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Jones Software Corp. — Velocity Learning Management Ecosystem Privacy Policy

Jones Software Corp. — Velocity Learning Management Ecosystem Privacy Policy

Version 3.0 | Effective Date: October 31, 2025
Last Reviewed: 11/01/2025

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In short:
The Velocity Learning Management Ecosystem (“VLME”) helps schools and organizations deliver AI-enabled learning securely and responsibly. This Privacy Policy explains what data we collect, how we use it, how we protect it, and the rights you have under applicable privacy laws.

Applies to:
www.j-softech.com, the Velocity Learning Management Ecosystem (VLME), and all connected services, including iLikeMath, Velocity Learning Virtual Classroom, and integrated copilots powered by Microsoft, Intel, and Google APIs.

1. Controller / Contact Information

In short: This section explains who controls your data and how to contact us.

Jones Software Corporation (“JSC,” “we,” “our,” or “us”) is the controller of personal data processed through VLME.

Mailing Address:
Jones Software Corporation
222 W. Merchandise Mart Plaza, Suite 1212
Chicago, IL 60611 USA

Privacy Contact / Data Protection Officer:
📧 privacy@j-softech.com

For EU and UK residents, our designated Data Protection Representative may be contacted via the same address.

2. Data We Collect

In short: We collect only what is necessary to operate, secure, and improve VLME.

We collect the following categories of information:

  • Account Information: Name, email address, organization, role, authentication credentials

  • Telemetry & Usage Data: Device identifiers, browser type, IP address, learning activity, progress metrics

  • Content Data: Course materials, assignments, assessments, chat messages, and Copilot prompts/responses

  • Support Data: Help desk tickets, feedback, and correspondence

  • Payment / Billing Data: Only if subscriptions are purchased; processed exclusively by secure third-party payment providers (e.g., Microsoft Commerce Platform)

JSC does not require biometric or sensitive personal data unless voluntarily included within educational content by authorized users.

3. Purpose & Legal Basis for Processing

In short: We process data to deliver services, meet legal obligations, and responsibly improve learning outcomes.

Purpose Legal Basis
Delivering VLME services Contract performance
Account management and authentication Contract performance / Legitimate interest
Platform analytics and improvement Legitimate interest
AI-assisted learning insights Consent / Legitimate interest
Legal compliance and security Legal obligation
Marketing communications Consent (where required)

4. Use of Third Parties / Subprocessors

In short: We rely on vetted technology partners under strict data-protection agreements.

JSC engages trusted subprocessors solely to support VLME operations under contractual confidentiality and data-protection obligations.

Key subprocessors include:

  • Microsoft Azure (hosting, security, Fabric analytics, Azure OpenAI)

  • Microsoft Copilot / Azure OpenAI Service (AI-driven learning features)

  • Google Cloud / Gemini API (optional integrations)

  • Intel Cloud Services (AI acceleration and analytics)

  • TD SYNNEX Commerce (hardware logistics and resale support)

The current Subprocessor List is maintained at:
🔗 https://www.j-softech.com/subprocessors
and updated upon any material change.

5. Data Sharing & International Transfers

In short: Data is stored and transferred securely using international safeguards.

Personal data may be processed in the United States, the European Union, and other jurisdictions where subprocessors operate.

JSC implements:

  • Standard Contractual Clauses (SCCs) for EU/UK transfers

  • Azure Education data-residency controls where applicable

  • Encryption and access controls aligned with ISO 27001 and ISO 27018

All institutional customers must execute JSC’s Data Processing Addendum (DPA) prior to service activation.
The standard DPA is available at:
🔗 https://www.j-softech.com/legal/dpa

6. Student Data (FERPA & SOPPA Compliance)

In short: Student data is used only under school authorization and never sold or traded.

When VLME is used by educational institutions, JSC acts as a “school official” under FERPA, processing student data solely to provide educational services.

  • Directory Information: Not disclosed without institutional authorization

  • Parental & Student Rights: Controlled by the institution

  • Access Controls: Role-based permissions and audited access logs

JSC complies with:

  • FERPA (34 C.F.R. §99.31(a)(1)(i)(B))

  • Illinois Student Online Personal Protection Act (105 ILCS 85)

Student data is never sold, leased, or used for targeted advertising.

7. Children’s Privacy (COPPA)

In short: Under-13 access requires verified parental or school consent.

VLME is not directed to children under 13 except through school-managed accounts.

Verified parental or institutional consent is required prior to account activation.
Parents or guardians may review or request deletion of a child’s data by contacting privacy@j-softech.com.

8. Retention & Deletion

In short: Data is retained only as long as necessary and securely deleted.

  • Active accounts: Retained while services are active

  • Education tenants: Deleted within 30 days of institutional request

  • Backups: Purged within 90 days

  • Anonymized analytics: Retained for research and service improvement

Anonymization uses industry-standard techniques including k-anonymity and differential privacy.
All deletions are logged and auditable within Azure Education tenants.

9. Security Measures

In short: VLME uses enterprise-grade security aligned with Microsoft Zero Trust.

Security controls include:

  • TLS 1.2+ encryption in transit; AES-256 encryption at rest

  • Azure AD-based RBAC and multi-factor authentication

  • Centralized logging via Microsoft Sentinel

  • Quarterly access reviews and annual penetration testing

  • Incident response with notification within 72 hours

Annual DPIAs and AI threat-model reviews are conducted for new features in alignment with Microsoft Secure-by-Design and Responsible AI standards.

Security inquiries: security@j-softech.com

10. User Rights

In short: You control your data and can exercise your rights at any time.

Depending on jurisdiction, users may:

  • Access, correct, delete, or export personal data

  • Opt out of sale or sharing (CPRA)

  • Object to or restrict processing (GDPR)

Requests may be submitted via:

Requests are acknowledged within 7 days and completed within 30 days (45 days if permitted).
Appeals may be submitted within 15 days.

11. Automated Decision-Making & AI

In short: AI enhances learning — it does not replace human judgment.

VLME uses Azure OpenAI and proprietary models under strict governance:

  • Human-in-the-loop oversight for grading and recommendations

  • No personal data used to train foundation models

  • Prompt and output filtering for safety and fairness

  • Evaluation data retained up to 12 months

No automated decisions produce legal or similarly significant effects.

12. Cookies & Tracking

In short: Cookies help VLME function and improve — you control your choices.

We use:

  • Essential cookies (authentication, security)

  • Analytics cookies (usage metrics)

  • Preference cookies (accessibility and language)

Users may manage preferences via the Cookie Settings panel or the “Do Not Sell or Share My Personal Information”footer link.

13. Changes to This Policy

We may update this Policy to reflect legal or product changes.
Notice will be provided via email or in-app banner.

14. Effective Date & Versioning

  • Version 3.0 — Effective October 31, 2025

  • Supersedes all prior drafts

Archived versions are available in the Policy Archive.

15. Links & Availability

This Policy is publicly available at:
🔗 https://www.j-softech.com/privacy

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