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877 914 4366

Privacy Policy for Gemm Learning

Last Updated: June 2026

Westchester Learning Corporation (doing business as Gemm Learning) is committed to protecting the privacy of our website visitors, students, and their families.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website (www.gemmlearning.com) or use our remote learning software and professional oversight services.

By accessing or using our services, you agree to the terms of this Privacy Policy. If you do not agree with these terms, please do not access our site or use our services.

1. Information We Collect

We collect information about you in a few different ways when you interact with our website and services:

A. Information You Voluntarily Provide

When you complete an inquiry or registration form, or email/text our team, we may collect personally identifying information, including:

  • Full name
  • Email address
  • Phone number (including mobile number for text alerts)
  • Child’s age or birth date
  • General educational background or learning concerns

B. Automatically Collected Information

Like most online platforms, we automatically collect certain technical data when you browse our website or when students log into our learning applications. This includes:

  • IP address, browser type, and operating system
  • Device identifiers and geolocation data
  • Usage Patterns: Time spent on specific pages, clicks, and paths taken through the site.
  • Software Performance Analytics: For registered students, via the Scientific Learning Portal, we log daily usage statistics, including session lengths, specific cognitive exercises accessed, error reports, and milestone achievements, to provide remote clinical oversight.

C. Cookies and Tracking Technologies

We use cookies and web beacons to enhance your experience, analyze web volume, and track site functionality. You can set your browser to refuse cookies, though doing so may prevent certain interactive features of our website from working properly.

2. How We Use Your Information

We use the data we collect to deliver, optimize, and support our online cognitive and reading programs. Specifically, we use your information to:

  • Provide Professional Oversight: Track student clicks, progress, and error logs daily so our program management team can individualize protocols and send weekly progress updates.
  • Respond to Requests: Fulfill your demo requests, review Fit Quiz results, and manage customer service inquiries.
  • Improve Our Services: Analyze aggregate, non-identifying statistical data to optimize website flow and software efficacy.
  • Communicate Updates: Send newsletters, promotional offers, or critical system updates (subject to your opt-out preferences).

3. Data Sharing and Third-Party Disclosures

We do not sell, rent, or trade your personally identifiable information to external third parties for marketing purposes.

We only share information under the following limited circumstances:

  • Service Providers: We utilize trusted third-party platforms to track web usage volume, manage our servers, host our platform (e.g., secure cloud hosting), and handle billing. These entities are contractually obligated to maintain your data’s strict confidentiality.
  • SMS & Text Messaging Privacy: If you opt-in to receive SMS notifications or mobile communications from Gemm Learning, your opt-in consent and mobile phone number will not be shared with any third-party organizations or affiliates for marketing purposes.
  • Legal Requirements: We may disclose your information if required by law, subpoena, court order, or to protect the safety, rights, and property of Gemm Learning, our users, or the public.

4. Children’s Privacy (COPPA Compliance)

Because Gemm Learning provides cognitive training for children, we take youth privacy very seriously.

Our public website is intended for parents, guardians, and adult educators. We do not knowingly collect personally identifiable information from individuals under 13 years of age via our public forms. Student profiles are created exclusively by parents or legal guardians during enrollment.

If a parent or guardian discovers that a child under 13 has provided personal data without consent, please contact us immediately (using the details below), and we will delete the information from our records as quickly as possible.

5. Security of Your Information

We employ customary administrative, technical, and physical security measures designed to protect your personal data from unauthorized access, loss, or alteration. Data transmissions through our site are secured via industry-standard encryption protocols.

However, please remember that no method of online transmission or electronic storage is 100% secure.

6. Your Rights and Choices

Depending on your jurisdiction, you may have specific rights regarding your personal data. At any time, you can:

  • Opt-Out of Marketing: Click the “unsubscribe” link in our emails, or text “STOP” to opt out of any mobile text alerts.
  • Access or Delete Data: Request a copy of the personal data we hold about you or ask that we erase your data (excluding information we are legally or administratively required to maintain).

Policy Changes

We may, at any time, amend the provisions in this Privacy Policy. Changes to this policy will be reflected by the “Effective Date” as displayed in the upper left-hand corner of this Privacy Policy. Your continued use of this web site following the posting of changes to these terms constitutes your acceptance of those changes.

Privacy in Testimonials and Case Studies

We love celebrating our students’ success, but we value their privacy even more. To protect the identities of the families we serve, all student and parent names used in the success stories, testimonials, and case studies featured on our website have been changed. Furthermore, any student photographs or family images displayed alongside these stories are not real photos of the actual participants.

7. Contact Us

If you have questions, comments, or data removal requests regarding this Privacy Policy, please contact us at:

Gemm Learning
Attn: Privacy Compliance
699 Main Street, New Rochelle, NY 10801

Phone: 877-914-4366
Email: support@gemmlearning.com
Website: www.gemmlearning.com

Disclaimer: This draft serves as an updated template based on Gemm Learning’s known operational model. It should be reviewed by your internal legal counsel to ensure precise compliance with ever-changing regional privacy acts like the CCPA/CPRA, GDPR, or state-specific privacy laws.

Links & Logos Policy

Any trademarks or logos used throughout this website are the property of their respective owners.

We may include links to websites outside of our website. These links are provided to offer users additional relevant information they may wish to explore.

We are not responsible for the content of external websites. The inclusion of a link to a third-party website from our website should not be understood as an endorsement or authorization of any content, concepts, offers, advertising, or any other content or information. Many of these other websites may send their own cookies to users, collect data, or solicit personal information and we do not guarantee the security of any information that you may disclose.

We are not responsible for the content of external websites that link to our website. Any external link to our website should not be understood as an endorsement or authorization of any content, concepts, offers, advertising or any other content or information.

No Warranties

We do not warrant that our website will operate error-free or that our website or server is free of computer viruses and other harmful components. If your use of our website results in the need to service or replace equipment or data, we are not responsible for those costs or any related damage.

YOU ASSUME TOTAL RESPONSIBILITY AND RISK FOR YOUR USE OF OUR WEBSITE. WE ARE PROVIDING OUR WEBSITE “AS IS”. WE MAKE NO WARRANTIES, EXPRESS OR IMPLIED, ABOUT OUR WEBSITE. NEITHER WE NOR ANY OF OUR AFFILIATES OR OUR OR THEIR EMPLOYEES, DIRECTORS, OFFICERS, LICENSEES, REPRESENTATIVES OR AGENTS SHALL BE LIABLE FOR ANY DAMAGES RELATING TO OUR WEBSITE OR THIS PRIVACY POLICY, TO THE GREATEST EXTENT PERMITTED BY LAW, EVEN IF WE OR THEY HAVE BEEN ADVISED OF THE POSSIBILITY OF DAMAGES.

Copyright Information

Our website and all of its content are copyrighted by Westchester Learning dba Gemm Learning and protected by U.S. and international copyright laws. The compilation of content on our website is the exclusive property of Gemm Learning and may not be used for any purpose other than browsing and using the services and information provided for your own private use. You are only permitted to use our website as expressly authorized by us. Nothing in this Privacy Policy transfers any express or implied right, title, or interest in our web site to you.

Additional Points about the Terms and Conditions of this Privacy Policy

The terms and conditions of this Privacy Policy and the agreement it creates, shall be governed by and interpreted according to the laws of the State of New York (without applying the State’s conflict-of-law principles). We reserve the right to bring any civil action in New York, arising from your violation of the terms and conditions of this Privacy Policy.

If any provision of this Privacy Policy is unlawful, void, or unenforceable, it will not affect the validity and enforceability of any remaining provisions. This is the entire Privacy Policy regarding all the matters that have been discussed in the preceding paragraphs.