FERPA Notice — US School Use
1. Roles
Where a school enters into an agreement with us, the school generally remains the owner or controller of “education records” under the Family Educational Rights and Privacy Act (FERPA, 20 U.S.C. § 1232g). We act as a school official / service provider with a legitimate educational interest, performing services the school would otherwise perform itself, under the school’s direction and control. The school is responsible for its own notices, consents and parental-access procedures.
2. Data involved
Seat names and levels entered by the school or teacher, saved words, reading progress and account status are processed only to deliver the reading service and support the school. We do not use student data for advertising, profiling for marketing, or sale, and we do not disclose it to data brokers.
3. Disclosures
Student data is shared only with the sub-processors needed to run the service (hosting, email delivery, content delivery/security and, for billing, our Merchant of Record — which receives the school’s billing contact, not student records), under contractual confidentiality obligations, or where the law requires it. A Data Processing Agreement and a current sub-processor list are available on request.
4. Access, correction and deletion
Parents and eligible students should direct inspection or amendment requests to the school under its FERPA policy. We will assist the school promptly. On the school’s written instruction, or when the service relationship ends, we delete or return student records within 30 days, except where a law requires limited retention (for example billing records held by the Merchant of Record).
5. Security
Access is protected by TLS, account controls, optional two-factor authentication, rate-limiting and audit logging. We will notify the school without undue delay of a confirmed breach affecting student records and cooperate with its notification obligations.
6. Contact
School data-handling requests: [email protected] · Contact & Imprint.
MandarinMiles is operated by David Chen, an individual based in mainland China.