1. Our Role
When a school, district or educational institution licenses FinSimTrading, the institution controls the student records created on the Platform. We process those records on the institution's behalf and under its direction, consistent with the "school official" exception under FERPA (34 CFR § 99.31(a)(1)) where applicable.
2. What Constitutes Education Records Here
- Roster and enrollment data provided by the school
- Assignment, lesson and course completion data
- Quiz scores, mastery levels and progress reports
- Simulation performance and competition submissions completed for class
- Certificates and badges awarded through the school account
3. Our Commitments to Schools
- Use education records only to provide the contracted services
- Do not sell student data or use it for behavioural advertising
- Do not use student personal information to train general-purpose AI models
- Restrict access to authorised personnel under confidentiality obligations
- Apply encryption in transit and access controls, including row-level security
- Support access, correction, export and deletion requests directed by the school
- Notify the school without undue delay of a confirmed data incident affecting its records
4. School Responsibilities
- Determine that use of the Platform is consistent with its annual FERPA notification and directory-information practices
- Obtain any parental consent required by state or local law
- Manage rosters, teacher permissions and seat assignments
- Direct us regarding retention and deletion at the end of a term or contract
5. Parent and Eligible Student Requests
Parents and eligible students should direct FERPA access or amendment requests to their school. If we receive such a request directly, we refer it to the school. Institutional contact: [PRIVACY EMAIL].
State student-privacy laws (for example SOPIPA-style statutes) may impose additional requirements; contact us to discuss a state-specific data protection addendum.