Terms of Service – Young Learner Amendment

Last updated: July 28, 2023

This Amendment applies if you are a secondary school, college or university offering access to CITI Program to your students between the ages of 13 and 18.

This Amendment amends CITI Program’s general Terms of Service located at  https://staging-citiprogram.kinsta.cloud/terms-of-service/ (the “TOS”) as it pertains to your students’ use of the Services. Capitalized terms that are not expressly defined in this Amendment have the meanings given to them in the TOS.

As required by applicable law, Subscribing Organization shall obtain parental consent for its students to access CITI Program.

Upon Subscribing Organization’s written request, CITI Program will identify all of Subscribing Organization’s student accounts to ensure that no CITI Program marketing materials are directed to the Subscribing Organization’s students. Such a request may be done by opening a support ticket through the CITI Program help desk at the time of initial set-up.

CITI Program does not control third-party marketing operations (e.g., Google, Facebook). Subscribing Organization’s students must block the use of third-party cookies on their own devices to prevent such solicitations. This is addressed in CITI Program’s TOS.

CITI Program’s core functionality is hosted in the United States.  Student data will remain in data centers located in the United States.

CITI Program will use good faith efforts to notify Subscribing Organization of a data breach within thirty (30) days of learning of such breach.

CITI Program does not have access to grade level, age, date of birth, or graduation information of Subscribing Organization’s students and so cannot determine when data retention is no longer necessary.

Upon request from Subscribing Organization, CITI Program will anonymize Subscribing Organization’s student data using Global Data Protection Regulation (“GDPR”) scripts. Certain data needs to be retained in CITI Program’s Learning Management System to ensure accurate counts of learners, completions, and usage for audit purposes. Hence, CITI Program will anonymize learner records specified in written requests from Subscribing Organizations but will not delete records.


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