SMS Terms.

Last updated: June 25, 2026

1. Program Overview

These SMS Terms & Conditions ("SMS Terms") govern the text-messaging program operated by CoPilot Data Solutions LLC ("CoPilot Data," "we," "us," or "our") on behalf of participating Texas public school districts.

CoPilot Data Solutions, on behalf of your school district, sends and receives text messages so that parents, guardians, and eligible students can ask about their own student's academic progress and Texas state assessment results, and be connected to district staff. An automated AI assistant replies to your messages and can hand the conversation off to district staff when appropriate.

This program is informational and conversational (a customer-care program). It is not a marketing program. CoPilot Data does not use this program to advertise or promote products or services to you.

2. Consent and How You Join

2.1 How you opt in

You join this program by taking one of these actions yourself (parent-initiated):

• by sending a text message to the phone number published by your school district (an inbound, parent-initiated message); or
• by completing a sign-up made available by your school district (for example, a sign-up form or checkbox) where you affirmatively consent to receive text messages about your student.

Your consent to receive text messages is voluntary and is not a condition of any product, service, enrollment, or educational benefit. You can decline or opt out at any time and continue to receive all district services through other channels. Your consent is specific to your district's program and is not shared across districts.

2.2 Who is responsible for consent (TCPA)

• For messages you start (inbound): When you text the district-published number, you are initiating contact and consenting to receive replies from the AI assistant and district staff in that conversation.
• For messages the district starts (outbound): Your school district is responsible for obtaining and documenting your prior express consent before sending you any non-solicited outbound text messages, in compliance with the Telephone Consumer Protection Act (TCPA). CoPilot Data and its messaging carrier (Twilio) send outbound messages only at the district's direction and only to recipients the district represents have consented. CoPilot Data does not independently market to you or text you without a basis the district has established.

2.3 Where consent is documented

The record of your opt-in is maintained in the messaging platform's inbound-consent log (for texts you send to the district-published number) or in the district's sign-up system (for sign-ups you complete). A copy of these SMS Terms and our Privacy Policy is available at the URLs in Section 16 at the time you opt in.

By texting the district-published phone number, or by completing a district sign-up, you agree to these SMS Terms.

3. How the Program Works

• Parents, guardians, and eligible students text a phone number published by their school district, or opt in through a district sign-up.
• An automated AI assistant reads your message and replies with information about your own student's academic progress and state assessment results, or connects you to district staff.
• The assistant will only discuss the student you are authorized to receive information about, and only after your identity has been verified as that student's parent, guardian, or eligible student under the district's authority and instructions. Before any student-specific information is shared, we verify your identity by matching your mobile number to a parent or guardian number the district has on file, and confirming a one-time passcode (OTP) sent to you. No student record is disclosed until this verification succeeds.
• The school district owns and controls the student records involved and authorizes this messaging program. CoPilot Data operates the program as a service provider acting under the district's direction (see Section 9).

4. Message Frequency, Rates, and Carriers

4.1 Message frequency

Message frequency varies. You will generally receive messages in response to your own texts, plus occasional service or confirmation messages.

4.2 Message and data rates

Message and data rates may apply for any messages sent to you from us and to us from you. Contact your wireless provider with questions about your text or data plan.

4.3 Carrier registration (A2P 10DLC)

This program is delivered over carrier networks using application-to-person (A2P) 10DLC messaging. CoPilot Data registers a single brand (CoPilot Data Solutions LLC) and one messaging campaign for this program with The Campaign Registry (TCR) through its messaging provider (Twilio), using a pool of per-district sender numbers, and operates the program in accordance with carrier (A2P 10DLC) and CTIA messaging requirements. Consent is per-program and is not shared across districts.

4.4 Carrier disclaimer

Carriers are not liable for delayed or undelivered messages.

5. Quiet Hours

Outbound messages that are not direct replies to a message you have just sent are sent only during permitted hours — between 8:00 a.m. and 9:00 p.m. in your local time zone. Replies to your own inbound messages, and your own messages to us, are not restricted to these hours.

6. How to Opt Out — Reply STOP

You can cancel the SMS service at any time. Just reply STOP. After you send STOP, we will send a one-time message to confirm you have been unsubscribed, and you will no longer receive messages from us. We also honor the opt-out keywords CANCEL, END, QUIT, UNSUBSCRIBE, OPT-OUT, and REVOKE.

Opt-out requests are honored as soon as practicable and no later than ten (10) business days after your request, consistent with FCC rules and CTIA messaging principles.

If you opt out, you can rejoin at any time by texting the district-published number again or by signing up through your district.

7. How to Get Help — Reply HELP

Reply HELP at any time to receive help and contact information for this program. You can also reach a person through the customer-care contacts in Section 8.

8. Customer Care Contact

For questions about this messaging program, contact CoPilot Data Solutions at:

• Email: [email protected]
• Phone / support: (817) 752-4766
• Mailing address: CoPilot Data Solutions LLC, 608 E Hickory St, Ste 128, Denton, TX 76205

9. Privacy, Student Records, and Our Role

9.1 Our role, the district's role, and how each privacy law applies

The school district owns and controls all student education records. CoPilot Data acts solely as a service provider performing a function the district would otherwise perform with its own employees, under the district's documented instructions and direct control. In that role:

• FERPA — student education records. CoPilot Data is a "school official" with a legitimate educational interest under the federal Family Educational Rights and Privacy Act (FERPA), acting under the district's annual FERPA notification and under its direct control as to the use and maintenance of education records.
• Texas Education Code Chapter 32, Subchapter D (Texas Student Privacy Act) — student covered information. CoPilot Data is an "operator" and uses covered information only for school-authorized purposes.
• TDPSA — your own consumer data, with a FERPA carve-out. The Texas Data Privacy and Security Act (TDPSA) does not apply to student education records that are governed by FERPA — that student data is FERPA-exempt and is handled under FERPA and Chapter 32, not under the TDPSA. Your own phone number and the content of the messages you send are your personal consumer data, which is not a FERPA education record. To the extent the TDPSA applies to that parent/consumer data, CoPilot Data acts as a "processor" for the district (the controller). Regardless of how the TDPSA's exemptions are ultimately construed, CoPilot Data follows TDPSA processor norms — processing only on documented instructions, assisting with data-subject requests, and imposing equivalent duties on its sub-processors — for all data in this program.

CoPilot Data processes student data only on the district's behalf and under its documented instructions.

9.2 Information we process for this program

For the SMS program, CoPilot Data processes your phone number and the content of your messages, together with the student education records the district authorizes us to surface (for example, STAAR/EOC assessment results and academic-progress data). Your phone number and message content are processed only to operate this messaging service. They are never sold, never rented, and never used for marketing.

9.3 Texting your student's records is a FERPA disclosure

Responding to a text with a specific student's education records is a disclosure of that student's records that occurs under the district's authority. For that reason, the assistant discloses a student's records only after your identity has been verified (see Section 3), discloses only that student's own records, only to a verified parent, guardian, or eligible student, and only as authorized by the district. CoPilot Data does not treat any student data as "directory information" on its own initiative; directory-information handling follows each district's designation and honors district-conveyed opt-outs.

9.4 Use limitation, no sale, no targeted advertising, no profiling

CoPilot Data uses student covered information and education records (the student's data, controlled by the district) and your phone number and message content (your own consumer data) only for the purpose for which the district disclosed them — delivering and supporting this service for that district — and for no other purpose. CoPilot Data:

• does not sell or rent any student's covered information or personally identifiable information (PII), or your phone number or message content;
• does not use covered information or persistent identifiers to engage in or enable targeted advertising to students or parents, and does not allow third parties to do so; and
• does not build a profile about a student except for a school purpose, and does not create profiles for advertising or any other commercial purpose.

9.5 No mobile data shared for marketing

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. Information sharing to 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 parties.

9.6 De-identified and aggregate data

CoPilot Data may create de-identified or aggregate information (for example, anonymized counts and trends that do not identify any individual student). Any such use complies with FERPA (34 C.F.R. § 99.31(b)), Texas Education Code § 32.154, and the SDPC Texas Student Data Privacy Agreement (Article IV.5). CoPilot Data will not attempt to re-identify de-identified data, and any party to which de-identified or aggregate data is provided is contractually prohibited from re-identifying it or attempting to do so. De-identified or aggregate data will not be used for any advertising or commercial purpose.

9.7 Parental access and correction go through the district

FERPA gives parents (and students who are 18 or older, or who attend a postsecondary institution) the right to inspect, review, and seek amendment of the student's education records. These rights are exercised through the school district, not through CoPilot Data or this SMS assistant. CoPilot Data does not respond to record-access or correction requests directly; we route any such request we receive to the district and support the district in verifying identity and responding (generally within 45 days under FERPA). When a student turns 18 or enters a postsecondary institution, FERPA rights transfer to the student, and access requests are still routed through the district.

9.8 PPRA acknowledgment

This SMS program is not used to administer surveys or assessments. If any data surfaced through this program derives from a survey or evaluation that touches one of the eight protected categories under the Protected Pupil Rights Amendment (PPRA), that survey is administered under the school district's control and consent procedures, not by CoPilot Data.

9.9 COPPA (students under 13)

For students under 13, CoPilot Data relies on the school district's authorization as the consent basis under the Children's Online Privacy Protection Act (COPPA). That authorization is valid only because the data is collected and used solely for the school-authorized educational purpose and for no other commercial purpose. In accordance with the FTC's amended COPPA Rule (effective June 23, 2025; full compliance by April 22, 2026), CoPilot Data:

• provides the district the COPPA-required notice of our data-collection, use, and disclosure practices for children's personal information, and gives the district the ability to review and request deletion of that information;
• maintains a written data-retention policy for children's personal information, retains it only as long as reasonably necessary for the educational purpose for which it was collected, and does not retain it indefinitely;
• maintains a written information-security program with safeguards appropriate to the sensitivity of children's personal information (see Section 9.10); and
• does not disclose children's personal information to third parties for any purpose beyond the school-authorized educational purpose, and would obtain separate, verifiable consent (through the school-consent mechanism) before any disclosure to a third party that is not integral to providing the service.

9.10 Data minimization and security

CoPilot Data collects only the minimum personal information needed to operate this program. We maintain a written information-security program with administrative, technical, and physical safeguards appropriate to the sensitivity of the data, including encryption in transit and at rest, access controls limiting access to authorized personnel with a legitimate need, and regular risk assessment and monitoring.

9.11 Data retention and deletion

• Student covered information / education records. Retained only as long as necessary to provide the service or as the district directs, not indefinitely. On the district's request, or on termination of the district's contract, CoPilot Data will delete or return the student covered information under the district's control. Under Texas law, deletion occurs no later than 60 days after a district deletion request unless the parent or eligible student consents to retention.
• Phone numbers and message content (your consumer data). Retained only as long as needed to provide the service. They are deleted within 60 days after the district's contract ends, or on request, whichever is earlier, unless a longer period is required by law.

9.12 Breach notification

If CoPilot Data discovers a security incident involving student PII or your personal data, we will notify the affected district within seventy-two (72) hours of confirming the incident, including what was affected and the steps taken, and will cooperate with the district's breach-response and notification obligations (in Texas, districts report to the Texas Education Agency and notify affected parents). This 72-hour window is set to match the notification window in the SDPC Texas Student Data Privacy Agreement; where a signed Data Privacy Agreement specifies a different window, that agreement controls.

9.13 Compelled disclosure

If CoPilot Data receives a subpoena, court order, or other legal demand to disclose student records or your personal data, CoPilot Data will notify the affected school district before disclosing, so the district can seek a protective order or otherwise respond, unless we are legally prohibited from giving that notice. CoPilot Data does not voluntarily disclose student records or message content to law enforcement or other third parties.

9.14 Full privacy policy

This summary supplements, and does not replace, our full Privacy Policy. See our Privacy Policy at https://www.copilotdata.com/privacy-policy.

10. Service Providers (Sub-Processors)

CoPilot Data uses the following service providers to deliver this messaging program. Each is bound by written terms no less stringent than our own obligations, may use data only to provide services to CoPilot Data, may not use the data for any other purpose or further disclose it, and may not re-identify any de-identified data:

• Twilio — SMS message delivery and A2P 10DLC carrier registration.
• Google Cloud Platform / Firebase — hosting, database, and file storage, in United States storage regions (us-central1).
• Third-party AI / large-language-model provider(s) — natural-language processing for the AI assistant; bound by contract not to train on or retain message content. Current providers are identified to each district in the Data Privacy Agreement.

The AI providers process message content transiently through their APIs to generate responses and do not train on the data. Student PII and SMS content are not used to train or fine-tune any machine-learning or AI model, and the AI providers, the messaging provider, and the hosting provider are contractually prohibited from retaining the content for, or using it in, model training.

11. About the AI Assistant

Replies are generated by an automated AI assistant for informational purposes only. They are not professional or educational advice and are not a guaranteed substitute for official district records. AI-generated responses may contain errors. The underlying assessment and accountability data (including STAAR/EOC results and A-F / CCMR information) is derived from Texas Education Agency (TEA) and district source data and may be preliminary, subject to TEA revision, or contain source errors; CoPilot Data does not warrant the accuracy of TEA-derived or district-derived data surfaced through this program. For authoritative answers about your student, contact district staff. The assistant may hand off your conversation to district staff at any time.

12. Availability

The SMS service is provided on an as-is and as-available basis and may not be available in all areas, at all times, or on all carriers. (Broader warranty disclaimers and the allocation of liability for the underlying data and platform are governed by the district's Terms of Service and Master Services Agreement, not by this parent notice.)

13. Eligibility

This service is intended for a student's parent, guardian, or authorized adult, or for an eligible student. The school district controls eligibility and identity verification. Do not use this program to request information about a student you are not authorized to receive information about.

14. Governing Law and Precedence

These SMS Terms are governed by the laws of the State of Texas, without regard to its conflict-of-laws rules.

For matters involving student education records, where CoPilot Data has signed a school district's Data Privacy Agreement (for example, the SDPC Texas Student Data Privacy Agreement), that agreement controls over these SMS Terms in any conflict. The order of precedence among the governing documents is: signed Data Privacy Agreement → order form / Master Services Agreement → district Terms of Service → these SMS Terms and other incorporated policies.

Venue and forum for any dispute with a district customer are governed by the district's agreement; where the SDPC Texas Student Data Privacy Agreement applies, venue lies in the school district's (LEA's) county as provided in that agreement (Article VII.6), which controls over any contrary venue provision.

15. Changes to These SMS Terms

CoPilot Data may update these SMS Terms from time to time. Material changes will be communicated to participating districts and clearly flagged with a revised "Last updated" date, rather than made silently. Continued use of the program after an update constitutes acceptance of the updated SMS Terms.

16. Contact

CoPilot Data Solutions LLC
608 E Hickory St, Ste 128
Denton, TX 76205
Email: [email protected]
Phone: (817) 752-4766
Web: https://www.copilotdata.com
Privacy Policy: https://www.copilotdata.com/privacy-policy
SMS Terms: https://www.copilotdata.com/sms-terms