Orcanomics

Financial learning for 3-8
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Student DPA

Download Standard DPA Template

Effective date: March 18, 2026
For Educational Institutions and School Districts

This Student Data Privacy Agreement ("DPA") establishes the terms and conditions under which FinSpark, LLC. ("Provider", "we", "us") handles, protects, and processes Student Data provided by a Local Education Agency, School District, or Educational Institution ("LEA", "School") when using the Orcanomics financial literacy platform.

Orcanomics is deeply committed to protecting the privacy of students and complies strictly with the Family Educational Rights and Privacy Act (FERPA), the Children's Online Privacy Protection Act (COPPA), the Student Online Personal Information Protection Act (SOPIPA), and applicable state student privacy laws.

1. Purpose and Scope

This DPA is intended to ensure that any Student Data shared with Orcanomics is used solely for the purpose of providing and improving educational services to the LEA and its students. This DPA supplements our Terms of Service and Privacy Policy when Orcanomics is deployed in a school or district environment.

2. Nature of Data Collected

Orcanomics operates on a principle of data minimization. We only collect the Student Data necessary to provide our educational services.

  • Roster Data: Student first name, last initial, grade level, and school email address (for login purposes only).
  • Performance Data: In-app quiz scores, module completion status, and virtual currency ("Orca-coins") balances.
  • Academic Snapshots: If integrated with an LEA Student Information System (SIS), Orcanomics may process an anonymized snapshot of academic fields strictly for the generation of adaptive, custom financial literacy quizzes.

3. Strict Prohibition on Data Misuse

Orcanomics acknowledges that Student Data is the property of and under the control of the LEA. Under no circumstances will Orcanomics:

  • Sell, rent, or trade Student Data.
  • Use Student Data to engage in targeted advertising or marketing to students.
  • Create a commercial profile of a student, other than for purposes authorized by the LEA or for providing the educational service.

4. Artificial Intelligence (AI) and Custom Generation

Orcanomics utilizes third-party Artificial Intelligence (AI) to generate adaptive quizzes and lessons. Because protecting student privacy is our highest priority, we employ strict data safeguards regarding AI processing:

  • Anonymization: All Student Data is strictly anonymized and de-identified before interacting with any external AI service. Direct identifiers (names, emails, student IDs) are completely stripped from the payload.
  • No Model Training: Our contracts with third-party AI vendors explicitly prohibit the use of LEA data, prompts, or inputs for training, retraining, or improving their foundational models.
  • Parental/LEA Consent: Custom AI quiz generation is treated as a premium feature requiring explicit verification and consent from an authorized LEA administrator or a verified Parent Account.

5. Data Security

Orcanomics implements robust administrative, physical, and technical safeguards to protect Student Data from unauthorized access, disclosure, and use.

  • Encryption: All Student Data is encrypted in transit (using TLS 1.2 or higher) and at rest (using AES-256 encryption).
  • Access Controls: Access to Student Data is restricted to authorized Orcanomics personnel who require access to perform their job duties and who are bound by strict confidentiality obligations.
  • Breach Notification: In the event of an unauthorized disclosure or security breach affecting Student Data, Orcanomics will notify the LEA without unreasonable delay, and in no event later than forty-eight (48) hours after confirming the breach.

6. Data Retention and Deletion

Orcanomics does not retain Student Data longer than necessary to fulfill the purposes of our educational services.

  • Upon Termination: Upon termination or expiration of the agreement with the LEA, Orcanomics will securely delete or return all Student Data to the LEA within thirty (30) days, except where retention is required by applicable law.
  • Upon Request: The LEA may request the deletion of a specific student's data at any time. Orcanomics will comply with such requests within fourteen (14) business days.

7. Third-Party Service Providers

Orcanomics may utilize approved third-party service providers (Subprocessors) to host and operate the platform (e.g., cloud hosting, database management). All Subprocessors are heavily vetted and contractually bound to uphold privacy and security standards that are equally as stringent as those outlined in this DPA. A current list of Subprocessors will be provided to the LEA upon request.

8. Access and Correction (FERPA Compliance)

In compliance with FERPA, Orcanomics acknowledges that parents, legal guardians, and eligible students have the right to access and correct erroneous Student Data. Orcanomics will assist the LEA by providing the necessary tools or technical support to facilitate these requests. All direct requests from parents regarding LEA data will be routed to the LEA for authorization.

9. Execution and Standard Agreements

Orcanomics willingly signs the National Data Privacy Agreement (NDPA) and state-specific alliances (such as the CSDPC, SDPC, or TXDPA). If your district requires a signed DPA, please download our standard template above or send your district's preferred NDPA exhibit to our compliance team.

DPA Contact Information:
Legal & Privacy Department
privacy@orcanomics.example
FinSpark, LLC.