Data Privacy

Educational Purpose

ThinkingEngine is an AI-powered Socratic dialogue platform designed to support critical thinking instruction in K-12 classrooms. The platform enables teachers to create discussion topics, engage students in structured reasoning conversations, and receive AI-generated reasoning scores and feedback.

ThinkingEngine is operated as a tool under the direction of classroom teachers. The service is not a consumer app — it is an instructional tool used in an educational context, with teacher-controlled access to all student data.

School and District Agreements

ThinkingEngine can enter into Data Privacy Agreements (DPAs) with school districts as required by district procurement policies or state law. DPAs formalize the roles and responsibilities of ThinkingEngine as a "school official" under FERPA and establish the data handling commitments described in this document and in our Privacy Policy.

To initiate a DPA review or request a template, contact privacy@thinkingengine.org. We will respond to all district inquiries within five business days.

ThinkingEngine has not entered into the Student Privacy Pledge administered by the Future of Privacy Forum, but our data practices align with its commitments regarding data collection, retention, use, and security.

FERPA-Style Education Records

ThinkingEngine is designed so that the data generated through its use qualifies for treatment as education records under FERPA. The platform operates under the "school official" exception:

• ThinkingEngine performs an institutional function for which the school would otherwise have to use its own employees
• The school has direct control over the data, including who can access it and for what purpose
• ThinkingEngine does not use the data for purposes other than those for which disclosure was made

Student dialogue transcripts, reasoning scores, and session records are education records when they are directly related to students and maintained by the school or a party acting for the school — which includes a teacher using the platform as part of instruction.

Schools retain the right to access, review, and request deletion of any student data stored by ThinkingEngine through the teacher dashboard or by contacting privacy@thinkingengine.org.

Ohio Student Data Privacy

ThinkingEngine is operated from Ohio and is subject to Ohio student data privacy law. Ohio has enacted several statutes governing the collection, use, and protection of student data in K-12 schools, including provisions related to data governance, parental rights, and restrictions on data sharing.

ThinkingEngine complies with Ohio student data privacy requirements, including:

• Limited data collection: We collect only the minimum data necessary to operate the service. Students provide a first name or nickname — no other personally identifying information is required.
• No sale or sharing for commercial purposes: ThinkingEngine does not sell, share, or provide student data to third parties for commercial purposes, advertising, or profiling.
• Data security: ThinkingEngine implements technical and organizational safeguards consistent with industry standards. See our Privacy Policy for details on security measures.
• Breach notification: In the event of a data breach affecting student data, ThinkingEngine will notify affected schools and districts as required by Ohio law.

Ohio school districts seeking to verify ThinkingEngine's compliance posture may contact privacy@thinkingengine.org to request documentation, answer questions, or initiate a formal review process.

Access, Export, Correction, and Deletion of Student Records

Students and their parents or guardians have rights to access, review, and request correction or deletion of education records under FERPA and applicable state law. These requests may be directed to the student's teacher or school, who can then submit the request to ThinkingEngine.

ThinkingEngine supports the following data subject requests:

• Access: Schools and teachers can access all student data through the teacher dashboard, including session transcripts, reasoning scores, and usage history.
• Export: ThinkingEngine can provide a machine-readable export of all data associated with a specific student or session upon verified request from the school or district.
• Correction: Teachers can correct student roster data (first name or session associations) at any time through the dashboard. For other corrections, contact privacy@thinkingengine.org.
• Deletion: Schools and districts can request deletion of student data at any time. Deletion requests are processed within 30 days and include removal from active databases and scheduled removal from backups (within the 30-day backup retention window).

To submit a data access, export, correction, or deletion request on behalf of a student or school, contact privacy@thinkingengine.org. For security-related concerns: security@thinkingengine.org.