Legal

Privacy Policy

Effective October 21, 2026 · Updated November 3, 2026 · Applies to arraycourses.com, the ARRAY platform at app.arraycourses.com, and the ARRAY AI Academy apps for iPhone, iPad and Android

The short version
  • Schools and districts own and control student data. We use it only to provide ARRAY to them.
  • We never sell personal information, never show targeted advertising, and never build profiles of students for any non-educational purpose.
  • We do not use student data to train AI models.
  • Ray, our AI teaching assistant, never receives IEP, 504, diagnostic or medical information.
  • Schools can export a student's full record, or remove the student's personal details, at any time. Accommodation delivery records stay with the school until its agreement says to delete them, and backups expire within 14 days.

1. Who we are

ARRAY AI Academy ("ARRAY," "we," "us") provides an AI education platform to K–12 schools and districts. The platform includes the ARRAY Academy curriculum, the Educator Studio and Teacher Ecosystem tools for teachers, inclusion and accommodation-documentation tools, the ARRAY Leadership Network, and district administration tools. Ray is the AI teaching assistant that runs across them.

This policy explains what information we handle, why, and the choices available to schools, families and users.

2. Our role with schools

ARRAY is provided to schools and districts, not sold directly to students. When a school or district uses ARRAY, it decides which students and staff have accounts and what information is provided to us.

  • The school controls student data. Under the Family Educational Rights and Privacy Act (FERPA), we act as a "school official" with a legitimate educational interest, under the school's direct control, and use education records only for the purposes the school authorizes.
  • Agreements come first. Where a school or district has signed a data privacy agreement or contract with us, that agreement governs our handling of its data. If it conflicts with this policy, the agreement controls.
  • Requests go through the school. Parents and eligible students who want to see, correct or delete student records should contact their school. We help the school respond.

3. What we collect

CategoryExamplesSource
Account and roster informationName, school email address, role (student, teacher, administrator), school, classes and enrollmentsThe school or district, its roster system, or the user at sign-up
Student workAssignments, writing drafts and revision history, quiz responses, capstone project entries, reflections and messages with RayStudents, as they use ARRAY
Teacher contentLesson plans, rubrics, syllabi, class settings, seating and private notes, approvalsTeachers
Accommodation recordsApproved supports and records of their delivery (ARRAY Shield)Authorized school staff only
Mentor informationName, organization and contact details of Leadership Network mentorsMentors, through our intake process
Technical informationSign-in events, device and browser type, IP address, error and security logsCollected automatically when the platform is used

4. What we don't collect

  • We don't use webcams, and we don't ask students for personal photos. Students can attach project files (images or PDFs up to 5 MB) to their own capstone.
  • Student avatars are illustrations. We never use student photos or faces.
  • We don't collect precise location, contacts or biometric information.
  • Ray never receives IEP, Section 504, diagnostic or medical information.

5. How we use information

We use information only to provide, secure and improve ARRAY for the schools that use it. That covers:

  • running accounts, classes, assignments, grading tools and teacher workflows;
  • generating AI responses that teachers and students ask for;
  • sending service messages, such as account invitations, sign-in codes and password resets;
  • giving school and district administrators reporting on pacing and usage;
  • keeping the platform secure, preventing misuse, and fixing problems;
  • meeting legal obligations.

Any analysis we do to improve ARRAY uses aggregated or de-identified information, and is never used to identify or target an individual student.

6. AI and Ray

  • Where AI runs. Ray's responses are generated by AI models through Amazon Bedrock, in Amazon Web Services' United States data centers.
  • No training on student data. We do not use student data to train AI models. Amazon Bedrock does not use the prompts and responses we send it to train models.
  • No logging of AI conversations by the model provider. We keep Bedrock's invocation logging turned off. Our own operational logs record that an event happened, not what was said.
  • Protected records are walled off. Ray has no access to IEP, 504, diagnostic or medical records.
  • Teachers stay in control. Ray drafts and suggests. Anything that leaves ARRAY for students, families or another system needs a teacher's approval. Teachers set how much AI help students may use in written work, and students must cite AI help.
  • AI can make mistakes. AI-generated content should be reviewed by an educator before it is relied on.

7. Signing in with Google or Microsoft

If your school lets you sign in with a Google or Microsoft account, we receive only your name, email address and basic profile information from that provider, and use it only to sign you in and match you to your ARRAY account. We do not request access to your email, files, calendar or contacts through sign-in.

ARRAY's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

8. Who we share with

We share information only with service providers that help us run ARRAY, under contracts that limit their use of it to providing services to us, and as described below.

ProviderPurpose
Amazon Web ServicesHosting, database, file storage, sign-in (Amazon Cognito), AI models (Amazon Bedrock) and service email (Amazon SES)
VercelHosting for this public website
Google and MicrosoftSign-in, only if your school enables it

We may also disclose information when the law requires it, to protect the safety of students or others, or in connection with a merger or acquisition. In a merger or acquisition, student data remains subject to this policy and to the school's agreement, and schools will be notified.

Leadership Network mentors never receive students' contact details, and students never receive mentors' contact details. All contact goes through teachers.

9. What we never do

  • Sell personal information or student data.
  • Use student data for targeted or behavioral advertising.
  • Build a profile of a student for any purpose other than the school's educational purposes.
  • Use student data to train AI models.
  • Use real student data in demos, marketing or screenshots. We use synthetic students instead.

10. Retention and deletion

  • We keep school data for as long as the school uses ARRAY, or as its agreement specifies.
  • School administrators can export a student's full record, or permanently remove a student's personal details, at any time. Each of these actions is recorded in an audit trail.
  • When a school or district stops using ARRAY, we delete or return its data as its agreement requires.
  • Operational logs are kept for a short period, currently 14 days, and contain no student content.
  • Accommodation delivery records in ARRAY Shield are append-only, so that they remain a reliable record for the school. They are deleted along with the rest of a school's data when the school's agreement requires it.

11. Security

We protect information with administrative, technical and physical safeguards. These include:

  • encryption in transit (HTTPS) and at rest;
  • role-based access, so each user sees only what their role allows;
  • audit logging of sensitive actions;
  • separate handling of accommodation records.

No system is perfectly secure. If we learn of a security incident affecting school data, we will notify the affected schools and districts promptly and as required by law and our agreements, so they can notify families where required.

12. Your rights

Depending on where you live, you may have rights to access, correct or delete personal information, or to object to certain uses of it.

  • Students and parents: contact your school. Under FERPA and state law, the school decides on requests about education records, and we help it respond.
  • Teachers, administrators and mentors: contact your school, or us at the address below.

California residents: ARRAY is designed to meet the requirements of California's Student Online Personal Information Protection Act (SOPIPA) and Education Code § 49073.1 for student data.

13. Children's privacy

Some ARRAY users may be under 13. In accordance with the Children's Online Privacy Protection Act (COPPA), when a school uses ARRAY with students under 13, the school may consent on behalf of parents to the collection of students' personal information, solely for the school's educational purposes. We use that information only for those purposes. Parents can ask the school to review or delete their child's information.

14. This website

arraycourses.com is an informational website. It has no forms, no analytics and no advertising trackers, and it does not set cookies. The site loads its fonts from Google Fonts, which receives your IP address when your browser requests them. The "Request a briefing" button takes you to a scheduling page operated by a third party. Information you enter there is governed by that provider's privacy terms.

15. Changes to this policy

If we change this policy, we will post the new version here with a new effective date. We will not make a material change to how we handle student data without first notifying the schools and districts we serve, and as their agreements require.

16. Contact us

To delete your account, see Delete your ARRAY account. Questions or requests about privacy: hello@arraycourses.com. Schools and districts can also contact their ARRAY implementation specialist.