Data Processing Agreement

Last updated: November 8, 2026 · Beta version · doc v2026-11-08b

This Data Processing Agreement ("DPA") forms part of the Terms of Service between you (the practice organization, "Customer") and Learners Voyage, LLC, a New Jersey limited liability company operating the LearnersVoyage service ("LearnersVoyage", "we", "us"). It applies to personal data you or your clients enter into the service — including student, parent, and household information — whenever LearnersVoyage processes that data on your practice's behalf during any authorized use of the service, whether under a paid subscription, a free trial, or a complimentary production pilot.

Roles

You are the controller of the data you enter. LearnersVoyage acts as a processor (or service provider) and processes that data only on your documented instructions, which include using the service as designed and the settings you configure.

Scope of processing

• Subject matter: practice-management data you record — student profiles, session notes, assessment results, scheduling, and billing records.
• Nature and purpose: storing, organizing, and displaying that data to provide the service; generating AI-assisted content only when you use AI features.
• Duration: for the life of your account, then the retention period you select at offboarding (immediate deletion on request, a defined retention window, or the 3-month default).
• Data subjects: your students, their parents or guardians, and practitioners in your practice.

Our obligations

• Process personal data only to provide and maintain the service, never to sell it or use it for advertising.
• Keep personal data confidential and restrict access to personnel and subprocessors bound by confidentiality.
• Maintain technical and organizational measures appropriate to the sensitivity of student data: encryption in transit (TLS) and at rest, per-practice tenant isolation, role-based access controls inside the application, OAuth sign-in through Google or Microsoft (with the provider's own MFA) in addition to password sign-in, and an operator audit trail recording privileged administrative actions.
• Pseudonymize identifying fields — student, parent, and referral-source names are replaced with tokens and dates of birth are reduced to age in months — before optional AI-processing calls, per the Privacy Policy.
• Notify you without undue delay — and in any event within 72 hours — if we confirm a breach of the systems we operate affecting your data.
• Assist you, within reason, in honoring data-subject requests (access, correction, export, deletion) through in-app tools or on request.
• Delete or return your data at the end of service per the retention option you select, subject to payment records we must retain under legal hold. The self-serve export in Settings → Data & Privacy is the return mechanism: it produces a ZIP of your practice's records as structured data (uploaded attachment files are listed by name and details rather than copied as files — copies of file attachments are available on request).

Your responsibilities

As controller you are responsible for the lawfulness of the data you place in the service: holding the consents or other authority your practice needs, keeping your own copies of records you must retain, and telling families what tools (including optional AI features) you use on their data.

Subprocessors

The providers we use to deliver the service are listed in the Privacy Policy — currently Render (hosting and managed database), Stripe (billing), Google/Gmail (transactional email), AWS Bedrock (optional AI features only, no-training and no-retention terms), and Microsoft (optional sign-in identity verification). We will update the Privacy Policy before engaging a new subprocessor that touches personal data; you may object to a new subprocessor by contacting us within 14 days of the update. If you object, we will either not engage that subprocessor for your account, make the affected features unavailable to you instead, or — where the subprocessor is essential to the service — let you terminate your account before it takes effect with a pro-rated refund of prepaid, unused fees.

Security & audits

On reasonable request we will make available information demonstrating our compliance with this DPA (for example, current security measures and subprocessor details). Formal on-site audits are not required for beta accounts.

Transfers

We process and store data in the United States, and the service is offered only to practices located in the United States.

Educational records

Where records you enter qualify as education records under FERPA, you confirm you have the authority (parental consent, school contract, or other lawful basis) to place them in the service. We handle them only as a data processor acting on your documented instructions — we do not claim to be a "school official" under FERPA and assert no independent right to use or disclose the records.

Contact

Questions about this agreement: admin@learnersvoyage.com.