FERPA Privacy Policy

1 Introduction

Grade Lens ("we," "us," or "our") provides software that helps teachers convert paper grading sheets and student worksheets into organized digital grading data. Because our users are educators who process information about students, we are committed to protecting student privacy in accordance with the Family Educational Rights and Privacy Act ("FERPA"), 20 U.S.C. § 1232g, and its implementing regulations at 34 CFR Part 99.

This FERPA Privacy Policy explains how Grade Lens collects, uses, stores, shares, and protects student education records, and describes the rights of parents, eligible students, schools, and districts with respect to those records.

This policy is specific to FERPA-covered data. It supplements, and in the event of conflict controls over, our General Privacy Policy with respect to information that constitutes an "education record" under FERPA.

2 Our Role Under FERPA

Grade Lens does not have a direct relationship with students or parents. Schools and districts are the entities directly subject to FERPA, and individual teachers handle student information on their institution's behalf as part of their regular classroom duties.

Today, Grade Lens is used primarily by individual teachers who sign up on their own to streamline the grading work they already do by hand — photographing their own paper grade sheets, extracting scores, and producing digital records for their own gradebooks. In this common case, Grade Lens functions as a private productivity tool for the teacher, comparable to a spreadsheet application or a scanner app, used in place of manual transcription. The teacher remains responsible for handling student information in accordance with their school's policies and applicable law.

When a school or district formally adopts Grade Lens, we are also prepared to operate as a "school official" with a "legitimate educational interest" under 34 CFR § 99.31(a)(1)(i)(B), meaning we: (1) perform an institutional service or function for which the school would otherwise use its own employees; (2) act under the direct control of the school with respect to the use and maintenance of education records; and (3) are subject to the requirements of 34 CFR § 99.33(a) governing the use and re-disclosure of personally identifiable information from education records.

In either case — individual teacher use or institutional adoption — Grade Lens uses student information only to provide the requested service to the teacher, and does not re-disclose that information except as described in Section 6.

3 Information We Process

3.1 Student Information ("Education Records")

When teachers use Grade Lens, the following categories of student information may be uploaded, extracted, or stored on our systems:

• Student names as they appear on paper grading sheets, rosters, or worksheets.
• Scores, grades, and marks for quizzes, tests, homework, rubrics, and other assessments.
• Assignment and course identifiers such as class name, subject, period, or assignment title.
• Photographic images of grading sheets and student worksheets uploaded by teachers.
• Extracted text and score data generated from those images.
• Teacher-entered notes associated with a student's scores.

We do not intentionally collect: Social Security numbers, dates of birth, home addresses, parent contact information, disciplinary records, health records, biometric identifiers, or any other category of personally identifiable information beyond what is necessary to associate a score with a student in a teacher's gradebook workflow.

3.2 Teacher Account Information

Grade Lens also collects information about the teacher or administrator user of the service (name, email, school affiliation, subscription status, usage data). This information is governed by our General Privacy Policy and is not an "education record" under FERPA.

4 How We Use Student Information

Grade Lens uses student information solely to provide the service requested by the teacher or institution, including:

• Extracting scores and student names from photographed grade sheets and worksheets.
• Organizing those scores into editable digital gradebook sheets.
• Calculating averages, course percentages, and applying grading templates and curves.
• Matching extracted worksheet scores to student rows in a teacher's gradebook.
• Exporting finished grade data to CSV, XLSX, or PDF at the teacher's direction.
• Enabling Grade Lens Sync to type scores into the teacher's external gradebook application on their local device.

We do not: sell, rent, or trade student information; use student information for targeted advertising or marketing of any kind; build profiles of students for any purpose other than providing the service; use student information to train machine learning or AI models beyond the narrow, per-user processing necessary to extract scores from that user's own uploads; or disclose student information to third parties except as described in Section 6.

5 Legal Basis and Authorization

Grade Lens processes student information under the authority of the teacher who uploads the data. By uploading student information to Grade Lens, the teacher represents that they are authorized as part of their regular duties to handle the student information they are uploading; that their use of Grade Lens as a productivity tool is consistent with their school or district's policies on classroom technology; and that they will handle the data in the tool in accordance with applicable law, including FERPA.

Schools and districts that wish to formally adopt Grade Lens institution-wide, or that require a written Data Privacy Agreement, Data Sharing Agreement, or FERPA addendum, are welcome to contact us at privacy@gradelens.app. We are happy to work through institutional agreements, but one is not required for individual teachers to use the product.

6 Disclosure of Student Information

Grade Lens does not disclose student information except in the following limited circumstances:

1. To the teacher or institution that provided it.
2. To our subprocessors, who provide infrastructure services (cloud hosting, database storage, payment processing for teacher subscriptions) under contractual obligations that require them to protect the data and use it only to perform services for Grade Lens.
3. As required by law, such as in response to a valid subpoena, court order, or other legal process.
4. To protect the safety of any person, in the event of an articulable and significant threat, as permitted under 34 CFR § 99.36.
5. In connection with a business transfer, such as a merger or acquisition, provided the successor entity agrees in writing to honor the commitments in this policy.

We do not disclose student information to parents or eligible students directly. Requests to inspect, correct, or delete education records must be directed to the school or district that controls the records, in accordance with 34 CFR §§ 99.10–99.22.

7 Rights of Parents and Eligible Students

Under FERPA, parents and eligible students have the right to inspect and review education records, request correction, consent (with certain exceptions) to disclosures, and file a complaint with the U.S. Department of Education if they believe their FERPA rights have been violated.

Because Grade Lens acts as a tool used by individual teachers (and, where applicable, by schools), requests to inspect, correct, or delete a student's education records must be directed to the teacher, school, or district that controls those records. Grade Lens will cooperate promptly with any teacher who needs to access, correct, or delete data stored in their own account, and with any school or district that formally adopts Grade Lens and needs to act on a records request.

8 Data Security

Grade Lens maintains administrative, technical, and physical safeguards designed to protect student information against unauthorized access, disclosure, alteration, or destruction. These include encryption in transit (TLS), encryption at rest for stored grade sheets and extracted data, access controls scoped per account, authentication requirements, subprocessor vetting, logging and monitoring, and least-privilege internal access.

9 Data Retention and Deletion

Grade Lens retains student information only for as long as necessary to provide the service to the teacher, or as required by law. Teachers can delete individual sheets, worksheets, classes, folders, or their entire account from within the application. On account closure, student data is deleted from active production systems within 30 days, and from backups within 90 days thereafter, except as required by law.

10 Directory Information

Grade Lens does not make independent determinations about what constitutes directory information. All student information uploaded to Grade Lens is treated as protected education record data regardless of how the originating school classifies it.

11 Children Under 13 and COPPA

Grade Lens is a teacher-facing tool. Students do not create accounts or interact with the service directly. Teachers using Grade Lens as a productivity tool to process their own classroom grading data are doing so in their capacity as educators, and Grade Lens does not knowingly collect personal information directly from children under 13.

12 State Student Privacy Laws

In addition to FERPA, Grade Lens strives to comply with applicable state student privacy laws, including SOPIPA (California), New York Education Law § 2-d, Illinois SOPPA, and the Colorado Student Data Transparency and Security Act. Schools and districts in states with specific data privacy agreement requirements are encouraged to contact us if they wish to formally adopt Grade Lens institution-wide.

13 Data Breach Notification

In the event of a confirmed unauthorized disclosure or acquisition of student information, Grade Lens will take prompt steps to contain and investigate the incident, notify affected teachers and, where applicable, the school or district point of contact without unreasonable delay, and cooperate with the institution's own breach notification obligations under FERPA and applicable state law.

14 Changes to This Policy

We may update this FERPA Privacy Policy from time to time. Material changes that affect the handling of student information will be communicated to active account holders by email and reflected on our public website (including an updated "Last updated" date on this page) at least 30 days before taking effect. Continued use of Grade Lens after the effective date of a change constitutes acceptance of the updated policy.

15 Contact Us

If you have questions about this policy, are a school or district interested in a Data Privacy Agreement, or wish to make a request regarding education records stored in Grade Lens, you can reach us through our contact form (choose "Privacy concern") or email privacy@gradelens.app with the subject line FERPA Inquiry.

For requests from parents or eligible students: please contact your child's teacher or your school directly. Grade Lens will cooperate with the teacher or institution to fulfill valid requests.