Privacy Policy

1. Introduction

Scholargleam, Inc. ("the Company," "we," "us," or "our") operates scholargleam.com (the "Service"), an adaptive learning and prerequisite gap detection platform for K-12 classrooms and test-preparation programs. This Privacy Policy explains what information we collect through the Service, how we use it, and the choices available to you. It applies to information collected through scholargleam.com and through direct communications with us.

The Company is based at 500 Boylston Street, Suite 1200, Boston, MA 02116 and can be reached at [email protected].

2. Information We Collect

2.1 Information You Provide

We collect information you submit directly, including:

• Contact details (name, email, phone) when you fill out a form, request early access, or subscribe to updates;
• Professional information (school or program name, role, grade levels served) you choose to share when evaluating the Service;
• Account credentials and classroom configuration (course name, subject, grade level) when teachers or administrators create accounts;
• The content of any messages you send us.

2.2 Information Collected Automatically

When you visit scholargleam.com, we automatically collect limited technical information:

• IP address and approximate location (city/region level);
• Browser type, operating system, device class;
• Pages visited, referring URLs, time on page;
• Cookie and similar identifiers (see Section 5).

2.3 Student Data Processed Under School Direction

The Company's core Service involves processing student diagnostic responses to identify prerequisite knowledge gaps. When a school or educational program contracts with the Company, it may provide student data -- including roster information, student usernames, grade levels, and class assignments -- and student answers to diagnostic exercises. This data is processed solely to deliver the gap detection and reporting features the school has configured, not for the Company's own commercial purposes.

Under the Family Educational Rights and Privacy Act ("FERPA"), student educational records remain under the control of the educational institution. The Company functions as a school official with a legitimate educational interest, subject to the written Data Processing Agreement ("DPA") the school executes before student data is shared. Schools are responsible for obtaining any required parental consent before providing student data to the Service.

The Company does not use student diagnostic data submitted through school accounts to train or improve its machine learning models without the school's explicit written consent, which must be specified in the applicable DPA.

2.4 Children's Data (COPPA)

The marketing website at scholargleam.com is not directed to children under 13 and the Company does not knowingly collect personal information from children through direct signup on this site. Student-facing features of the Service are accessible only through school-managed accounts, where the school acts as the operator under the Children's Online Privacy Protection Act ("COPPA") school exception (16 C.F.R. Part 312.5(b)(1)). If you believe a child has provided personal information directly to us outside of a school account, contact [email protected] and we will delete it promptly.

3. How We Use Information

We use the information we collect to:

• Respond to inquiries and provide requested information about the Service;
• Operate, maintain, and improve the gap detection and adaptive practice features;
• Generate prerequisite gap reports and teacher dashboard views that schools have requested;
• Send service updates and (with your consent where required) communications about the Service;
• Detect, investigate, and prevent fraud or unauthorized access;
• Comply with legal obligations, including responding to lawful requests by courts and government authorities.

Student diagnostic data submitted through school accounts is processed only as directed by the school under the applicable DPA. We do not sell personal information for monetary value. Where applicable state law treats certain advertising arrangements as a "sale" or "share," see your state's section below.

4. Sharing of Information

We share personal information only with:

• Service providers acting on our behalf (for example, cloud hosting, email delivery, and anonymized analytics) under contractual confidentiality terms that prohibit them from using the data for their own purposes;
• The school or educational program that executed the applicable DPA, which may access reports and student diagnostic data for its own enrolled students;
• Authorities, when required by law or to protect rights, safety, or property;
• A successor entity in the event of a merger, acquisition, or asset sale, subject to this Policy and any applicable DPA.

We do not sell personal information to third parties. We do not disclose student data to any third party except as described above or as required by the applicable DPA or law.

5. Cookies and Tracking

We use cookies and similar technologies to operate the site, remember preferences, and measure usage. For details and choices, see our Cookie Policy.

6. Data Retention

We retain personal information only as long as needed for the purposes described, to comply with legal or accounting obligations, and to resolve disputes. Specifically:

• Teacher and administrator account data is retained for the duration of the school's contract plus 12 months, after which it is deleted or anonymized;
• Student diagnostic data processed under a school DPA is retained for the term specified in that agreement; upon contract expiration, the Company deletes or returns student data as the DPA requires;
• Marketing inquiry records for contacts who have not converted to accounts are purged after 24 months;
• Server access logs are retained 90 days, then aggregated.

7. Security

We use administrative, technical, and physical safeguards designed to protect personal information, including TLS encryption in transit, restricted-access databases, and least-privilege access controls. No system is perfectly secure; we cannot guarantee absolute security. If you believe a security incident involving student or user data has occurred, contact [email protected] promptly.

8. Your General Rights

Depending on your jurisdiction, you may have rights including access, correction, deletion, and the ability to limit certain processing. To make a request, email [email protected]. We will respond within the timeframe required by applicable law. Rights requests regarding student educational records are typically directed to the school as the FERPA rights holder; the Company will coordinate with the school as required.

9. Massachusetts Residents

Massachusetts does not currently have a comprehensive consumer privacy statute. As a matter of policy, the Company extends the following baseline rights to all U.S. residents regardless of state of residence.

9.1 Baseline Rights

• Right to Know: request the categories of personal information we have collected about you.
• Right to Delete: request deletion of personal information you have provided.
• Right to Correct: request correction of inaccurate personal information.
• Right to Opt Out of Marketing: unsubscribe from marketing emails or opt out via the link in each marketing message.

9.2 How to Exercise

Email [email protected] with a description of your request and enough detail for us to verify your identity. We respond within 45 days.

9.3 Sector-Specific Rights

If you are protected by federal sector laws (e.g., HIPAA, GLBA, FERPA), those laws may give you additional rights with respect to data covered by them. In particular, FERPA rights in student educational records are held by the school; please contact your school administrator to exercise those rights.

9.4 California Visitors

If you are a California resident, you may also exercise the rights granted under the California Consumer Privacy Act ("CCPA") and California Privacy Rights Act ("CPRA"), including the right to know, the right to delete, the right to correct, and the right to opt out of sale or sharing. The Company does not sell personal information and does not "share" personal information for cross-context behavioral advertising.

To submit a CCPA / CPRA request, email [email protected] with the subject line "California Privacy Request."

10. Changes to This Policy

We may update this Policy from time to time. Material changes will be reflected by a new "Last updated" date and, where appropriate, a notice on the Service.

11. Contact

Questions, requests, or complaints can be sent to:

Scholargleam, Inc.
500 Boylston Street, Suite 1200, Boston, MA 02116
Email: [email protected]
Phone: +1 (617) 338-0176