Privacy Policy

AgenticED, Inc.
Effective Date: October 13, 2026
Supersedes: Privacy Policy dated January 6, 2026

1. Who We Are and What This Covers

AgenticED, Inc. ("AgenticED," "we," "us") builds agent coordination and governance infrastructure for K-12 school districts. Our platform lets a district control which AI agents may reach its data, under what conditions, and with a record of every change.

This Privacy Policy covers our website, our platform, our administrative portals, and our products, including Next Move, JustData, The Ledger, Ground Truth, Board Response, and Workspace. It explains what we collect, why, who else processes it, how long we keep it, and what you can do about it.

One distinction governs the rest of this document. For almost all student and family information, the school district decides what is collected and why. We process it on the district's instruction and under a written agreement with that district. In privacy law this makes the district the controller and AgenticED the processor or service provider. Under FERPA it makes us a school official acting under the district's direct control. FERPA Compliance explains what that means in practice.

Where we act on our own behalf (our website, our marketing, our own employees, and our direct relationships with vendors) we are the controller, and we say so in the sections below.

2. What We Collect

2.1 Information About Students

Student information reaches us in three ways: a district sends it through a system integration, a parent or guardian provides it, or a student provides it directly. In every case the district's agreement with us defines what we may hold.

The platform stores the following when a district's configuration calls for it:

We do not collect a Social Security number. No field for one exists anywhere in the platform.

We do not store health records. The platform has no health table and no health field. A student's health information may reach us only when it is part of an education record, such as a special education or Section 504 plan, or when a parent writes it in a message. We handle both as education records. See Section 9.

2.2 Information About Parents, Guardians, and Households

For families using our benefits and opportunity products, we hold contact details, mailing address, language preference, and notification preferences. We hold the relationship of each adult to each student, including access level, custody share, and schedule. Where a district or court has established one, we hold the existence and reference details of a court order or contact restriction affecting a family member.

For benefits eligibility we hold household information in ranges instead of exact amounts: an income bracket, income stability, and a housing cost bracket, together with household size, the number of adults, the presence of children in age ranges or adults over sixty, single-parent status, housing type and stability, whether a household member has a disability, verified meal-program eligibility and tier, foster care status, housing instability, migrant status, and military-connected status.

We do not store an exact income figure, salary, or adjusted gross income. No such field exists. Eligibility is determined from ranges.

2.3 Documents

Families and districts upload documents to a secure vault: tax returns, W-2s, benefit award letters, identity and residency documents, and education plan documents. For each document we store the file, its type and size, a checksum, a record of the encryption applied, a verification status, and the data extracted from it. We record each access to a stored document and the access count.

Uploaded tax documents are read by a third-party AI model. This is the most sensitive outbound flow in our platform, and Section 4.3 describes it.

2.4 Conversations

Our agents are conversational, so we store conversation content: messages exchanged with our agents, agent session context, and questions asked of our knowledge base. Where a district enables email intake, we store inbound parent email (sender, recipient, subject, body, and headers) and the drafted replies.

Where a family uses co-browsing to get help completing an outside agency's application, we capture the page address and a snapshot of the form, including form field contents, in order to assist. The snapshot is sanitized before storage.

We do not record or store voice. Our products can read text aloud. Nothing is captured from a microphone, and no audio file or voice transcript is stored anywhere in the platform. Section 4.2 explains the text-to-speech flow, which sends text to a third party.

2.5 Information About District and School Staff

For district employees we hold name, an external employee identifier, employment status, start and end dates, separation reason, duties, assignments, caseloads, and certifications.

We hold no employee compensation data. No salary, wage, or pay field exists in the platform.

Where a district enables our workforce products, we hold signals about an employee's working conditions (a summary, a direction of travel, and a severity) organized by domain, together with that employee's own consent grants, which the employee can revoke for each domain. Three protections are enforced in the database, so our own application code cannot bypass them:

• An administrator, superintendent, or HR administrator sees aggregates only, never an individual. The individual view is reserved to the employee.
• An aggregate is suppressed entirely unless the group meets a minimum size: seven for general signals, fifteen for sensitive signals, and ten for grievance-related signals. A district cannot set a floor below those numbers.
• A request made for the purpose of employee evaluation, or by an evaluator, is refused with an error.

We administer no employee survey. We do not collect engagement or burnout survey responses, and no survey response table exists.

2.6 Information We Collect Automatically

When you use our platform we collect device and browser information, pages and features used, IP address, and approximate location derived from the IP address. We use strictly necessary cookies for sign-in and session management.

Our public website uses no analytics, advertising, or tracking cookies. Our website loads its typefaces from Google Fonts, so Google receives your IP address and browser information when your browser requests them.

2.7 Billing Information

For districts and vendors we hold a billing contact name and email and a payment processor customer reference. We do not store card numbers. Our payment processor holds payment credentials, and we retain only a reference token.

3. Why We Use It

We use student and family information only for the purposes the district's agreement specifies. In practice that means operating the agent services the district has authorized; estimating eligibility for benefits and opportunities and helping families apply; showing academic signals to the educators entitled to see them; coordinating appointments and communication; keeping the audit and consent records the district relies on for compliance; and providing support.

For our own relationships with website visitors, vendors, and employees, we use information to provide and secure the service, to bill, to communicate, to meet legal obligations, and to improve the product.

What we do not do, under any circumstance:

• We do not sell personal information. We have never sold it, and the platform has no mechanism to do so.
• We do not use student information for advertising, for targeted advertising, or to build an advertising or marketing profile.
• We do not use student or family information to train or fine-tune an AI model, ours or anyone else's. See Section 4.3 and the Data Use Policy.
• We do not disclose student information to anyone except as the district directs, as this policy describes, or as law requires.

4. Who Else Processes It

We use the service providers below. Each receives only what it needs, each is bound by contract or service terms to use it only to provide its service to us, and each is listed because it processes data. We do not list vendors we merely have accounts with.

We will give districts at least thirty days' notice before adding a service provider that will process student data, consistent with the subprocessor provisions of the National Data Privacy Agreement.

4.1 Infrastructure

4.2 AI Processing

4.3 How We Work With AI Providers

We are an AI company, and you are entitled to know exactly where the AI sits.

Our language-model providers do not train on your data. We use Anthropic and OpenAI under their commercial API terms, which do not permit them to use the content we send, or the results they return, to train their models. Those terms allow each provider to keep content for a limited period to detect and prevent abuse.

Uploaded tax documents are read by a vision model. When a family uploads a tax return or W-2 to support a FAFSA application, the document image is sent to our model provider to extract the figures the application needs. We offer this because typing tax figures by hand is a leading reason families abandon the FAFSA. Every extracted value is shown to the family as a proposed value to confirm or correct before it is used. A family may skip the upload and enter the figures by hand instead.

Nothing learned from one district reaches another. What the platform learns is held as a trait of the district it was learned from. The Data Use Policy explains this.

4.4 Communications

A district may elect to send platform email through its own sending identity, so that messages to its families come from the district. See the Data Use Policy.

We no longer use SendGrid. A prior version of this policy named SendGrid as our email processor. It processes nothing for us.

4.5 Identity, Calendar, and Billing

4.6 Operations

4.7 Services Inside Our Own Network

Benefits eligibility is calculated inside our own infrastructure. We run the PolicyEngine rules engine as our own service inside our private network. Household composition and income ranges are evaluated there. We do not send household information to PolicyEngine's public service. If our own instance is unavailable, the platform declines to calculate instead of sending household data outside our network.

4.8 Services That Send Us Data

A district's own systems (its student information system, its Ed-Fi instance, Clever, ClassLink, Infinite Campus, or a OneRoster feed) send data to us under the district's control and its own agreements. They are the district's systems of record, and they are not our service providers.

We also load public reference data: federal school directories and school codes from the National Center for Education Statistics, academic standards structure from the Learning Commons knowledge graph, and authenticator information from the FIDO Alliance. None of these sources receives any student, family, or staff information. A request to the Learning Commons knowledge graph contains only a public standard code.

4.9 Other Disclosure

We disclose information when the district directs us to; when a law, subpoena, or court order requires it, in which case we will notify the district unless the law prohibits it; and to protect a person from imminent harm.

If AgenticED is merged or acquired, student and family information may transfer to the successor only if the successor is bound by the same commitments in this policy and in each district's agreement. We will notify affected districts before the transfer.

5. How Long We Keep It

The amended COPPA Rule requires a written retention policy that states why we collect information, why we keep it, and when we delete it, and it prohibits keeping a child's information indefinitely. This section is that policy. These are the longest periods we will keep each kind of record.

When a district's agreement ends, we return or delete that district's data as the district directs, within sixty days of the district's direction, or sooner if the district's agreement sets a shorter period.

A district may request erasure of a family's records at any time, and a parent may ask the district or us to start that request. Erasure is a true deletion. The records are removed from more than sixty tables in a single operation that either completes entirely or changes nothing. We then issue a receipt listing what was deleted, the record counts, and each kind of record we deliberately kept, with the reason for each. The records we keep are audit and consent evidence. We keep them because deleting the proof that a disclosure was authorized would take away the family's ability to establish who saw their information.

6. How We Protect It

The Security Overview describes our controls. In summary: data is encrypted in transit over the internet and encrypted at rest; access to student records is restricted by policies enforced in the database itself, in addition to our application; every change is written to a tamper-evident audit log; credentials are held in a managed secrets service and never in code; and the database is not reachable from the internet.

No system is perfectly secure. If we confirm a breach affecting district data, we will notify the district within seventy-two hours of confirming it, and we will support the district in notifying affected families and authorities as law requires.

7. Children's Privacy

Our platform is built for use in schools, including by students under thirteen.

We rely on school authorization. Under COPPA, a school may consent on behalf of parents where a service is used for a school-authorized educational purpose and the data is used only for that purpose. We operate under that authorization, and it carries a condition we take seriously: it does not cover any commercial use of the data. We do not use student information for advertising of any kind, to build a profile, or for any purpose beyond the educational service the district authorized. If we ever did, the school's authorization would not cover it, and we would need verifiable parental consent instead.

Parents keep their rights. A parent may review the information we hold about their child, ask that it be deleted, and refuse further collection, without their child losing access to any activity that does not require that information. Requests reach us fastest through the child's school, which holds the record. A parent may also write to privacy@agenticed.com and we will work with the district. See Student Data Privacy.

We publish a retention schedule and we do not keep information indefinitely. Section 5 is that schedule.

Third parties are disclosed. Section 4 names every service provider. We do not disclose a child's information beyond what is necessary to operate the service the district authorized, and we do not share it with any third party for that party's own purposes.

8. State Student Privacy Laws

Many states impose requirements beyond FERPA, and several give parents rights directly against a vendor. We comply with the student privacy law of each state where we provide services. Where a district's state has a Student Data Privacy Consortium State Alliance, we sign that alliance's state exhibit as part of our Data Processing Agreement, which is how state-specific obligations attach.

New York. For New York educational agencies, we sign each agency's Parents' Bill of Rights for Data Privacy and Security, supply the supplemental information Education Law Section 2-d requires for our contract, and meet the data security and privacy plan requirements of 8 NYCRR Part 121.

Commitments we make in every state, which meet the common requirements of these laws: we do not sell student information; we do not use it for targeted advertising; we do not build advertising profiles of students; we do not use it for any commercial purpose; we delete or return it on the district's direction; we maintain reasonable security; and we do not change how we use it without the district's consent.

9. Sensitive Categories

Some of what we hold calls for added care, and we handle it accordingly.

Special education and Section 504 information is protected under IDEA as well as FERPA. Access is limited to staff with a role-based educational need. We do not use disability status, disability category, or plan contents for any purpose other than delivering the educational service, and never for eligibility decisions outside that purpose.

Discipline records are education records and are restricted the same way. The student's ethnicity is recorded with each discipline referral so that districts can produce the disproportionality analysis that federal and state law often requires. It is not used for any decision about an individual student.

Immigrant or refugee status is held only as a yes-or-no indicator, only where a district or family provides it, and only to match a student to scholarships and programs limited to or set aside for those students. We do not share it with any government agency except as law compels, and we would notify the district before any such disclosure unless the law prohibits it.

Benefits information (program participation, eligibility estimates, denial reasons, and award amounts) is held for the family's own benefits navigation. It is visible to the family and to the district staff the family's consent reaches, and to no one else. We do not disclose a family's benefits participation to a school unless the family's consent covers it.

Meal program eligibility carries its own federal limits on redisclosure under the National School Lunch Act, and we honor them.

Court orders, custody arrangements, and contact restrictions are held because serving a family safely requires knowing them. Access is limited to staff whose role requires it, and changes are recorded.

Health information. We do not operate as a HIPAA business associate and we hold no protected health information under HIPAA. The platform has no health record, no health field, and no connection to a clinical system. Health information may reach us in two narrow ways: within a special education or Section 504 plan, where it is an education record under FERPA and treated as one, and as free-form text a parent writes in a message to us. We do not extract, index, or structure health information from parent messages.

Race and ethnicity are held to support the equity reporting districts are required to produce. They are not used for eligibility, targeting, or any individual decision.

10. Your Rights

If you are a parent or guardian, your rights in your child's education record come from FERPA and are exercised through the district. We support the district in answering you, and we will never refuse a district's instruction to produce, correct, or delete a record. Student Data Privacy explains how to exercise these rights.

If you are a California resident, you may ask for the categories and specific pieces of personal information we hold about you, their sources, our purposes, and the categories of third parties we share with; ask us to correct it; ask us to delete it, subject to the retention obligations in Section 5; and limit our use of sensitive personal information. We do not sell personal information and we do not share it for cross-context behavioral advertising, so there is nothing to opt out of, but you may make the request and we will confirm it. We will not treat you differently for exercising any of these rights.

If you live in another state with a consumer privacy law, we honor the equivalent rights that law gives you, whether or not we meet that law's size thresholds.

If you are an employee of a district using our workforce products, you may see your own signals, grant and revoke consent for each domain separately, and rely on the fact that no administrator can see you as an individual. Your district's agreement and any collective bargaining agreement apply alongside this policy.

To exercise any right, write to privacy@agenticed.com. We will acknowledge your request within ten business days and respond within forty-five days. We may need to verify your identity, and for a student record we will coordinate with the district that holds it.

11. Where Your Information Is

Our services operate in the United States, and your information is stored and processed here. We do not transfer personal information outside the United States. If that changes, we will update this policy and put appropriate safeguards in place before any transfer.

12. Changes

We may update this policy. We will post the updated version with a new effective date. For any material change affecting student or family information, we will notify affected districts directly at least thirty days before the change takes effect.

13. Contact

AgenticED, Inc.
Attn: Privacy Officer
240 West 136th Street
New York, NY 10030

Privacy: privacy@agenticed.com
Security: security@agenticed.com

If we cannot resolve your concern, you may contact your state attorney general or, for a student record, your district's privacy officer and your state education agency.