Introduction
Transparent Donation Inc., doing business as BobbyBrowser ("BobbyBrowser," "we," "us," or "our"), provides an educational browser, dashboard, and related tools used by teachers and students in classroom settings (collectively, the "Service"). This Privacy Policy describes the information we collect when you use the Service, how we use and share it, and the choices available to you.
By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree, please discontinue use of the Service. This Privacy Policy is incorporated into our Terms of Service.
Information We Collect
We collect information in three main ways: information you provide to us, information we collect automatically when you use the Service, and information we receive from third parties.
Information you provide. When you create an account or use the Service, you may provide information such as your name, email address, role (teacher, student, administrator), school or classroom affiliation, password, and profile preferences. Teachers may also provide roster information for students in their class. Anyone may provide additional information when contacting support, responding to a survey, or otherwise communicating with us.
Content you submit. Some features of the Service work by processing content you submit, such as prompts you send to AI features, text you write while using the writing-feedback feature, files you upload, and messages you exchange in classroom tools. We refer to this as "Your Content."
Activity within the Service. While a student is using BobbyBrowser during a teacher-assigned session, we record activity that takes place inside the browser, including pages visited, time spent on those pages, and interactions with BobbyBrowser features. We do not record what happens in other applications on the device; if a student switches away from BobbyBrowser, we only note that the BobbyBrowser window lost focus and for how long.
Technical information. We automatically collect technical information about the device and connection used to access the Service, such as browser type and version, operating system, device identifiers, language preference, referring URLs, network address, and timestamps of activity. We use cookies and similar technologies to operate the Service, keep you signed in, and remember preferences.
Information from third parties. If you sign in through a third-party identity provider (such as a school single-sign-on provider), or if your school provides us with roster information, we receive information from those sources as authorized by the school or by you.
The table below lists the specific data elements we collect, where each comes from, why we collect it, how long we keep it, and who receives it. Where we do not collect something, we say so.
Data elements we collect| Data element | Source | Purpose | Retention | Who receives it |
|---|
| Student name | Provided by the teacher or school at roster setup, or by the student at sign-up | Identify the student to their teacher and in classwork | 12 months after contract end or deactivation | Teacher and school; Microsoft Azure; Clever |
| School email address | School single sign-on only. We do not ask students to type in an email address | Authenticate the student and link the account to the school | 12 months after contract end or deactivation | Teacher and school; Microsoft Azure; Google or Clever, depending on the sign-on method |
| Grade level | Provided by the teacher or school | Match assignments and AI responses to the student’s level | 12 months after contract end or deactivation | Teacher and school; Microsoft Azure |
| Age | Provided at account setup, or calculated from date of birth | Apply COPPA protections to students under 13 | 12 months after contract end or deactivation | Teacher and school; Microsoft Azure |
| Date of birth | Provided at account setup | Recalculate age automatically so COPPA protections start and stop at the right time | 12 months after contract end or deactivation | Microsoft Azure |
| Student ID | Not collected. We do not collect or store a state-assigned student identifier, or the student ID number a school prints on a badge or keeps in its student information system | Not applicable. We assign each account an internal identifier that has no meaning outside the Service | Not applicable | Not applicable |
| Single sign-on identifier | Issued by Clever, Microsoft, or the school’s learning management system when a school uses single sign-on. Not collected for schools that do not | Match the account to the school’s roster and keep sign-in working across sessions | 12 months after contract end or deactivation | Microsoft Azure; the sign-on provider the school uses |
| AI chat transcripts | Generated when a student uses AI or writing-feedback features | Produce AI responses and feedback, and show a teacher their student’s work | 12 months | Teacher and school; Microsoft Azure; Azure OpenAI; LangSmith |
| Uploaded files and written work | Submitted by the student | Provide writing feedback and let a teacher review the work | 12 months | Teacher and school; Microsoft Azure; Azure OpenAI |
| Activity within the Service | Recorded automatically during a teacher-assigned session | Show a teacher what their student worked on | 13 months | Teacher and school; Microsoft Azure |
| Mouse clicks | Recorded automatically during a teacher-assigned session: the position of the click, which button, and the page it happened on | Distinguish active work from an idle screen in the teacher’s activity view | 13 months | Teacher and school; Microsoft Azure |
| Keystrokes | Not collected. We do not record what a student types, key by key | Not applicable | Not applicable | Not applicable |
| Password | Set by the user. Stored only as a cryptographic hash, never in readable form | Authenticate the account | 12 months after contract end or deactivation | Microsoft Azure |
| Teacher name and email address | Provided by the teacher or school | Create and manage the teacher account and their classes | 12 months after contract end or deactivation | School; Microsoft Azure |
| Policy-builder contact details and document | Provided by an adult using the public School AI Policy Builder | Verify the email, save the requested document for the private Admin Dashboard, prevent abuse, and create a BobbyBrowser sales contact for follow-up | Until deletion is requested; one-time Admin activation links expire after 72 hours | BobbyBrowser staff and internal BobbyCRM; Microsoft Azure |
| Technical and device information | Collected automatically when the Service is used | Operate the Service, keep users signed in, and prevent abuse | 90 days in application logs | Microsoft Azure; Cloudflare; PostHog; Sentry; Vercel |
How We Use Information
We use the information we collect to:
• provide, operate, maintain, and improve the Service;
• create and manage accounts, authenticate users, and provide customer support;
• display student activity and progress to the teacher or school that has been granted access to the student’s session;
• generate AI-assisted responses, feedback, and suggestions through the Service;
• personalize the Service and remember preferences;
• communicate with account holders about the Service, including service announcements, security alerts, and administrative messages;
• deliver requested public tools and follow up about BobbyBrowser products or services when an adult submits business contact information through those tools;
• monitor, investigate, and prevent fraud, abuse, security incidents, and violations of our Terms of Service or applicable law; and
• comply with legal obligations and enforce our agreements.
We do not sell personal information. We do not use student personal information to serve advertising, and we do not build advertising profiles of students.
How We Share Information
Teachers and schools. A teacher who creates an assignment or class in the Service can see the activity and submissions of the students they have invited to that class. Schools and administrators that contract with us may have similar visibility into accounts created under their organization.
Service providers. We share information with a limited number of third-party sub-processors that perform services on our behalf. Each operates under a data processing agreement and is authorized to use information only as needed to provide services to us. Our current sub-processors are:
• Microsoft Azure: cloud hosting, database storage, and search infrastructure for the Service;
• Azure OpenAI: AI inference for prompts and content submitted to AI and writing features;
• LangSmith: tracing and diagnostics for our AI tutoring features. Traces contain the prompt and response text of an AI conversation. They are not tagged with a student’s name, email address, or account identifier;
• Clever: roster synchronization and single sign-on for schools that use it;
• Google: single sign-on authentication for users who sign in with a Google account, and delivery of transactional email such as account verification and password resets;
• Cloudflare: bot and abuse prevention on sign-in and password-reset forms;
• PostHog: product analytics describing how the Service is used;
• Sentry: error and crash monitoring; and
• Vercel: hosting and delivery of our web dashboard and website.
Changes to this list. We will give school administrators at least 30 days’ notice before a new sub-processor begins processing student personal information, and before an existing sub-processor begins processing student personal information for a new purpose. Notice goes to the administrator contact on file for the school. Schools with questions or objections can reach us at [email protected].
Legal and safety. We may disclose information if we believe in good faith that disclosure is necessary to comply with applicable law, regulation, legal process, or governmental request; to enforce our Terms of Service; to detect, prevent, or address fraud, security, or technical issues; or to protect the rights, property, or safety of BobbyBrowser, our users, or others.
Business transfers. If BobbyBrowser is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, information may be transferred as part of that transaction. We will provide notice before personal information becomes subject to a different privacy policy.
With your direction. We may share information with third parties when you or your school direct us to do so, for example by enabling an integration.
Cookies and Similar Technologies
We use cookies, local storage, and similar technologies to keep you signed in, remember your preferences, understand how the Service is used, and operate and improve the Service. You can control cookies through your browser settings; however, disabling cookies may affect the functionality of the Service.
Data Retention
We retain information for the periods described below, measured from the date the information is created unless stated otherwise.
• Account information: deleted 12 months after the school’s contract ends or the account is deactivated, whichever comes first;
• Activity and session data: 13 months, which covers a full school year and a grace period;
• AI chat transcripts: 12 months;
• Application and error logs: 90 days;
• Audit logs: 7 years. We maintain records of disclosures of education records for as long as we maintain the underlying record, consistent with FERPA § 99.32;
• Policy-builder submissions and Admin Dashboard policy drafts: until deletion is requested; one-time activation links expire after 72 hours; and
• Backups: 35 days.
We may retain limited information for longer periods when necessary to comply with legal obligations, resolve disputes, prevent abuse, or enforce our agreements. Aggregated or de-identified records that cannot reasonably be used to identify a student may be retained without a fixed time limit.
Account holders, parents, and schools may request deletion of their account or associated information by contacting us at [email protected]. We will action verified requests within 30 days, subject to the retention requirements above.
When a school’s agreement with us ends. The school may ask us to return or delete all student personal information we hold for that school. We will complete a verified request within 30 days of receiving it. If the school does not make a request, we delete student personal information on the schedule described above.
Security
We use commercially reasonable administrative, technical, and physical safeguards designed to protect the information we collect, including encryption of personal information in transit and at rest, access controls, and monitoring. Our security program is aligned to the NIST Cybersecurity Framework v1.1. No method of transmission or storage is perfectly secure, and we cannot guarantee absolute security. You are responsible for keeping your account credentials confidential.
For Schools: FERPA and COPPA
BobbyBrowser is designed to be used by schools and districts, and we structure our handling of student information to support their compliance obligations under the Family Educational Rights and Privacy Act (FERPA), the Children’s Online Privacy Protection Act (COPPA), and applicable state student-privacy laws.
FERPA. When a school uses BobbyBrowser, we act as a school official with a legitimate educational interest under FERPA, and we process student education records under the direction and control of the school. We use student information only to provide the Service to the school and not for any other commercial purpose.
COPPA. For students under 13, we rely on the school to provide consent on behalf of parents for the collection of student personal information in the educational context, as permitted under COPPA. Schools are responsible for determining what student information may be collected and for providing any direct parental notice or consent their own policies or applicable state law require. Some state student privacy laws require direct parental consent and apply to students of all ages, not only to students under 13. See State Student Privacy Laws below.
Our commitments. We do not sell student personal information. We do not serve advertising to students or use student information to build advertising or behavioral profiles outside of authorized educational purposes. We do not use student personal information to train artificial intelligence or machine learning models.
Data ownership and access. The school owns its student data. Schools, teachers, and parents may request to review, correct, export, or delete student information at any time through the admin console or by contacting us at [email protected], and we honor verified requests subject to the retention obligations described above.
Security incidents. If we become aware of a confirmed security breach that compromises student personal information, we will notify the affected school without undue delay, and in any event within 72 hours of confirmation, so that the school can meet its own notification obligations.
State Student Privacy Laws
In addition to FERPA and COPPA, we support our school customers in meeting their obligations under the student privacy laws of the states where they operate. Several of those laws apply to students of all ages rather than only to students under 13, and several impose requirements that go beyond federal law.
Louisiana. Louisiana law places strict limits on the collection and sharing of personally identifiable student information, applies to students of all ages, and provides for penalties for unlawful disclosure. For schools in Louisiana, we commit to the following:
• We do not collect or store student Social Security numbers. Our systems redact Social Security numbers automatically if one appears in submitted content;
• We do not collect or store a state-assigned student identifier. Each account receives an internal identifier that has no meaning outside the Service. Where a school signs in through Clever, Microsoft, or a learning management system, we store the account identifier that provider issues, solely so that accounts match the school’s roster;
• We do not sell student personal information, use it for targeted advertising, or use it to train artificial intelligence or machine learning models;
• Parents may review, correct, export, or request deletion of their child’s information by contacting the school or by contacting us at [email protected]; and
• Where state law requires parental consent before student personal information is shared with us or with the sub-processors named above, the school or governing authority is responsible for obtaining that consent. We will supply what a school needs in order to obtain it, including the list of sub-processors and the data elements each one receives.
We enter into a data processing agreement with each school that sets out these obligations. Schools outside Louisiana can contact us at [email protected] to confirm how we support the requirements that apply in their state.
Children
The Service is designed for use in schools, and student accounts are typically created under the direction of a teacher or school. Where applicable law requires parental consent before a child uses an online service, schools and parents are responsible for obtaining and maintaining that consent. We rely on schools to determine and communicate to us what information may be collected from students.
Parents who have questions about the information we collect about their child can contact us at the address below or contact the student’s school, which has primary control over the student’s use of the Service.
Your Choices and Rights
You can review and update most account information from inside the Service. You may also contact us at [email protected] to request access to, correction of, or deletion of personal information we hold about you. We will respond to verified requests as required by applicable law. Some requests may be subject to verification and to retention requirements described above.
You may opt out of non-essential communications by following the unsubscribe instructions in those messages. We may still send you administrative communications related to your account or the Service.
Third-Party Links and Services
The Service may link to or interoperate with third-party websites, applications, and services that we do not control, including sites students visit while using the browser. This Privacy Policy does not apply to those third parties, and we are not responsible for their information practices. We encourage you to review the privacy policies of any third-party service you use.
Google User Data
Teachers and school administrators can connect a Google account to BobbyBrowser. We request only the access the connected features need: Google Classroom scopes to import a course roster and its coursework and to return grades, and read-only Google Drive access so a school administrator can designate a single Drive folder as the school’s digital library for Bobby to read.
We use student email addresses from Google Classroom for one purpose: matching a Google Classroom student to the BobbyBrowser account the school has already created for them. Files read from a designated library folder are used to answer student questions about the materials their teacher assigned. We do not sell Google user data, use it for advertising, or use it to train AI models.
A teacher or administrator can disconnect Google at any time from the dashboard, which deletes the credentials we hold. Access can also be withdrawn directly from your Google Account permissions page.
BobbyBrowser’s use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.
International Users
BobbyBrowser is operated from the United States. If you access the Service from outside the United States, you understand that your information may be transferred to, stored in, and processed in the United States, where data protection laws may be different from those in your country.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last Updated" date above and, where appropriate, provide additional notice (for example, by email to account administrators or in-product notice). Your continued use of the Service after a change takes effect means you accept the updated Privacy Policy.
Contact Us
If you have questions about this Privacy Policy or our handling of your information, please contact us at [email protected].