Privacy Policy

1. Who We Are

Education Management Studio (d/b/a “EMStudio,” “we,” “us,” or “our”) operates the EMStudio platform at emstudio.pro, an education management application for teachers, private tutors, and educators.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform. By accessing or using EMStudio, you agree to the terms of this Privacy Policy and our Terms of Service. If you do not agree, please do not use the platform.

For questions about this policy, contact us at info@emstudio.pro.

2. Data We Collect

Teacher Account Data

When you create an account, we collect:

Account information: name, email address, password (hashed), profile picture
Subscription information: billing email, payment method (via Stripe — we never see your full card number), subscription status
Preferences: language, theme, notification settings

Student Education Records

Teachers enter student data into EMStudio as part of their educational workflow. This data may include:

Identity: student first and last name, student ID, profile photo
Contact: student email, parent/guardian email, phone number, address
Academic: grades, assignments, attendance records, behavioral notes, report cards. These constitute education records under FERPA.
Organizational: class enrollment, semester assignment, group membership

Student data belongs to the school

EMStudio does not own student data. Teachers enter this data under the authority of their school. If a school designates EMStudio as a school official under FERPA, we process the data solely on the school's behalf. See our Data Processing Addendum for the formal terms.

Lesson & Curriculum Content

Teachers create lesson plans, unit plans, assignments, tasks, and notes within EMStudio. This content is teacher-authored and remains the teacher's intellectual property. See our Terms of Service for ownership details.

File Uploads

Teachers may upload files (documents, images, attachments) to lessons and assignments. These files are stored in Cloudflare R2 and are only accessible to the uploading teacher.

Special Category Data

We do not intentionally collect special category data (health, disability, religion, ethnicity). However, teachers may enter IEP/504 notes, medical accommodations, or other sensitive information in student notes fields. If they do, we process this data under the same legal basis and with the same protections as all other student data — it is never shared, sold, or used for any purpose beyond the teacher's educational use. See our 12 privacy commitments for how we safeguard sensitive data.

3. Information Collected Automatically

When you use EMStudio, we may automatically collect:

Device information: browser type, operating system, screen resolution
Usage data: pages visited, features used, clicks, time spent (via PostHog, only with your consent in regions that require it)
Log data: IP address, request timestamps, error logs (IP addresses are not stored long-term; error logs are scrubbed of personally identifiable information). See our Security page for how we protect log data.

We do not collect biometric data, precise geolocation, or browsing activity outside of EMStudio.

4. Information from Third Parties

We receive limited information from third-party services you choose to connect:

Google or Microsoft sign-in: name, email address, and profile picture from your OAuth provider. We never access your contacts, calendar, drive, or any other data from your Google or Microsoft account.
Stripe: billing email, last four digits of your card, country, and subscription status. We never receive or store your full card number. See Stripe's privacy policy for how they handle payment data.

5. How We Use Your Data

We process your data for the following purposes:

Service Delivery

Provide, maintain, and improve EMStudio's features
Authenticate your identity and manage your account
Process payments and manage subscriptions
Deliver AI-powered lesson planning assistance (see Section 13)

Communication

Send transactional emails (password resets, subscription confirmations)
Respond to support requests
Send product updates and tips (only with your opt-in consent — see Section 15)

Safety & Compliance

Detect and prevent fraud, abuse, and security incidents
Comply with legal obligations
Enforce our Terms of Service

Product Improvement

Analyze aggregated, anonymized usage patterns to improve the product (only with consent where required)
We never analyze individual student data for product improvement

What we never do with your data

Sell or rent personal information to anyone
Use student data for advertising or behavioral targeting
Build profiles about students for non-educational purposes
Train AI models on your content or student data
Share data with data brokers

6. Legal Basis for Processing

Under the GDPR and similar laws, we process data on the following bases:

Purpose	Legal Basis
Providing the EMStudio service	Contract (Art. 6(1)(b))
Processing student data on behalf of a teacher/school	Contract + school authorization
Payment processing	Contract (Art. 6(1)(b))
Analytics (PostHog, GA)	Consent (Art. 6(1)(a))
Marketing emails	Consent (Art. 6(1)(a))
Security & fraud prevention	Legitimate interest (Art. 6(1)(f))
Legal compliance	Legal obligation (Art. 6(1)(c))

We do not rely on “legitimate interest” as the legal basis for processing children's data. For student data, we act as a processor on behalf of the teacher or school (the controller), under their contractual authorization. See our GDPR compliance page for details.

7. Children's Data

EMStudio is designed for teachers, not for children to use directly. However, teachers enter data about their students, some of whom may be under 13. We comply with the FTC's COPPA Rule and FERPA requirements for student data.

Under COPPA (the Children's Online Privacy Protection Act), we rely on the school authorization exception: teachers represent in our Terms of Service that they have authority under their school's policies to enter student data, and that any required parental consents have been obtained through the school's own process.

We protect children's data with these commitments:

No behavioral advertising or profiling of students
No selling or renting of student data
No use of student data for AI model training
Data minimization — we only store what the teacher enters
Deletion when the teacher removes the data or closes their account
Parents may request review or deletion of their child's data through the school or teacher

For complete details, see our dedicated COPPA compliance page and FERPA alignment page.

We share data only with the service providers (“sub-processors”) necessary to operate EMStudio. We do not sell, rent, or trade your data. Every sub-processor is under contractual obligations to protect your data, as detailed in our Data Processing Addendum.

Vendor	Purpose	Data Shared
Supabase	Database & authentication	All app data
Cloudflare R2	File storage	Uploaded files
Stripe	Payment processing	Billing email, card details
OpenRouter (Google Gemini)	AI lesson assistance	Lesson title, subject, preview — no student data
PostHog	Product analytics	Usage events (consent required)
Vercel	Hosting	Request metadata

For the complete list with data locations and links to each vendor's privacy policy, see our Sub-Processors page.

We may also disclose data when required by law, subpoena, or court order, or when necessary to protect the safety of our users or the public.

9. International Data Transfers

EMStudio is operated from the United States. If you are accessing the platform from outside the US (including the EU, UK, or other jurisdictions), your data will be transferred to and processed in the United States.

For EU/UK users, we rely on Standard Contractual Clauses (SCCs) as the legal mechanism for these transfers, as described under GDPR Article 46 and incorporated into our Data Processing Addendum. Our sub-processors maintain their own data transfer safeguards as detailed on our Sub-Processors page.

10. Data Retention

We retain your data only as long as necessary for the purposes described in this policy:

Data Type	Retention Period
Teacher account data	Until account deletion
Student records	Until teacher deletes them or closes their account
Soft-deleted records (classes, students, lessons)	30 days, then permanently purged
Uploaded files	Until parent record is deleted
Error logs	90 days
Payment records	As required by tax law (typically 7 years)
Analytics data	Aggregated and anonymized

When you delete your account, we permanently erase all your data — including student records, files, grades, and attendance — from our systems and all sub-processors within 30 days. You can also export your data at any time from Settings.

11. Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

Right of access (Art. 15): Request a copy of all data we hold about you. Use the “Export Data” button in Settings for instant access.
Right to rectification (Art. 16): Correct inaccurate data. You can edit your profile, student records, and all content directly in the app.
Right to erasure (Art. 17): Delete your account and all associated data. Use the “Delete Account” option in Settings.
Right to restriction (Art. 18): Request that we limit processing of your data in certain circumstances. Contact us to exercise this right.
Right to data portability (Art. 20): Receive your data in a structured, machine-readable format (CSV files in a ZIP). Available via Settings > Export Data.
Right to object (Art. 21): Object to processing based on legitimate interest. Contact us to exercise this right.
No automated decision-making (Art. 22): We do not make any decisions about you based solely on automated processing. Our AI features are tools that assist teachers — they do not make decisions about students.

We respond to all data rights requests within one month (GDPR) or 45 days (CCPA). We will never charge a fee for exercising your rights or discriminate against you for doing so.

12. How to Exercise Your Rights

You can exercise most rights directly in the app:

Access & export: Settings > Export Data
Rectification: Edit your profile, students, lessons, or any content directly
Erasure: Settings > Delete Account
Cookie preferences: Update via the cookie consent banner or Settings. See our Cookie Policy for details.

For rights that require manual processing (restriction, objection), or if you need assistance, email us at info@emstudio.pro. We may ask you to verify your identity before processing your request.

13. AI Features & Data

EMStudio includes an optional AI assistant that helps teachers plan lessons. Here is exactly what happens with your data when you use AI features:

What we send to the AI

When you use the AI chat, we send only:

Lesson title
Subject
Class name
Date
A preview of your lesson content (with emails, phone numbers, and other PII automatically scrubbed)

What we never send to the AI

Student names, grades, attendance, or any student data
Parent contact information
Your email, password, or payment information

AI provider

We use OpenRouter to route requests to Google Gemini. OpenRouter operates under a zero-retention policy — your prompts and responses are not stored or used for training after the request completes.

We never train AI on your data

Your lesson content, student data, and all other information in EMStudio is never used to train, fine-tune, or improve any AI model — ours or any third party's. This is a permanent commitment.

You can disable AI features entirely from your profile settings. See our Transparency page for the complete data flow diagram.

14. Cookies & Tracking

EMStudio uses only essential cookies for authentication and session management. Analytics cookies (PostHog, Google Analytics) are only activated with your explicit consent in regions where consent is required (EU, UK, California).

We never use advertising cookies, tracking pixels, or third-party cookies for behavioral targeting.

For full details, including a per-cookie inventory table, see our Cookie Policy.

15. Marketing Communications

We only send marketing emails (product tips, feature announcements) if you explicitly opt in. You can unsubscribe at any time via the link in any email or from your account settings.

Transactional emails (password resets, subscription confirmations, security alerts) are not considered marketing and will always be sent regardless of your marketing preferences.

16. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

Categories of personal information we collect

Identifiers (name, email, IP address)
Commercial information (subscription status, payment history)
Internet activity (pages visited, features used — with consent only)
Education information (student records entered by teachers)

We do not sell or share your personal information

EMStudio does not sell personal information as defined by the CCPA. We do not share personal information for cross-context behavioral advertising.

Your California rights

Right to know: Request the categories and specific pieces of personal information we have collected. Use Settings > Export Data.
Right to delete: Request deletion of your personal information. Use Settings > Delete Account.
Right to correct: Request correction of inaccurate information. Edit directly in the app.
Right to opt-out of sale/sharing: We do not sell or share, but you can contact us at info@emstudio.pro for any questions.
Right to non-discrimination: We will never deny service, charge different prices, or provide different quality because you exercised your privacy rights.

Submission methods

You can submit requests via Settings (export/delete) or by emailing info@emstudio.pro. We respond within 45 days.

Shine the Light (Civil Code §1798.83)

We do not disclose personal information to third parties for their direct marketing purposes.

California minor erasure rights (Business & Professions Code §22581)

If you are a California resident under 18, you can request removal of content you posted by contacting us at info@emstudio.pro.

17. Data Breach Response

In the unlikely event of a data breach that poses a risk to your rights and freedoms:

We will notify the relevant supervisory authority within 72 hours of becoming aware of the breach (GDPR Art. 33)
We will notify affected users without undue delay if the breach is likely to result in a high risk to their rights (GDPR Art. 34)
If we have a school relationship via a DPA, we will notify the school within 24 hours
Our notification will include: what happened, what data was affected, what we are doing about it, and what steps you can take

For full details on our incident response procedures, see our Security page.

18. Your Right to Complain

If you believe we have not handled your data correctly, you have the right to lodge a complaint with a data protection supervisory authority in your jurisdiction. For EU users, you can find your local authority at edpb.europa.eu. For UK users, contact the Information Commissioner's Office (ICO).

We'd prefer you contact us first at info@emstudio.pro so we can try to resolve the issue directly.

19. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you via a notification in the app and update the “Last updated” date at the top of this page. For significant changes that affect how we handle student data, we will provide at least 30 days' advance notice. Our Transparency page documents all historical changes to this policy and our data practices.

We will never change this policy to be less protective of student data without notifying affected users.

20. Contact Us

For questions about this Privacy Policy, your data, or to exercise your rights:

Education Management Studio
d/b/a EMStudio
Email: info@emstudio.pro