Whole Child Record Privacy Policy

Exclusive Education Inc. · Effective date: November 6, 2026 · Version 2026-11-06.1

What changed (Version 2026-11-06.1): Added how we handle in-app feedback.

Earlier change (Version 2026-11-04.1): Added how we use sign-up campaign codes and anonymous counts of deletions and opt-outs.

The short version

• Whole Child Record (WCR) is a private records tool for parents and guardians. Adults 18 and older keep records about their K-12 children. Children do not have accounts.
• Your family's information is used to run WCR for you. We use identifiable information only to provide, secure, and support the service for you and the people you invite.
• We never sell your personal information. We never use it for advertising. We never build profiles of your child for anything other than your record.
• Research, product improvement, and reports we may share or sell use only de-identified, aggregated data that meets a strict standard (Section 5): group totals of at least 10 children, never anything about one child. We publicly commit never to try to re-identify it, and anyone who receives it must promise the same in a contract.
• Identifiable information is never used for research unless you separately opt in. We do not run any research program today. If we ever start one, it will be a separate, optional choice that is off unless you turn it on.
• AI is optional, and it only drafts suggestions. It runs only when you ask it to, and nothing is saved until you review and confirm it. Before text goes to AI, we remove names and other identifiers we know about. Every AI provider we use must agree in writing not to train on your family's information and not to keep it longer than needed to return the result, and we never use your family's information to train AI models.
• You stay in control. You can see, correct, download, and delete your information, and you can ask us for a full copy at any time.
• We name every company that helps us run WCR in our subprocessor list (Section 7), and we tell you how we handle changes (Section 15).

Contact: info@wholechildrecord.com

1. Who we are and what this policy covers

Whole Child Record ("WCR") is operated by Exclusive Education Inc. ("we," "us," "our"). This policy explains what we collect, how we use and share it, how long we keep it, how we protect it, and the choices you have.

It covers every way you use WCR: our website at wholechildrecord.com, any demo or practice areas, the signed-in service, and any mobile apps, browser extensions, or other versions we offer now or later ("the Service"). If a version works differently in a way that affects your privacy, we will say so in this policy before that version launches.

This policy applies to the family edition, the version families sign up for themselves. If a school, district, co-op, or other organization signs a written agreement with us, Section 13 also applies, and that agreement controls for the data it covers.

Our Terms of Use (wholechildrecord.com/terms) are a separate document. They explain the rules for using WCR.

2. Who WCR is for

WCR is a data and records management tool for parents, guardians, and schools. It is not directed to children and is not meant for children to use. Children do not create accounts or sign in. Information about a child is entered only by eligible adults.

Who can use WCR. You must be 18 or older and be one of the following:

• The child's legal parent or guardian, keeping a record of your own child's development and schooling, from kindergarten through grade 12.
• An adult the parent or guardian has given permission, such as a tutor, teacher, therapist, or relative invited as a collaborator. A collaborator sees only what they were invited to, and only after they accept.
• An authorized user of a school, district, co-op, or other organization using WCR under a written agreement with us (Section 13).

The parent or guardian is in control. The parent or guardian decides who can see and add to their child's record, and can remove anyone's access at any time.

No child accounts. No one under 18 may create an account. If we learn that a child under 13, or anyone under 18, has created an account, we will close it and delete its information.

When you sign up, you confirm that you are 18 or older and that you are the child's legal parent or guardian, or have that parent's or guardian's permission. You also agree to the Terms of Use and confirm that you have read this Privacy Policy. We record the version of this policy you agreed to and when. You must verify your email address before you can use your account.

3. Information we collect

We collect only what the record and the Service need. We describe information by category, so this section stays accurate as individual features change. If we ever want to collect a new category of information about children, we will ask you first (Section 15).

3a. Information you give us

If you send us feedback through the app, we keep your answers and rating with your account so we can improve Whole Child Record. We never use them for advertising or share them. Please don't include your child's name or other details. You can export your feedback with your other data. If you delete your account, we keep your feedback only in anonymous form, with your name, email and any identifying details removed, so it can't be linked back to you or your child.

About your child's information. A record can hold sensitive details, such as learning differences, health, behavior, or family circumstances. We treat everything about a child as sensitive. Add only what helps you see your child's growth. You never need to add diagnoses, medical details, IEP or 504 documents, Social Security numbers, or anything about other children.

Especially sensitive information. Services, supports, assessments, and similar entries get extra protection:

• Private by default. Each item starts visible only to you, the account owner. You choose, item by item, whether collaborators can see it, and they can only view it.
• Off reports and transcripts unless you turn it on, item by item.
• Not sent to AI. Entries in the Services section are never sent to AI.
• Never sold, used for advertising, or shared except with the people you choose and the subprocessors who run WCR.
• You can export or delete it at any time.

Please don't upload full IEP or medical documents unless needed; a summary is usually enough.

3b. Information collected automatically

When you sign up from one of our links, we save the short campaign code in that link (for example, which online group it came from) with your account. We use it only to count which outreach works, it's never used to profile you or your child, and it's never sold or shared. It's deleted when you delete your account.

The companies that provide these services are named in our subprocessor list (Section 7).

3c. What we do not collect

We do not ask for Social Security numbers, government IDs, precise GPS location, your contacts, or advertising identifiers. We do not use advertising or cross-site tracking tools, in the website or any app. Because children do not sign in, we do not collect information directly from children.

Photos and files. Where we can, we re-save photos in your browser or app before upload, which removes hidden details such as GPS location. Some formats can't be re-saved and are stored as uploaded, and documents such as PDFs are stored as uploaded. Remove anything you don't want kept before uploading.

4. How we use information

We use identifiable information about you and your child only to:

1. Provide the Service: store, organize, and display your records; show progress, summaries, and content suited to your child; create reports and transcripts; and let the collaborators you approve see and add to a record.
2. Customize and personalize the record inside your own account: for example, showing content that fits your child's age or grade, remembering your settings, or suggesting next steps. This stays inside your account. It is never used for advertising, and it is never used to build profiles for anyone else. Resource suggestions are the same for everyone viewing a standard and are not personalized to your child.
3. Run the AI features you choose to use (Section 6).
4. Run imports and integrations you turn on, only to move the information you choose.
5. Keep WCR secure: verify accounts, prevent fraud and abuse, investigate security incidents, and fix problems.
6. Send service messages: email verification, password resets, collaborator invitations, billing notices if you have a paid plan, and notices about your account or this policy. We may also send account holders a monthly WCR newsletter and occasional emails about product updates, tips, and offers. These emails are never based on your child's information, and we never use your child's records to target or personalize marketing. Resource suggestions in the app are tied to the learning standard you're viewing, and everyone viewing that standard sees the same ones. You can opt out anytime using the unsubscribe link in any of these emails or in Settings. We honor opt-outs within 10 business days, usually right away. Opting out doesn't stop service messages, such as sign-in, security, password-reset, account, and policy-change emails.
7. Support you when you ask for help. Someone on our team looks at a record only when you ask for help, when it is needed for security, or when the law requires it.
8. Follow the law: meet legal obligations, respond to valid legal process, and enforce our Terms.
9. Improve WCR, using de-identified data only (Section 5).

Resource suggestions. WCR shows learning resources tied to each learning standard and grade, and everyone viewing that standard sees the same ones. Some are affiliate links to partners such as Amazon and IXL, and WCR may earn a commission. Partners receive only an anonymous click code, not your child's name, records, or account details. When you visit a partner's site, its own privacy policy applies.

What we never do:

• Sell or rent personal information about you or your child, including to data brokers.
• Use it for targeted advertising, on WCR or anywhere else. WCR shows no ads. Resource suggestions may include affiliate links, as described above.
• Build a profile of a child, a family, or a group for any purpose other than providing WCR to you.
• Use your child's information for non-educational commercial purposes, or to make decisions about your child such as eligibility, placement, credit, insurance, or employment.
• Use your information, identifiable or de-identified, to train AI models, or let any AI provider train on it (Sections 5 and 6).
• Use information we already hold in a materially different way without first asking for your consent (Section 15).

5. De-identified data, research, and product improvement

We want WCR to get better, and we want to learn what helps children and families, without putting any family's privacy at risk. These rules apply to any use of WCR data beyond running the Service for you, including product analytics.

5a. What "de-identified" means at WCR

Data counts as "de-identified" only when it cannot reasonably be used to identify, or be linked to, a specific child, parent, or household, and all of the following are true:

1. Direct identifiers are removed. Names, email addresses, account and record IDs, collaborator details, IP addresses, and exact dates are removed.
2. Indirect identifiers are generalized. For example, birthdate becomes an age band or grade band, dates become a school term or year, and small or unusual categories are combined.
3. Free text, photos, and uploaded files are left out. Journal text, notes, photos, and uploaded documents can identify a child even with the name removed, so we never include them in de-identified data sets.
4. Small groups are hidden. In any summary we share or publish, we suppress any group of fewer than 10 children or families. We also hide other numbers that could be used to work out a hidden one.
5. Our method follows recognized guidance. We follow the U.S. Department of Education's guidance on de-identification or the National Institute of Standards and Technology's (NIST) de-identification guidance, and we document how each data set was made.
6. We publicly commit not to re-identify. We will keep de-identified data in de-identified form and will not attempt to re-identify it, except to test that our own de-identification works.
7. Recipients are bound by contract. Anyone who receives de-identified data from us must agree in writing not to re-identify it, not to combine it with other data in a way that could identify someone, not to pass it on, and to follow these same rules.

This standard is consistent with U.S. privacy-law definitions of de-identified information, the Federal Trade Commission's guidance, and the de-identification terms of the Student Data Privacy Consortium's National Data Privacy Agreement.

5b. How de-identified data may be used

We may use de-identified and aggregated data to:

• improve and develop WCR's features, checklists, and educational content;
• understand how the Service is used, for example which features are used and how often;
• show whether WCR is effective; and
• publish aggregate findings about child development and learning, or share aggregated statistics with education researchers who agree to the contract terms in 5a; and
• license or sell aggregated reports and statistics, such as "how many 3rd graders are still working on fractions," to partners such as curriculum publishers, education technology companies, and researchers. Every group in these reports has at least 10 children, meets every rule in 5a, and every recipient must agree in writing to the contract terms in 5a. These reports are not personal information.

What we will not do, even with de-identified data: sell, license, or give record-level data (data about one child, even with the name removed) to anyone outside WCR, use it for advertising, or use it to train AI models. Only aggregated results, with every group of at least 10, ever leave WCR.

5c. Research with identifiable information: only with your separate opt-in

WCR does not run any research program that uses identifiable information. We will never use or share identifiable information for research unless you give separate, optional, and revocable consent. If we ever offer a research program:

• Separate: we will ask you separately. It will never be part of signing up or a condition of using WCR, and saying no will change nothing about your account.
• Specific: before you decide, we will tell you the purpose of the study, who is running it, what information would be used, how long it would be kept, and how it would be protected.
• Off by default: nothing is included unless you actively agree, for each child and each study.
• Revocable: you can withdraw at any time by emailing info@wholechildrecord.com. After you withdraw, we will stop using your information for new research and delete identifiable research copies we control within 30 days. Results that were already de-identified, combined, or published cannot be pulled back.
• Reviewed: studies involving identifiable information about children will go through an independent ethics review, such as an Institutional Review Board, when the law or a research partner requires it.
• Protected: researchers must sign an agreement that limits use to the approved study, bans resale and re-identification, requires security, and requires deletion when the study ends.

We will update this policy before any such program begins.

6. AI features

WCR's AI features are optional drafting tools. AI drafts are suggestions for you to review. AI runs only when you ask it to, and nothing is saved to your record until you confirm it. AI can be wrong, so please check every suggestion. AI output is not a diagnosis, evaluation, or professional advice.

What is sent. When you use an AI feature, we send only what that request needs, such as text you typed or pasted, an image or document you chose, or a short summary built from the record. Entries in the Services section are never sent to AI. Before any text goes to AI, we remove names, emails, phone numbers, addresses, birthdates, ID numbers, and school and teacher names we know about, and we check AI results the same way before you see them. Nicknames, names you haven't entered in the app, and details about siblings may not be caught. We can't edit photos or scans before AI reads them, so please crop out names, ID numbers, and IEP/504 notes first.

Summaries and lesson suggestions. When you ask WCR to summarize or find patterns across your records, such as with the Quick AI Snapshot, or to suggest lesson ideas for a skill, or similar features we may add, AI runs only when you tap the button. We send only the journal entries or other records you choose to include, along with their dates, after removing names and identifiers as described above. Entries that mention diagnoses, IEP/504 plans, therapy, or similar health or special-education details are left out before anything is sent.

Our standards for every AI provider. Any company that runs AI for WCR must meet all of these standards, now and in the future:

• No training: it may not use your family's information, what we send or what it returns, to train or improve AI models.
• No retention beyond the request: it may keep what we send, and what it returns, only as long as needed to return the result, apart from limited exceptions it must follow for legal, safety, or security reasons.
• Written limits: its use of the information is limited by written terms, such as a contract or data processing agreement, to providing the service to us. It may not sell or share the information.
• No storage or logging switched on by us: we do not turn on any provider feature that stores or logs the content of AI requests.

We never use your family's information to train AI models ourselves. The current AI provider is named in our subprocessor list (Section 7). Adding or switching AI providers follows Section 15.

What WCR keeps. Files and text sent only for an AI draft are not stored by WCR after the draft comes back. When you confirm an AI result and save it, WCR keeps it in our own database as part of your child's record, under the same retention schedule (Section 9) and your rights to download and delete (Section 11). Saved results stay in WCR's database and never move to an AI provider.

Your choices. You can use every part of WCR without AI. Where AI is offered in a demo, please do not type real children's details.

7. How we share information

We share identifiable information only in the following cases.

1. With collaborators you invite. A collaborator must sign in with a verified email address and accept before seeing anything. Invitations expire. Collaborators see only what you allow; especially sensitive items (Section 3a) stay private until you share them, item by item. You can remove a collaborator at any time, and their access ends promptly.
2. With our service providers ("subprocessors"), listed below, who process data on our behalf to run WCR, under written terms that limit their use of personal information to providing their service to us.
3. With integrations you turn on. If you connect WCR to another app or service, we send it only what you choose, only after you turn it on, and you can turn it off at any time. That service's own privacy policy governs what it receives.
4. For legal reasons: to comply with a valid subpoena, court order, warrant, or other legal requirement, or to protect someone's safety or the security of WCR. Unless the law forbids it, we will tell you before we disclose, and we will push back on overly broad requests.
5. In a business transfer (see below).
6. At your direction: for example, when you download a report or transcript and share it yourself. You choose what appears on it.

We never sell, rent, or trade personal information, or share it for cross-context behavioral advertising.

Subprocessors

This list names every company that processes personal information for WCR. It is current as of this policy's effective date and is also kept, with its last-updated date, at wholechildrecord.com/privacy/subprocessors.

Third parties (not subprocessors)

These companies are not subprocessors. They do not process personal information for WCR. They receive information only if you tap a resource link, and then only an anonymous click code.

Earlier versions of this list are available on request. How we add or change subprocessors is described in Section 15.

If WCR changes hands

If Exclusive Education Inc. is merged or acquired, or sells WCR, personal information may be transferred only to a successor that agrees to be bound by this policy's commitments for the data it receives. These include no selling, no targeted advertising, and the research limits in Section 5. We will notify you by email at least 30 days before your information is transferred or becomes subject to a different privacy policy, and you can download or delete it first. A successor may not use existing information in a materially different way without your consent.

8. Cookies, analytics, and Do Not Track

• Cookies and app storage. WCR sets cookies, or uses similar storage in an app, only to keep you signed in securely and remember your settings. A session lasts a limited time and renews while you use WCR. We use no advertising or tracking cookies.
• Analytics. We use only privacy-friendly analytics that count page views and measure performance without advertising cookies or cross-site tracking. Any analytics on record data uses de-identified data only (Section 5).
• Do Not Track and Global Privacy Control. WCR does not track you across other websites or apps over time, and does not let third parties do so through WCR. We treat all visitors the same whether or not a Do Not Track signal is sent. We treat Global Privacy Control signals as a request to opt out of sale or sharing. We don't sell or share personal information to begin with.

9. How long we keep information (retention schedule)

We keep personal information only as long as we need it for the purposes in this policy, and never indefinitely.

Inactive accounts. We may delete an account that has had no sign-in for 24 months. We may also close an inactive account sooner if we need to in order to manage storage, but only if it has had no sign-in for at least 12 months. Either way, we will first email the account address at least 30 days before anything is deleted, so you can sign in to keep the account or download your data. Signing in at any time before the date in that email keeps your account open. After an inactive account is closed, its information is deleted on the same schedule as any other deleted account.

We keep anonymous counts of account deletions and email opt-outs, with no information that identifies you or your child.

We may keep specific information longer only when the law requires it, for example to resolve a dispute or comply with a legal hold, and only for as long as required.

10. How we protect information

• Encryption: WCR is served only over encrypted connections, and our database provider encrypts stored data.
• Strong sign-in: passwords are stored only as strong one-way hashes, and email verification is required.
• Access checks on every request: the server checks that you own a record, or are an accepted collaborator on it, before showing or changing anything.
• Limited access: only the Exclusive Education Inc. personnel who need it to run WCR can reach our hosting and database accounts.
• Data minimization for AI: we send only what each AI request needs, remove the identifiers we know about first (Section 6), and use only AI providers that meet our standards.
• No third-party ad or tracking code in the Service.

No online service can promise perfect security. Please use a strong, unique password and keep your own copies of important documents.

If there is a data breach

If we confirm that personal information in WCR was accessed or disclosed without authorization, we will act quickly to contain it. We will notify affected account holders by email without unreasonable delay, and within 72 hours of confirming the breach, unless law enforcement asks us to wait. The notice will say what happened, what information was involved, what we are doing, and what you can do. We will also notify regulators and others where the law requires.

11. Your rights and choices

Any account holder can do the following:

Making a request. Email info@wholechildrecord.com from your account email address. We verify requests, usually through your account email. If you are a child's parent or guardian and believe someone created a record about your child without your permission, contact us. We will verify your relationship and work with you, including deleting the record when appropriate. You may use an authorized agent with your written permission. We respond to requests within 30 days, and provide full exports within 45 days. We will never treat you differently for using your rights. These rights apply on every plan and in every version of WCR.

12. Children's privacy and COPPA

The Children's Online Privacy Protection Act (COPPA) and the Federal Trade Commission's COPPA Rule (16 CFR Part 312) protect personal information collected online from children under 13. WCR is a records tool for adults. It is not directed to children, and children do not have accounts or sign in. We do not knowingly collect information directly from children. Parents, guardians, and the adults they permit add information about children, and the parent or guardian controls it.

We still follow COPPA's core protections for every child's information in WCR:

• the parent or guardian decides what is collected and who can see it;
• we collect only what the record needs;
• we name every company that receives the information (Section 7);
• we do not disclose children's information to third parties except the subprocessors who run WCR and services the parent chooses to connect, and we would ask for separate consent before any other disclosure;
• we follow a retention schedule (Section 9) and never keep information indefinitely;
• we protect the information with reasonable security safeguards (Section 10);
• the parent can review, correct, download, and delete everything, and can stop further use at any time (Section 11); and
• we ask the parent again before any materially new use, new category of collection, or new kind of sharing of a child's information (Section 15).

If we learn that a child under 13 has created an account or given us information directly, we will close the account and delete that information. If you believe this has happened, contact info@wholechildrecord.com.

13. School, district, and organization editions (FERPA)

This section applies only if a school, district, co-op, or other organization signs a written agreement with us. If no such agreement is in place, this section does not apply.

The Family Educational Rights and Privacy Act (FERPA) protects education records held by schools that receive federal funding. Records that you keep in the family edition are your own records, not your school's education records.

If a school or district (a "local educational agency") signs a written agreement with us to use WCR with its students:

• We act as a "school official." As FERPA allows (34 CFR §99.31(a)(1)(i)(B)), we perform a function the school would otherwise use its own staff for, under the school's direct control, and we use and re-disclose student records only as 34 CFR §99.33(a) permits.
• The school owns and controls student data it provides or that is created in its edition. We use it only to provide the service to the school, or as the school instructs.
• Parent requests go to the school. Parents and eligible students ask the school to review, correct, or delete student data, and we help the school respond within 30 days.
• No selling, targeted advertising, or non-school profiles. We will not use school student data for any commercial purpose other than providing the service, or as authorized by the school or the parent.
• De-identified data: we use de-identified school data only for the purposes the school's agreement allows. We will not re-identify it or transfer it to third parties (other than subprocessors) unless the school permits, and we will get the school's written approval before publishing anything that names the school.
• Deletion: we delete or return school student data within 60 days of the school's written request or the end of the agreement.
• Breach notice: we notify the school within 72 hours of confirming a breach involving its student data.
• State terms: our school agreements include any student-privacy terms required by the school's state, and we follow applicable state student online privacy laws. We expect to use the Student Data Privacy Consortium's National Data Privacy Agreement, with any required state terms, for school agreements.
• Changes: changes to how we handle school data are governed by the school's agreement, not by Section 15.

Co-ops and other organizations that are not schools receive the protections in their written agreement, and never less than this policy.

If an organization's agreement conflicts with this policy for the data it covers, the agreement controls.

14. U.S. state privacy rights

Your rights, wherever you live. Several U.S. states have consumer privacy laws. We may not meet their size thresholds, but we give everyone these rights anyway:

• the right to know what personal information we collect, use, and disclose;
• the right to delete;
• the right to correct;
• the right to opt out of sale and sharing (we don't sell or share);
• the right to limit the use of sensitive personal information (we use it only to provide WCR); and
• the right not to be discriminated against for using these rights.

We do not sell or share anyone's personal information, including information about children and teens.

We collect the categories of personal information described in Section 3: identifiers (such as name, email, and IP address); customer and, if you choose a paid plan, billing records; education information; sensitive personal information (account login, children's information, and any health or disability details you choose to enter); internet activity (request logs); approximate location derived from IP; and photos and files. They come from you, from collaborators you invite, from services you choose to connect, and automatically from your device. We use them for the purposes in Section 4, and disclose them only as Section 7 describes. We do not disclose personal information to third parties for their own direct marketing.

What this policy tells you. This policy describes:

• the categories of information we collect and with whom we share it (Sections 3 and 7);
• how you can review and change your information (Section 11);
• how we notify you of changes (Section 15);
• its effective date (at the top); and
• how we respond to Do Not Track signals (Section 8).

Student privacy laws. Many states have student online privacy laws that mainly cover services designed and marketed for school purposes. We follow their core protections for all users:

• no targeted advertising;
• no non-educational profiles;
• no selling student information;
• reasonable security; and
• deletion on request.

Making a request. We honor these requests from everyone, wherever you live (Section 11).

15. How we handle changes

WCR will grow. This section explains, honestly, what we can change on our own and what needs your notice or your permission. Whatever changes, the promises in the short version stay in place: no selling of personal information, no advertising, no AI training on family data, the de-identified research rules, opt-in for identifiable research, your rights in Section 11, and no accounts for children.

1. Subprocessor-list update only. We may add or replace a subprocessor by updating the list in Section 7 when all of these are true: it serves a purpose already described in this policy (for example, hosting, email, payments, or AI drafting); it receives no new category of information; it meets the same standards (for AI providers, the standards in Section 6); and it is bound by written terms. We will post the updated list, with its date, before the new subprocessor receives personal information.

2. Notice (email and website, at least 30 days ahead). We will give notice of material changes that don't expand how we use children's information. Examples: - new features or versions that use information only in ways already described; - clarifications that change the meaning of a commitment; - changes to retention periods or to how you exercise your rights; and - a subprocessor that serves a new purpose but still receives no new category of children's information.

If you don't agree, you can download your data and close your account before the change takes effect.

3. Your consent first (opt-in). We will not do any of the following until the parent or guardian has agreed. Anything not agreed to stays off. - use children's information already collected in a materially different way; - collect a new category of information about children; - share children's information with a new kind of recipient, or for a new kind of purpose, other than subprocessors under item 1; or - make any other change that COPPA or the Federal Trade Commission treats as material for children's information.

Research with identifiable information always needs separate opt-in (Section 5c).

Schools and organizations. For data covered by a school or organization agreement, changes follow that agreement (Section 13).

Small changes, such as fixing typos or improving wording without changing meaning, may be posted with a new version date and no other notice. We keep every earlier version and will send it to you on request.

16. Contact us

Exclusive Education Inc., operator of Whole Child Record Email: info@wholechildrecord.com

If you have a concern about how we handle your child's information, please tell us. We want to fix it.