1. Introduction
My Progress Bridge, Inc. (“My Progress Bridge,” “we,” “us,” or “our”) is a New York corporation. We provide the My Progress Bridge platform, a K-12 analytics service licensed to school districts and other local educational agencies (each, an “LEA” or “Customer”) to support student progress, early intervention, and educational decision-making (the “Service”).
This Privacy Policy describes how we collect, use, disclose, and protect information in connection with our website at www.myprogressbridge.com and any subdomains (the “Site”) and the Service. It applies to (a) visitors to the Site, (b) authorized personnel of LEA Customers who use the Service, and (c) personally identifiable information from education records (“Student Data”) that LEAs upload to or transmit through the Service.
2. Our Role and Authority
2.1 My Progress Bridge as a School Official
When My Progress Bridge processes Student Data on behalf of an LEA, we do so as a “school official” with a “legitimate educational interest” under the Family Educational Rights and Privacy Act (“FERPA”), 20 U.S.C. § 1232g and 34 C.F.R. Part 99, and as a contractor that the LEA would otherwise use its own employees to perform. We are subject to the LEA’s direct control with respect to the use and maintenance of Student Data and are bound by the confidentiality and use limitations of FERPA.
2.2 New York Education Law § 2-d
When we provide the Service to New York LEAs, we act as a “third-party contractor” as defined in New York Education Law § 2-d and 8 NYCRR Part 121. We comply with the Parents’ Bill of Rights for Data Privacy and Security adopted by each New York LEA we serve and execute a Data Sharing and Confidentiality Agreement (“DSCA”) and supplemental information addendum where required.
2.3 LEA Customer Responsibilities
LEAs are responsible for obtaining and maintaining all consents, notices, and authorizations required under applicable law for the disclosure of Student Data to My Progress Bridge, including those required under FERPA, COPPA, the Protection of Pupil Rights Amendment, and applicable state laws.
3. Information We Collect
3.1 Information From Site Visitors
- Contact information you submit through forms (name, work email, job title, district name, message contents).
- Device and usage data such as IP address, browser type, OS, referring URL, pages viewed, and timestamps.
- Marketing data such as engagement with our communications, event registrations, and demonstration requests.
3.2 Information From Authorized Users
When an LEA authorizes a user (administrator, principal, teacher, counselor) to access the Service, we collect account information including name, work email, role, school or district affiliation, authentication identifiers, and audit-log data describing actions taken in the Service.
3.3 Student Data
At the direction of the LEA, the Service ingests and processes Student Data, which may include:
- Identifiers such as student name, student ID number, grade, school, and enrollment status.
- Demographic information that the LEA elects to provide for equity analytics.
- Attendance, behavior, and discipline data.
- Assessment results, course grades, and progress-monitoring scores.
- Special program participation indicators where the LEA configures such fields.
- Parent/guardian contact information used solely for LEA-authorized notifications.
3.4 Information We Do Not Collect
We do not knowingly collect Social Security numbers, financial account numbers, biometric identifiers, precise geolocation, or sensitive health information unless an LEA expressly configures the Service for a documented educational purpose. We do not use facial recognition or scrape facial images.
4. How We Use Information
- Providing the Service. Operating, maintaining, securing, and improving the Service.
- Authorized educational purposes consistent with FERPA § 99.31(a)(1)(i)(B) and the LEA’s written direction.
- Customer communications. Responding to requests, providing support, sending service notices.
- Product analytics and improvement using aggregate or de-identified data only.
- Security and integrity. Detecting, investigating, and preventing fraud and abuse.
- Legal and compliance. Complying with applicable laws and enforcing agreements.
We do not sell Student Data, and we do not use Student Data for targeted advertising. We do not build profiles of students for any commercial purpose unrelated to the LEA’s authorized educational purpose.
5. Disclosure of Information
We disclose information only to authorized users within the LEA, vetted subprocessors (such as cloud-hosting providers) bound by written agreements, and as required by law or legal process. We do not sell personal information or Student Data, and do not “share” personal information for cross-context behavioral advertising.
6. Data Retention and Destruction
We retain personal information only as long as necessary for the purposes described and as specified in the LEA’s contract. Upon expiration or termination, we will return or destroy Student Data within the contracted timeframes (and within sixty (60) days for New York LEAs).
7. Security
We maintain a written information security program with administrative, technical, and physical safeguards aligned with the NIST Cybersecurity Framework and the AICPA SOC 2 Trust Services Criteria, designed to satisfy the New York SHIELD Act. See our Data Security Policy for details.
8. Data Breach Notification
If we experience a security incident affecting personal information, we will notify the affected LEA without unreasonable delay and in no event later than the timeframes required by the applicable contract and law (no later than seven (7) calendar days from discovery for New York LEAs).
9. Children’s Privacy (COPPA)
Where students under 13 access the Service through their LEA, we rely on the LEA to provide consent on behalf of parents, consistent with the FTC’s COPPA school-context guidance. We use Student Data only for authorized educational purposes.
10. Parent and Eligible Student Rights
FERPA and Education Law § 2-d provide parents and eligible students with rights to inspect, review, and request amendment of education records. These rights are exercised through the LEA. Requests directed to My Progress Bridge will be referred to the LEA.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Material changes will be posted with a new “Last Updated” date. For LEA Customers, no change will be applied retroactively to executed contracts in a manner that would reduce protections for Student Data without the LEA’s written consent.
12. Contact Us
Privacy questions or requests may be directed to:
My Progress Bridge, Inc.
Attn: Privacy Officer / Data Protection Officer
Email: contact@myprogressbridge.com