Student data privacy, in plain words.

At a glance

• A class’s owner can add co-teachers, who see the same class and can send reminders, share reports and score free responses. Connecting Google Classroom or an LMS and sending grades to them stay with the owner.
• Every course page works without an account. A class needs a student account only so the student’s work can reach the teacher.
• Classes are for students 13 and older. We ask at the join page and do not store the answer.
• The teacher sees one course’s progress and the name the student typed. Never the student’s email, other courses, notes, study assistant questions, streak or study time.
• No ads, no selling, no profiling. Student data is used only to run the class for the teacher and the student.
• No parent contact details are collected. Families get a printout or an expiring link the teacher or student hands over.
• Deletion on request within 30 days, and students can delete their own account at once.
• We are willing to sign the Student Data Privacy Consortium’s National Data Privacy Agreement (NDPA) or your state’s version. A draft with our exhibits filled in is below.

This page explains the teacher classes for districts. The privacy policy covers the whole site and is the one that governs; this page adds nothing to it and takes nothing away.

What is collected

Outside classes, the site-wide items in the privacy policy apply to every visitor: cookieless analytics (which signed-in students carry as a one-way account tag, and which Do Not Track turns off), anonymous answer totals, error reports and, for a signed-in student, a synced copy of their progress.

FERPA

When a school or district signs a data privacy agreement with us, we act under its direct control as a school official with a legitimate educational interest: we use education records only to provide the classes, do not re-disclose them except to the subprocessors listed below for that purpose, and delete them as the agreement says. Parents and eligible students who want to see or correct a record go through the school, and we help the school answer within the time the agreement sets.

A teacher can also use the free classes without a district agreement. Then it is the teacher’s and school’s decision whether that fits local policy; we handle the data the same way either way.

COPPA and age

LevlPrep is not directed at children under 13, accounts need users to be 13 or older, and classes ask students to confirm it before joining. We do not rely on a school’s consent on behalf of parents under COPPA, because classes are not for children under 13. If we learn an account belongs to a child under 13, we delete it; a parent or school can tell us at [email protected].

Retention and deletion

• A student leaving a class, or a teacher removing them, deletes that membership’s summary, sent answers, scores, report links and Classroom or LMS ids at once.
• Deleting a class deletes its assignments, memberships and everything attached to them. Deleting an account deletes all of these with it, and any Class Premium quote request it sent.
• The reminder log is cleared of anything older than 30 days every hour; expired report links and LMS launch ids go at the same time.
• A school, teacher or parent can email [email protected] to have what we hold for a student’s address deleted; we do it and confirm in writing within 30 days.
• At the end of a district agreement, we delete or hand back the district’s student data as its Directive for disposition (Exhibit D) says.
• Payment records that Polar keeps as the seller, and the one-way hashes the privacy policy lists, are not class data and follow that policy.

Security

• Every database table has row-level security on; the browser reaches class data only through functions that check the signed-in person teaches the class or that the data is their own.
• The keys that can read past those checks stay on our server (a Cloudflare Worker), never in a browser. Google tokens are encrypted before they are stored; report links are stored as one-way hashes.
• All traffic is over HTTPS. We do not hold a security certification such as SOC 2; if your district needs a questionnaire answered, send it.
• If student data is ever exposed, we tell the district in writing, with what happened and what we are doing, within the time the signed agreement sets.

Subprocessors

We tell districts with a signed agreement before adding a subprocessor that handles student data.

Data privacy agreement

This is a draft to fill in, not a signed agreement. It follows the structure of the Student Data Privacy Consortium’s National Data Privacy Agreement (NDPA) and fills in LevlPrep’s exhibits from what the site actually does. The agreement that binds anyone is the SDPC’s official text (or your state’s version) with these exhibits, signed by both sides. LevlPrep’s signature is added by its owner after review; nothing here is signed by LevlPrep. This is not legal advice. The official templates and the registry of signed agreements are at sdpc.a4l.org.

Parties

Local education agency (LEA): district or school name State LEA address LEA designated representative: name and title Their email and phone

Provider: LevlPrep (levlprep.com), operated by Olivier Testa, Minnesota, United States. Designated representative: Olivier Testa, [email protected].

Article I: Purpose and scope

The Provider makes its teacher classes available to the LEA’s teachers and students so teachers can assign work in LevlPrep’s courses (AP® Biology, AP® Chemistry and the others) and see their students’ progress. The Provider uses Student Data only to provide those services, described in Exhibit A, and for no other purpose.

Article II: Data ownership and authorized access

Student Data remains the property and under the control of the LEA. The Provider gives the LEA, on request, the Student Data it holds for a student, and helps the LEA answer a parent’s or eligible student’s request to review or correct it. The Provider does not disclose Student Data to third parties except the subprocessors listed on this page, for the services, under written terms at least as protective.

Article III: Duties of the LEA

The LEA provides Student Data in line with FERPA and its state’s laws, names its designated representative, and reports any unauthorized access it learns of.

Article IV: Duties of the Provider

• Uses Student Data only for the services: no targeted advertising, no selling, no profiles beyond what the services need.
• Keeps employees and subprocessors with access to Student Data bound to confidentiality.
• Uses de-identified data only to improve the services (for example, anonymous totals of which questions are hard) and does not re-identify it.

Article V: Data provisions

Breach notice to the LEA within (as your state requires) Term of this agreement

Security as described under Security on this page. On request, or at the end of the term, the Provider deletes or returns Student Data as Exhibit D says.

Article VI: General offer of privacy terms (optional)

The Provider offers these same terms to any other LEA in the state that signs Exhibit E.

Article VII: Miscellaneous

Precedence, governing law, amendments and notices follow the official NDPA text. Governing law: the LEA’s state.

Exhibit A: Description of services

Free teacher classes for LevlPrep’s courses such as AP® Biology: a teacher makes a class for one course, students 13 and older join with a code, the teacher assigns practice, review, exams and free response and sees each student’s progress in that course. Optional, only when the teacher or school turns them on: reminder emails sent by the teacher, family progress reports, teacher scoring of free responses with comments, Google Classroom (roster, coursework, a join-link announcement, grades), and Canvas or Schoology through LTI 1.3. Class Premium, if bought, unlocks more of the same content.

Exhibit B: Schedule of data

Category	What LevlPrep collects	Used
Application technology metadata	IP address (used for a moment to rate-limit; not stored by us); browser and device type in cookieless analytics	Yes
Application use statistics	Pages viewed and study milestones in cookieless analytics, under a one-way account tag for signed-in students (off with Do Not Track)	Yes
Assessment	Scores on practice, exams and free responses in the class’s course	Yes
Attendance, conduct, discipline, health, special education, schedule, transcript	None	No
Demographics (date of birth, gender, ethnicity, language)	None. Students confirm they are 13 or older; the answer is not stored	No
Enrollment	Membership of a LevlPrep class; the Classroom or LMS user id if the teacher or school links one	Yes
Parent or guardian contact information	None	No
Parent or guardian name	None	No
Student contact information	Account email, used to sign in and for teacher reminders; never shown to the teacher. No email addresses are read from Google Classroom	Yes
Student identifiers	LevlPrep account id; Classroom user id (the student’s Google account id, matched to their Google sign-in) or LMS user id when linked	Yes
Student name	The name the student types when joining a class	Yes
Student in-app performance	Progress summary in the class’s course (see the table above)	Yes
Student work	Free-response answers the student chooses to send to the teacher	Yes
Teacher data	Display name, optional school, classes, assignments, scores and comments given	Yes

Exhibit C: Definitions

As in the official NDPA text.

Exhibit D: Directive for disposition

At the end of the term or on request, the Provider shall:

Delete all Student Data of the LEA’s students Return it to the LEA (as a JSON export), then delete it Delete the categories listed here:

Categories, or a date by which to dispose

Exhibit E: General offer (only if Article VI is ticked)

Another LEA signs here to accept the same terms.

Exhibit F: Data security requirements

The Provider does not hold a named security framework certification. It follows the practices under Security and answers the LEA’s security questionnaire on request.

Exhibit G: State supplement

Terms your state’s NDPA version adds (paste them or name the exhibit)

Signatures

For the LEA

Signature: ______________________

Printed name and titleDate

For LevlPrep

Not signed. Olivier Testa, owner, signs after reviewing the completed agreement. Send it to [email protected].

Signature: ______________________

Date: ______________

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