Lingua — Privacy Policy

Effective date: October 15, 2026

This Privacy Policy explains how Integra EdTech LLC ("Integra EdTech," "we," "us") collects, uses, protects, and shares personal information in connection with the Lingua platform (the "Service"). It is incorporated into our Terms of Service. If Integra EdTech has signed a data privacy agreement ("DPA") with a school or district (a "School"), that DPA controls over this Policy to the extent they conflict, with respect to that School's student data.

At a Glance

• Lingua is only for people 13 and older. We do not allow accounts for children under 13.
• We collect student information only to provide the Service for the School's educational purposes.
• We never sell personal information, never use student data for advertising of any kind, and never build advertising or non-educational profiles on students.
• Student work — including audio recordings of student speech — is processed by AI to provide grading and feedback. We do not use student, teacher, or any user data to train AI models, and our AI providers are prohibited from doing so.
• Students never receive marketing communications.
• Schools own and control their students' education records; we act as a "school official" under FERPA.
• We delete student personal information at the School's request and when accounts are deleted. Student data from a free trial class is deleted 14 days after the trial ends unless the School upgrades.
• Questions and requests: privacy@linguaclassroom.com.

1. Who This Policy Covers

• Teachers — adults who create accounts to run their classes.
• Students — students 13 and older who use the Service only through a School-administered class. Students never use the Service outside School authorization. No one under 13 may use the Service (Section 8).
• Visitors — people browsing our public pages (which collect essentially nothing; see Section 3.4).

2. Our Role With Student Data

For student personal information, the School controls the data and directs its use; we collect and process it on the School's behalf, solely to provide the Service. Where FERPA applies, we operate as a "school official" with a legitimate educational interest, under the School's direct control with respect to education records. Parents/guardians exercise review, correction, and deletion rights through the student's School (Section 9); we support the School in fulfilling those requests.

3. Information We Collect

Information comes from three sources: provided directly by the user (account details, coursework, recordings), provided by the teacher/School (student names, student IDs, class rosters), or generated by the Service (AI transcripts, grades, feedback, integrity signals). If a user signs in with Google, we receive their name and email from Google.

3.1 Account information

• Teachers: name, email address, password (we never store plaintext passwords — they are hashed by our authentication provider), optional profile photo/avatar, and — only if the teacher connects Canvas — an encrypted Canvas access token and Canvas domain (Section 6.3).
• Students: first and last name, a School-assigned student ID (if the teacher uses one), email address (used for sign-in and essential account emails such as password reset), an optional avatar, and class enrollment (which course/section they belong to).

3.2 Student coursework and educational records

Collected because they are the Service's core function:

• Written work — essay/writing submissions, quiz and comprehension answers, chat conversation text.
• Images of written work — photos/scans a student uploads of handwritten work (for handwriting-based writing assignments).
• Audio recordings of student speech — recordings created during oral assignments, voice conversations, and voice-chat calls, plus AI-generated transcripts of those recordings.
• Grades and feedback — scores, rubric results, AI-assisted feedback, teacher comments, skill points, and progress/level data.
• Study artifacts — notes, highlights, vocabulary practice lists, and helper-chat conversations (e.g., with the Quetzalita study assistant).

3.3 Assessment-integrity signals

When a teacher enables secure testing mode for an assignment, we record limited integrity signals: counts of tab switches and early exits, and detection events for in-browser AI-assistance tools. These are visible only to the assigning teacher and School officials and are used solely for assessment-integrity review by a human teacher. The Service does not webcam-monitor students: although the software includes a camera-monitoring capability, it is disabled platform-wide and unavailable to any teacher, and in its current state the Service does not request camera access or capture, transmit, or store any camera image or video. We would update this Policy and notify Schools before enabling any camera-based feature.

3.4 Technical information

• Authentication cookies — essential session cookies from our authentication provider so users stay signed in. We do not use advertising or third-party analytics cookies.
• Local storage — small on-device preferences (e.g., UI settings) that stay in the browser.
• Infrastructure logs — our hosting and database providers keep standard server logs (e.g., IP address, timestamps) for security and reliability, retained on those providers' standard short-term cycles. We do not use them to profile users.

3.5 Teacher marketplace data

Teachers who use LinguaVerse (our teacher-to-teacher content marketplace) have a public teacher identity there (display name, teacher ID, shared assignment listings, reputation points). Student content is never published to LinguaVerse.

3.6 What we do NOT collect

No advertising identifiers, no precise location, no social-media data, no browsing history outside the Service — and while the Service records student speech for coursework (Section 3.2), we do not create voiceprints or any other biometric identifiers or templates. Public pages (home, blog, tutorials) require no account and set no tracking cookies.

4. How We Use Information

• Provide the Service: host and display coursework, run AI-assisted generation/grading/feedback/transcription, compute grades and analytics for the teacher and student, sync grades to Canvas when the School's teacher enables it.
• Maintain and secure the Service: authentication, abuse and rate-limit protection, debugging, backups.
• Communicate: service emails (e.g., password reset); responses to support/contact requests. Students never receive marketing communications; product updates and offers go only to teachers and School administrators.
• Improve the Service: only using aggregated or de-identified data — never identifiable student records, and never to train AI models (Section 5).

We do not use personal information for targeted or behavioral advertising; we do not build advertising profiles; we do not sell or rent personal information; we do not disclose student personal information except as described in Section 6.

5. AI Processing

The Service's AI features are provided through Google's Gemini models, acting as our service provider:

• What is sent: assignment content and student work needed for the specific feature — e.g., a student essay for grading feedback, a recording of an oral assignment for transcription and rubric evaluation, and, during live voice conversations, the student's audio streamed in real time so the AI conversation partner can respond.
• No AI training: Integra EdTech does not use student, teacher, School, or other user data — including conversations, audio recordings, transcripts, writing, prompts, and AI responses — to train artificial-intelligence models, whether our own or anyone else's. Our AI providers may not use this data to train their models and may use it only to provide the service to us.
• Human in charge: AI output (grades, feedback, integrity flags) is a tool for the teacher, who can review and override it. No automated decision with legal or similarly significant effect is made about a student.

6. When Information Is Shared

We share personal information only in these cases:

6.1 Within the class

Teachers see their students' work, grades, feedback, and integrity signals. Students see their own work and results. Students do not see other students' data.

6.2 Service providers (subprocessors)

Vendors that help us operate the Service, bound to use data only to provide it to us:

We will update this list before adding a subprocessor that handles student personal information and, where a DPA requires, notify the School.

6.3 Canvas (School-directed)

If a teacher connects their School's Canvas LMS and enables grade sync for an assignment, we send that assignment's grade and the student's School ID to the School's Canvas instance. This happens only at the School's/teacher's direction. The teacher's Canvas token is stored AES-256-GCM encrypted and used only server-side.

6.4 Legal and safety

We may disclose information if required by law (e.g., subpoena) — where lawful, we will notify the School before disclosing student data — or to protect the rights, safety, or security of users or the Service.

6.5 Business transfers

If Integra EdTech is involved in a merger, acquisition, or asset sale, personal information may transfer to the successor only subject to the commitments of this Policy (and any DPAs), and Schools will be notified with the opportunity to delete their students' data first.

We never sell personal information to anyone, and we never share student personal information for advertising.

7. Data Retention and Deletion

• While active: student data is retained while the student's enrollment/account is active, so the class can function and the School can access its records.
• Inactive accounts: if an account has had no activity for 12 months, we delete it and its associated data, unless a School or a signed DPA specifies a different period.
• Deletion on request: we delete a student's personal information at the request of the student's School (or a parent/guardian acting through the School) — within 10 business days, except where law requires retention. Requests: privacy@linguaclassroom.com.
• Account deletion: deleting an account removes the user's personal information and content from our production systems — including coursework, enrollment data, and the stored files behind it (recordings, uploaded work images, avatars), which are purged as part of the same deletion process. Residual copies in our database provider's encrypted backups expire on its standard backup-retention cycle.
• Recordings and source audio: audio recordings and images of student work are, by default, retained on the same terms as other coursework (they exist so the teacher can review and grades can be verified) and are covered by the same deletion rights. Where a School prefers, the Service can be configured to delete the source audio recording within 24 hours of transcription and scoring, retaining only the transcript and the score.
• Integrity signals (Section 3.3) are retained with the submission they belong to and are deleted with it — when the submission or account is deleted, or on a Section 7 deletion request.
• Trial classes: a teacher may use the Service with students during a free 14-day Institution trial. When the trial ends, students lose access right away, and 14 days after the trial ends we delete the student data from that teacher's classes (submissions, recordings, uploaded work images, grades, feedback, and enrollments, plus student accounts that were used only in those classes), unless the School upgrades to Institution before then. The teacher's own coursework is kept.
• End of a School relationship: when a School stops using the Service, we delete its students' personal information upon the School's request as described above; a signed DPA may additionally specify an automatic post-termination deletion window, which we will honor.
• De-identified data (with identifiers removed such that a student cannot reasonably be identified) may be retained for product improvement; it is not used to train AI models. We do not attempt to re-identify de-identified data and do not permit recipients to do so.

8. Children's Privacy: No Users Under 13

Lingua is only for people 13 years of age or older. We do not allow anyone under 13 to use the Service, under any arrangement, including with School or parental consent, and we do not knowingly collect personal information from children under 13.

• Students who sign up themselves confirm that they are 13 or older when they create their account. We record only that confirmation and when it was made; we do not collect birthdates.
• Students whose accounts are provided by their School through Canvas (or another School-installed integration) are covered by the School's agreement with us. The School is responsible for giving access only to students who are 13 or older.
• Teachers must not invite students under 13.
• If we learn that we have collected personal information from a child under 13, we will delete the account and its data. If you believe a child under 13 is using Lingua, contact privacy@linguaclassroom.com.

Many students who use Lingua are still minors (ages 13 to 17). For them, we collect personal information only for the School's educational purposes, never for advertising, and parents/guardians may exercise their rights through the School (Section 9).

9. Your Rights

• Schools may access, correct, export, or delete their students' data at any time (much of this is self-serve in the teacher interface; the rest via privacy@linguaclassroom.com).
• Parents/guardians exercise rights for their child through the School (Sections 2, 8).
• Teachers may access and correct their account information in the app and may delete their account (and its data) at any time.
• We will not discriminate against anyone for exercising privacy rights. We do not sell or share personal information as those terms are defined under state consumer-privacy laws, so no opt-out is needed.

10. Security

We maintain reasonable administrative, technical, and physical safeguards appropriate to the sensitivity of the data, including: encryption in transit (TLS) for all connections; encryption at rest by our storage providers; encrypted storage of Canvas credentials (AES-256-GCM); access controls enforced in our application and server code (role-based route gating plus authorization checks on sensitive operations); short-lived signed URLs for access to stored recordings; internal access to personal information limited to personnel who need it to operate the Service, under confidentiality obligations; and the principle that AI providers receive only the data needed for the requested feature. No system is perfectly secure; if we discover a breach of security affecting student personal information, we will notify affected Schools without unreasonable delay, consistent with applicable law, with the information the School needs to meet its own notification duties.

11. Where Data Is Processed

The Service is operated from the United States and data is stored in the United States. If you use the Service from outside the U.S., you understand your information will be processed in the U.S.

12. Changes to This Policy

We may update this Policy from time to time. For material changes, we will provide notice (email to account holders or a prominent in-Service notice) at least fifteen (15) days before the changes take effect. We will not make material changes that weaken protections for previously collected student personal information without the notice and consent that applicable law or the School's DPA requires. The effective date above always reflects the current version.

13. Contact

Integra EdTech LLC 16034 Bella Woods Dr, Tampa, FL 33647

• Privacy, student data, security, and data requests: privacy@linguaclassroom.com
• Legal notices: legal@linguaclassroom.com