Privacy Policy

1. Introduction

CLAROEdu, Inc. ("CLARO," "we," "us," or "our") is committed to protecting the privacy of students, teachers, and school administrators who use our platform. This Privacy Policy describes how we collect, use, disclose, and protect information in connection with our cognitive learning assessment service.

CLARO is designed for use in PPK–12 educational settings. We take our obligations under the Family Educational Rights and Privacy Act (FERPA), the Children's Online Privacy Protection Act (COPPA), and the Student Online Personal Information Protection Act (SOPIPA) seriously.

2. Information We Collect

From Teachers and Administrators

• Name, email address, and school or district affiliation
• Class rosters and student enrollment data provided by the teacher
• Usage data including session creation, text assignments, and dashboard interactions

From Students

• First name and last initial (or a teacher-assigned display name)
• Dialogue responses during Chispa sessions (text input only)
• Cognitive state progression data generated by the CLARO system
• Language detection metadata (English, Spanish, or mixed)

We do not collect student email addresses, home addresses, phone numbers, photographs, biometric data, or any government-issued identification numbers.

3. How We Use Information

We use the information we collect solely to:

• Provide and improve the CLARO platform and its features
• Generate DialogIQ™ assessments and cognitive state reports for teachers
• Support teachers in understanding student thinking patterns
• Maintain platform security and prevent unauthorized access
• Communicate with teachers and administrators about their accounts

We do not use student data for advertising, marketing, or to build profiles for purposes unrelated to education. We do not sell student data to third parties.

4. FERPA Compliance

CLARO operates as a "school official" under FERPA when providing services to schools and districts. We access and process student education records only as directed by the educational institution and only for legitimate educational purposes. Schools and districts retain ownership and control of all student education records.

5. COPPA Compliance

CLARO does not knowingly collect personal information directly from children under 13 without verifiable parental consent. Student accounts are created and managed by teachers and school administrators, who are responsible for obtaining any required parental consent under applicable law. If you believe we have inadvertently collected personal information from a child under 13 without proper authorization, please contact us immediately at [email protected].

6. Data Security

We implement industry-standard security measures to protect the information we collect, including encrypted data transmission (TLS), access controls, and regular security reviews. All dialogue data is stored in encrypted databases hosted in the United States.

In the event of a data breach that affects student personal information, we will notify affected schools and districts in accordance with applicable law.

7. Data Retention and Deletion

We retain student dialogue data for the duration of the school's active subscription plus 90 days. Schools and districts may request deletion of student data at any time by contacting us at [email protected]. We will process deletion requests within 30 days.

8. Third-Party Services

CLARO uses a limited number of third-party services to operate the platform, including cloud hosting and inference providers. All third-party providers are contractually bound to process data only as directed by CLARO and in accordance with applicable privacy laws. We do not share student data with third parties for their own use.

9. Your Rights

Teachers, parents, and eligible students have the right to review, correct, and request deletion of personal information held by CLARO. Requests should be submitted to your school or district administrator, who may then contact us on your behalf. Direct requests can also be submitted to [email protected].

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify schools and districts of material changes via email and by posting the updated policy on our website. Continued use of CLARO after the effective date of any changes constitutes acceptance of the updated policy.

11. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact us: