Privacy Policy

Last updated: September 30, 2026

1. Who we are and what this policy covers

Student EI provides technology that helps school districts make their Portrait of a Graduate visible, measurable, and credentialed. Student EI was founded in 2021 by Tyler Gough.

This policy explains how we handle information in the Student EI platform, which we provide to school districts and other educational agencies under contract, and on our website, www.studentei.com. Our practices are designed to comply with the Family Educational Rights and Privacy Act (FERPA), New York Education Law §2-d, and Part 121 of the Regulations of the New York State Commissioner of Education.

2. Districts own their data

Each district owns and controls its data. That includes the information the district rosters into Student EI and everything our technology creates or populates about its students, such as assessment results, evidence of demonstrated skills, reflections, and credential progress.

Student EI processes this data only on the district's behalf and under its direction. Under FERPA, we act as a school official with a legitimate educational interest and under the direct control of the district for the use and maintenance of education records. Under Education Law §2-d, we are a third-party contractor. We do not claim ownership of student data.

3. Information we receive

Data rostered by the district

We receive the data and information a district chooses to roster from its Student Information System (SIS) or Student Management System. This typically includes:

• First and last name
• School email address
• Graduation year
• Mobile number (optional, only if provided)
• Other fields the district elects to roster

We receive only what the district shares with us, and we use it only to provide Student EI to that district.

Data created in Student EI

As students and educators use Student EI, the platform generates records such as assessment responses and results, evidence, reflections, and skill and credential progress. These records belong to the district and are treated with the same protections as rostered data.

4. How we use student data

We use student and educator personally identifiable information only to provide the services described in our contract with the district, including supporting and securing the platform. We will not:

• Sell personally identifiable information
• Use or disclose it for any marketing, advertising, or commercial purpose
• Build profiles of students for any purpose other than the educational purposes authorized by the district
• Use it for any purpose not explicitly authorized in our contract with the district

5. How we protect data

As required by Education Law §2-d and Part 121, Student EI:

• Adopts technologies, safeguards, and practices that align with the NIST Cybersecurity Framework
• Uses encryption to protect personally identifiable information while in motion and at rest
• Limits internal access to employees and subcontractors who need it to provide the services
• Trains employees with access on the federal and state laws that govern the confidentiality of this information
• Maintains reasonable administrative, technical, and physical safeguards
• Complies with each district's data security and privacy policy

6. When we share data

We do not disclose student or educator personally identifiable information to anyone other than the district that provided it, except:

• To subcontractors who help us provide the services, who are bound by written agreements to the same data protection obligations we are
• With the prior written consent of a parent or eligible student
• When required by law or court order, in which case we will notify the district beforehand unless the law prohibits it

If Student EI is involved in a merger, acquisition, or sale of assets, any successor must honor this policy and our existing agreements with districts.

7. Retention and deletion

We keep student data only as long as needed to provide services under the district's contract. When the contract ends, or when the district directs us, we return or securely delete the district's data as the contract specifies. When a district deletes an individual's account during an active contract, that person's personal data is deleted or de-identified within 28 days.

8. Rights of parents, eligible students, and educators

Under FERPA, parents and eligible students have the right to inspect and review education records and to request corrections to records they believe are inaccurate. Because the district controls its data, these requests should go to the student's school or district. We will support the district in responding.

New York districts publish a Parents' Bill of Rights for Data Privacy and Security, and our contracts with New York educational agencies include the supplemental information that Education Law §2-d requires. Complaints about possible breaches or unauthorized release of student data may be submitted to the district, or to the New York State Education Department's Chief Privacy Officer at privacy@nysed.gov.

9. Breach notification

If we discover a breach or unauthorized release of personally identifiable information, we will notify each affected district in the most expedient way possible and without unreasonable delay, and no more than seven calendar days after discovery. We will cooperate with the district and law enforcement to protect the integrity of investigations.

10. Our website

Visiting www.studentei.com does not require you to share personal information. If you request a demo, we receive the details you enter in the form (such as your name, email, school or district, position, and message) and use them only to respond to you. We use HubSpot to manage business contacts. Our website host, Netlify, and Google Fonts process standard technical information such as IP addresses to deliver the site. Our website does not use advertising or analytics cookies. Website contact information is deleted after one year without contact, or within 28 days of a request to delete it.

This section covers website visitors only. It does not apply to student data, which is never used for marketing.

11. Changes to this policy

We may update this policy to reflect changes in law or in our services. We will post the updated policy here with a new date, and we will notify districts of material changes that affect how we handle their data.

12. Contact us

Questions about this policy or our data practices can be sent to info@studentei.com.