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School Data Privacy Policy

Last updated: July 16, 2026
Provider: ZillyPlanet, Inc.
School / District / LEA: [Insert school, district, or local education agency name]
Agreement reference: This School Data Privacy Addendum is attached to and forms part of the agreement, pilot agreement, terms of service, purchase order, or other written agreement between ZillyPlanet, Inc. and the School / District / LEA.


1. Purpose


This School Data Privacy Addendum describes how ZillyPlanet protects student data when the ZillyPlanet learning platform is used by a school, district, teacher, tutor program, or other education organization.


ZillyPlanet provides digital learning services for students, including math learning missions, strategy exploration, mission briefing videos, AI-supported hints and explanations, progress tracking, parent or educator visibility, rewards, and related learning support features.


This Addendum is intended to support school and district use of ZillyPlanet and to help align ZillyPlanet’s practices with common student data privacy expectations, including FERPA, COPPA, PPRA, and applicable state student privacy laws.


2. Relationship to Other Policies


For school or district use, this Addendum controls ZillyPlanet’s handling of Student Data. If there is a conflict between this Addendum and ZillyPlanet’s public privacy policy, website terms, or other general terms, this Addendum controls for Student Data provided by or on behalf of the School / District / LEA.


This Addendum does not limit protections provided in ZillyPlanet’s public privacy policy. It adds school-specific protections for Student Data.


3. Definitions


Addendum means this School Data Privacy Addendum.


De-Identified Data means data that has been processed so it cannot reasonably identify a student, parent, guardian, teacher, school, district, or household.
Education Records means records protected under FERPA that are directly related to a student and maintained by the School / District / LEA or by ZillyPlanet on behalf of the School / District / LEA.


LEA means a local education agency, school, district, charter school, private school, homeschool organization, or other education organization using ZillyPlanet with students.
School User means an educator, administrator, school staff member, parent, guardian, student, or other user authorized by the LEA to access ZillyPlanet.


Services means the ZillyPlanet platform, applications, websites, educator pilot tools, student learning experience, parent or educator dashboards, ZillyTV learning content, AI learning support features, reporting tools, and related services provided by ZillyPlanet.


Student Data means personally identifiable information, education records, student work, student-generated content, account information, learning activity, progress data, performance data, and related information collected, generated, transmitted, stored, or processed by ZillyPlanet in connection with the Services on behalf of the LEA.


Subprocessor means a third-party service provider that processes Student Data on behalf of ZillyPlanet to provide the Services.


4. Student Data Ownership and Control


Student Data remains the property of, and under the control of, the LEA.
ZillyPlanet does not own Student Data. ZillyPlanet receives and processes Student Data only to provide the Services, support learning, maintain the platform, protect security, troubleshoot issues, provide customer support, generate authorized reports, and improve the educational functionality of the Services as allowed under this Addendum.
ZillyPlanet will follow the LEA’s reasonable written instructions related to Student Data, subject to applicable law and platform capabilities.


5. Authorized Use of Student Data


ZillyPlanet will use Student Data only for education-related purposes connected to the Services.


Permitted uses include:

  • Creating and managing student, educator, parent, guardian, or classroom accounts

  • Providing access to ZillyPlanet learning content

  • Supporting student progress through math worlds, mission briefings, Labs, personalized missions, hints, retries, explanations, and mastery tracking

  • Providing AI-supported learning guidance within the product

  • Showing progress information to authorized educators, parents, guardians, or school staff

  • Supporting educator pilots, classroom use, tutoring use, homeschool use, or school-approved learning programs

  • Maintaining, securing, troubleshooting, and improving the Services

  • Responding to support requests from authorized users

  • Generating aggregated or de-identified insights to improve ZillyPlanet learning features

  • Complying with applicable law or valid legal process

 

ZillyPlanet will not use Student Data for purposes unrelated to providing the Services without written authorization from the LEA or as required by law.


6. No Sale of Student Data


ZillyPlanet will not sell Student Data.
ZillyPlanet will not rent, trade, transfer, disclose, or otherwise make Student Data available to third parties for monetary or other valuable consideration.
This section does not prevent ZillyPlanet from using approved Subprocessors to provide the Services, responding to lawful requests, supporting a school-authorized user, or completing a business transfer where the successor agrees to protect Student Data under terms at least as protective as this Addendum.


7. No Targeted Advertising


ZillyPlanet will not use Student Data for targeted advertising.
ZillyPlanet will not use Student Data to create advertising profiles, behavioral profiles, or marketing profiles of students, parents, guardians, classrooms, or schools.
ZillyPlanet will not allow third-party advertising networks to collect Student Data through school accounts or student learning experiences.
ZillyPlanet may communicate with authorized account holders about service updates, product changes, safety notices, pilot activities, or education-related features, provided those communications are not based on targeted advertising using Student Data.


8. AI and Student Data


ZillyPlanet may use AI-supported features to provide hints, explanations, learning support, personalization, mission generation, or adaptive learning experiences.
ZillyPlanet will not use identifiable Student Data to train external foundation models or general-purpose AI models without express written authorization from the LEA.
ZillyPlanet will take reasonable steps to limit the sharing of personally identifiable Student Data with AI subprocessors. Where AI subprocessors are used, ZillyPlanet will require contractual protections designed to protect Student Data, restrict unauthorized use, and prohibit sale or targeted advertising.
AI-supported outputs are designed to assist learning and are not a replacement for educator judgment.


9. Data Collection


ZillyPlanet will collect only the Student Data reasonably needed to provide and support the Services.


Depending on implementation, ZillyPlanet may collect or process:

  • Student first name or display name

  • Student username or account identifier

  • Student grade level

  • Student year of birth or age range, if used for age-appropriate learning setup

  • School, class, group, or educator association

  • Parent or guardian account connection, where applicable

  • Educator account information

  • Learning activity and progress

  • Subject, world, concept, standard, and mission activity

  • Hints used, retries, explanations viewed, and challenge activity

  • Student responses and student-generated learning content

  • Reward progress and coin activity

  • Device, browser, IP address, log, cookie, session, and security metadata

  • Support communications related to the Services

 

ZillyPlanet will not intentionally collect sensitive student information that is not needed for the Services, such as Social Security numbers, government ID numbers, precise geolocation, medical records, biometric identifiers, or financial account details.


10. Parent, Guardian, and Student Access


The LEA is responsible for managing parent, guardian, and eligible student rights under FERPA and other applicable laws.
ZillyPlanet will reasonably assist the LEA in responding to authorized requests to access, review, correct, export, or delete Student Data held by ZillyPlanet.
If a parent, guardian, or student contacts ZillyPlanet directly about Student Data connected to a school account, ZillyPlanet may refer the request to the LEA or coordinate with the LEA before responding.


11. Student-Generated Content


Student-generated content created in ZillyPlanet as part of school use is treated as Student Data.
Student-generated content may include responses, explanations, written reasoning, mission answers, learning artifacts, or other student-created activity within the Services.
ZillyPlanet will process student-generated content only as allowed under this Addendum.


12. De-Identified and Aggregated Data


ZillyPlanet may use De-Identified Data or aggregated data to improve the Services, develop learning features, measure product effectiveness, support research, create internal analytics, improve AI-supported learning experiences, and demonstrate product impact.
ZillyPlanet will not attempt to re-identify De-Identified Data except as permitted by law and only for security, testing, or data validation purposes.
ZillyPlanet will not publicly identify the LEA, school, teacher, student, parent, guardian, or classroom in any case study, marketing material, report, or research output without prior written approval from the LEA or the appropriate authorized party.


13. Subprocessors


ZillyPlanet may use Subprocessors to provide hosting, infrastructure, authentication, analytics, AI support, email delivery, customer support, payment processing, security monitoring, or other services required to provide and operate ZillyPlanet.
ZillyPlanet will require Subprocessors that process Student Data to protect Student Data under written terms designed to be no less protective than ZillyPlanet’s obligations under this Addendum.
ZillyPlanet will not authorize Subprocessors to sell Student Data or use Student Data for targeted advertising.
ZillyPlanet will maintain a list of Subprocessors used for the Services and will provide the list to the LEA upon request.


14. Data Security


ZillyPlanet will maintain reasonable administrative, technical, and physical safeguards designed to protect Student Data from unauthorized access, acquisition, disclosure, destruction, loss, misuse, or alteration.


Safeguards may include:

  • Role-based access controls

  • Secure authentication practices

  • Encryption in transit

  • Encryption at rest where commercially reasonable

  • Access logging and monitoring

  • Least-privilege access practices

  • Employee confidentiality obligations

  • Security training for personnel with access to Student Data

  • Vendor and Subprocessor review

  • Backup and recovery procedures

  • Secure development practices

  • Vulnerability management

  • Incident response planning

 

ZillyPlanet will designate a security contact for LEAs and will provide security contact information upon request.


15. Security Review and Documentation


Upon reasonable written request from the LEA, ZillyPlanet will provide information about its security practices, subject to confidentiality, security, and operational limitations.
ZillyPlanet may provide summaries, security questionnaires, policy summaries, or other documentation rather than confidential internal security materials.
ZillyPlanet will review its security practices at least annually and after material security events.


16. Data Breach Notification


If ZillyPlanet confirms a Data Breach involving Student Data, ZillyPlanet will notify the LEA without unreasonable delay and, where feasible, within 72 hours after confirmation.


The notice will include available information such as:

  • Nature of the incident

  • Date or estimated date range

  • Types of Student Data involved

  • Number or categories of affected users, if known

  • Steps taken to contain or investigate the incident

  • Recommended actions, if any

  • ZillyPlanet contact information for follow-up

 

ZillyPlanet will reasonably cooperate with the LEA in investigating and responding to the Data Breach.


The LEA is responsible for determining and sending any required notifications to students, parents, guardians, regulators, or other parties unless otherwise required by applicable law or agreed in writing.


17. Data Retention


ZillyPlanet will retain Student Data only as long as needed to provide the Services, comply with legal obligations, support the LEA relationship, resolve disputes, maintain security, or fulfill authorized school, parent, or user requests.
ZillyPlanet will make retention practices available to the LEA upon request.


18. Data Deletion and Return


Upon written request from the LEA, ZillyPlanet will delete or return Student Data associated with the LEA within a commercially reasonable period, unless retention is required by law, security, backup, dispute resolution, or legitimate business obligations allowed under this Addendum.
After termination of the Services, ZillyPlanet will delete or de-identify Student Data within 60 days of the LEA’s written request, unless a different timeline is required by law or agreed in writing.
Backups may persist for a limited period under ZillyPlanet’s backup retention schedule, but Student Data in backups will remain protected and will not be used for active processing except recovery, security, or legal needs.


19. Data Location


ZillyPlanet will disclose to the LEA, upon request, whether Student Data is stored or processed outside the United States.
If Student Data is stored or processed outside the United States, ZillyPlanet will provide the LEA with the relevant country or countries upon request.


20. Legal Requests


If ZillyPlanet receives a subpoena, court order, warrant, government request, or other legal demand for Student Data, ZillyPlanet will notify the LEA before disclosure unless legally prohibited.
ZillyPlanet will disclose only the Student Data reasonably required to comply with valid legal process.


21. School Official Status


To the extent required under FERPA, ZillyPlanet may act as a school official with a legitimate educational interest in providing the Services to the LEA.
ZillyPlanet will remain under the LEA’s direction and control with respect to Student Data as described in this Addendum.


22. COPPA Support


Where the LEA uses ZillyPlanet with children under 13 in a school context, the LEA may provide consent on behalf of parents where permitted by COPPA and applicable guidance.
ZillyPlanet will use personal information collected from children under 13 in the school context only for educational purposes authorized by the LEA and not for commercial purposes unrelated to the Services.
For family accounts created outside a school relationship, ZillyPlanet may obtain parental consent directly as described in its family-facing privacy policy.


23. PPRA Support


ZillyPlanet will not use Student Data collected through school accounts for advertising or non-education marketing surveys.
If ZillyPlanet introduces surveys, questionnaires, or research activities involving students, ZillyPlanet will work with the LEA to identify whether PPRA or other notice and consent requirements apply.


24. Product Improvement


ZillyPlanet may use Student Data internally to maintain, support, secure, troubleshoot, and improve the Services, including learning features, accessibility, age-appropriate content, standards alignment, adaptive learning, hints, explanations, missions, reporting, and product reliability.
Product improvement use will remain tied to educational service delivery and will not include sale of Student Data, targeted advertising, or unrelated commercial profiling.


25. Rewards and Parent-Approved Motivation


ZillyPlanet may allow students to earn coins or progress indicators and may allow parents or guardians to select reward options.
Reward information will be used only to provide student motivation, parent visibility, and related learning features.
ZillyPlanet does not sell reward data or use reward data for targeted advertising.


26. Communications and Messaging


ZillyPlanet may send service-related communications to authorized account holders, including teachers, administrators, parents, or guardians.
Student-facing communication features, if offered, will be limited to education-related product experiences and will not include open public messaging.
ZillyPlanet will not allow public social networking features for students as part of school use unless expressly approved by the LEA in writing.


27. No Student Profiling for Non-Educational Purposes


ZillyPlanet will not create profiles of students, parents, guardians, classrooms, or schools for non-educational commercial purposes.
ZillyPlanet may create learning profiles, progress indicators, mastery states, recommended practice paths, and personalized mission contexts to provide the educational Services.


28. State-Specific Requirements


ZillyPlanet will work with the LEA to address applicable state student data privacy requirements.
If a state-specific privacy addendum is required, the parties may attach a state-specific exhibit, district-specific exhibit, or SDPC state alliance document.
Where a state-specific exhibit conflicts with this Addendum, the parties should identify the controlling terms in writing.


29. Substantive Product Changes


If ZillyPlanet materially changes the Services in a way that changes the categories of Student Data collected or the way Student Data is used, ZillyPlanet will provide notice to the LEA.
Examples may include launch of new subjects, new AI learning features, new reporting dashboards, new classroom tools, or new integrations that require new data elements.


30. Integrations


If the LEA requests an integration with a learning management system, student information system, rostering provider, single sign-on provider, or other school system, ZillyPlanet will process data from that integration only to provide the Services.
The LEA is responsible for authorizing integrations and controlling which data is shared through the integration.


31. Account Management


The LEA is responsible for authorizing user access, managing educator or administrator roles, approving student account creation where applicable, and removing access when a user no longer needs the Services.
ZillyPlanet will provide reasonable account management support to the LEA.


32. Confidentiality


ZillyPlanet personnel with access to Student Data will be required to protect Student Data and use it only for authorized service purposes.
ZillyPlanet will limit access to Student Data to personnel and Subprocessors with a legitimate need to access the data for the Services.


33. Service Providers and Business Transfers


If ZillyPlanet is involved in a merger, acquisition, financing, corporate reorganization, sale of assets, or similar business transfer, ZillyPlanet will require the successor entity to protect Student Data under terms no less protective than this Addendum or will provide the LEA with notice as required by applicable law or written agreement.


34. Pilot Programs


For educator pilots, this Addendum applies to Student Data collected or processed during the pilot unless a separate written agreement provides stronger protections.
Pilot data may be used to evaluate product fit, improve learning experience, identify bugs, refine standards alignment, develop educator reporting, and support student learning.
ZillyPlanet will not publicly name a school, district, educator, student, parent, or guardian from a pilot without written permission.


35. Service Availability and Support


ZillyPlanet will use commercially reasonable efforts to provide reliable access to the Services during school use.
ZillyPlanet may suspend access to protect security, prevent misuse, comply with law, respond to technical issues, or address unauthorized access.


36. Term and Termination


This Addendum remains in effect while ZillyPlanet retains Student Data connected to the LEA.
Either party may terminate use of the Services according to the applicable agreement.
Termination does not remove ZillyPlanet’s obligations to protect Student Data retained after termination.


37. Order of Precedence


For Student Data, this Addendum controls over inconsistent terms in ZillyPlanet’s public privacy policy, general website terms, marketing statements, purchase order terms, or other general documents.


If the parties sign an official SDPC National Data Privacy Agreement, state alliance agreement, district-specific DPA, or other negotiated school privacy agreement, that signed agreement controls where it conflicts with this Addendum.


38. Contact Information


ZillyPlanet privacy contact:
Name: Deanne Watt
Title: CPO
Email: deanne@zillyplanet.com
Address: 151 Crandon Blvd #928; Key Biscayne, FL 33149

​

ZillyPlanet security contact:
Name: Deanne Watt
Title: CPO
Email: deanne@zillyplanet.com
Address: 151 Crandon Blvd #928; Key Biscayne, FL 33149

 

LEA contact:
Name: [Insert name]
Title: [Insert title]
Email: [Insert email]
Address: [Insert address]


Exhibit A: Description of Services


ZillyPlanet provides a digital learning platform for grades 2-8 students.


Current Services include:

  • Math learning experience

  • Math worlds tied to concept areas such as Geometry, Fractions, Place Value, Multiplication, Division, Ratios, Statistics, and Equations

  • Character-led concept overviews

  • Mission briefing videos

  • Strategy Lab for visual exploration and step-by-step learning

  • Personalized mastery missions based on student interests

  • Hints, retries, and explanations

  • Challenge missions

  • Coins and parent-approved reward settings

  • Parent and educator dashboards

  • Standard-level progress visibility

  • Off-screen activity suggestions

  • ZillyTV learning content

  • AI-supported learning guidance

 

Planned Services may include science, technology, engineering, expanded ZillyTV content, additional reporting, integrations, and future learning pathways.


Exhibit B: Student Data Elements


ZillyPlanet may collect or process the following categories of Student Data, depending on implementation:

 

Account and Identity Data

  • Student first name or display name

  • Student username or account ID

  • Student app-assigned identifier

  • Parent or guardian account link, where applicable

  • Educator account link, where applicable

  • Class, group, or school association, where applicable

 

Learning Setup Data

  • Grade level

  • Subject selection

  • Math world selection

  • Learning level or placement data

  • Interest selections

  • Learning pace settings

 

Learning Activity Data

  • Missions started and completed

  • Concepts practiced

  • Standards practiced

  • Hints used

  • Retries

  • Explanations viewed

  • Answers selected or submitted

  • Student explanation responses, where applicable

  • Challenge mission activity

  • Time spent in learning activities

  • Progress and mastery indicators

 

Parent and Educator Visibility Data

  • Current mission

  • Skills practiced

  • Concepts mastered

  • Growth areas

  • Recommended next steps

  • Off-screen activity suggestions

  • Reward settings selected by parent or guardian, where applicable

 

Technical and Security Data

  • IP address

  • Device and browser information

  • Log data

  • Cookie or session identifiers

  • Authentication metadata

  • Error logs

  • Security event data

  • Application use statistics

 

Support Data

  • Support messages

  • Troubleshooting information

  • Account requests

  • Feedback submitted by authorized users

 

ZillyPlanet does not intentionally collect:

  • Social Security numbers

  • Government ID numbers

  • Precise geolocation

  • Student financial account information

  • Biometric identifiers

  • Medical records

  • Open public student messaging

  • Advertising profile data

 

Exhibit C: Subprocessors

​

ZillyPlanet will maintain a current Subprocessor list and provide it upon request.


Subprocessor categories may include:

  • Cloud hosting and infrastructure

  • Authentication and account management

  • Database and storage providers

  • AI infrastructure or AI model providers

  • Email delivery

  • Customer support

  • Analytics for product performance and reliability

  • Security monitoring

  • Payment processing for paid family accounts, where applicable

 

ZillyPlanet will require Subprocessors that process Student Data to protect Student Data under written terms designed to support ZillyPlanet’s obligations under this Addendum.


Exhibit D: Data Retention and Deletion


ZillyPlanet will retain Student Data only for the time needed to provide the Services and support the LEA relationship, subject to legal, security, backup, and operational needs.


Upon LEA written request, ZillyPlanet will delete or return Student Data within a commercially reasonable period.


Target deletion timeline after written request: 60 days.


Backup deletion may follow ZillyPlanet’s backup retention schedule. Backup data will remain protected during the retention period.

​

Exhibit E: Security Measures


ZillyPlanet’s security program may include:

  • Role-based access controls

  • Least-privilege access

  • Employee confidentiality obligations

  • Secure authentication

  • Encryption in transit

  • Encryption at rest where commercially reasonable

  • Access logs

  • Security monitoring

  • Backup and recovery processes

  • Vendor review

  • Incident response plan

  • Annual review of security practices

  • Data minimization practices

  • Secure development practices

 

Exhibit F: School Pilot Terms


For school pilots:

  • ZillyPlanet may provide pilot access at no cost or under separate pilot terms.

  • Pilot use may be limited by duration, number of teachers, number of students, subject access, or feature availability.

  • Pilot feedback may be used to improve the Services.

  • ZillyPlanet will not publicly identify the LEA, educator, student, parent, or guardian without written approval.

  • Pilot Student Data is protected under this Addendum.

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