FTC COPPA 16 CFR Part 312FERPA 34 CFR Part 99SDPC Model DPA Standards

Children's Privacy (COPPA) & Education Records (FERPA) Center

Cognitino is engineered from the architecture up to safeguard young learners. This portal establishes our statutory commitments, direct parental notices, institutional school official agreements, and verifiable consent mechanisms under federal student privacy laws.

Parent Consent Portal

Review and grant verifiable consent for your child under 13 with granular AI scaffolding toggles.

Open Consent Portal
Parent Data Rights

Download complete JSON learning archives or request hard cascade erasure under COPPA § 312.6.

Manage in Dashboard
Institutional DPA

Review our standard Student Data Privacy Agreement aligned with SDPC and FERPA School Official rules.

Request Custom DPA

1. Direct Notice to Parents & Legal Guardians (16 CFR § 312.4)

The Children's Online Privacy Protection Act requires online services to provide direct notice to parents regarding the collection, use, and disclosure of personal information from children under 13.

1.1 Categories of Personal Information Collected

We practice strict data minimization. We collect only what is strictly required to deliver adaptive educational instruction:

  • Student Name & Date of Birth: Used solely for account identification, age-gating, and developmental curriculum band placement.
  • Learning Interaction Records: Answers to questions, scoring accuracy, timestamped response latencies, and prerequisite completion states.
  • Presentation Preferences: Learner skin choices (e.g. Space, Fantasy, Nature realms) and vocabulary reading level configurations.
Strict Exclusion: Cognitino strictly prohibits the collection or storage of biometric data, facial recognition scans, audio recordings of children, real-time GPS geolocation, racial or ethnic origin, religious beliefs, or payment card data from minors.

1.2 Zero Advertising & Commercial Exploitation Policy

Cognitino is fundamentally an educational space. We maintain an uncompromising policy regarding student data commercialization:

  • We never sell, rent, or lease student personal information to third parties under any circumstances.
  • We never display behavioral or targeted advertisements to students.
  • We never build marketing profiles or track students across external applications or websites.

2. Five-Layer Architecture & Non-Authoritative AI Boundary

In compliance with educational governance guidelines, Generative AI (LLMs) is strictly partitioned from authoritative decision engines:

Layers 1–4: Deterministic Core (Authoritative)

All item scoring, mastery calculations (M = decay × weighted accuracy), prerequisite gating, and track readiness classifications are 100% deterministic, mathematically verifiable, and run without AI.

Layer 5: AI Assist (Non-Authoritative)

Generative AI operates exclusively as an assistive scaffolding tutor providing hints and conceptual explanations. Prompts are completely anonymized before submission to LLM providers. Parents may toggle AI assistance off at any time.

3. Parental Rights to Inspect, Export, and Delete (16 CFR § 312.6)

Federal law grants parents continuous, unencumbered rights to oversee and control their child's educational footprint:

Right to Review (COPPA § 312.6(a)(1)):Parents can review every question attempt, response latency, accuracy score, and reflection entry submitted by their child through the Parent Dashboard.
Right to Machine-Readable Portability (GDPR Art. 20 / COPPA § 312.6):Parents can trigger an automated export generating a structured, complete JSON archive containing all student profile records, capabilities, mastery histories, and journal entries.
Right to Refuse & Delete (COPPA § 312.6(a)(2)):Parents can revoke consent at any time to freeze account activity, or initiate permanent hard cascade erasure wipping all personal records from the primary database and audit caches.

4. Institutional FERPA Compliance Framework (34 CFR Part 99)

When deployed across K-12 public, charter, or private school environments, Cognitino adheres to the Family Educational Rights and Privacy Act and federal student privacy regulations:

4.1 The School Official Exception (34 CFR § 99.31(a)(1)(i))

Cognitino qualifies and acts as an authorized "School Official" with legitimate educational interests:

  • Institutional Service: We perform an institutional adaptive learning and formative assessment function for which the school would otherwise employ its own staff.
  • Direct Control: Cognitino operates under the direct administrative control and supervision of the school or district with respect to the use, maintenance, and destruction of education records.
  • Prohibited Redisclosure: Student education records are accessed exclusively for the designated educational purpose and are never redisclosed without prior written school or parental consent.

4.2 Student Data Privacy Consortium (SDPC) Alignment

We execute standard Student Data Privacy Agreements (National Data Privacy Agreement / NDPA Version 2.0 or state-specific equivalents) committing to:

  • Data minimization, breach notification within 72 hours, and annual third-party security audits.
  • Zero algorithmic bias or discriminatory profiling based on protected student attributes.
  • Immediate data return and certified shredding upon termination of the institutional service contract.

Questions or Data Privacy Requests?

Our Data Protection Office is dedicated to transparent student data stewardship. Contact us directly for parental consent assistance, school DPA requests, or compliance inquiries.

Email Data Protection OfficerView Main Privacy Policy