Privacy Policy

Who We Are

Welcome to RevolutionEd, operated by iCode Technologies LLC. Our platform empowers educators with advanced AI-driven tools to create custom lesson plans, quizzes, and educational experiences for K-12 students. This privacy policy describes how we collect, use, and protect personal information on our admin.revolutioned.ai portal, which serves educators and school administrators.

What Personal Data We Collect and Why

Account and Profile Information

Name, email address, school affiliation, and role are collected during registration. Educators may also provide optional profile details — such as a phone number, U.S. state, a profile photo, and teaching preferences (for example, the subjects taught and available classroom hardware). Sign-in may use a password or single sign-on (Google, Clever, or ClassLink), which supplies the associated login identifiers. This information is used to create educator accounts, manage classes, and provide access to educational features.

Student Data (Provided by Teachers)

• First and last names of students
• Grade level, and — where a roster import provides them — class/cohort, section, and enrollment information
• Reading level and learning-progress data used to personalize activities
• Quiz responses and educational activity
• Interests submitted by students
• AI chat interactions (moderated and accessible to the student's teacher and the school's authorized staff)
• Voice/audio recordings created when a student reads aloud during pronunciation practice (the read-aloud "Listen and Learn" module only plays audio and records nothing)
• Photographs or images uploaded as part of an activity or profile
• Email address — only when supplied by a school roster import (Google Classroom, Clever, or ClassLink); it is not collected when a teacher adds a student manually
• Teacher-authored notes about a student, which a teacher may choose to enter for individualization and which can include accommodation or IEP/504 (special-education) information

Student accounts are never created directly; access is granted through teacher-generated QR codes or links.

Cookies

• Essential cookie: One session cookie keeps you signed in, protects forms against forgery and holds choices you make in the Service, such as the language a student picks. It is always on and is not subject to consent.
• Browser storage: Some pages also keep working information in your browser's storage, such as a draft in progress or whether you have seen a tutorial. It is used only to make those pages work.
• Analytics and marketing cookies: We do not use any. On October 5, 2026 we removed Google Analytics, which was not configured to run, and CallRail, a call-attribution service that had been loading on pages of the Service (latterly only on public pages, after you accepted marketing cookies). With nothing optional to accept, the Service shows no cookie banner.
• Embedded content: For videos embedded from YouTube, see Embedded Content; for the Microsoft viewer that educators use to open curriculum lesson decks, see Document Viewing.

You can opt out of any sale or sharing through the "Do Not Sell or Share My Personal Information" link, and we honor an enabled Global Privacy Control (GPC) browser signal as a valid opt-out. We record either kind of opt-out, and it would apply to anything non-essential we added later.

Device and Usage Information

When the platform is used, we automatically collect limited technical information — including IP address, browser and device information, and session activity — which is recorded in security and operational logs. We use it to authenticate users, protect and secure the service (including web-application-firewall and abuse protection), and keep the service running reliably. Personal identifiers in these logs are minimized, and this information is not used for targeted advertising.

Media Uploads

Educators may upload media (e.g., images, documents). Uploaded images are automatically re-encoded on upload, which removes embedded metadata — including any location data (EXIF GPS) — so it is not retained. Other document types (for example PDF, Word or PowerPoint files) are validated and virus-scanned but are not re-encoded, so any metadata their author embedded travels with them; please avoid uploading documents that carry information you do not intend to share.

Embedded Content

Some curriculum lessons, including lessons a teacher assigns to students, contain YouTube videos. We show them in YouTube's embedded player, one of the YouTube API Services, in privacy-enhanced mode (youtube-nocookie.com). We never start a video automatically, and when a video ends, YouTube suggests only videos from the same channel. When a page with a video loads, the viewer's browser connects directly to Google, which receives the device's IP address, browser and device information, our site's web address and the video being shown; more is shared if the video is played. Google states that in this mode a view is not used to personalize the viewer's YouTube experience or the advertising they see, and that any ads shown on the video are not personalized. The player may store or read information on the device, such as cookies or similar technologies. We send YouTube no account, school or student information, and we receive nothing back. Google's use of this information is described in the Google Privacy Policy. The player also shows YouTube's own links; following one opens YouTube, outside RevolutionEd, where YouTube's terms apply.

How We Use Your Information

• To personalize lesson plans and student experiences
• To facilitate collaboration between teachers and students
• To analyze learning outcomes and improve platform features
• To export documents an educator chooses into the educator's Google Workspace Drive

Legal bases (EU/UK GDPR). Where the EU or UK GDPR applies, we rely on these lawful bases: performance of our contract with your school or with you (Art. 6(1)(b)); compliance with our legal obligations (Art. 6(1)(c)); your consent where required (Art. 6(1)(a)); and our legitimate interests in providing, securing, and improving the Service (Art. 6(1)(f)). Student personal data is processed on behalf of and under the authority of the school. We use AI tools to assist educators; we do not make decisions producing legal or similarly significant effects about students solely by automated means — an educator remains responsible for educational decisions.

AI & algorithm transparency. For a plain-language explanation of every place we use AI or an automatic decision — what each does, the information it uses, the human oversight, and your override/opt-out choices — see our AI & Algorithm Transparency disclosure (Texas SCOPE Act, Tex. Bus. & Com. Code ch. 509 — advertising & algorithm disclosure, § 509.055).

Children's Privacy (COPPA) and the School Consent Exception

RevolutionEd is designed for K-12 schools and is made available to students at the direction of their school or district. Where a student is under 13, we rely on the school to provide consent on behalf of parents under the COPPA "Schools Exception" — personal information is collected solely for the use and benefit of the school and for no other commercial purpose. Consistent with that exception:

• We collect personal information from students only to provide the educational service the school has authorized.
• We do not use student personal information for advertising, sell or rent it, or build profiles for any non-educational purpose.
• We do not condition a student's participation on disclosing more personal information than is reasonably necessary for the activity.

The school owns the data. Student data is and remains the property of, and under the control of, the school or district (and, as applicable, the parent or eligible student). RevolutionEd acts only as the school's data processor and obtains no ownership right, license, or interest in student data beyond the limited right to process it to deliver the service the school has authorized. When a school leaves or asks us to delete its data, we return the data to the school before destroying it.

Parental rights. The school consents to each student's use of RevolutionEd, including its AI features and the AI providers named in our sub-processor list, acting in loco parentis and as the agent of the student's parent or guardian. Because the school provides consent as the parent's agent, a parent who wishes to review the personal information collected from their child, direct its correction or deletion, or refuse to permit further collection or use should contact their child's school, which will instruct us as the data processor; we act only on the school's verified instruction. Parents may also submit a request directly through our Parent Privacy Request form (review, refuse further collection, or request deletion), or contact us using the details below; we will route the request to the controlling school/district and track it on our response timeline.

FERPA annual notice. Under FERPA (34 CFR § 99.7), your school or district — not RevolutionEd — is responsible for the annual notification of FERPA rights to parents and eligible students, including the rights to inspect and review education records, to request the amendment of inaccurate records, to consent to certain disclosures, and to file a complaint with the U.S. Department of Education. As the school's data processor, RevolutionEd supports and does not displace or replace that notice; we refer you to your school or district's annual FERPA notification for a full description of these rights and how to exercise them, and we honor requests routed to us by the school.

New York students. For students in New York State, our Parents' Bill of Rights for Data Privacy and Security (issued under New York Education Law § 2-d) is available on our Parents' Bill of Rights page, from your school, or on request.

Languages / accessibility of this notice. Under FERPA, NY Education Law § 2-d / 8 NYCRR Part 121, and NYC Chancellor's Regulation A-820, your school or district is responsible for providing notices to parents and guardians in a language and format they can access (including translation for families with limited English proficiency). As the school's data processor, RevolutionEd supports that obligation: on a school's or family's request we will provide the source text of this notice and the Parents' Bill of Rights for translation, and we will furnish the documents in an accessible format. Contact us using the details below.

Our Core Privacy Commitments

RevolutionEd is built for K-12 schools, and we hold ourselves to the privacy commitments that student-privacy reviewers (including the Common Sense Privacy Program) treat as the minimum bar for a trustworthy education product. We make each of the following commitments without exception for students, teachers, and account holders:

• We do not sell personal information. We do not sell or rent personal information to any third party for monetary or other valuable consideration.
• We do not use personal information for third-party marketing. We do not disclose personal information to third parties for their own marketing, and we do not send our users third-party marketing communications.
• We do not use personal information for targeted advertising. We do not use personal information to deliver targeted, behavioral, or interest-based advertising, and we serve no third-party advertising in the Service.
• We do not allow third-party tracking. We do not permit third parties to collect personal information through the Service to track users for their own purposes. The Service loads no analytics or advertising scripts. Embedded YouTube videos, and in educator tools Google's file picker and document viewer and Microsoft's document viewer, load from those providers, which receive the browser's request data and may set their own cookies; see Embedded Content and Document Viewing.
• We do not track users across other apps or websites. We do not engage in cross-app or cross-site tracking of users over time across services we do not operate.
• We do not build commercial profiles. We do not create or use profiles of students for any advertising, marketing, or other non-educational commercial purpose.

These commitments apply to all personal information, and student personal information is additionally used only to provide the educational service authorized by the student's school or district. They restate, in one place, commitments that also appear throughout this policy and that are contractually binding on us under our agreements with educational agencies.

Data Sharing and Sub-Processors

We do not sell or rent personal information to third parties. We use the following sub-processors for infrastructure, AI generation, identity, payments, communications, curriculum and reference data, document viewing, and browser-side asset delivery and embedded content. The student data RevolutionEd stores is kept in the United States, but several of these providers process data outside the United States — see Where Data Is Stored and Processed, below. RevolutionEd has a written agreement with each of these providers that receives personal information from us, binding it to data protection standards no less protective than those in our agreements with educational agencies.

1. Infrastructure & Hosting (server-side)

• Google Cloud Platform (Alphabet Inc.) – Application hosting (Cloud Run), database (Cloud SQL for MySQL), object storage (Cloud Storage), container registry (Artifact Registry), identity management (Cloud IAM), secret storage (Secret Manager), edge protection (Cloud Armor + Cloud CDN), DNS (Cloud DNS), audit logging (Cloud Logging). Continuously attested under SOC 2 Type II, ISO/IEC 27001, ISO/IEC 27017, and ISO/IEC 27018. Data Processing Addendum executed. The student personal data and education records that RevolutionEd stores reside in the United States: the production database and its read replica in us-central1, a domestic disaster-recovery replica in us-east1, and file storage in US multi-region. Secret storage and operational logging use Google-managed replication that is not pinned to a single region; neither holds student personal data.

2. AI Generation (server-side)

• Google Gemini API – Primary AI generation in tools for educators: lesson plans, quizzes, narratives, presentations, images, text-to-speech, and lesson individualization. For most generation we send only the lesson topic, grade level, and prompt text. For the optional lesson-individualization features, a teacher may additionally send a student's name, grade and reading level, interests, and teacher-authored IEP/accommodation notes so the output can be tailored to that student — this is processor use to deliver the educational service under the FERPA school-official exception and NY Education Law § 2-d, never a sale and never used for advertising. Under the Gemini API terms for paid use, Google does not use prompts or responses to improve its products; it keeps them for 55 days to detect policy violations, and flagged data may train only the models Google uses for policy enforcement. On the student portal, since October 7, 2026, Gemini only generates pictures: a picture of the character a student designs, from the name and description the student writes, and the character's poses, from that picture; and the pictures in the online-safety practice chat. It receives nothing else from the student portal; the rest of the student portal's AI runs on Microsoft Azure (below). See the authoritative sub-processor list (Exhibit A) for exactly what each processor receives.
• OpenAI – Two roles, in tools for educators; since October 7, 2026 OpenAI receives nothing from the student portal. (1) Safety screening (an augmenting layer). When enabled, the OpenAI Moderation API screens text that teachers save (including accommodation notes about a student) and AI-generated text — among them OpenAI's own generated output when OpenAI is the active text-generation provider — for harmful content and for indications of self-harm or crisis. On the student portal, Microsoft Azure AI Content Safety does this screening instead (below), alongside RevolutionEd's own always-on self-harm control, a deterministic crisis-lexicon classifier. In tools for educators, harmful-content screening falls back to a small internal keyword list when the OpenAI layer is unavailable, and the active AI provider's built-in safety filter (Google Gemini's by default) screens AI-generated output. Where a self-harm indication is detected in what a student writes on the student portal, the student is shown crisis-support resources (such as the 988 Suicide & Crisis Lifeline) and a minimized alert — with no name and no message content — is sent to the school's administrators and any safety contact the school designates, so the school can follow its own student-safety procedure; it is not sent to parents or law enforcement by default, and detection is based on the safety concern, never a student's identity. (2) A fallback text-generation provider for tools for educators: when our primary generator (Google Gemini) is briefly unavailable, an instructional AI request may be served by OpenAI instead, and RevolutionEd may configure OpenAI as the primary generator (an operational setting managed by RevolutionEd, not a school control). In that role OpenAI performs the same text-based instructional generation tasks as Google Gemini — including the optional lesson-individualization features, where a teacher may additionally send a student's name, grade and reading level, interests, and teacher-authored IEP/accommodation notes so the output can be tailored to that student. Voice recordings, text-to-speech, and image generation are never handled by OpenAI and are never failed over to it: a pronunciation recording goes only to Microsoft Azure AI Speech, and text-to-speech and image generation in tools for educators stay with Google. As with Gemini, this is processor use to deliver the educational service under the FERPA school-official exception and NY Education Law § 2-d, never a sale and never used for advertising. OpenAI is engaged under its Services Agreement and data processing addendum, and under those terms nothing we send it is used to train its models. Zero Data Retention, an arrangement OpenAI must approve, is not enabled for our organization; we have asked OpenAI to approve it. OpenAI keeps no copy of text sent for safety screening. Text sent for generation may be kept in OpenAI's abuse-monitoring logs, which OpenAI uses to detect misuse of its service, for up to 30 days, and longer only where the law requires it or to protect against harm; it is then deleted. Email addresses, Social Security numbers in their standard format, and formatted phone numbers are removed from that text before it is sent.
• Microsoft Azure AI Speech – Two uses. Pronunciation assessment: scoring a student's recorded reading of a sentence or paragraph during pronunciation practice. We send short audio clips (typically ≤30 seconds) with the text being read; the clip is not retained (Azure audio-and-transcription logging is disabled) and is deleted on our side immediately after scoring. No voiceprint or other biometric identifier is created from the audio. The recording is sent to no other service: if Azure cannot score a reading, the student is asked to try again. We keep no pronunciation scores or transcripts. The transcript Azure returns is shown to the student and screened for safety using Microsoft Azure AI Content Safety (below); a transcript the screening flags leaves an excerpt of up to 120 characters in the student's safety record. And, since October 7, 2026, reading text aloud to students (text to speech): reading-practice passages and word definitions, practice sentences, pronunciation tips and character voice samples. It receives that text only, and the voice students hear is a synthetic, AI voice. Microsoft does not store the text or the audio it produces.
• Microsoft Azure AI Translator – Optional translation into a student's chosen language. When a student selects a language other than English, two things are translated. The interface text — buttons, labels and messages — is a set of fixed labels built into the product and contains no personal information. AI-generated replies and story text written for that student are also translated; that text can include the student's first name and can answer what the student wrote, and it is the only translation that carries a student's information. For students in New York, AI-generated content is not translated and stays in English. Text a student typed is never sent for translation, and neither are account identifiers, email addresses, voice recordings or images. Where a teacher has set a lesson to another language, the partner curriculum in it is translated as well — published curriculum, carrying no student information. Microsoft does not store text submitted for translation and does not use it to train its models (Microsoft Translator “No Trace”).
• Microsoft Azure OpenAI – AI on the student portal, since October 7, 2026: the tutor chat, feedback on writing and reflections, practice questions and quiz grading, the online-safety practice chat, reading a picture a student uploads (to describe it, and to delete it if it shows a real person), citations, reading-level estimates, personalized lessons, pronunciation tips and choosing a voice for a character a student designs, and the follow-up checks in safety screening. It receives what students type and the context those features need, which can include a student's first name, class, teacher and school, grade, reading level, interests the student gives, quiz answers and scores, and a picture the student uploads; in the online-safety practice chat it also receives the student's school-assigned ID. For the follow-up checks it receives text that Azure AI Content Safety rates as possible self-harm or sexual content, which can be an AI reply, a pronunciation transcript or a report written on our report-a-concern pages. It receives no voice recordings. Email addresses, Social Security numbers in their standard format, and formatted phone numbers are removed first. Microsoft does not use this data to train models and does not make it available to OpenAI. The deployments we use process data only in Microsoft's United States data zone, and our requests use Microsoft's stateless mode, so Microsoft keeps no conversation history. Microsoft temporarily stores prompts and outputs in the United States to detect abuse, and authorized Microsoft employees may review content its systems flag; Microsoft publishes no fixed period for that storage. Microsoft may also keep the beginning of a prompt in a cache for at least 30 minutes, possibly longer, to speed up similar requests. As with Gemini, this is processor use to deliver the educational service under the FERPA school-official exception and NY Education Law § 2-d, never a sale and never used for advertising.
• Microsoft Azure AI Content Safety – Safety screening on the student portal, since October 7, 2026: what students write, the AI's replies in chats and citations, pronunciation transcripts and tips, text read aloud to students, and report-a-concern text are checked for hate, sexual content, violence and self-harm. The tutor chat is not sent to it; there, our own crisis check and Azure OpenAI's built-in content filter apply instead. When something a student writes in a chat, answer or report indicates self-harm, the student is shown crisis-support resources and the school is alerted as described above, and apparent sexual content involving a minor in what a student submits can open a confidential review record. It receives the text only, with email addresses, Social Security numbers and formatted phone numbers removed, and no account details; the text itself can contain personal information, such as what a student types or a student's first name in an AI reply. Microsoft does not store the text, use it for training or make it available for human review, and processes it in our resource's region, East US 2. If it is unavailable, a small internal keyword check runs instead.

3. Identity & Single Sign-On (server-side)

• Google OAuth 2.0 / OpenID Connect – Teacher and administrator login via Google account.
• Clever, Inc. – Single Sign-On and roster sync (api.clever.com) for districts that use Clever. Clever is the district’s own provider: it supplies student and teacher IDs, email addresses, names, grades and sections to us at the district’s direction, and receives no personal information from us.
• ClassLink, Inc. – Single Sign-On (launchpad.classlink.com) and OneRoster roster sync (nodeapi.classlink.com, oneroster-proxy.apis.classlink.com) for districts that use ClassLink. ClassLink is the district’s own provider: it supplies student and teacher IDs, email addresses, names, grades, sections and enrollments to us at the district’s direction, and receives no personal information from us.
• Have I Been Pwned (Pwned Passwords range API, api.pwnedpasswords.com) – Breached-password screening when a user sets or resets a password, so known-compromised passwords are rejected. Only the first five characters of the password's SHA-1 hash are sent (k-anonymity) — the password, the full hash, and all personal data never leave our server, so no PII is transmitted. If the service is unreachable the password change still proceeds (fail-open), so it is not a dependency of the login path.

4. Roster & Document Integration (server-side)

• Google Classroom API – Optional teacher-initiated roster import for teachers who use Google Classroom. Receives teacher email, course roster, and student IDs/emails/names.
• Google Drive / Docs / Slides APIs – Optional, for educators only: a teacher can export a lesson plan, quiz or curriculum-tool result as a Google Doc to Google Drive, and a school administrator can export one of a teacher at the same school (we no longer use the Slides API). Since October 5, 2026 this works only with a Google Workspace account — a school's or another organization's — which we check with Google at each export, and not from a RevolutionEd staff account; before then an export could also go to a personal Google account, and documents exported then stay where they were saved. The lesson-plan page and the tool pages that offer a folder choice load Google's file picker when they open, so Google receives the browser's IP address and device details, and we receive only the chosen folder's ID. Our server creates the document with the authorization the teacher gave at Google sign-in, limited for Drive to the drive.file scope, which reaches only files our service creates and the folder chosen; we read nothing else in the teacher's Drive. The document usually carries the teacher's name and school. A document made for one student — a lesson plan individualized for that student or a quiz built from it, or a curriculum-tool result for a selected student — can also carry that student's name, including in its title, and content written from the teacher's notes about the student, which can repeat those notes and reveal a disability, a health or behavioral need, or an IEP or 504 plan. The document takes the sharing of the folder it is placed in and is held under the agreement with Google of the organization that manages the account, until the teacher or that organization deletes it. We keep no copy of it. We keep the teacher's Google authorization until the educator account is deleted, and about a week longer in backups; until then it lets our service reach the documents it created, which it does only when the teacher exports. Deleting the account does not remove the grant from the teacher's Google Account, where the teacher can remove it. Separately, one curriculum browser shows Office files in Google's Docs viewer (docs.google.com): the educator's browser loads the viewer from Google, which receives the browser's IP address and device details and a five-minute link to the curriculum file, and fetches the file from that link; no student information is in the link or the file.

5. Administrative & Communications (server-side)

• Stripe, Inc. – Retained only for administrative customer-record deletion: during account/data disposal an administrator invokes Stripe's Customer.delete API on a legacy customer identifier. There is no payment surface — no self-serve checkout, no subscription billing, no Stripe Elements or card capture, and no Stripe inbound webhook (all removed 2026-06-30). District/enterprise licensing is billed off-platform by negotiated contract/invoice, not through Stripe. No cardholder data is stored or processed.
• SendGrid (Twilio, Inc.) – Transactional email (account confirmations, password resets, notifications) and event webhook. Receives recipient email, name, and message body. Sender domain: registration@revolutioned.ai.

6. Curriculum & Reference Data (server-side)

• JASON Learning – Curriculum resource lookup. Search query strings only; no PII.
• Texas Instruments – TI educational activity resource lookup and file downloads. Search queries; no PII.
• Library of Congress (www.loc.gov) – Primary source search for the Deep Dive History feature. No PII sent.
• Serper.dev – Web image-search proxy for presentation imagery. Search query strings only.
• randomuser.me – Synthetic character profile generation for the Make It Stick chat feature. No outbound data — synthetic profiles are fetched.

7. Document Viewing (educator tools)

• Microsoft Office Online viewer (view.officeapps.live.com) – Renders a curriculum lesson deck inside the document viewer that signed-in educators use. It is not part of the student experience. Our server creates a link to the deck that expires in five minutes; Microsoft fetches the deck from that link and renders it, and the educator's browser loads the rendered view from Microsoft, which receives the browser's IP address and device details. While it runs, Microsoft's viewer also checks with Microsoft's sign-in services whether the browser is signed in to a Microsoft account, so Microsoft can link the session to that account if it is; sends Microsoft usage and diagnostic data; and, where the browser allows, sets Microsoft cookies that identify the browser. Only published curriculum documents are sent — no student personal information is in the link or in the files — and nothing comes back to us. Microsoft publishes no retention period for this viewer; its handling of what it receives is governed by the Microsoft Privacy Statement.

8. Browser-side Analytics & Tracking

• None. The Service loads no analytics, advertising or tag-manager script. We removed Google Analytics and CallRail from the Service on October 5, 2026.

9. Browser-side Asset CDNs and Embedded Video

The following networks deliver fonts, icons, JavaScript libraries and embedded videos to the user's browser. RevolutionEd does not transmit any PII or education records to these networks.

• YouTube (Google) (youtube-nocookie.com) – Videos in curriculum lessons, in privacy-enhanced mode. See Embedded Content.
• Google Fonts (fonts.googleapis.com, fonts.gstatic.com) – Web fonts.
• jsDelivr CDN – JavaScript libraries (Bootstrap, KaTeX, DOMPurify, Tom Select, Chart.js, marked, Three.js).
• Cloudflare cdnjs (cdnjs.cloudflare.com) – The Font Awesome icon library (stylesheet and icon fonts) and the Spectrum color-picker stylesheet, each pinned to one version and checked by the browser against a fixed hash. No scripts are loaded from cdnjs.
• MathJax CDN – LaTeX math rendering.
• Plotly CDN – Chart rendering on administrative dashboards only.
• Brandfolder embed – Bluebonnet curriculum preview embed (public embed key).
• Imgur – Static logo asset embedded in generated PDFs and emails. No user data flows to Imgur (logo fetch only). Migration to a self-hosted asset is planned.

Authoritative sub-processor list. The complete, current sub-processor list is published at /sub-processors (the same list is Exhibit A, which is incorporated by reference into any Data Privacy Agreement executed between RevolutionEd and an educational agency). It also lists, for transparency, providers that receive no personal information from us, such as the networks above; under our Data Privacy Agreement those providers are not sub-processors. Before a new or replacement sub-processor begins processing student data, RevolutionEd gives the educational agency at least thirty (30) days' advance notice and an opportunity to object on reasonable data-protection grounds; removals and other material changes are notified within thirty (30) days. See how to object.

Where Data Is Stored and Processed

We keep two things separate here: where RevolutionEd stores student data, and where the providers we send data to process it. Until September 16, 2026 this notice said that all of our sub-processors operate from facilities in the United States. That was not accurate for the providers named below, and it has been corrected.

Stored by RevolutionEd: United States only. Every place where RevolutionEd itself stores student personal data and education records is in the United States: the production database and its read replica in Google Cloud's us-central1 region (Iowa), a disaster-recovery replica in us-east1 (South Carolina), and file storage and backups in Google Cloud's US multi-region. None of it is replicated outside the United States, and our application servers run in us-central1. Two supporting services use Google-managed replication that is not pinned to one region: secret storage, which holds service credentials only, and operational logs, which are scrubbed of personal identifiers.

Processed by providers outside the United States. The following providers can process the data we send them outside the United States, under their own terms:

• Google Gemini API (AI generation). Receives prompt text from tools for educators that can include a student's name, grade and reading level, interests, teacher-written IEP or accommodation notes and student work, and, from the student portal, the name and description a student writes for a character whose picture it generates. Google's terms for paid use say this data “may be stored transiently or cached in any country in which Google or its agents maintain facilities”, and Google logs prompts and responses for a limited period to detect abuse.
• OpenAI (safety screening, and text generation when Gemini is unavailable or selected, in tools for educators). Receives text that teachers write, AI-generated text sent for screening, and generation prompts, which can include student information a teacher works with, with email addresses, formatted phone numbers and Social Security numbers removed; since October 7, 2026 it receives nothing from the student portal. OpenAI's data processing addendum does not limit processing to the United States.
• SendGrid (Twilio; email delivery). Receives the email we send. Twilio's data processing addendum also lets Twilio use email content for its own purposes, such as security and developing its products, so the alerts and notices our platform sends about a student do not identify the student: a self-harm or crisis alert, an alert about a flagged AI-chat message, and a notice of a student's support request or of a privacy request carry no student's name and none of the student's words, and point to a page that requires signing in, where the school or our staff see the details. Text that someone types into a form addressed to us, such as an educator's support request, reaches our staff by email as written. Twilio's security terms place its hosting providers in the United States, but Twilio's published sub-processor list includes United States and European Union locations for routing and hosting SendGrid email, and SendGrid offers no United States-only option.
• Google Workspace (our staff email). Email that people send us, which can name a student (a parent's privacy request, for example), is delivered to our staff mailboxes, which Google hosts in locations that are not limited to the United States.
• Google Classroom, Google sign-in and Google Drive (optional, teacher-initiated). Google operates these services worldwide. A Classroom roster is read from the school's own Google account, and a Drive export goes to the teacher's Google Workspace account (a school's or another organization's), and can carry a student's name and content written from the teacher's notes when the teacher exports a document made for that student; where Google keeps that data follows that organization's agreement with Google.
• Stripe, which receives no student data, also processes data in countries other than the United States.

Processed in the United States. Microsoft Azure AI Speech (our Speech resource is in Microsoft's East US region, where Microsoft says Speech data stays and is processed, and Microsoft processes the audio in memory without storing it), Microsoft Azure AI Translator (Microsoft's Americas endpoint, which processes in East US 2 or West US 2), Microsoft Azure OpenAI (the deployments we use for the student portal use Microsoft's United States data zone, and the data Microsoft keeps to detect abuse is stored in the United States) and Microsoft Azure AI Content Safety (our resource is in Microsoft's East US 2 region, where Microsoft says the text is processed).

Delivered to your browser. Fonts, script libraries, embedded videos and the document viewer are served from global networks operated by Google, Cloudflare, jsDelivr, Microsoft and others. They receive your device's IP address and ordinary request details, usually at a location near you, and no student records.

Every provider that receives student data is bound by a written agreement, and the AI providers may not use it to train their models. The published sub-processor list shows each provider's location.

International Data Transfers

RevolutionEd's own infrastructure is in the United States; some providers process data outside it, as set out above. Where we process the personal data of individuals located in the EU, the UK, or other regions with cross-border-transfer requirements, those transfers are made under an appropriate safeguard — for example the EU-US Data Privacy Framework (and UK Extension) where the recipient is certified, or Standard Contractual Clauses together with a transfer risk assessment.

Data Security

• Encryption: AES-256 at rest, TLS 1.2+ in transit
• Access Controls: IAM-based least-privilege access, audit logging
• Password Security: scrypt hashing with unique salts
• Multi-factor authentication (MFA): available through your single sign-on provider (Google, Clever, or ClassLink), which your school or district can require; RevolutionEd does not store a separate password when you sign in with SSO
• Monitoring: GCP Security Command Center and automated intrusion detection
• Staff Training: Secure development and data privacy training
• Backups: Daily automated database backups with continuous point-in-time recovery over a 7-day window, encrypted at rest and isolated so the application cannot delete them. Deleted student records are not separately scrubbed from backups; they age out of that 7-day window, after which they are no longer retained in backups.

Data Retention

We retain personal information only for as long as reasonably necessary to provide the educational service and to meet legal, accounting, or reporting obligations. We do not retain children's personal information indefinitely. Student personal information is kept only for the period needed for its educational purpose and is then deleted or de-identified. Upon request or contract termination, student personal information is returned and/or securely deleted within 30 days, including from backups after the backup-retention window, and we provide a certificate of destruction on request. For New York City public-school (NYC DOE) data, we do not de-identify it at all: NYC DOE student data is returned to the school and/or securely destroyed only — never de-identified and retained (NYC DOE Chancellor's Regulation A-820).

The categories of data we hold and how long we keep each are summarized below; our full data-retention policy and schedule are available to educational agencies on request.

Your Rights Over Your Data

Depending on your location and applicable law (including the EU/UK GDPR, the CCPA/CPRA, and U.S. state privacy laws such as the Connecticut Data Privacy Act), you may have the right to (see our dedicated Your Privacy Rights page for a full description and how to exercise each):

• Know about and access the personal information we hold about you
• Correct inaccurate personal information
• Delete your personal information
• Restrict or object to certain processing
• Receive a portable copy of your data (data portability)
• Withdraw consent where processing is based on consent
• Opt out of the "sale" or "sharing" of personal information and of targeted advertising — note that we do not sell or share personal information or use it for targeted advertising
• Limit the use of sensitive personal information
• Not be discriminated against for exercising your privacy rights
• Appeal a decision we make about a privacy request

To exercise any of these rights, submit a privacy request or contact us using the details at the end of this policy. If your request concerns a student's education records, we act on behalf of the student's school/district and will route your request to them as the controller of those records. If we decline your request, you may appeal by replying to our decision or contacting us at registration@revolutioned.ai; we will respond to an appeal within 45 days (within the period applicable law allows). You may also contact your state Attorney General or your data-protection supervisory authority (see "Complaints and Supervisory Authorities" above).

All subject access requests (SARs) and deletion requests will be handled within 30 days, with extensions up to 60 additional days for complex cases, in line with GDPR requirements. Users will be notified within the initial 30 days if more time is needed.

Student Data Requests

If a parent or student contacts us directly, we will refer the request to the School Administrator. We act as a data processor under the school’s direction and will only process or delete student data upon the School’s instruction.

Complaints and Supervisory Authorities

If you have a concern about how we handle personal information, please contact us first using the details below so we can try to resolve it. You also have the right to lodge a complaint with a regulator:

• Schools and parents (United States): you may raise concerns with your school or district, with the U.S. Federal Trade Commission (FTC), or with your state Attorney General.
• Individuals in the EU / UK: you may lodge a complaint with your local data protection authority, or with the UK Information Commissioner's Office (ICO).

Breach Notification Policy

In the event of a breach or unauthorized release involving student data, we notify the affected School / educational agency in the most expedient way possible and without unreasonable delay, and no later than seven (7) calendar days after discovery (consistent with New York Education Law § 2-d and 8 NYCRR Part 121). Where a specific state law or a district's data privacy agreement requires faster notification, we comply with that shorter timeline. Details provided include: nature, scope, affected systems, and mitigation steps. Notifications are delayed only if and to the extent a law-enforcement agency determines that notification would impede a criminal investigation. We coordinate closely with Google Cloud Platform to investigate and respond to incidents.

Law Enforcement and Legal Requests

iCode Technologies LLC may disclose personal information where required by applicable law or court order. The School will be notified unless legally prohibited. All requests are reviewed by legal and compliance personnel and documented internally.

Changes to This Privacy Policy

We may update this privacy policy from time to time. When we do, we revise the "Last Updated" date above and keep a record of each version so the wording in effect on any prior date can be retrieved.

Before we make a material change — for example, collecting a new category of personal information, using personal information for a new purpose, using students' personal information to train AI models, adding a new AI feature or AI provider that processes student data, adding a new sub-processor with access to student data, disclosing information to a new recipient, retaining data longer than previously stated, or reducing your rights or our safeguards — we provide prominent notice in advance, typically at least 30 days before the change takes effect. That notice is given through an in-product banner and by email to account holders (schools and educators), in addition to updating this page, so you have an opportunity to review the change and, where applicable, to opt out before it applies to you.

Because students use RevolutionEd under their school's authorization (the COPPA Schools Exception), where a material change affects the collection, use, or disclosure of a child's personal information we obtain new authorization — school re-authorization or new verifiable parental consent — before that change is applied to information already collected, as required by the Children's Online Privacy Protection Act Rule (16 C.F.R. § 312.4(b) and § 312.5(a)(1)). We will not apply a material change retroactively to data governed by a prior version without the notice and any consent described here.

Contact Us

If you have questions about this policy or your data, contact our designated Privacy Officer — the data-protection point of contact for privacy requests, complaints, and breach inquiries:

• Arsenios Scrivens, Chief Privacy & Compliance Officer (Designated Privacy Officer & data-protection point of contact)
• Email (privacy & data protection): registration@revolutioned.ai
• Telephone: (972) 654-0412
• Mailing Address: iCode Technologies LLC, 3201 Dallas Pkwy St. 810, Frisco, TX 75034

Effective Date: May 21, 2026
Last Updated: October 7, 2026
Site: https://admin.revolutioned.ai/