FERPA Compliance

The Family Educational Rights and Privacy Act (FERPA) is a federal law (20 U.S.C. Section 1232g) that protects the privacy of student education records. FERPA applies to all schools that receive funds under an applicable program of the U.S. Department of Education. Under FERPA, schools must have written permission from a parent or eligible student before releasing any information from a student's education record, with certain exceptions.

When a school or district uses Sheelon, Sheelon acts as a "school official" with a "legitimate educational interest" under FERPA. This means:

• We perform functions that the school would otherwise use its own employees to perform
• We are under the direct control of the school with respect to the use and maintenance of education records
• We use education records only for the purposes for which we were given access
• We comply with the re-disclosure requirements of FERPA

What We Collect

When students participate in Sheelon games, the following data may be considered education records when linked to a student:

• Player nickname (chosen by the student at time of joining a game)
• Quiz responses and answer data
• Scores and performance analytics
• Time spent on questions

Game screens are also session-recorded by Microsoft Clarity, the analytics provider we use to see where the product confuses people, so a replay can show a player's nickname, the answers they picked and the scores on screen. Our Privacy Policy sets out what that covers.

What We Do NOT Collect

• Student ID numbers, Social Security numbers, or other government identifiers
• Home addresses or phone numbers
• Parent or guardian information
• Student birthdates. We do not ask a student's age at any point, and we run no age gate.
• Disciplinary records, health records, or financial information

Sheelon is designed with data minimization as a core principle:

• A game needs no student account. Anyone joining a game with a Game PIN gives only a self-chosen nickname. No email, no real name, nothing else. That is still how most Sheelon games run.
• A class is the other path, and it is the teacher's choice. A teacher can create a class: a named list of their students that lasts the school year, so the same homework can go to the whole group and results carry real names instead of nicknames. The names come from the teacher, either typed in or imported from Google Classroom. Students on a class either sign in with their own account or pick their name from the list, depending on how the teacher set the class up.
• Minimal data collection. We only collect the data necessary to run the game and provide analytics to the teacher.
• Teacher controls data visibility. Only the teacher who hosted a game can access detailed player-level analytics and reports.
• A persistent student profile exists only inside a class. Data from a PIN game stays attached to that one game session. Data from work set for a class is attached to that student on that class list, which is the point of a class: a teacher needs to see who has not started. Deleting the class deletes the list and every student row on it.

Sheelon does not know how old any student is. We never ask for a birthdate, there is no age gate at sign-up, and we do not operate a parental consent flow of our own. What we have instead is the teacher, and one question we ask them.

Before a teacher creates a class, or imports one from Google Classroom, they are shown this and have to tick it:

Sheelon will store these students' names and keep their scores against them. I have whatever permission my school or country requires for that.

The class cannot be created until it is ticked. When it is, we record three things against that class and keep them: the moment it was ticked, the exact version of the wording that was on screen, and which account ticked it. Nothing is inferred later and nothing is backfilled.

This is the whole mechanism, and it is worth being plain about what it is and is not. It is a record that a named educator took responsibility for the consents their school, district or country requires, parent or guardian consent for students under 13 included. It is not verification: Sheelon does not contact parents, does not check that consent exists, and cannot. When a school uses Sheelon in a classroom, the school acts as the agent of the parent for the purposes of COPPA consent, and this tick is the school saying so.

Schools and districts using Sheelon have the following controls:

• Teachers can delete game session data, including all player responses and analytics
• Organization administrators can manage teacher accounts within their school
• Schools can request complete data deletion for all accounts associated with their organization
• Schools can request an export of all data associated with their organization

Sheelon will never sell student data. We will never use student data for targeted advertising. We will never build profiles of students for non-educational purposes. Student data is used exclusively for the educational purposes of the Service.

We implement appropriate security measures to protect student education records:

• All data transmitted over the network is encrypted using TLS/HTTPS
• Database access is restricted and requires authentication
• Access to student data is limited to the teacher who hosted the game session
• We conduct regular security reviews and apply updates promptly
• We use industry-standard hosting infrastructure with security certifications

Under FERPA, parents (or eligible students over 18) have the right to:

• Inspect and review their child's education records held by the school
• Request correction of records they believe are inaccurate
• Consent to disclosure of personally identifiable information (with certain exceptions)

If a parent or eligible student wishes to exercise these rights regarding data held by Sheelon, they should contact their school or district, which can work with us to fulfill the request. Parents may also contact us directly at [email protected].

In the event of a data breach that affects student education records, Sheelon will:

• Notify affected schools and districts as promptly as possible, and no later than 72 hours after discovery
• Provide details about the nature of the breach and the data affected
• Describe the steps we are taking to contain and remediate the breach
• Cooperate with schools in notifying affected parents as required by law

Schools and districts may request a Data Processing Agreement (DPA) or Student Data Privacy Agreement (SDPA) that formalizes our commitments under FERPA and applicable state student privacy laws. Contact us to initiate this process.

For questions about FERPA compliance, data privacy, or to request a Data Processing Agreement, please contact:

Email: [email protected]