Privacy Policy

1. Introduction

Locke-N-Roll, LLC ("we," "our," or "us"), operating as SnapIQ™, is committed to protecting the privacy of educators, administrators, and students whose data is handled through our platform. This Privacy Policy explains how we collect, use, and safeguard information when you use SnapIQ™.

2. Information We Collect

• Account Information: Name, email address, and role (e.g., teacher, admin, parent) collected at sign-in.
• Student Data: Behavioral goal scores, compliance records, kudo points, anecdotal notes, and work samples entered by authorized educators.
• Usage Data: Pages visited, features used, and general interaction patterns to improve the platform's user experience.
• Uploaded Files: Work sample images or PDFs you upload are stored securely and associated with the relevant student record.

3. How We Use Your Information

• To provide, operate, and maintain the SnapIQ™ platform.
• To generate behavior and progress reports for students.
• To send reports and communications to parents or teachers as directed by educators.
• To process data for the sole educational purpose of generating requested AI reports (see Section 6).
• To comply with applicable laws and protect the rights of users.

4. FERPA Compliance and "School Official" Designation

SnapIQ™ is fully committed to protecting student privacy and supporting our educators' compliance with the Family Educational Rights and Privacy Act (FERPA). When providing services to educators or schools, SnapIQ™ operates under the "School Official" exception of FERPA (34 CFR § 99.31(a)(1)).

Under this exception, SnapIQ™ performs an institutional service (academic tracking and behavior report generation) strictly under the direct control of the authorizing educator regarding the use and maintenance of education records. We use provided data exclusively for the authorized educational purpose. We do not sell, rent, or share student data with third parties, nor do we use it for advertising purposes.

5. Google OAuth

We use Google OAuth for authentication. When you sign in with Google, we receive your name and email address. We do not access your Google Drive, Gmail, or any other Google services beyond basic profile information needed for authentication.

6. AI Processing and Zero-Training Policy

We understand the necessity of trust regarding AI in the classroom. SnapIQ™ utilizes a secure, closed-loop architectural model for AI features:

• No Model Training by SnapIQ: SnapIQ™ does not use your inputs, behavioral notes, work sample images, or generated reports to train, retrain, or fine-tune any AI model we operate. We do not build or maintain models trained on user data.
• Provider API Terms: SnapIQ's AI features are powered through commercial API access to third-party foundational model providers (such as OpenAI, Google, and Anthropic). These providers' published API terms state that data submitted through their APIs is not used to train their models. SnapIQ relies on these stated terms and does not independently control or audit the internal data-handling practices of these third-party providers.
• Data Pseudonymization: We strictly instruct users to omit Personally Identifiable Information (PII) from student profiles. Students should only be identified using initials and arbitrary ID numbers.
• Purpose-Limited Processing: When you submit a work sample or behavior log, AI processes the data solely to generate your requested output (e.g., an IEP summary). SnapIQ does not retain the submitted prompt data for training or model-improvement purposes.

7. Data Security

We implement industry-standard security measures to protect your data, including encrypted data transmission (HTTPS) and access controls. Only authorized users can access student records based on role-based permissions.

8. Data Retention

We retain your data for as long as your account is active or as needed to provide services. You may request the deletion of your account and associated data at any time by contacting us.

9. Contact Us

If you have questions about this Privacy Policy, please contact us at: holler@locke-n-roll.com