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Privacy Policy

 

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Apollo SRM, Inc EdTech Privacy Policy

Last Revised: July 18, 2025

  1. Introduction & Scope

Apollo SRM, Inc (“we,” “us,” “our”) provides an online education platform (“Service”) for schools, students, teachers, and parents. This Privacy Policy explains how we collect, use, share, and protect personal data—including SMS via Twilio—and outlines your rights regarding that data.

  1. Definitions
  • PII: Personally Identifiable Information, e.g., name, email, phone number.
  • Student PII: PII for individuals under 18.
  • School Official Exception (FERPA): Permits certain PII disclosures to providers (ftc.gov).
  1. Information We Collect
  • Registration data: name, role (student/teacher/parent), email, phone number
  • Usage metadata: session logs, quiz responses, grades, timestamps
  • Device/app information: IP address, browser, device type
  • SMS communications: messages sent via Twilio, including timestamps and statuses
  • Children under 13: date of birth for COPPA compliance
  1. How We Collect Data
  • Direct input during sign-up forms
  • Integration with school systems (e.g., LMS/SIS via LTI)
  • SMS opt-in via Twilio with double-confirmation
  1. Legal Basis for Processing
  • Consent: Verifiable parental consent for children under 13 (COPPA)
  • Contract necessity: Providing educational services
  • Legitimate interest: Analytics, fraud prevention, and service improvement
  • Compliance requirement: Legal obligations and dispute handling
  1. How We Use Data

We use data to:

  • Deliver and improve educational features (assignments, SMS alerts, dashboards)
  • Send SMS notifications (course updates, reminders, authentication codes)
  • Comply with FERPA, COPPA, GDPR, CCPA
  • Provide support, detect and prevent fraud
  • Maintain secure and stable service operations
  1. SMS via Twilio

We use Twilio to send SMS messages such as alerts, reminders, and account notifications. All communications follow TCPA and CTIA guidelines.

 

7.1 Data Sharing (Twilio-Specific Requirement)

“We do not share, sell, or disclose your mobile phone number or SMS message content with any third parties or affiliates for marketing or promotional purposes. We only share such information with trusted service providers (e.g., Twilio) to deliver messaging services, or as required by law.”

 

7.2 Consent, Identification & Opt-Out

“By subscribing, you expressly consent to receive recurring SMS messages from Apollo SRM, Inc regarding [e.g., course updates, reminders, account alerts]. Message/data rates may apply. Messages will clearly identify Apollo SRM, Inc as the sender.

To unsubscribe, reply STOP, STOPALL, UNSUBSCRIBE, CANCEL, END, QUIT, REVOKE, OPTOUT, or STOPALL. Upon receipt, you will receive one final confirmation message, and no further messages will be sent unless you re‑subscribe. For support, reply HELP or email support@Apollosrm.com.”

 

  1. Data Sharing & Disclosure

We may share data with:

  1. Schools and educational institutions – to fulfil service delivery
  2. Service providers – like Twilio, hosting, analytics platforms, under data protection agreements
  3. Legal authorities – when legally required or to protect rights
  4. Business transitions – e.g., mergers, acquisitions—with notice

8.1 Student Privacy Compliance

  • FERPA: We act under school authorization and handle student records as directed by contracts
  • COPPA: We obtain verifiable parental consent prior to collecting info on children under 13; parents can review and delete their child's data
  1. Data Retention & Deletion
  • We retain PII and Student PII only as needed for service operation or required by law
  • For children under 13, data can be deleted or anonymized at parental request or account closure
  • Users and parents have the right to access, correct, or delete their data
  1. Security Measures

We safeguard information via AES‑256 encryption (in transit and at rest), access controls, regular security audits, and multi‑factor authentication.

  1. User Rights
  • GDPR: Access, correction, deletion, portability, and objection rights
  • CCPA/CPRA: Right to opt‑out of sale/disclosure and request data deletion
  • FERPA: Parents/students may inspect and restrict use of education records
  • COPPA: Parents may revoke consent at any time
  1. Cookies & Tracking

We use cookies and similar technologies; consent banners and controls are available. Users may disable these via browser settings.

  1. International Data Transfers

For EU/EAA data, we employ Standard Contractual Clauses or equivalent safeguards under GDPR.

  1. COPPA Disclosures
  • Clear notice appears whenever Student PII is collected
  • Parental consent is obtained before data collection
  • Parents may access and delete children’s data
  1. FERPA Disclosures

We comply with FERPA as a school-authorized service provider—only using education records as permitted by contract and applicable law.

  1. Policy Updates

Changes to this policy will be posted with a new “Last Revised” date. Significant updates may also be communicated via SMS, email, or within the platform.

  1. Contact Us

For inquiries, data requests, or privacy concerns:

Apollo SRM, Inc
Email: privacy@apollosrm.com