Privacy Policy

Last Updated: 07/03/2025

1. Introduction

This Privacy Policy describes how FERGUSON SOFTWARE SOLUTIONS, LLC ("we," "our," or "us") collects, uses, and protects personal information in connection with our financial literacy application ("Trinity Capital").

2. Information We Collect

Account Information: Name, email address, school affiliation, and role.
Authentication Data: Encrypted OAuth tokens that allow teachers to send emails from their school email addresses through our platform.
Usage Data: Basic platform usage metrics for service improvement (pages accessed, login times).
Student Data (if applicable): Only minimal information needed to support lesson delivery and reporting features.

3. Gmail API Integration

We use Google's Gmail API solely to enable teachers to send emails from their school email addresses.
We do not read, store, or analyze email content, subject lines, or message bodies.
Email delivery is handled directly by Gmail's secure servers.
We store only encrypted authentication tokens necessary for this functionality.
Teachers maintain full control over their email communications.
OAuth tokens are automatically deleted when users revoke access through their Google account settings.

4. How We Use Your Information

To provide and improve the App experience.
To authenticate teachers with their school email accounts for secure email sending.
To enable teachers to send emails from their school email addresses through our platform.
To respond to user inquiries and provide technical support.
To meet legal and educational compliance standards (e.g., FERPA).

5. Sharing and Disclosure

We do not sell personal data. Information is shared only under these circumstances:

With your school or district for administrative purposes.
With trusted service providers that help us operate the App (e.g., MongoDB database hosting, Railway cloud infrastructure).
As required by law or to protect rights and safety.
We do not share email content or communications data with any third parties.

6. Data Retention

We retain data only as long as necessary to provide the service or as required by law. Users may request deletion of their account and associated data at any time.

OAuth tokens are automatically deleted when users revoke access through their Google account settings.
No email content is stored on our servers.

7. Security

We implement industry-standard safeguards to protect data from unauthorized access, loss, misuse, or alteration. However, no method is 100% secure.

All OAuth tokens are encrypted both in transit and at rest.
Database connections use encryption and secure protocols.
Our infrastructure is hosted on secure, compliant cloud platforms.

8. Student Data and FERPA Compliance

We comply with the Family Educational Rights and Privacy Act (FERPA). Student data is handled only for legitimate educational purposes and never for commercial gain.

9. Your Choices

You may review, update, or delete your personal information at any time by contacting us.
You may opt out of non-essential communications through your account settings.
You can revoke Gmail API access at any time through your Google account settings.
Revoking access will prevent email sending through our platform but will not affect your Google account.

10. Data Subject Rights

You have the right to:

Access the personal information we have about you
Correct any inaccurate information
Delete your account and associated data
Revoke OAuth permissions at any time
Receive a copy of your data in a portable format

11. Changes to This Privacy Policy

We may update this policy periodically. Continued use of the App after changes are posted constitutes your acceptance of the revised terms.

12. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at trinitycapitalsim@gmail.com.