Privacy policy

1. Our role

• For customer data (the requests, records, correspondence and letters customers and requesters put into perapro), we act on behalf of the agency, school district or firm that uses perapro. That customer decides how its data is used and kept. For school districts, we act as a "school official" under FERPA.
• For information about visitors to perapro.com, people who book a demo, and the staff accounts our customers create, we decide how the information is used, as described here.

If you have a question about a request or a record held by an agency, the agency is usually the right place to start. We'll help it respond.

2. Information we collect

When you file or track a request

• Your name, email address and, if you give it, your phone number.
• What you ask for, any files you attach, and messages between you and the agency.
• If you pay a fee, payment details go directly to our payment provider, Stripe. We receive confirmation of the payment, not your full card number.

When customers use the workspace

• Staff and counsel names, work email addresses, roles and the organization they belong to.
• Sign-in information, handled by our sign-in provider.
• An activity log of what each user does on each request, such as uploads, redactions, letters and releases. The audit trail is part of the product.
• The records customers upload for review and release. These may contain personal information about many people, including students, employees and members of the public.

When you contact us or book a demo

• Your name, work email, organization, role, state, and anything you choose to tell us, plus optional phone number.
• A one-way hash of your IP address, kept to stop spam. We don't keep the IP address itself for demo requests.

Automatically, when you use perapro

• Technical information such as browser and device type, pages viewed and error reports, used to keep perapro working and secure.
• Cookies that keep you signed in and remember settings, and product analytics that tell us which features are used. We don't use advertising cookies or allow ad networks to track you on perapro.

3. How we use information

• To deliver your request to the agency, keep you updated, and let you track it and download released records.
• To provide the workspace to customers: routing, deadlines, review, redaction, letters, payments and release.
• To secure perapro, prevent fraud and abuse, and keep the audit trail.
• To provide support, and to respond to demo requests and questions.
• To improve perapro, using aggregated or de-identified information that can't reasonably be linked to a person.
• To meet legal obligations.

We never sell personal information, use customer data or student data for targeted advertising, or build profiles of students or requesters for any purpose other than providing the service to our customers.

4. Student data and education records

School districts use perapro to respond to records requests, which can involve education records and other student information. When we handle student data for a district, we commit to the following:

• The district owns and controls the data. We use it only to provide perapro to that district, as the district directs.
• We act as a school official under FERPA (20 U.S.C. § 1232g; 34 CFR § 99.31(a)(1)(i)(B)), and don't redisclose education records except on the district's behalf as FERPA permits (34 CFR § 99.33).
• No sale or rental, no targeted advertising, no profiling, and no use to train AI models.
• We collect and keep only what the district's use of perapro needs.
• We maintain a written information security program with administrative, technical and physical safeguards.
• We delete a district's student data within 45 days of the district's request or the end of its subscription, unless the law requires us to keep it or the district tells us in writing to keep it, and confirm deletion in writing on request.
• We notify the district promptly, and within 24 hours of confirming it, of any unauthorized access to or disclosure of its student data, and help it meet its own notification duties.
• We hold our service providers to the same commitments by contract, and anyone who acquires perapro must honor them.
• We don't collect information from students for marketing. Surveys and the other activities covered by the Protection of Pupil Rights Amendment (20 U.S.C. § 1232h) aren't part of perapro.

Parents and eligible students who want to see, correct or ask about an education record should contact their school district, which controls the record. We help districts respond.

5. State student privacy laws

The commitments above are designed to meet the student data privacy laws in the states our customers are in, including:

• Georgia: Student Data Privacy, Accessibility, and Transparency Act, O.C.G.A. § 20-2-660 et seq.
• North Carolina: N.C.G.S. § 115C-401.2 (protection of student information by operators), and the Identity Theft Protection Act's breach notice provisions, N.C.G.S. § 75-65.
• Virginia: Va. Code § 22.1-289.01 (school service providers).
• Tennessee: Student Online Personal Protection Act, T.C.A. § 49-1-708.
• Florida: Student Online Personal Information Protection, Fla. Stat. § 1006.1494.
• Maryland: Student Data Privacy Act, Md. Code, Educ. § 4-131.
• Colorado: Student Data Transparency and Security Act, C.R.S. § 22-16-101 et seq.
• California: Student Online Personal Information Protection Act, Cal. Bus. & Prof. Code § 22584, which many of these laws are modelled on.

Where a district's state law, or its data privacy agreement with us, sets a stricter requirement, we follow the stricter requirement for that district. Districts can ask us for a list of the student data perapro holds for them and how it's used.

6. Children's privacy

perapro's requester portal is a general-audience service for filing public records requests. It isn't directed to children under 13, and we don't knowingly collect personal information from them through it. If we learn that a child under 13 has given us personal information without a parent's consent, we'll delete it, and a parent can ask us to do so at support@perapro.com.

Records about children may be uploaded by a school district as part of responding to a request. That information is the district's, used only for the district's purposes, and handled as described in "Student data and education records". We follow the Children's Online Privacy Protection Act and the FTC's rule under it (15 U.S.C. §§ 6501–6506; 16 CFR Part 312) where they apply, including keeping a written security program and retention policy.

7. How information is shared

• With the agency or school district you file with, and with the staff and outside counsel it authorizes. Outside counsel never contacts requesters; all messages come from the agency.
• With the public, only when the agency decides to release records or the law requires it. Agencies may be required to disclose requests and responses under public records laws.
• With service providers who help us run perapro, under contracts that limit their use of the information to providing their service to us.
• When the law requires it, or to protect the rights, safety and security of perapro, its users or the public. We tell the affected customer first unless the law prevents it.
• In a merger or acquisition, to a successor that agrees to honor this policy for the information we already hold.

8. Our service providers

• Vercel: hosting.
• Supabase: database and file storage.
• Cloudflare: encrypted nightly backup copies of stored files. Files are encrypted with a key held by perapro before they reach Cloudflare.
• Auth0 (Okta): sign-in.
• Postmark: email delivery.
• Stripe: payment processing for request fees.
• Sentry: error monitoring.
• PostHog: product analytics.
• Anthropic: AI-assisted redaction suggestions in the workspace, used only when a customer's staff runs the feature, under terms that don't allow the data to be used to train models.
• Slack: internal alerts to the perapro team about support tickets and demo requests.

We update this list when our providers change, and notify customers in advance where their agreement requires it.

9. Security

• Information is encrypted in transit, and requester personal details are also encrypted at rest in our database.
• Each customer's data is kept separate, with access limited to the people that customer authorizes.
• Redacted records are released as page images, so redacted text can't be copied out.
• Every action on a request is logged with who did it and when.
• We maintain a written information security program, review it at least once a year, and limit our own staff's access to what their role needs.

No system is perfectly secure. If you think your information or an account has been compromised, contact us right away at support@perapro.com.

10. How long we keep information

• Requests and records: as long as the customer keeps them in perapro, following its records retention schedule, and deleted within 45 days after the customer asks or its subscription ends, unless the law requires otherwise.
• Customer staff accounts: while the account is active, then deleted or de-identified, except for entries in a customer's audit trail.
• Demo requests: up to two years after our last contact, then deleted.
• Technical logs and error reports: kept only as long as needed for security and troubleshooting, generally no more than 12 months.

11. Your choices and rights

• Requesters: to see, correct or ask about the information in a request, contact the agency you filed with. You can also write to us and we'll pass it on and help the agency respond.
• Parents and eligible students: contact the school district about education records. FERPA rights are exercised through the district.
• Customer staff: your organization's administrator can update or remove your account.
• Anyone: you can ask us what personal information we hold about you for our own purposes, and ask us to correct or delete it, at support@perapro.com. We'll respond within 45 days. Some state laws give you additional rights, and we honor them where they apply.
• We don't send marketing emails to requesters. If you book a demo, we use your details only to arrange it and follow up, and you can ask us to stop at any time.

12. Where information is stored

perapro is operated in the United States, and customer data is stored in the United States.

13. Changes to this policy

We'll post updates here with a new date. If we make a material change to how we use personal information, we'll give customers at least 30 days' notice before it takes effect and won't apply it to student data we already hold without the district's agreement.

14. Contact us

Privacy questions and requests: support@perapro.com. perapro, Inc.