Privacy Policy

1. Who we are and what this policy covers

Agenteach ("we," "us") provides an AI-assisted teacher workspace that helps educators organize student evidence, track follow-ups, and draft family communications. Our service is offered to schools and districts ("LEAs") and their authorized staff. This policy covers the Agenteach application (portal.agentea.ch), our API (api.agentea.ch), our marketing site (agentea.ch), and the district-system integrations we operate through our integration partner Ednition (§7).

Agenteach is used by teachers and school staff only. Students do not have accounts, do not log in, and never interact with Agenteach directly.

2. Our role and student data ownership

When an LEA uses Agenteach, we act as a school official with a legitimate educational interest under FERPA (34 CFR § 99.31(a)(1)), operating under the LEA's direct control with respect to education records, typically through a signed Data Privacy Agreement (such as the SDPC National Data Privacy Agreement).

All student data belongs to the LEA. We claim no ownership or license beyond what is needed to provide the service. We use student data only for the educational purposes the LEA authorizes — never for advertising, never for profiling, never for sale, and never to train AI models.

3. Data we collect

3.1 Student data (from Google Classroom, the district's SIS/LMS via Ednition, teacher entry, or teacher uploads)

3.2 Teacher and staff data

Account identity (name, school email, photo), role and school/district affiliation, timezone and working-hours preferences, and Google/Microsoft OAuth tokens used to connect authorized integrations (stored encrypted — see §8). Where a district connects its SIS or single sign-on through Ednition, staff directory data (name, school email, role, school) may also arrive from that district-approved source..

3.3 Data we do NOT collect

No student browsing history, no location data, no biometric data, no social media data, no student-facing accounts or chat, no advertising identifiers, and no third-party analytics or tracking cookies anywhere in the application.

4. How we use data

Solely to provide the service the LEA authorizes: syncing rosters and coursework, surfacing follow-ups and alerts for teachers, organizing evidence and observations, and helping teachers draft family communications that they review and send. Aggregated, de-identified data may be used to maintain and improve service reliability; de-identification follows NIST-aligned standards and we commit not to attempt re-identification.

5. AI features

• AI (Google Vertex AI / Gemini, under Google Cloud's enterprise terms) helps draft and extract — e.g., drafting a parent email or extracting facts from a teacher's note. Teachers review every AI draft before anything is sent or saved as a record.
• AI does not make decisions about students (no grading, discipline, eligibility, or diagnostic determinations), and AI output is never auto-sent.
• Student data is never used to train AI models — ours or Google's. Vertex AI is used under terms that exclude training on customer data.
• Where feasible we minimize what AI sees (e.g., email drafting sends first names only). Some features (observation cleanup, communication extraction) process the full text the teacher provides.
• Each AI call is recorded in our audit log (provider, model, purpose — never raw content).

6. Third parties and subprocessors

We share data only with subprocessors necessary to run the service, bound by data protection agreements with confidentiality, security, deletion, and breach-notification obligations. Current subprocessors (see the Subprocessor List for the maintained version):

We provide advance notice of subprocessor changes to LEAs under agreement, and any new subprocessor is bound to equivalent terms. We never sell data, never share it for advertising, and never disclose it except as this policy and our LEA agreements describe or as law requires.

7. Our integration partner: Ednition

Districts run many different student information systems (SIS), learning platforms, and sign-on providers. Rather than ask each district to build and maintain a custom connection to Agenteach, we partner with Ednition, Inc. (a Delaware corporation headquartered in Kaysville, Utah) and its RosterStream platform — rostering and data-interoperability infrastructure built specifically for K-12 vendors. Ednition is an infrastructure subprocessor working under our direction. It does not own, license, or independently use any district data, and Agenteach remains the single party accountable to the LEA for everything in this policy.

7.1 What Ednition does for Agenteach

• Roster and enrollment sync from the source the district approves: PowerSchool, Infinite Campus, Skyward and other OneRoster-compliant SIS platforms, Clever, ClassLink, or an Ed-Fi data exchange. Students, staff, schools, courses, and section enrollments arrive already normalized to the 1EdTech OneRoster standard.
• Single sign-on through the district's existing identity provider (Google, Microsoft, Clever, ClassLink, SAML, or OpenID Connect), so teachers keep using their district login and the district's MFA policy continues to apply. Agenteach never holds teacher passwords.
• Optional LMS connections (Canvas, Schoology, or Google Classroom via LTI 1.3) only where a district chooses to enable them.
• District control at the source. Every connection is created, scoped, and approved by the district's technology team, and the district can revoke it at the source at any time. Districts see Agenteach throughout the connection process; Ednition operates behind the scenes as our infrastructure.

Teachers whose district uses Google Classroom only, without an SIS connection, continue to authorize that integration directly (§3); Ednition is not involved in the Google Classroom OAuth path or in sending teacher-approved emails.

7.2 What Ednition processes — and what it never sees

Ednition's own privacy statement describes the student data it handles as student names and class schedules, times, and locations — roster data — and commits Ednition to process it only as instructed by its customer and only to provide the service. Under our agreement, that customer is Agenteach, and our instructions are limited to the purposes in §4.

7.3 Ednition's security and privacy posture

Ednition publishes its controls and independent assurance reports through a real-time Trust Center at trust.ednition.com. As published there and on Ednition's site, Ednition brings the following to our partnership:

• SOC 2 Type 2 attestation across the Trust Services Criteria (Security, Availability, Processing Integrity, Confidentiality, and Privacy), held continuously since RosterStream launched, with the report available to districts on request.
• ISO/IEC 27001:2022 certification, audited annually by an accredited certification body and covering the platform, its student-data handling, and its information security management system.
• Annual third-party penetration testing, with results available through the Trust Center, plus continuous automated control monitoring published in real time.
• Encryption: TLS 1.2 or higher for all data in transit, and AES-256 encryption at rest for roster, identity, and extended data.
• Least-access data principles: role-based access controls designed for FERPA, so a vendor receives only the data elements it is authorized to use.
• Hosting on Amazon Web Services as an AWS Partner Network member. RosterStream supports region-pinned hosting; Agenteach's tenancy is pinned to United States regions (§9).
• Open standards and edtech privacy commitments: 1EdTech member, 1EdTech OneRoster 1.1 and 1.2 certified, built on the Ed-Fi Unifying Data Model, and a signatory of the 1EdTech TrustEd Apps Pledge.
• Written no-training and purpose-limitation commitments: Ednition's terms contractually bind its own contractors and service providers never to use customer or student data to train any large language model or other AI model, and prohibit disclosure or use of student data for any purpose other than providing the service. Ednition does not sell student data, use it for advertising, or build profiles.
• Bounded retention: Ednition's terms cap retention of customer data at 60 days after termination, inside our own 60-day deletion commitment (§10).
• Cyber-insurance documentation and security questionnaires are available through the Trust Center for district vendor-risk reviews.

7.4 How Ednition is bound to this policy

• Contract terms today; DPA in procurement. Ednition operates as a sub-processor under its standard Terms of Service and Privacy Statement, which already bind it to process student data only as instructed by Agenteach, to use it for no purpose other than providing the service, to prohibit AI training on it, to keep it confidential, and to delete it within 60 days of termination. We are currently procuring Ednition's Data Processing Addendum and Security Addendum, which will formalize the full flow-down of the obligations in this policy and in our LEA agreements: purpose limitation, confidentiality, no sale, no advertising, no profiling, no AI training, security controls, deletion, and cooperation with LEA requests. We will update this section and the change log when they are executed.
• Incident notification. Ednition's terms require it to promptly notify Agenteach in writing of any breach or potential breach affecting district data, so that we can meet the LEA notification timelines in §13. Agenteach, not Ednition, notifies the LEA.
• Deletion on request or exit. When a district disconnects an integration or its agreement ends, we direct Ednition to delete that district's roster data; Ednition's contractual maximum is 60 days, and we confirm destruction in writing as part of our own exit process. Student-level erasure requests (§10) are propagated to Ednition where the record originated from a district SIS connection.
• Subprocessor transparency. Ednition is listed on our public Subprocessor List, and LEAs under agreement receive advance notice of any change to that list, per §6.
• Assurance for your review team. On request, and under Ednition's standard confidentiality terms, we provide Ednition's SOC 2 Type 2 report, ISO/IEC 27001 certificate, and penetration-test summary as part of our district procurement pack, or your team can request them directly from trust.ednition.com.

7.5 How the partnership maps to the frameworks districts review against

Ednition's certifications and attestations are Ednition's, verified by its independent auditors and published on its Trust Center; they do not transfer to Agenteach, and our own third-party certifications remain roadmap items as described on our Security & Privacy Architecture page.

8. Security

• TLS 1.2+ encryption in transit everywhere; HSTS on all production hosts.
• Encryption at rest for databases, file storage, and backups; OAuth tokens are additionally application-layer encrypted (Fernet with key rotation).
• Role- and relationship-based access control: every request is checked server-side by district, school, role, and teacher-student relationship.
• Append-only audit logging of sensitive reads, writes, exports, erasures, and AI calls, enforced at the database level.
• Rate limiting, single sign-on via the district's Google or Microsoft identity (or the district's Clever, ClassLink, SAML, or OpenID Connect provider through Ednition SSO Connect), and least-privilege OAuth scopes (read-only Classroom access).
• Teacher sign-in uses single sign-on through the district's Google or Microsoft identity provider and therefore inherits the district's multi-factor authentication policy. Agenteach does not maintain separate passwords for teachers.

9. Data residency

All student data is stored and processed exclusively in United States regions. Application hosting and databases run in Microsoft Azure US regions (Central US), and AI processing runs in Google Cloud Vertex AI's us-central1 (Iowa) region. Roster data synced through our integration partner Ednition (§7) is held in Ednition's Amazon Web Services environment in United States regions; although RosterStream offers multi-region hosting, Agenteach's tenancy is pinned to the US. No student data is stored or processed outside the United States, and our infrastructure configuration pins these regions explicitly rather than relying on provider defaults.

10. Retention and deletion

• We keep student data only while the LEA authorizes the service, plus the retention windows in our published Data Retention & Deletion Schedule (e.g., unsent draft emails ≤ 365 days, resolved alerts ≤ 180 days). Windows are LEA-configurable, and automated purging enforces them.
• On LEA request or contract termination, student data is exported (if requested) and deleted within 60 days, consistent with NDPA § 4.6 and Texas Education Code § 32.156. Legal holds and correction-record obligations can defer specific records, and deletion propagates to backups on the backup rotation cycle — we never promise instantaneous eradication from every backup medium, and we say so honestly.
• Deletion extends to our subprocessors. Roster data held by Ednition for a district is deleted when the district disconnects or the agreement ends (contractual maximum 60 days), and student-level erasures are propagated where the record came from a district SIS connection (§7.4).
• Parents and eligible students exercise access/correction/deletion rights through their LEA; we support LEA requests within 30 days.

11. Cookies

Agenteach uses only strictly necessary cookies:

No advertising, analytics, or tracking cookies. The app (portal.agentea.ch) and API (api.agentea.ch) are subdomains of the same site; these cookies are scoped to agentea.ch, marked Secure, sent only over HTTPS, and never shared with any third party.

12. Children's privacy (COPPA)

Agenteach is teacher-facing; children under 13 never use it directly. Where student records include data about children under 13, we process it solely for the school's educational purposes under the school-consent framework, with the protections in this policy (no ads, no profiling, no sale, no AI training, published retention limits, written security program). If we add any student-facing features, we will implement full COPPA notice and consent controls first.

13. Breach notification

We maintain a written incident response plan. If a breach affects student data, we notify affected LEAs without unreasonable delay and within the timelines our agreements and applicable law require (72 hours under NDPA v2.2, and Texas Business & Commerce Code § 521.053 timelines for Texas individuals/AG where applicable), including the nature of the breach, data involved, steps taken, and contact information. Our subprocessors, including Ednition, are contractually required to notify us of incidents affecting district data so that these windows are met regardless of where an incident originates.

14. Changes to this policy

We post changes here with an updated effective date and a changelog, and we notify LEA contacts and account holders (email or in-app) in advance of material changes.

15. Contact

Agenteach LLC, a Delaware limited liability company
privacy@agentea.ch