FERPA Policy

Sara Technology, Inc.
Last Updated: December 15, 2025

IMPORTANT NOTICE REGARDING ACCEPTANCE

By creating an account, accessing, or using the Sara Technology platform in an educational or institutional capacity, you acknowledge that you have read, understood, and agree to be legally bound by this FERPA Student Data Privacy Notice and the Sara Terms of Service. If you do not agree, you may not create an account or use the platform.

1. Scope

This Student Data Privacy Notice ("Notice") applies when Sara Technology, Inc. ("Sara," "we," "us") is used by schools, school districts, educators, or educational institutions and processes student education records subject to the Family Educational Rights and Privacy Act ("FERPA"), 20 U.S.C. §1232g, and its implementing regulations.

This Notice applies only to institutional or professional use of the Sara platform in an educational context and does not apply to direct-to-consumer family accounts, which are governed by Sara's Privacy Policy and COPPA consent documentation.

2. Our Role Under FERPA

When used in an educational setting, Sara acts as a "School Official" with a "Legitimate Educational Interest" as defined under FERPA, performing institutional services or functions for which the educational institution would otherwise use its own employees.

Sara operates under the direct control of the educational institution with respect to the use, maintenance, and disclosure of student education records and uses such data solely for authorized educational purposes.

Sara does not independently determine educational outcomes, grading, placement, or eligibility decisions.

3. Representations by Educational Institutions and Educators

By creating an account or using Sara in an educational or institutional capacity, you represent, warrant, and agree that:

You are an authorized representative of an educational institution or acting under its authority
You have the legal right to disclose student education records to Sara
You will use the platform only for legitimate educational purposes
You will comply with FERPA and all applicable state student privacy laws
You will not request or permit Sara to use student data in a manner inconsistent with FERPA

Sara relies on these representations in providing services.

4. Student Data We May Process

On behalf of an educational institution, Sara may receive, store, process, or transmit student education records, including but not limited to:

Student first name, initials, or unique identifier
Grade level or educational classification
Speech articulation performance, therapy goals, and progress metrics
Audio recordings of speech practice activities
Platform usage, interaction, and engagement data
Metadata associated with educational activities

Sara does not require Social Security numbers, full birthdates, or financial account information to provide services.

5. Permitted Uses of Student Data

Student data is used solely and exclusively for the following purposes:

Delivering personalized speech practice and educational feedback
Providing progress reporting to authorized educators and, where permitted, parents or guardians
Supporting instructional planning and student monitoring
Improving the educational effectiveness, accessibility, and reliability of the platform
Maintaining platform security, integrity, and functionality

Sara does not use student data for targeted advertising, behavioral advertising, or non-educational profiling, and does not sell or rent student information.

6. Disclosure of Student Data

Student data may be disclosed only under the following circumstances:

To authorized educators, administrators, or school personnel with legitimate educational interests
To parents or guardians, as directed or permitted by the educational institution
To service providers or subcontractors performing services on Sara's behalf, provided they are bound by written confidentiality and data protection obligations
To government authorities, courts, or regulators when required by law or valid legal process

Sara does not disclose student data to third parties for independent commercial use.

7. Data Retention and Deletion

Student data is retained only for as long as reasonably necessary to provide services, fulfill contractual obligations, or comply with applicable law.

Upon written request from an educational institution or upon termination of services, Sara will, to the extent feasible and lawful, return or delete student data, subject to backup retention, audit requirements, or legal obligations.

8. Parent and Student Rights

All rights afforded under FERPA, including rights of access, amendment, consent, and disclosure restrictions, are exercised through the educational institution, not directly with Sara.

Sara supports educational institutions in responding to valid FERPA requests and inquiries as required by law.

9. Security Measures

Sara maintains reasonable and appropriate administrative, technical, and physical safeguards designed to protect student data, including but not limited to:

Encryption of data in transit and at rest
Role-based access controls and authentication mechanisms
Secure cloud infrastructure and monitoring
Incident detection and response procedures

While Sara takes data protection seriously, no system can be guaranteed to be completely secure.

10. Compliance with Other Laws

This Notice is intended to supplement, and not replace, obligations under other applicable privacy laws, including COPPA, state student data privacy statutes, and contractual obligations with educational institutions.

In the event of a conflict, the educational institution's FERPA obligations control.

11. Contact Information

Sara Technology, Inc.
Email: support@saraspeech.com

By creating an account or using the platform, you acknowledge and agree to the HIPAA Notice of Privacy Practices, Business Associate Agreement, FERPA Student Data Privacy Notice, Privacy Policy, and applicable Terms of Service.