How we handle student data.

01Who this covers

This policy applies to Whale Talk, the platform made by Overcoded LLC (“Whale Talk”, “we”), which includes littleWhale, teacherCoWork, and teachHub, and to this website. Overcoded LLC is a company registered in New Jersey, in the United States.

It describes how we work with schools in the United States and with visitors to this site. This policy is a general statement: the project contract between Whale Talk and the school governs, and where that contract says something different, the contract applies.

Schools outside the United States are served under separate agreements, by the local operating company, and under the privacy rules of their own country.

02Who owns the data

When a school uses Whale Talk, the school decides why and how its students’ and staff’s personal information is used. The school owns that information. Under FERPA we act as a school official with a legitimate educational interest, working under the school’s direct control.

We process that information only to provide the service, only on the school’s instructions, and only for as long as the school asks. We do not use it for advertising, we do not sell it, and we do not use it to train AI models for ourselves or for anyone else.

03What we process

Information the school gives us, or that the school’s use of Whale Talk produces:

• Students: name, student ID, grade and class, exam scores, any ID number and guardian contact details the school enters, and littleWhale activity such as answers, progress, and level.
• School staff: name, account, phone number, role and permissions, and the requests they make in teacherCoWork along with the files it produces.
• School files: teaching materials, administrative documents, and notices.

Visitors to this website: the name, school or organization, role, email address, and message you choose to send through the contact form. We use it only to reply to you. This site uses no advertising or tracking cookies and no third-party analytics, and it serves its own fonts, so nothing about your visit is sent to another company.

04Where the data lives: in the United States

• teachHub runs on the school’s own servers, inside the school. Student records, scores, school files, and notices stay on campus.
• teacherCoWork’s backend runs on the school’s server too. It reads data through teachHub, within each teacher’s own permissions, and saves the files it creates back into teachHub.
• littleWhale’s learning records — answers, progress, and level — are kept on the school’s own servers as well.

We keep no copy of a school’s data on servers of our own. For US schools, everything we operate alongside them runs in the United States, and their student data neither leaves the school nor leaves the country.

05How AI features use data: models in the United States

teacherCoWork calls large language models to understand a teacher’s request and produce the finished work. To do that, the request and the data needed to complete it, which can include student names and scores, are sent to the model provider the school and we have agreed on.

• The model providers are agreed between the school and us. For a school in the United States, we put forward providers that serve the requests in the United States, and the school makes the call.
• We require providers not to train models on this data and not to use it for anything beyond completing the request.
• A teacher can only reach the data their teachHub permissions already allow. teacherCoWork never works around those permissions.
• The computing we run ourselves, such as producing explainer videos and tuning our own models, runs on GPUs in the United States.

06Sharing

• We share personal information only with the model providers agreed with the school, and with service providers who work for us under contract, on the same terms.
• We do not sell personal information, and we do not disclose it publicly.
• We may disclose information if the law requires it, and we will tell the school unless the law forbids it.

07Students under 13, and student privacy law

Most of our users are K-12 students. We take only the information teaching requires, and we follow the Family Educational Rights and Privacy Act (FERPA), the Children’s Online Privacy Protection Act (COPPA), and the student privacy laws of the states our schools are in.

• The school obtains parental consent before students use Whale Talk, and how it does so is set out in the project contract. For students under 13, the school gives that consent on behalf of parents for educational use, as COPPA allows. Parents can ask the school to review or delete their child’s information.
• We never show students behavioral advertising, and we never build profiles of them for anything other than their own learning.
• The wellbeing early alerts we are building will only raise a signal for the school’s own counselor to review. They are never a diagnosis, and the data behind them never leaves the school.

08How we protect it

• teachHub runs on the school’s own servers, so the data stays in the school’s hands.
• Access follows each person’s role: everyone sees what their role needs, and nothing more.
• Sensitive details such as ID numbers and family phone numbers are encrypted in the database.
• An audit log records who changed what, and when.
• littleWhale and teacherCoWork sign in through teachHub and follow the same permissions.
• Because a school’s data stays on its own servers, we hold no copy that could be exposed on our side. If we learn of anything that puts a school’s data at risk, we tell the school right away.

09Keeping and deleting

• A school’s data stays on the school’s own servers and belongs entirely to the school, which also decides how long to keep it. We hold no separate copy, so there is nothing on our side to return or delete.
• Messages sent through this website are kept for 30 days after we reply, then deleted.

10Your rights

Parents and eligible students have the right to see, correct, and ask for deletion of a student’s records. Because the school owns those records, please start with the school; we help the school answer promptly.

Visitors to this website can ask us to show, correct, or delete what they sent through the contact form, using the contact details below. Depending on where you live, state law may give you further rights, and we honor them.

11Changes to this policy

We may update this policy as the law or the product changes. We will describe any significant change on this page and tell partner schools directly. The date at the top always shows the latest update.

12Contact us

If you have any question about this policy or about how we handle personal information, write to us. We read every message.