Suntara ("Suntara,""we,""us," or "our") operates a teaching assistant platform that helps educators generate personalized, standards-aligned assignments using student data, including grades and Individualized Education Programs (IEPs). We are committed to protecting the privacy of students and educators who use our platform.
This Privacy Policy describes how we collect, use, store, and disclose information in connection with our services and explains our compliance with the Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. § 1232g, and its implementing regulations at 34 C.F.R. Part 99, as well as New York Education Law § 2-d and its implementing regulations at 8 N.Y.C.R.R. Part 121.
Suntara provides services to schools and educational institutions. When we receive, process, or store student education records on behalf of a school, district, or educator, we act as a "school official" or "legitimate educational interest" service provider as defined under FERPA, and as a "third-party contractor" as defined under New York Education Law § 2-d.
We do not own or control education records — we process them solely at the direction of the educational institution or authorized educator who has provided them, and only for the purposes for which they were disclosed.
Schools and educational agencies are responsible for ensuring that their use of Suntara complies with applicable FERPA and NY Ed Law 2-d requirements, including executing appropriate data privacy agreements, obtaining necessary consents, and making required disclosures to students and parents.
In accordance with New York Education Law § 2-d, Suntara affirms the following rights of parents and eligible students with respect to student data:
Suntara will enter into a Data Privacy Agreement (DPA) with any New York educational agency prior to receiving student data. That DPA will conform to the requirements of 8 N.Y.C.R.R. Part 121 and will be appended to or incorporated into any service agreement.
Information Educators Provide
When educators register and use Suntara, we collect account information including name, email address, phone number, and school name. Beyond that, the information we receive is entirely dependent on what each educator chooses to provide. Educators may optionally upload or enter any combination of the following:
Educators are not required to provide all of the above in order to use Suntara, and may choose to use the platform with limited or no student data. The personalization and features available may vary depending on what information is provided.
Automatically Collected Information
When you use our platform, we automatically collect:
Student Data
Any student data that an educator chooses to upload to Suntara — which may include IEPs, grades, reflections, and other education records — is treated as education records under FERPA and as "protected information" under NY Education Law § 2-d. This includes "personally identifiable information" (PII) as defined under both laws. Such data is processed solely for the purpose of generating personalized assignments and related educational services, and for no other purpose.
We use the information we collect to:
Prohibited Uses of Student Data Under NY Education Law 2-d
In compliance with NY Education Law § 2-d, Suntara will not:
Educator Account Information
Information that educators voluntarily provide when creating and managing their Suntara account — such as their name, email address, phone numbers, school names, and lesson plans — is used solely to improve the platform. This information is not sold, rented, or shared with third parties for commercial purposes. While general educator account information of this nature is not the primary subject of NY Education Law § 2-d's teacher protections (which are focused on APPR data), we apply the same principles of data minimization and confidentiality to all information on our platform.
We Do Not Sell Student Data. Suntara does not sell, rent, or trade student education records or any personally identifiable information derived from such records, consistent with FERPA and NY Education Law § 2-d.
We Do Not Share Student Data with Third Parties for Their Own Purposes. Student education records are never shared with third-party advertisers, data brokers, or unrelated commercial entities.
Limited Disclosures Permitted Under FERPA and NY Ed Law 2-d
We may disclose education records only in the following circumstances:
Subcontractor Disclosure
Consistent with 8 N.Y.C.R.R. § 121.6, Suntara will publish and maintain a list of authorized subcontractors that may have access to student PII in connection with the services we provide. This list is available upon request and will be included in or appended to any Data Privacy Agreement with a New York educational agency.
De-identified or Aggregated Data
We may use and disclose de-identified, aggregated, or anonymized data — from which all personally identifiable information has been removed in accordance with the standards set forth under FERPA and NY Ed Law 2-d — for research, product improvement, and reporting purposes. Such data cannot reasonably be used to identify any individual student.
We implement administrative, technical, and physical safeguards designed to protect student education records and other personal information from unauthorized access, disclosure, alteration, or destruction, consistent with the data security requirements of FERPA and 8 N.Y.C.R.R. § 121.8. These measures include:
No data security measures are 100% foolproof. In the event of a breach or unauthorized release of student PII, we will notify affected educational agencies in accordance with NY Education Law § 2-d and applicable breach notification law, and will cooperate with the educational agency's obligations to notify parents and NYSED.
In the event of an unauthorized release, disclosure, or acquisition of student PII ("data breach"), Suntara will:
Educational agencies are responsible for notifying parents, eligible students, and NYSED as required by NY Ed Law 2-d following receipt of notice from Suntara.
We retain education records and account data for as long as an educator's account is active and as necessary to provide services, consistent with the terms of any applicable Data Privacy Agreement.
Upon expiration or termination of a service agreement, or upon written request from a New York educational agency, Suntara will return or securely destroy student PII in accordance with 8 N.Y.C.R.R. § 121.9, unless retention is required by law. Educators may also delete their account data at any time through their account settings or by contacting us.
FERPA grants parents and eligible students (students aged 18 or older, or those attending post-secondary institutions) certain rights with respect to education records. These rights are exercised through the educational institution, not directly through Suntara. Such rights include:
Parents and eligible students should direct requests regarding these rights to the school, district, or educator who uses Suntara on their behalf.
Parents, eligible students, and educational agency employees who believe that student PII has been released in violation of NY Education Law § 2-d may file a complaint with the New York State Education Department. Information about filing a complaint is available at:
New York State Education Department
89 Washington Avenue
Albany, New York 12234
www.nysed.gov
Complaints may also be directed to Suntara using the contact information in Section 15 below. We will investigate and respond to complaints in a timely manner.
Suntara is a platform for educators, not for direct use by students. We do not knowingly collect personal information directly from students under the age of 13. Student data we receive is provided by educators and processed solely for educational purposes. If you believe a child has provided personal information to us directly without appropriate authorization, please contact us immediately using the information in the "Contact Us" section below.
We use cookies and similar technologies to operate our platform, maintain user sessions, and improve functionality. We do not use tracking technologies to build advertising profiles from student data or to track students outside of our platform, consistent with the prohibitions on commercial use of student data under NY Education Law § 2-d.
You may configure your browser to refuse cookies, though doing so may affect the functionality of the platform.
Suntara may use third-party infrastructure and technology providers (such as hosting services) to operate the platform. Any subcontractor that may access student PII is required to:
A list of subcontractors authorized to access student PII is available upon request and will be provided to New York educational agencies in connection with any Data Privacy Agreement.
We may update this Privacy Policy from time to time. If we make material changes, we will notify educators via email or a prominent notice on the platform prior to the changes taking effect. The updated policy will include a revised effective date. Any changes that affect the processing of student PII will be reflected in updated Data Privacy Agreements with affected educational agencies. Continued use of Suntara after any changes constitutes acceptance of the updated policy.
If you have questions about this Privacy Policy, your education records, our FERPA compliance practices, or our compliance with NY Education Law § 2-d, please contact us at:
Suntara, LLC
www.suntara.io
Email: privacy@suntara.io
For questions specifically related to NY Education Law § 2-d and the rights of parents or eligible students, you may also contact the New York State Education Department at www.nysed.gov.