Life Ready Schools LLC | 825 Tiffanie Ct., Lexington, KY 40514 | 859.338.1717

Data Privacy & Security Policy

Effective Date: January 1, 2026

Life Ready Schools LLC ("Life Ready Schools," "we," "us," or "our") is committed to protecting the privacy and security of student, staff, and school data entrusted to us by our partner schools and districts. This Data Privacy & Security Policy describes how we collect, use, store, protect, and dispose of data, and it is designed to meet the expectations of public school districts and align with applicable federal and state laws, including FERPA and COPPA.

1. Scope

This policy applies to all data accessed, collected, processed, stored, or transmitted by Life Ready Schools LLC in connection with our software, services, training, and support provided to K–12 schools and school districts, including but not limited to the Life Ready Schools platform and related services.

2. Types of Data Collected

Life Ready Schools may collect or process the following categories of data, solely as necessary to provide contracted services:

Student Data: Name, school ID number, grade level, course participation, program participation, and other education records as defined by FERPA.
Staff Data: Name, school email address, role/title, and professional information necessary for system access and implementation.
User Account Information: Login credentials, access logs, and usage data.
Operational Data: System-generated data related to platform performance, support, and security.

Life Ready Schools does not collect Social Security numbers, biometric data, financial account information, or student health records unless explicitly authorized in writing by the district.

3. Purpose Limitation & Data Use

Life Ready Schools:

Uses data solely for educational purposes and to fulfill its contractual obligations to schools and districts.
Acts as a School Official with a legitimate educational interest, as defined under FERPA.
Does not sell, rent, or trade student or staff data.
Does not use student data for targeted advertising, marketing, or profiling.

4. FERPA Compliance

Life Ready Schools complies with the Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g; 34 CFR Part 99).

Specifically:

Student education records remain the property of the school district.
Life Ready Schools only accesses education records under the direction of the district.
Data is disclosed only as permitted by contract, FERPA, or applicable law.
Parents and eligible students retain all rights granted under FERPA.

5. COPPA Compliance

Life Ready Schools complies with the Children's Online Privacy Protection Act (COPPA) (15 U.S.C. §§ 6501–6506).

Life Ready Schools relies on the school district to provide consent for the collection and use of student data for educational purposes.
Student data is collected only as necessary for school-authorized activities.
Data is not used for commercial purposes unrelated to education.

6. Data Security Safeguards

Life Ready Schools maintains commercially reasonable administrative, technical, and physical safeguards to protect data, including:

Role-based access controls
Unique user credentials
Secure cloud-hosted infrastructure
Data encryption in transit (where supported by hosting providers)
Regular system monitoring and access logging
Limited access by authorized personnel only

7. Data Sharing & Third Parties

Life Ready Schools may use vetted third-party service providers (e.g., cloud hosting or backup providers) solely to support delivery of services.
All third parties are contractually bound to confidentiality and data protection obligations.
No student or staff data is shared with third parties for advertising or unrelated commercial purposes.

8. Data Breach & Incident Response

In the event of a data breach or security incident involving student or staff data:

Life Ready Schools will notify the affected school district within seventy-two (72) hours of discovery, consistent with KRS 61.931 et seq. and applicable agreements.
Life Ready Schools will cooperate fully with district investigations and remediation efforts.

9. Data Retention & Disposal

Data is retained only for the duration of the contract and as necessary to provide services.
Upon contract termination, Life Ready Schools will, at the district's direction:
- Return district data, or
- Securely delete or overwrite district data in accordance with standard procedures and legal requirements.
One archival copy may be retained if required by law.

10. Transparency & Access Requests

Life Ready Schools will:

Assist districts in responding to parent or eligible student data access requests, as required under FERPA.
Provide reasonable documentation of data handling and security practices upon request.

11. Policy Updates

This policy may be updated periodically to reflect legal, regulatory, or operational changes. Material changes will be communicated to partner districts.

12. Contact Information

Questions regarding this policy or data privacy practices may be directed to:

Life Ready Schools LLC
825 Tiffanie Ct.
Lexington, KY 40514
Phone: 859.338.1717
Website: LifeReadySchools.com

This Data Privacy & Security Policy is intended to complement, not replace, the terms of Life Ready Schools LLC service agreements and data sharing addenda executed with school districts.

Appendix A: Contract & Data Sharing Crosswalk

This appendix documents how this Policy aligns with existing Life Ready Schools LLC contractual obligations, including the Software as a Service Agreement and District Data Sharing Addenda.

A.1 Data Ownership & Control

Policy Sections: 3, 4, 9
Contract Alignment: Customer Data remains the property of the school/district; Life Ready Schools receives a limited license solely to provide services.
District Assurance: District retains full ownership and control of education records.

A.2 FERPA – School Official Designation

Policy Sections: 3, 4
Contract Alignment: Vendor acts under the direction of the Customer with legitimate educational interest.
District Assurance: Access to education records is limited to authorized educational purposes.

A.3 COPPA – School-Authorized Consent

Policy Sections: 5
Contract Alignment: Customer is responsible for obtaining necessary consents; Vendor uses data only for contracted educational purposes.
District Assurance: No commercial use or advertising to students.

A.4 Data Security & Confidentiality

Policy Sections: 6, 7
Contract Alignment: Confidential Information protections; commercially reasonable safeguards; restricted third-party access.
District Assurance: Administrative, technical, and physical safeguards are in place.

A.5 Breach Notification

Policy Sections: 8
Contract Alignment: Data Sharing Addendum requires notification within 72 hours under KRS 61.931 et seq.
District Assurance: Timely notification and cooperation in incident response.

A.6 Data Retention & Destruction

Policy Sections: 9
Contract Alignment: Post-termination return or deletion of Customer Data, with limited legal retention exceptions.
District Assurance: No indefinite retention of student data.

A.7 Third-Party Subprocessors

Policy Sections: 7
Contract Alignment: Life Ready Schools may use third parties solely to provide services and are subject to confidentiality obligations.
District Assurance: No resale or secondary use of data.

Appendix A is provided for transparency and district review and does not modify contractual obligations.

Appendix B: District Privacy Assurance (One-Page Summary)

Life Ready Schools LLC – District Privacy Assurance

Life Ready Schools LLC provides educational software and services to K–12 schools and school districts. This District Privacy Assurance is provided to support vendor approval, procurement review, and data governance requirements.

Regulatory Compliance

Life Ready Schools LLC affirms that it:

Complies with the Family Educational Rights and Privacy Act (FERPA)
Complies with the Children's Online Privacy Protection Act (COPPA)
Complies with applicable Kentucky data privacy statutes, including KRS 61.931 et seq.

Role Under FERPA

Life Ready Schools LLC acts as a School Official with a legitimate educational interest.
Student education records remain the property of the school district at all times.
Data is accessed and used only at the direction of the district and solely for educational purposes.

Data Collection & Use

Only the minimum data necessary to deliver contracted services is collected.
Student and staff data is never sold, rented, or used for advertising.
Data is not used for profiling, targeted marketing, or commercial purposes.

COPPA Assurance

Life Ready Schools relies on school-authorized consent for student data collection.
Student data is used exclusively for school-directed educational activities.

Data Security

Life Ready Schools maintains commercially reasonable safeguards, including:

Role-based access controls and unique user credentials
Secure, cloud-hosted infrastructure
Restricted internal access to authorized personnel only

Data Sharing

Data is shared only with approved third-party service providers as necessary to deliver services.
All third parties are contractually bound to confidentiality and data protection requirements.
No data is shared for advertising or secondary commercial use.

Breach Notification

Any security incident involving student or staff data will be reported to the district within 72 hours of discovery.
Life Ready Schools will cooperate fully with district response and remediation efforts.

Data Retention & Destruction

Data is retained only for the duration of the contract.
Upon contract termination, data will be returned or securely deleted at the district's direction, subject to legal requirements.