StarCoach AI
Privacy Policy
Effective Date: April 19, 2026
StarCoach AI, Inc. (“StarCoach AI,” “we,” “us,” or “our”) develops and operates an AI-powered instructional platform designed to support teachers and school staff (“Educators”) in planning, assessing, differentiating, and reflecting on instruction (the “Service”).
This Privacy Policy describes how we collect, use, and share personal information.
This Privacy Policy applies to personal information we collect directly from Educators, administrators, and website visitors. Student Data processed on behalf of schools or school districts (“Institutions”) is primarily governed by our Data Privacy Agreement (“DPA”) with those Institutions, applicable law, and the written instructions of the Institution. This Privacy Policy also describes our Student Data practices for transparency, so that schools, parents, and students understand how we protect student information. When we process Student Data, we act as a service provider (“school official” under FERPA) under the direction of the Institution.
1. Our Commitments Regarding Student Data
When we process Student Data on behalf of an Institution, we follow strict protections:
- All Student Data remains under the ownership and control of the Institution.
- We do not sell Student Data
- We do not use Student Data for advertising or marketing
- We do not build profiles of students
- We do not use Student Data to train, fine-tune, or improve general-purpose AI models
- We contractually prohibit our AI providers from using Student Data for model training
- We collect only the minimum data necessary to provide the Service
- We process Student Data solely for educational purposes as directed by the Institution
We will notify Institutions of any confirmed data breach involving Student Data without undue delay and in accordance with applicable law.
2. FERPA (Family Educational Rights and Privacy Act)
StarCoach AI acts as a “school official” with a “legitimate educational interest” when processing Student Data on behalf of an Institution.
We:
- Use Student Data only to provide the Service
- Do not re-disclose Student Data without authorization (except as required by law)
- Support Institutions in responding to access and correction requests
- We act as a service provider (or processor) and process Student Data solely on behalf of and under the direction of the Institution.
Parents and students should contact their school or district to exercise FERPA rights.
3. COPPA (Children’s Online Privacy Protection Act)
Our Service is designed for Educators, but students under 13 may use it through their school.
We rely on Institutions to provide consent to the extent required under applicable law.
We:
- Collect only necessary information (e.g., student identifiers, usage data)
- Do not collect sensitive data unless required for an educational purpose
- Do not use student data for commercial purposes
Parents may contact their school or email us at privacy@starcoach.ai for questions.
4. State Student Data Privacy Laws
We comply with applicable U.S. state student data privacy laws, including laws in California, New York, Texas, Colorado, Connecticut, Virginia, and others.
Where required, we enter into state-specific Data Privacy Agreements with Institutions.
5. Personal Information We Collect (Non-Student Data)
Information You Provide
- Educators and administrators provide name, professional email address, job title, and school or district affiliation.
- StarCoach AI does not require students to provide personally identifiable information such as email addresses, phone numbers, or external account credentials. Teachers create a class roster by entering each student’s first name and last initial only. Students access the Service by selecting their name from the roster and entering a teacher-assigned PIN. No student account registration, email address, or additional identifying information is required.
- Account and profile information
- Communications and feedback
- User-generated content (lesson inputs, prompts)
Note on Incidental Student References: Educator inputs such as lesson prompts or instructional queries may occasionally contain information that identifies or relates to a specific student. To the extent such inputs constitute Student Data, they are treated as Student Data and primarily governed by our Data Privacy Agreement with the Institution, consistent with Sections 1–4 of this Privacy Policy. Such data is subject to the same protections described in this Privacy Policy and our DPA.
Information Collected Automatically
- Device and browser information
- Usage data (pages, features used)
- Log and interaction data
We do not collect sensitive personal information unless necessary.
6. Cookies and Tracking Technologies
We use:
- Necessary cookies (for login and functionality)
- Performance cookies (analytics)
- Functional cookies (preferences)
We do not use advertising cookies within the Service.
7. Advertising Policy
StarCoach AI does not:
- Display ads in the Service
- Use tracking for targeted advertising
- Sell data to advertisers
- Build advertising profiles
We are subscription-based, not ad-supported.
8. How We Use Personal Information
We use Educator and administrator data to:
- Provide and operate the Service
- Personalize user experience
- Improve product functionality
- Communicate updates
- Comply with legal obligations
9. Use of AI Services
We use third-party AI providers (such as OpenAI and Anthropic) to generate content.
We ensure:
- Data is transmitted securely
- Providers are contractually prohibited from training on our data
- Data is retained only temporarily for security purposes
We do not use personal information or Student Data to train AI models.
10. How We Share Information
We may share information with:
- Service providers (hosting, analytics, support)
- AI providers (for processing inputs)
- Payment processors
- Legal authorities (when required by law)
- Business successors (with safeguards)
- We do not share personal information with third parties for advertising or unrelated purposes. Users cannot opt out of essential service providers required to operate the Service.
We do not sell personal information.
Subprocessors
We currently use:
- Google Cloud Platform (hosting and infrastructure)
- OpenAI (AI inference services)
- Anthropic (AI inference services)
All subprocessors are contractually required to protect data.
11. Data Retention
We retain data only as long as necessary to:
- Provide the Service
- Meet legal obligations
- Fulfill contracts with Institutions
Student Data is deleted or returned upon request or contract termination.
12. Your Rights and Choices
You may:
- Access and update your account
- Opt out of marketing emails
- Request account deletion
- Request data export
Parents and students should contact their Institution for Student Data requests.
13. U.S. State Privacy Rights
Depending on your state, you may have rights to:
- Access, correct, or delete your data
- Request data portability
We do not sell data or engage in targeted advertising.
California Residents: If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including the right to know what personal information we collect, the right to delete personal information, and the right to opt out of the sale or sharing of personal information (we do not sell or share personal information). To exercise these rights with respect to your own Educator account data, contact us at privacy@starcoach.ai. For rights related to Student Data processed on behalf of an Institution, please contact your school or district directly.
14. Security
We maintain commercially reasonable safeguards, including:
- Encryption in transit (TLS 1.2+)
- Encryption at rest (industry standard)
- Role-based access controls
- Access monitoring and logging
- Secure data storage in the United States
No system is completely secure, but we take appropriate steps to protect data.
15. Third-Party Links
We may link to third-party services. We are not responsible for their privacy practices.
16. Changes to This Policy
We may update this Privacy Policy from time to time. We will provide notice of material changes.
17. Contact Us
StarCoach AI, Inc.
28 Geary Street
Suite 650 #PMB
San Francisco, CA 94108
Email: privacy@starcoach.ai
Website: https://starcoach.ai
We are committed to protecting student and educator data and working transparently with schools and districts.
