“Student Education Records”
Information directly related to a student and maintained by SEL DEVELO on behalf of the School, consistent with FERPA.

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“Personal Information”
Any information that identifies or can reasonably be linked to an individual student, parent, or educator.

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“School Official”
A School-authorized individual or entity performing an institutional service or function, consistent with FERPA’s School Official exception.

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“Processing”
Any operation performed on data (e.g., collecting, storing, transmitting, analyzing, or deleting).

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“Subprocessor”
A third-party vendor engaged by SEL DEVELO to support the Services, operating under written contractual obligations aligned with this DPA.

SEL DEVELO processes Student Education Records solely to provide, maintain, secure, and improve the Services on behalf of the School. We do not use Student Education Records for:

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• advertising

• targeted or behavioral profiling

• marketing

• selling or monetizing data

• training non-educational AI models

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All processing is limited to the purposes authorized by the School.

SEL DEVELO acts as a School Official with a legitimate educational interest under FERPA. We comply fully with:

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• FERPA

• COPPA

• state student privacy laws (e.g., SOPPA, CSDPA, NY Ed Law 2-d, etc.)

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When children under 13 use the Services under School direction, COPPA consent is obtained from the School on behalf of parents.

The School is responsible for:

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• obtaining all necessary consents (including parental consent when required)

• ensuring student information provided to SEL DEVELO is accurate

• determining the appropriate access rights for staff and students

• complying with its own legal obligations as the data controller

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SEL DEVELO processes data only as instructed by the School.

SEL DEVELO will:

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• process data only for authorized educational purposes

• follow School instructions regarding data access, deletion, or correction

• maintain industry-standard security and encryption

• restrict access to authorized personnel with confidentiality obligations

• notify the School of any breach or unauthorized disclosure

• maintain a list of subprocessors used to support the Services

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SEL DEVELO will not change processing purposes without School authorization.

SEL DEVELO maintains administrative, technical, and physical safeguards that meet or exceed FERPA and industry standards. These include:

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Data Encryption

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• Encryption in transit (TLS 1.2+)

• Encryption at rest (AES-256 or equivalent)

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Access Controls

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• role-based access

• multi-factor authentication for internal systems

• least-privilege principles

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Monitoring & Logging

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• audit logs for access, changes, and administrative operations

• continuous monitoring for anomalous activity

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Data Segmentation

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• logical separation of customer data

• strict sandboxing of student-generated content

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Full details are available in the Security & Data Protection page.

SEL DEVELO may use trusted subprocessors to support hosting, security, analytics, AI scoring, and platform operations.

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All subprocessors:

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• are bound by written agreements

• follow strict confidentiality and security obligations

• may not use data for their own purposes

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A current list is maintained at: seldevelo.com/subprocessors

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SEL DEVELO will notify Schools of material changes when required.

At the School’s request, SEL DEVELO will:

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• provide access to Student Education Records

• correct inaccurate information

• delete records in accordance with School instructions

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Requests may be submitted to: privacy@seldevelo.com

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Deletion will occur within a reasonable timeframe consistent with School policy and legal requirements.

SEL DEVELO retains Student Education Records only for as long as the School account is active or as directed by the School.

Upon termination or written request:

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• data is deleted or returned to the School

• backups are purged within their standard lifecycle

• residual data in system logs is deleted on a rolling basis

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SEL DEVELO does not retain Student Education Records after account termination except as required by law.

In the event of unauthorized access, disclosure, or breach involving Student Education Records, SEL DEVELO will:

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1. Notify the School without unreasonable delay

2. Provide known details of the incident

3. Cooperate fully in investigation and remediation

4. Follow applicable state and federal breach-notification requirements

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SEL DEVELO will not notify students or families directly unless instructed by the School.

SEL DEVELO will not:

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• sell Student Education Records

• use data for targeted advertising

• build profiles unrelated to educational purposes

• use data to train generalized commercial AI models

• supplement student data with third-party marketing databases

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All data use is limited to educational function.

SEL DEVELO may use privacy-preserving AI tools (e.g., U.S. Data Zone models) solely to generate educational insights, such as:

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• reflection depth scoring

• SEL growth indicators

• learning progress analysis

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AI systems:

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• operate under strict School Official roles

• never use personal data to train commercial models

• do not retain input after processing

• apply differential privacy or de-identification where possible

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Details are provided in the AI Decisions & Scoring Statement.

All student data is stored and processed within the United States unless the School explicitly authorizes otherwise. We use U.S. regional hosting and U.S. Data Zone AI models for compliance.

This DPA remains in effect as long as SEL DEVELO processes data on behalf of the School.

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Upon termination of the Services:

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• SEL DEVELO will delete or return all Student Education Records as instructed

• School may request written confirmation of deletion

• surviving confidentiality and security commitments remain in place

If you have questions about this DPA or student privacy, you may contact us at:

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By email:

privacy@seldevelo.com

By mail:

SEL DEVELO, Inc.
Attn: Privacy Officer
1449 S Michigan Ave STE 13194
Chicago, IL 60605

United States of America

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Last revised on Nov 29, 2025