Feedback Forward Privacy Policy

Feedback Forward is a web-based assessment platform for educators and students. Feedback Forward enables teachers to create and administer assessments and other educational materials, collect and review student responses, and receive insights about student performance. 

Students cannot create accounts on their own. A teacher may add a student to their roster with a name and email in order to create a student account and enable access to the tool. Or a teacher may share a link for one-time use of an assessment or other instrument.

This Privacy Policy describes Opportunity Education Foundation’s (“OE”) collection, use, and disclosure of data provided when you use the Feedback Forward web application services (the “Service”). This Policy explains what data may be collected by third-party providers that the Service connects to. And the Policy describes your rights to review, correct, and delete any of your data OE maintains. Please contact us at support@opportunityeducation.org if you have any questions.

Please note that by using the Service, you agree to this Privacy Policy and our Terms of Service . This policy applies to individual users, and parents and teachers who may be navigating the Service on behalf of or with users. If you are a parent or teacher, by enrolling students, you certify that you have authority to provide information on the students’ behalf and that parents have been notified of this Privacy Policy, including what information OE collects and how it is used.

 

1. Collection and Use of Personal Information

Personal information is data that can be used to identify, contact, or reasonably identify a single person. OE collects only that personal information reasonably necessary to provide and improve the Service.

De-identified or aggregated data means data that cannot reasonably be used to identify an individual user.

You are not required to provide personal information requested by OE. However, failure to do so may limit access to certain features of the Service.

a. What Personal Information We Collect

When you create an Account, register for alerts, access the Service through a school, or contact us, we may collect information including:

• Name and other identifying information,
• Email address and other contact information,
• School or organizational affiliation, including location,
• Communication and contact preferences,
• Account credentials and authentication information,
• Student roster information, including names, grade levels, and school-issued email addresses synced or provided through educator accounts,
• Information related to classes, instructional assignments, and schedules,
• Demographic information, including eligibility for modifications to the education program according to the Individuals with Disabilities Education Act or Section 504 of the Rehabilitation Act of 1973, or
• Educational role.

We may collect learning activity data such as:

• Curriculum progress and instructional data,
• Teacher-created or school-provided assessments, assignments, and instructional materials,
• Student responses, submissions, and performance results,
• Metrics related to student engagement, reflection and other learning behaviors,
• Feedback exchanged between teachers and students, or
• Other education records or learning artifacts generated through use of the Service.

We may collect technical information including:

• Device identifiers,
• IP address,
• Browser type,
• Usage data,
• Log information, or
• Approximate location derived from IP address.

Precise geolocation data is not collected unless specifically enabled and permitted by applicable law.

OE does not knowingly collect health records or biometric identifiers (such as facial geometry, fingerprints, or voiceprints). If biometric information is ever collected, OE will obtain required written consent and comply with applicable biometric privacy laws.

b. How We Use the Personal Information We Collect

OE may use personal information to:

• Create, operate, deliver, maintain, secure, and improve the Service,
• Provide Service announcements and software updates,
• Communicate important notices, 
• Conduct auditing, analytics, research, and Service improvement, or
• Comply with legal obligations.

Student personal information is used solely for educational purposes and as directed by the educational institution.

OE does not:

• Sell Student Data,
• Use Student Data for targeted or cross-context behavioral advertising,
• Build commercial profiles unrelated to educational purposes, or
• Use Student Data to train artificial intelligence or machine learning systems except as necessary to provide, maintain, support, or improve the Service for educational purposes and as permitted by applicable law and contract.

c. De-Identified and Aggregate Data 

OE may derive de-identified and aggregate data from student activity on the Service, including assessment submission frequency and timing, time spent on assessments, and aggregate performance results. This information is processed in a form that cannot reasonably be used to identify any individual student.

De-identified and aggregate data is used solely for the following purposes:

• Improving and developing the Service,
• Generating anonymized benchmarks and reports, and
• Providing schools and teachers with aggregate insights about class and school-level performance trends.

De-identified and aggregate data is not sold, used for advertising, or shared with third parties for commercial purposes. It is not used to build individual profiles of students and is not re-combined with other data in a manner that would re-identify any individual.

OE applies de-identification standards consistent with FERPA’s definition of de-identified records, including the removal of all direct and indirect identifiers before any such data is used for the purposes described above.

Student data may be analyzed and shared with teachers. To generate reports , charts, and other summaries of student data for teachers, OE anonymizes student data and then sends that data to AI models for analysis. When OE receives output from the AI model, OE associates the report with a student record. 

 

2. How OE Uses Cookies

OE’s Service may use cookies connected to individuals and similar technologies and log files solely for:

• Service functionality,
• Security,
• Authentication,
• Analytics, and
• Service improvement.

OE does not use cookies or tracking technologies for targeted advertising involving data of minors or students.

Users may disable cookies in browser settings; however, doing so may make certain features not function properly.

 

3. Information from Services Integrated by Users

Users may connect their Service accounts to some third-party integrated services. If users connect such services, like Google or Clever, users give OE permission to collect and use personal information already associated with users’ accounts in those now “integrated services,” in a manner consistent with this Privacy Policy.

Adult users, including parents and teachers configuring the Service for student users, are responsible for ensuring that personal information from this Service is not used in an integrated service the user has connected in a manner that contravenes this Privacy Policy. 

 

4. Disclosure to Third Parties

We may use third parties to help host our Service, send out email updates, or process payments. These service providers may have access to your information for the limited purpose of providing the service we have contracted with them to provide. They are required to be bound by written agreements that include confidentiality obligations, appropriate security measures, and restrictions to process personal information only on our documented instructions and for the limited purposes of providing services to us. We may also store personal information in locations outside the direct control of Feedback Forward (for instance, on servers or databases co-located with hosting providers).

A list of our current subprocessors is available upon request by contacting support@opportunityeducation.org. Where required by contract (including DPAs) or applicable law, we provide advance notice of material changes to our subprocessors.

OE may make personal information available to authorized service providers and subprocessors that support hosting, analytics, security, and customer support functions. Such service providers may have access to personal information for the limited purpose of providing the service OE contracts with them to provide. Such providers agree to process personal information only on OE’s documented instructions, for the limited purposes of providing services to us. For example, these providers must

• Use personal information solely to provide services to OE,
• Maintain confidentiality,
• Implement appropriate administrative, technical, and physical safeguards,
• Comply with applicable federal and state student data privacy laws, and
• Not sell, retain, use, or disclose Student Data for any purpose other than providing contracted services.

OE requires that subprocessors maintain protections at least as protective as those set forth in this Privacy Policy and applicable law.

OE does not sell Student Data and does not share Student Data for targeted advertising.

In the event of a reorganization, merger, or sale, personal information may be transferred subject to the same privacy commitments.

OE may disclose personal information if required by law, legal process, or governmental request, or if necessary to enforce our terms or protect rights, property, or safety.

 

5. Security of Personal Information

OE implements reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction. Security measures include encryption in transit, access controls, and monitoring practices appropriate to the nature of the data.

In the event of a confirmed data breach involving personal information, OE will provide notice without unreasonable delay and within the timeframe required by applicable federal and state law, and will notify affected educational institutions as required.

 

6. Retention of Personal Information

OE retains personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, to comply with contractual obligations with schools, or as required by law.

Upon the termination of a contract, a user account, or upon request from a teacher, administrator, school or district, OE will delete or return Student Data within the timeframe required by law or contract unless retention is legally required.

OE applies data minimization and purpose limitation principles when retaining information.

 

7. Access to and Control of Personal Information

Subject to applicable law, individuals may have the right to:

• Access personal information,
• Correct inaccurate information,
• Request deletion,
• Obtain a copy of personal information, or
• Opt out of certain processing where applicable.

Requests may be submitted to support@opportunityeducation.org. OE may verify a requestor’s identity before processing requests.

Where Student Data is maintained pursuant to FERPA, requests relating to student education records must be directed to the educational institution, which retains control over such records.

To the extent applicable state consumer privacy laws apply, OE honors applicable rights requests consistent with those laws and applicable FERPA exemptions.

 

8. Third-Party Sites and Services

The Service may contain links to third-party websites or services. Information collected by third parties is governed by their privacy practices. OE encourages users to review third-party privacy policies.

 

9. Users Under Age 13

For children under 13, OE complies with the Children’s Online Privacy Protection Act (COPPA). Where required, OE relies on the school to provide consent on behalf of parents as permitted by law or obtains verifiable parental consent directly.

Parents seeking to review, correct, or delete education records should contact the educational institution directly when the Service is school-provided. OE will assist schools in responding to such requests as required by law.

OE does not condition a child’s participation on providing more information than reasonably necessary.

 

10. FERPA and School Use of the Service

When the Service is used by or on behalf of a school or educational institution:

• OE acts as a school official with a legitimate educational interest under FERPA,
• OE operates under the direct control of the educational institution,
• Schools retain ownership and control of Student Data,
• OE processes Student Data solely to and only for as long as necessary to provide, maintain, secure, and improve the Service for educational purposes,
• OE does not sell Student Data or use Student Data for advertising, marketing, or commercial profiling, 
• As further explained in Section 1.c., OE removes all direct and indirect student identifiers before transmitting any data to third-party AI models and OE does not permit third-party AI providers to retain, train on, or use student data for any purpose other than returning the requested output, and
• OE supports schools in complying with FERPA and the Protection of Pupil Rights Amendment (PPRA).

 

11. International Users

Information may be processed and stored in the United States and other jurisdictions. Where cross-border transfers occur, OE implements appropriate contractual, technical, and organizational safeguards consistent with applicable law.