1. Roles

The school is the controller of the student, family and staff records it places in Roslio. Digital Override LLC, doing business as CheatCode Solutions ("we") acts as a service provider to the school and, for the purposes of the Family Educational Rights and Privacy Act (FERPA), as a school official with a legitimate educational interest, under the school's direct control with respect to the use and maintenance of those records.

2. What we do with the data

We process the school's records only on the school's instructions and only to provide and support the service to that school. We do not sell the records, do not use them for advertising or to build profiles for any purpose other than the school's own, and do not use them to train models for anyone else. Data collected from students under 13 is collected on the school's authorization for the school's educational purposes only.

3. Disclosure

We disclose records only to the school's own authorized users, to the subprocessors listed below, or when the law requires, in which case we tell the school first unless the law forbids it. The access each guardian has is decided by the relationship records the school maintains.

4. Security

Data is encrypted in transit and at rest. Row-level security in the database separates each school from every other school, and this is tested automatically. Sensitive fields are restricted by role, access to medical and financial records is logged, and staff with sensitive access must use a second sign-in factor. Our own staff are bound by confidentiality and may enter a school's account only under a time-limited, logged access grant the school approves.

5. Subprocessors

We use the following to run the service: Vercel (hosting), Supabase (database and sign-in), Stripe (payments, when the school connects it), Twilio (text messages, when the school turns them on) and Resend (email). All are United States providers and the data is stored and processed in the United States. We give the school at least 30 days' notice before adding or changing a subprocessor, with a chance to object.

6. Incidents

If we learn of unauthorized access to the school's records, we will tell the school without undue delay and within 72 hours, with what we know about what was affected, and will help the school meet any notification duty it has.

7. The school's rights

The school can export all of its data at any time. It can ask us to correct or delete records, and we will do so or enable it. We will help the school respond to requests from parents and eligible students to inspect or amend their education records.

8. Retention and return

We keep the school's records for as long as the account is active. After the agreement ends, the data stays readable to the school for 90 days for export, and is then retained or deleted according to the school's written instruction. Backups age out of the system within 35 days after deletion.

9. Changes

If we change this agreement, we will ask the school to accept the new version; the version accepted is recorded with the date. Questions: brady@cheatcodesolutions.com.