隐私政策

以下为 Polytend Tech LLC 发布的英文原文;家长登录时勾选的「同意隐私政策」指的就是这份文件。

Prosistant Privacy Policy

Effective Date: September 18, 2026

Prosistant is built to protect the privacy of students, families, and school staff. This policy explains how we collect, use, protect, and delete your information, and how we comply with federal and state law.


Contents

  1. Scope and Who We Are
  2. Key Definitions
  3. Information We Collect
  4. How We Use Information
  5. Data Transfer and Confidentiality
  6. Data Security
  7. Federal and State Legal Compliance
  8. Data Storage and Deletion
  9. SMS Communications
  10. Your Rights
  11. Contact Us

1. Scope and Who We Are

Prosistant is a proprietary school administration and management platform developed and operated by Polytend Tech LLC, a Washington limited liability company ("Polytend," "we," "us," or "our"). Prosistant is accessible at Prosistant.com and through related applications, APIs, and administrative portals.

This Privacy Policy applies to all information collected through the Prosistant platform by Polytend on behalf of schools and educational organizations that subscribe to Prosistant ("School Customers"). It governs how Polytend handles information relating to students, parents, guardians, applicants, and school employees entered into or processed through Prosistant.

Important: Polytend operates Prosistant as a technology service provider to schools. Each School Customer is responsible for its own privacy obligations to students, families, and employees under applicable law. This policy describes Polytend's obligations as the platform operator. School Customers should provide their own privacy notices to their communities as required by applicable law.

This policy does not apply to information collected on third-party websites or services linked from Prosistant, or to the independent data practices of School Customers.


2. Key Definitions

School Customer — A school, childcare center, or educational organization that has entered into an agreement with Polytend to use Prosistant.

School Data — All information entered into, processed by, or generated through Prosistant by or on behalf of a School Customer, including student records, family information, employee records, and operational data. School Data belongs to the School Customer, not to Polytend.

Personally Identifiable Information (PII) — Information that identifies or could reasonably identify a specific individual, including name, address, date of birth, email address, phone number, financial information, and similar data.

Education Records — Records directly related to a student that are maintained by an educational agency or institution, or by a party acting on its behalf, as defined under FERPA (20 U.S.C. § 1232g).

Authorized Users — School owners, directors, administrators, and employees authorized by a School Customer to access Prosistant.

Subprocessor — A third-party service provider engaged by Polytend that processes School Data in connection with operating Prosistant, such as cloud hosting, database, or email service providers.


3. Information We Collect

3.1 Information Provided by School Customers

School Customers and their Authorized Users enter School Data into Prosistant in connection with school administration and operations. This may include:

3.2 Information We Collect Automatically

When Authorized Users access Prosistant, we automatically collect certain technical and usage information necessary to operate and secure the platform, including:

This technical information is used solely for platform operation, security monitoring, and troubleshooting. It is not used for advertising or marketing purposes.

3.3 Information We Do Not Collect

What Prosistant does not collect: Prosistant does not collect biometric data, social media information, or behavioral data for advertising purposes. We do not build commercial profiles of students, parents, or school employees. We do not knowingly collect any information directly from children, including through any student-facing interface, without school authorization and applicable parental consent.

4. How We Use Information

4.1 Permitted Uses

Polytend accesses and uses School Data only as necessary to:

4.2 Prohibited Uses

Polytend expressly prohibits the following uses of School Data. Polytend will not, under any circumstances:


5. Data Transfer and Confidentiality

5.1 Confidentiality Commitment

Polytend treats all School Data as strictly confidential. Polytend personnel and contractors are permitted to access personally identifiable School Data only to the extent necessary to perform authorized platform functions. All personnel with access to School Data are bound by confidentiality obligations.

5.2 Data Transfer Protections

All School Data transmitted between users and Prosistant, and between Prosistant and its infrastructure, is encrypted in transit using TLS 1.2 or higher. School Data is encrypted at rest using AES-256 or equivalent industry-standard encryption. Polytend maintains audit logs of access to and processing of School Data.

5.3 Subprocessors

Prosistant relies on certain third-party subprocessors for platform infrastructure, including cloud hosting, database, and communication services. Polytend:

5.4 Cross-Border Access

Polytend's development and technical support team may include personnel located outside the United States. Any such personnel who access personally identifiable School Data are bound by written confidentiality and data protection obligations consistent with this Privacy Policy, and their access is strictly limited to what is necessary for authorized platform development and maintenance activities. Polytend does not store personally identifiable School Data on infrastructure located exclusively outside the United States without the School Customer's prior written consent.

5.5 No Third-Party Marketing Disclosure

Polytend does not share, sell, or disclose personally identifiable School Data to any third party for marketing, advertising, or commercial purposes. This prohibition applies absolutely and is not subject to exception.

SMS and Phone Number Data: Phone numbers and mobile contact information collected through Prosistant for SMS communication purposes will not be shared with any third party or affiliate for marketing purposes. See Section 9 for full SMS terms.

6. Data Security

6.1 Security Safeguards

Polytend implements commercially reasonable administrative, technical, and organizational safeguards designed to protect School Data against unauthorized access, use, disclosure, alteration, or destruction. These safeguards include:

6.2 Security Incident Notification

In the event of a confirmed or reasonably suspected unauthorized access to, disclosure of, or destruction of School Data (a "Security Incident"), Polytend will:

6.3 Security Audit Rights

Upon written request, no more than once per calendar year, Polytend will provide School Customers with a written summary of its then-current data security practices applicable to School Data. If Polytend obtains a SOC 2 Type II report or equivalent third-party security audit, it will make the most recent such report available to School Customers upon request, subject to appropriate confidentiality protections.

While Polytend employs significant security measures, no system is completely immune from unauthorized access. Polytend cannot guarantee absolute security of School Data.


7.1 FERPA Compliance

Polytend acknowledges that School Data may include "education records" as defined by the Family Educational Rights and Privacy Act ("FERPA"), 20 U.S.C. § 1232g and 34 C.F.R. Part 99. Polytend operates as a "school official" with a "legitimate educational interest" in education records, as those terms are used under FERPA, solely for the purpose of providing the Prosistant platform to School Customers.

In this capacity, Polytend:

7.2 Washington State Student Privacy Act (RCW 28A.604)

Polytend complies with Washington State's Student Privacy Act, RCW 28A.604, and all rules promulgated thereunder. Pursuant to this obligation, Polytend will not:

7.3 COPPA Compliance

To the extent that Prosistant collects, stores, or processes personal information of children under the age of 13, Polytend complies with the Children's Online Privacy Protection Act ("COPPA"), 15 U.S.C. § 6501 et seq., and applicable regulations. Polytend does not collect personal information directly from children. School Customers are responsible for obtaining any parental consents required under COPPA prior to submitting children's personal information to Prosistant. Polytend will cooperate with School Customers to support COPPA compliance as reasonably requested.

7.4 Washington State Data Breach Notification Law (RCW 19.255.010)

In the event of a Security Incident involving personally identifiable information of Washington State residents, Polytend will comply with its obligations under RCW 19.255.010, including notifying affected School Customers within the timeframes required by law and cooperating with School Customers in providing required notifications to affected individuals. School Customers retain primary responsibility for notifying affected students, parents, guardians, and employees as required by applicable law.

7.5 Additional State Privacy Laws

Polytend monitors and complies with applicable state student data privacy laws in states where School Customers operate. To the extent additional state-specific student privacy obligations apply based on a School Customer's location, Polytend will work with that School Customer to satisfy applicable requirements. School Customers should contact Polytend to discuss state-specific compliance requirements applicable to their operations.

A note on regulatory coverage: The regulatory framework governing student data is evolving rapidly at both the federal and state level. Polytend is committed to monitoring legislative developments and updating its practices and this Privacy Policy as required. Material updates to this policy will be provided to School Customers with at least 30 days' notice.

8. Data Storage and Deletion

8.1 Where Data Is Stored

School Data is stored on cloud infrastructure located within the United States. Polytend does not store personally identifiable School Data on infrastructure located exclusively outside the United States without the School Customer's prior written consent.

8.2 Retention During Active Use

Polytend retains School Data for as long as the School Customer's agreement with Polytend remains in effect and as reasonably necessary to provide the Prosistant platform. School Customers retain ownership and control of their School Data at all times and may request correction, update, or deletion of specific records during the term of their agreement.

8.3 Data Retention Schedule

Data CategoryRetention PeriodBasis
Student and family recordsDuration of School Customer agreement, plus 30 days post-termination export windowSchool Customer ownership and FERPA compliance
Employee and staffing recordsDuration of School Customer agreement, plus 30 days post-termination export windowSchool Customer ownership
Financial and tuition recordsDuration of School Customer agreement, plus 30 days post-termination export windowSchool Customer ownership and applicable financial recordkeeping requirements
System access and audit logsUp to 12 months from creationSecurity monitoring and incident investigation
Aggregated, de-identified analyticsIndefinitePlatform improvement; no individual re-identification possible
SMS consent recordsDuration of consent plus 4 yearsTCPA compliance

8.4 Data Export on Termination

When a School Customer's agreement with Polytend expires or is terminated for any reason, Polytend will:

8.5 Secure Deletion Standards

Polytend deletes School Data using industry-standard secure deletion methods that render the data unrecoverable. Where School Data exists on backup media, Polytend will overwrite or destroy such media within its normal backup rotation cycle, not to exceed 90 days following the deletion confirmation provided under Section 8.4.

8.6 Retention of De-Identified Data

Polytend may retain aggregated, de-identified derivatives of School Data following termination, provided such data cannot reasonably be used to re-identify any individual and is not used in any manner inconsistent with this Privacy Policy. De-identified data is not School Data and is not subject to deletion obligations.

Legal hold exception: Notwithstanding the deletion timelines above, Polytend may retain School Data beyond the applicable retention period to the extent required by applicable law, court order, or regulatory obligation. Polytend will notify the affected School Customer of any such legal hold to the extent permitted by law.

9. SMS Communications

SMS Consent and Privacy: Phone numbers and mobile contact information collected as part of the SMS consent process will not be shared with any third party or affiliate for marketing purposes.

SMS Terms and Conditions

1. SMS Consent

By providing your mobile phone number and consenting to receive SMS messages from Prosistant or your School Customer through Prosistant, you agree to receive text messages as described below. Consent to receive SMS is not a condition of enrollment or any other service.

Phone numbers obtained as part of the SMS consent process will not be shared with third parties for marketing purposes.

2. Types of SMS Communications

If you have consented to receive text messages through Prosistant, you may receive messages related to the following school administration purposes:

Prosistant does not send promotional or marketing SMS messages to students, parents, or guardians without explicit consent that is separate from school administration communications consent.

3. Message Frequency

Message frequency varies depending on your school's administrative activity and your notification preferences. You can manage your notification preferences within your Prosistant account settings or by contacting your school administrator.

4. Message and Data Rates

Standard message and data rates may apply depending on your mobile carrier and pricing plan. These fees are charged by your carrier and are not controlled by Polytend or your school. Contact your carrier for details on your messaging plan.

5. How to Opt In

You may opt in to receive SMS messages through Prosistant in the following ways:

6. How to Opt Out

You may opt out of receiving SMS messages at any time by:

After opting out, you will receive a single confirmation message. You will not receive further SMS messages unless you opt back in. Opting out of SMS does not affect other methods of communication from your school.

7. Help

If you are experiencing issues with SMS messages from Prosistant, reply HELP to any message or contact us at support@prosistant.com. You can also contact your school administrator for assistance with your communication preferences.

8. Standard Messaging Disclosures


10. Your Rights

Parents, guardians, eligible students, and school employees have the following rights with respect to their information in Prosistant. Rights related to education records are exercised through the School Customer. Polytend will support School Customers in responding to rights requests as described below.

Right to Access — Parents and eligible students have the right under FERPA to inspect and review education records maintained in Prosistant. Submit requests to your school administrator.

Right to Correct — Parents and eligible students may request correction of inaccurate or misleading information in education records. Polytend will correct records in Prosistant within 10 business days of a school's written correction request.

Right to Delete — School Customers may request deletion of specific School Data records. Polytend will process deletion requests within 10 business days, subject to any applicable legal hold obligations.

Right to Data Portability — School Customers are entitled to export all of their School Data in a commercially reasonable electronic format at any time during the term of their agreement, and within 30 days following termination.

Right to Opt Out of SMS — You may opt out of SMS communications at any time by replying STOP or contacting your school administrator. See Section 9 for details.

FERPA Complaint Rights — If you believe your FERPA rights have been violated, you may file a complaint with the U.S. Department of Education's Family Policy Compliance Office at studentprivacy.ed.gov.

How to Submit a Rights Request

Rights requests relating to education records should be directed to your School Customer (the school your child attends or where you are employed). The school will coordinate with Polytend to fulfill the request. For questions about Polytend's data handling practices or to raise a privacy concern directly with Polytend, contact us using the information in Section 11.


11. Contact Us

If you have questions or concerns about this Privacy Policy, Polytend's data handling practices, or your rights with respect to School Data, please contact us:

Polytend Tech LLC Platform: www.prosistant.com Email: support@prosistant.com

Polytend Tech LLC is a Washington limited liability company.

Updates to This Privacy Policy

Polytend may update this Privacy Policy from time to time to reflect changes in our practices, the Prosistant platform, or applicable law. Material changes will be communicated to School Customers in writing at least 30 days prior to the effective date of such changes. The current version of this Privacy Policy will always be available at Prosistant.com/privacy. Continued use of Prosistant after the effective date of any update constitutes acceptance of the updated policy.

This Privacy Policy was last updated on: September 18, 2026


© 2026 Polytend Tech LLC. All rights reserved. Prosistant is a proprietary platform of Polytend Tech LLC.