Last updated: June 25, 2026
CoPilot Data Solutions LLC ("CoPilot Data," "we," "us," or "our") provides a software-as-a-service platform that helps Texas public school districts manage and analyze state accountability data. This Privacy Policy explains how we handle information when you visit our marketing website at https://www.copilotdata.com, when our platform at https://connect.copilotdata.com is used by school districts and their staff, and when parents or guardians use our text-message (SMS) assistant.
This policy is intended to be read together with the agreements we sign with each school district, including any Data Privacy Agreement (DPA), and together with our separate Terms and Conditions at https://www.copilotdata.com/terms-and-conditions and our SMS Terms of Use at https://www.copilotdata.com/sms-terms, which govern the mobile messaging program. Where a school district has signed a DPA with us, that DPA controls over this Privacy Policy with respect to student and education data. See Section 17 (Order of Precedence).
CoPilot Data Solutions LLC is a Texas limited liability company, classified for federal tax purposes as an S corporation (effective January 1, 2026) and treated as a single-member LLC under Texas law.
Our customers are Texas public school districts. We sell our platform business-to-business; we do not sell a product directly to students, parents, or guardians.
We handle two distinct categories of data, and our role differs for each.
This is the data a school district provides to us, or that is generated through the district's use of our platform, including student education records and personally identifiable information (PII). For this category:
We process District and Student Data only on the district's behalf and under its documented instructions, and only for the authorized educational purpose described in Section 5.
This is the data we collect directly through our marketing website, through the administration of district staff accounts, and through our parent/guardian SMS assistant, such as contact details, login information, website usage data, parent/guardian mobile phone numbers, and the content of text messages exchanged with the assistant. For this limited category, CoPilot Data is the controller. This category does not include student education records, which remain District and Student Data under Section 2.1.
We operate under the direct control of each school district with respect to the use and maintenance of education records (34 CFR 99.31(a)(1)(i)(B)). The district determines how its records are used, maintained, retained, and disclosed.
We will not unilaterally or silently change the way we handle District and Student Data in a way that conflicts with a district's instructions or its DPA. Material changes to our data-handling practices or to this Privacy Policy are communicated to districts and clearly flagged, not buried (see Section 16). This protects each district's ability to demonstrate the direct control that FERPA requires.
Working on behalf of districts, we process:
Under Texas Education Code 32.151, "covered information" expressly includes test results, photographs, voice recordings, geolocation, text messages, and student identifiers. Accordingly, assessment data, student photographs, and SMS message content tied to a student are "covered information" and receive the full protections of Chapter 32.
For the parent/guardian SMS assistant (see Section 7), we process:
When you visit our marketing site, we may collect standard usage and device information (such as IP address, browser type, and pages viewed) and any information you submit through contact or demo-request forms.
We use PII from education records only for the purposes for which the district disclosed it to us — namely, to deliver and support the contracted accountability-analytics and SMS services for that district — and for no other purpose (34 CFR 99.31(a)(1)(i)(B)(1); 34 CFR 99.33(a)(2); Texas Education Code 32.154).
We make the following affirmative commitments regarding student data:
These commitments are explained further in Section 6.
We do not, and will not, sell or rent any student's covered information or PII (Texas Education Code 32.152(a)(3)).
The only exception is the narrow successor-in-interest exception permitted by Texas Education Code 32.152(c): the transfer of student covered information to a successor entity in connection with a merger, acquisition, bankruptcy, or other acquisition or sale of all or a portion of CoPilot Data Solutions LLC. Such a transfer is permitted only if the successor entity continues to be subject to the same commitments and obligations with respect to that covered information as those set out in this Privacy Policy and in the applicable district DPA. We will not use this provision as a route to a general data sale. Any such transfer involving a district's student data will be handled consistent with the district's DPA, including the TX-NDPA's successor-and-assignment provisions, and the district retains the right under that DPA to disapprove the successor and terminate if it does not consent to the assignment.
We do not use covered information or PII (including persistent identifiers) to engage in targeted advertising to students or their parents, and we do not allow any third party to do so using data acquired through the service for a school purpose. "Targeted advertising" means presenting advertisements selected based on information obtained or inferred over time from a student's online behavior, usage, or covered information (Texas Education Code 32.151, 32.152(a)(1)).
We do not amass covered information to build a profile about a student except for a school purpose. We will not create profiles for advertising or for any commercial purpose unrelated to the contracted educational service (Texas Education Code 32.152(a)(2)). Adaptive, customized, and personalized academic recommendations made to support a student's education — including the academic-progress replies sent through the SMS assistant — are a permitted school purpose and are not "profiling."
Student PII and SMS message content are not used to train or fine-tune any machine-learning or artificial-intelligence model. Our AI sub-processors are one or more third-party AI / large-language-model providers that process content transiently through their application programming interfaces (APIs) solely to generate a response, and they are contractually prohibited from retaining that content for, or using it in, model training. We identify our current AI providers to each school district in the Data Privacy Agreement and notify the district of material changes. This keeps the SMS feature within the "authorized educational purpose only" boundary required by FERPA, COPPA, and Texas Education Code Chapter 32.
Student data is never used to train advertising systems, sold or shared via data brokers, or combined with non-educational datasets — even in de-identified form — beyond the limited, disclosed product-improvement uses described in Section 12.
The mobile messaging program is also governed by our separate SMS Terms of Use at https://www.copilotdata.com/sms-terms, which set out the program description, opt-in welcome message, message frequency, rate disclosures, and STOP/HELP instructions in full. This Section 7 summarizes the privacy-relevant terms.
Each district is assigned a dedicated sender phone number that parents and guardians can text to ask about their own student's academic progress and state assessment results. An automated AI assistant replies and can connect the texter to district staff. Parents and guardians opt in directly — they initiate contact or affirmatively sign up themselves — and we send messages only to people who have opted in or who text us first. CoPilot Data and our messaging carrier (Twilio) do not send unsolicited program messages. The district configures the program for its campuses and supplies the parent/guardian contact information used for the identity-verification gate described in Section 7.4.
We collect the parent/guardian mobile phone number, the content of the messages exchanged, and opt-in/consent records. We use this information only to operate the SMS service and to connect users to district staff.
Two different authorizations apply to the SMS feature, and they are not the same thing. Both must be satisfied before any student-specific text is sent, and one is never treated as standing in for the other:
For students under 13, the district's school authorization additionally serves as the COPPA consent basis for our collection and use of the student's information through the service (see Section 13).
Responding to a texter with a specific student's education records is itself a FERPA disclosure that occurs under the district's authority (34 CFR 99.31(a)(1); 34 CFR 99.33(a)). Before disclosing any student-specific information, the assistant verifies that the texter is an authorized parent, guardian, or eligible student for that specific student by matching the incoming mobile number against a parent/guardian contact number the school district has on file for that student and completing a one-time passcode (OTP) challenge sent to that number. If the number is not on file, or the OTP is not satisfied, the assistant discloses no student records and routes the texter to district staff. The assistant discusses only that student's own records and connects users to district staff for anything beyond the authorized scope. We do not ship or operate the SMS assistant for a district without this verification gate in place.
Replies from the SMS assistant are generated by a third-party AI / large-language-model provider for informational purposes. They may contain errors and are not a substitute for the district's official records or for advice from district staff. For authoritative answers, contact your district.
No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing with subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third party.
Additional terms for the messaging program (see also the full SMS Terms of Use at https://www.copilotdata.com/sms-terms):
Parent/guardian phone numbers and message content are processed only to operate this service. They are never sold and are never used for marketing.
We do not disclose or redisclose PII from education records to any other party without the prior written authorization of the district, except as otherwise permitted by FERPA or required by law (34 CFR 99.33(a)(1)). If we are compelled by law to disclose student data, we will notify the district before disclosure unless legally prohibited from doing so.
We use the following sub-processors and infrastructure providers to deliver the service:
| Sub-processor | Function | Notes |
|---|---|---|
| Google Cloud Platform / Firebase | Hosting, database, file storage | Data stored in the United States (us-central1 region) |
| Twilio | SMS message delivery | Processes phone numbers and message content to deliver texts at the district's direction |
| Third-party AI / large-language-model provider(s) | AI natural-language processing of messages | Processes content via API; contractually bound not to train on or retain the data; current providers identified to districts in the DPA |
Each sub-processor is bound by a written agreement that flows down our obligations to it, requiring confidentiality, security, purpose limitation, no AI-model training on the data, and no onward redisclosure, and permitting the sub-processor to use the data only to provide services to us (Texas Education Code 32.153, 32.155). The AI providers process content via their APIs and do not train their models on the data. We maintain this list and will notify districts of material changes to it.
All District and Student Data, and all SMS phone numbers and message content, are stored and processed within the United States on Google Cloud / Firebase in the us-central1 region. We do not store student covered information or SMS data outside the United States, consistent with our DPA commitments (including TX-NDPA Article V). Where a sub-processor could route data outside the U.S., we configure the service to keep the data in U.S. regions, and we will not change that configuration in a way that conflicts with a district's DPA.
We maintain a written information-security program with administrative, technical, and physical safeguards appropriate to the sensitivity of the data (Texas Education Code 32.155; 16 CFR 312.8 as amended, including the 2025 COPPA amendments). These include:
Our security program follows widely recognized information-security practices for handling sensitive student data. CoPilot Data does not currently hold a third-party security certification or attestation such as SOC 2 (Type I or Type II) or ISO/IEC 27001, and we do not represent that we hold any such certification. We will update this section if that status changes.
On a district's request, we will make summary results of any security assessment we have conducted available to that district. In addition, consistent with TX-NDPA Article V.2, a district (or its designated auditor) may, under a reasonable nondisclosure agreement and on reasonable advance notice, audit our compliance with the security and privacy obligations applicable to that district's data once per year, and additionally following a security incident affecting that district's data. We will cooperate reasonably with any such audit.
If we discover or are notified of a security incident or breach involving student PII, we will notify the affected district within 72 hours of confirming the incident, consistent with the TX-NDPA, unless a law-enforcement agency directs a delay. Our notice will describe what was involved, the date or date range of the incident, the remediation taken, and the steps to protect affected individuals. Where the applicable DPA (including the TX-NDPA) specifies a shorter notification requirement, that shorter requirement controls (see Section 17).
We will cooperate with the district's breach-response and notification obligations, including a Texas district's obligations to report to the Texas Education Agency and to affected parents (Texas SB 820; Texas Business & Commerce Code Chapter 521).
We retain student PII only as long as necessary to provide the contracted service or as the district directs — not indefinitely.
For the SMS assistant, phone numbers and message content are retained only as long as needed to provide the service, and are deleted within 60 days after the district's contract ends or upon request (whichever comes first), on the same basis as other data under the district's control.
We may use de-identified or aggregate data to maintain, support, evaluate, and improve the service and to demonstrate its effectiveness, consistent with FERPA (34 CFR 99.31(b)) and Texas Education Code 32.154. When we do:
Because our platform processes the records of K-12 students, including students under the age of 13, the federal Children's Online Privacy Protection Act (COPPA) applies.
For students under 13, we rely on the school/district's authorization (with the district acting as agent for the parent) as the COPPA consent basis. This basis is valid only because the data is collected and used solely for the school-authorized educational purpose and for no other commercial purpose. Consistent with COPPA and the FTC's COPPA Rule (16 CFR Part 312, including the 2025 amendments effective June 23, 2025, with full compliance required by April 22, 2026):
We acknowledge that any targeted advertising, commercial profiling, undisclosed third-party disclosure, or failure to provide the required notice and review-and-delete ability would void our ability to rely on school consent.
We collect only the minimum student PII needed to perform the contracted function (data minimization), consistent with COPPA's collection-limitation principle and recognized education-privacy best practice (16 CFR 312.7, 312.10).
FERPA gives parents — and "eligible students" (students who are 18 or older, or who attend a postsecondary institution) — the right to inspect and review, and to seek amendment of, the student's education records (20 U.S.C. 1232g(a)(1)(A); 34 CFR 99.10–99.12, 99.20–99.22). These rights are exercised through the school district, not through CoPilot Data.
We do not respond to parent or eligible-student record-access or correction requests directly. If we receive such a request, we route it to the district. We support the district by making the records we hold available to it so the district can verify the requester's identity and respond (generally within 45 days, as FERPA requires; sooner where a Texas district's DPA or state law sets a shorter window).
When a student turns 18 or enrolls in a postsecondary institution, FERPA rights transfer from the parent to the student. Access and amendment requests for those students are still routed through the district.
We treat data as "directory information" only as each district has designated and publicly noticed it, and we honor any parent or eligible-student opt-out from directory-information disclosure that the district conveys to us (34 CFR 99.3, 99.37). We do not treat any student data as directory information on our own initiative, and we do not disclose it as directory information without the district's instruction. This includes any display of student names or photographs and any element used in the SMS feature.
Districts direct our handling of their data through their contract and DPA, including issuing data-deletion or data-return requests, configuring the SMS program, and submitting or relaying data-subject requests.
Because parents and guardians opt in to the SMS assistant directly, they can also end that messaging relationship directly at any time by replying STOP (see Section 7.6). This is separate from, and in addition to, the record-access rights they exercise through the district.
If any survey or assessment data we process ever touches one of the protected categories under the Protected Pupil Rights Amendment (PPRA), it is administered under district control, with the district handling any required parental notice or consent.
We may update this Privacy Policy from time to time. We maintain version history and a change log, and the "Last updated" date at the top of this policy reflects the most recent revision. For material changes affecting District and Student Data, we provide advance notice to affected districts and clearly flag the change, rather than changing terms silently.
For student and education data, where a school district has executed a Data Privacy Agreement (DPA) with us, that DPA controls over this Privacy Policy and over our general Terms and Conditions in the event of any conflict regarding privacy, security, breach, data ownership, audit rights, data residency, and data return or deletion.
CoPilot Data signs each district's Texas Student Data Privacy Agreement — the SDPC / Texas Student Privacy Alliance instrument commonly called the TX-NDPA — and that signed district agreement is the controlling DPA. The order of precedence is: (1) the executed TX-NDPA (or other district-provided DPA) and its exhibits; (2) the signed order form or master subscription agreement; (3) our Terms and Conditions and SMS Terms of Use; and (4) this Privacy Policy and other policies incorporated by reference.
Two independent reasons may place CoPilot Data outside the substantive scope of the Texas Data Privacy and Security Act (TDPSA):
Regardless of whether either exclusion applies, we follow TDPSA processor norms for the data we handle. The non-education-record data the SMS feature introduces — a parent's or guardian's own phone number and message content — is the parent's consumer data rather than a student education record, and we handle it consistent with the TDPSA's processor obligations. Consistent with the TDPSA, we do not sell sensitive personal data.
This Privacy Policy and our relationship with you are governed by the laws of the State of Texas, without regard to conflict-of-laws principles.
Questions about this policy, or requests relating to data security and privacy, may be directed to:
CoPilot Data Solutions LLC
608 E Hickory St, Ste 128
Denton, TX 76205
info@copilotdata.com
(817) 752-4766
This Privacy Policy is subject to ongoing legal review and may be updated to reflect changes in applicable law or our practices.
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