the Student's parent or legal guardian. WIN ELEMENTS LLC acquires no ownership interest in Student Data.

(b) Our role. We collect, store, and process Student Data only on behalf of and at the direction of the Subscriber. Where the Subscriber is a school, school district, or other educational agency, we act as a "school official" with a legitimate educational interest under FERPA to the extent FERPA applies, and we comply with SOPIPA and Cal. Ed. Code § 49073.1 to the extent they apply.

(c) Prohibited uses. We do not and will not:

  1. sell, rent, or trade Student Data;
  2. use Student Data to serve, target, or measure advertising;
  3. use Student Data to build a profile of a Student for any purpose other than the educational purpose directed by the Subscriber;
  4. use Student Data to train, fine-tune, test, or improve any artificial intelligence, machine learning, or other automated model; or
  5. disclose Student Data except as described in paragraph (d).

(d) Permitted disclosures. We may disclose Student Data only: (1) to the Subscriber and to users the Subscriber authorizes; (2) to the service providers listed in Section 4, which process Student Data on our behalf and are bound by written obligations at least as protective as this Section 6; (3) as required by law, subpoena, or court order, in which case we will notify the Subscriber before disclosure unless legally prohibited; or (4) as otherwise directed in writing by the Subscriber.

(e) Security. See Section 7.

(f) Breach notification. See Section 13.

(g) Parent and eligible student access. See Section 17.

(h) Retention and deletion. See Section 17.

(i) Data privacy agreements. Where a written data privacy agreement, student data privacy agreement, or similar contract exists between WIN ELEMENTS LLC and a Subscriber, that agreement controls over this Privacy Policy with respect to Student Data to the extent of any conflict.

(j) Changes to Student Data practices. We will not make material changes to how we collect, use, or disclose Student Data without first providing notice to the Subscriber.

7. How do we protect your information?

When you interact with the Service, the information you supply is encrypted in transit using TLS. Your personal information is stored 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 use role-based access controls, log administrative access, and maintain regular encrypted backups. 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.

No method of transmission over the Internet or method of electronic storage is completely secure. If you believe your account has been accessed without authorization, contact us immediately at hello@winelements.com.

8. How do we share or transfer data?

We do not sell, rent, or trade personal information that we collect from users, and we do not use Student Data for targeted advertising. We share personal information only with the service providers listed in Section 4, with the Subscriber, as required by law, or as described in Section 6(d).

9. Do we use cookies?

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

On the Website, we use cookies to keep you logged in, maintain your session, and save your progress. We do not use cookies on Sleedu.com or its subdomains for advertising. On our online store (winelements.com), cookies are also used for functions such as remembering the items in your shopping cart.

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, you will not be able to log in and most features of the Service will not function.

10. Third-party links

Course content created by teachers, and occasionally content we provide, may include links to third-party websites or embedded third-party resources. These third-party sites have separate and independent privacy policies. We have no responsibility or liability for the content and activities of linked sites. Teachers are asked to review the privacy practices of resources they link in courses. 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.

11. California Online Privacy Protection Act (CalOPPA)

CalOPPA requires commercial websites and online services that collect PII 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.

We do not respond differently to browser "Do Not Track" signals because we do not track users across third-party websites.

12. 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 the child's school or by contacting us at hello@winelements.com. Where the child's account was created by a school or district, we will coordinate with that Subscriber in responding.

13. Data breach notification

If we discover unauthorized access to or acquisition of Student Data or other PII, we will:

  • notify the affected Subscriber without unreasonable delay after discovery, and in any event within the time required by applicable law or by our agreement with the Subscriber;
  • provide the Subscriber with the information reasonably needed to meet its own notification obligations under Cal. Civ. Code § 1798.82, Cal. Ed. Code § 49073.1, and other applicable law;
  • cooperate with the Subscriber in notifying affected students, parents, and staff, and in any investigation; and
  • where we hold PII of users not associated with a Subscriber, notify those users directly by email without unreasonable delay.

14. 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; we will assist the school or district in responding.

15. Email communications and CAN-SPAM

We collect your email address in order to create your account, send account and course notifications (such as password resets and assignment reminders), and respond to inquiries and requests.

We do not send marketing or promotional email to Students. Teachers and Subscriber staff may receive occasional emails about the Service itself, such as feature updates or scheduled maintenance.

In accordance with the CAN-SPAM Act, we will not use false or misleading subjects or email addresses; we will honor opt-out and unsubscribe requests promptly; and any non-transactional email will include an unsubscribe link. If at any time you would like to stop receiving non-transactional emails, follow the instructions at the bottom of the email or contact hello@winelements.com. Account and course notification emails are part of the Service and are controlled through your account or by your Subscriber.

16. 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.

16.1 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.

16.2 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.

16.3 Store privacy practices

Information collected on winelements.com is governed by the privacy policy posted on winelements.com. No Student Data is collected on, transferred to, or used by winelements.com. No advertising is served on Sleedu.com or its subdomains.

17. Data access, correction, retention, and deletion

17.1 Access and correction

Users may review and correct their own profile information by logging into their account. Requests by a parent, legal guardian, or eligible student to review, correct, or delete Student Data held on behalf of a school or district are handled through that Subscriber, and we will assist the Subscriber in responding. Parents and guardians may also contact us directly at hello@winelements.com and we will coordinate with the Subscriber.

17.2 Retention and deletion

We retain Student Data only as long as needed to provide the Service to the Subscriber. Upon the Subscriber's written request, or within ninety (90) days after the Subscriber ceases to use the Service, we will delete or return Student Data, except for copies held in routine encrypted backups, which are purged in the normal backup cycle, and except as we are required by law to retain. Users may request deletion of their own accounts at any time by contacting hello@winelements.com; where an account was created by a Subscriber, we will confirm the request with that Subscriber.

18. 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 the information we have collected from users as part of that transaction, provided that the successor agrees in writing to be bound by this Privacy Policy and by our agreements with Subscribers with respect to Student Data. We will notify affected Subscribers before any such transfer of Student Data so that they may exercise their rights under Section 17.

19. Changes to this Privacy Policy

We may modify this Privacy Policy from time to time. We will post the revised policy on this page with an updated "Last updated" date, announce changes on our Website, and make reasonable efforts to notify users by email at the address associated with their account. Material changes to how we collect, use, or disclose Student Data are subject to advance notice to Subscribers under Section 6(j). 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.

20. 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: Saturday, 5 September 2026, 9:47 AM