Polaris Global Academy
Privacy policy
Polaris Global Academy
Privacy policy
Updated: October 2026
At Polaris Global Academy, we consider children’s safety to be all-important. The following Privacy Policy describes our policies and procedures relating to the use of our site, our commitment to privacy, and the access and use of data.
Introduction
Polaris Global Academy exists to serve parents and students and strives to provide a safe, positive experience for children. We do not collect information directly from children. Any students under the age of 18 wishing to enroll, must do so by a parent or legal guardian. Polaris Global Academy does not sell or market directly to minors and always seeks the appropriate authorization whenever we identify a minor attempting to purchase a service. Whenever we collect Personally Identifiable Information, or “PII”, we do so with the sole purpose of supporting the educational goals of which the school was designed. We only distribute PII to third party partners for the purpose of delivering education services for students enrolled at Polaris Global Academy. We prohibit students from publicly posting or distributing PII without prior parental consent.
As you participate in classes, you will enter student data or interact with student data that has been entered for you. Federal law (the Family Educational Rights and Privacy Act, “FERPA”) allows a school district to release student records to an organization that is “conducting studies for, or on behalf of, educational agencies or institutions for the purpose of developing, validating, or administering predictive tests… [or] improving instruction.”
However, FERPA requires limitations on disclosure of those records and implementation of appropriate security measures to protect those records. To comply with FERPA, Polaris Global Academy has adopted certain practices, and requires that all third party partners working with Polaris Global Academy, maintain responsibilities to safeguard student data.
Identity of Registrants
Polaris Global Academy is designed to provide virtual education for students in grades 6-12. Parents or legal guardians may enroll their child with the school by providing their contact and billing information as well as other student data used to determine enrollment eligibility and to maintain appropriate student records. A user’s contact information may be used to send users service-related announcements when it is necessary or advisable to do so. User information may be shared with partners, business affiliates or third party service providers who work for Polaris Global Academy and operate some of its functionalities, such as hosting services, streaming services, academic instruction, and credit card processing. These third parties are established service providers, who are bound to practice adequate security measures and only use user information for the sole purpose of providing the services. A user’s information may also be shared with law enforcement or other third parties as required by law or if we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order or other legal process.
Polaris Global Academy has appropriate security measures in place to safeguard against unauthorized access to the personal information collected from our information systems, including limiting the number of people who have physical access to our database servers, as well as electronic security systems and password protections. We only store passwords in an encrypted format.
Parents or legal guardians enrolling their children with the school are asked to provide an email address during the enrollment process. We use email addresses to set up access to the course content, monitor enrollment compliance and identity verification. The email is also used to authenticate users when requesting technical support.
Collection, Use, Storage and Disclosure of Student Information
1. Purpose and scope
Polaris Global Academy collects only the personal data it needs to educate students, keeps it in a small set of approved systems, and deletes it on a fixed schedule. This policy applies to all students, parents and guardians, applicants, staff and contractors, wherever they live.
PGA is based in Florida, but because we enroll students in the EU, UK and elsewhere, we apply the EU General Data Protection Regulation (GDPR) and UK GDPR as our baseline for everyone. Where US law (such as COPPA for students under 13) or another country's law sets a stricter rule, we follow the stricter rule.
Data controller: Polaris Global Academy, 1768 Park Terrace, West Atlantic Beach, FL 32233, USA.
Data protection lead: Kevin Ferrone, Head of School. Privacy questions and requests: support@polarisglobalacademy.com (subject line "Privacy request").
EU / UK representative: [Patrycja Pietrzykowska, Student Success Coach based in Poland]
2. What we collect and why
Every category below has one stated purpose and one lawful basis under GDPR Article 6. We do not sell personal data, use it for advertising, or use it for any purpose not listed here.
Data
Examples
Purpose
Lawful basis
Identity and contact
Name, date of birth, address, email, phone, parent/guardian details
Enrollment, communication, safeguarding
Contract with the family
Academic records
Prior transcripts, grades, credits, attendance, coursework, test scores
Teaching, credit evaluation, transcripts, college and NCAA reporting
Contract; legal obligation for accreditation records
English level
CEFR placement results
Admission and course placement
Contract
Class recordings
Zoom video, audio and chat from live classes
Students who miss a class; teaching quality
Legitimate interest (with opt-out of camera)
Messages
Slack posts and direct messages
Community and day-to-day support
Legitimate interest
Support and wellbeing notes
Success Coach notes, accommodations, learning support needs
Supporting the student
Explicit consent for any health or disability data (Article 9)
Staff data
Contracts, payroll, background checks
Employment
Contract; legal obligation
Billing
Tuition invoices, payment records (card numbers held only by the payment provider)
Collecting tuition
Contract; legal obligation for tax records
Special category data (health, disability, religion, ethnicity) is collected only when a family chooses to share it, with written consent, and is visible only to the Head of School, the student's Success Coach and the teachers who need it.
Consent for under-16s: Where we rely on consent for a student under 16 (or the lower age set by their country, never below 13), a parent or guardian gives it. Consent can be withdrawn at any time by emailing us.
3. Approved systems
Personal data may be stored only in the systems below. Each vendor acts as a processor for PGA and must have a signed or accepted Data Processing Addendum (DPA) under GDPR Article 28 on file before any student data goes in.
System
What it holds
Who can access
GDPR safeguards
Official student record: enrollment, contacts, grades, attendance, transcripts
Admin staff, teachers (own classes), Success Coaches (own students)
Vendor reports GDPR compliance, SOC 2 Type II and ISO 27001 (2024). DPA to confirm.
Coursework, progress, assessment results
Teachers, Success Coaches, Academics team
Uses student data only to provide the service, no advertising; destroys it within 30 days of our request. DPA to confirm.
Live class video, audio, chat, recordings
Host teacher; recordings shared only with the class
DPA built into Zoom's terms, with EU Standard Contractual Clauses (SCCs).
Social and support messages
Members of each channel; workspace admins
DPA with SCCs available on every plan.
PGA Transcript Evaluator (Supabase, Vercel, Anthropic API)
Uploaded transfer transcripts and evaluations
Signed-in admissions and academic staff
Sign-in required, public sign-up off. Accept each vendor's DPA.
Rules for every system
-
Use school accounts platforms only. Students and parents use personal email addresses for account setup in each system.
-
Slack is for community and quick questions, not records. Grades, health information, discipline and safeguarding concerns go in Genius SIS, never Slack.
-
Zoom recordings are announced at the start of every class. Students should turn cameras on unless they have an approved reason. Recordings are shared by link with the class only, never posted publicly.
-
A new tool that touches student data needs Head of School approval and a DPA before use.
4. Storage, security and transfers
Access follows least privilege: staff see only the students they work with, and access ends the day someone leaves.
-
Accounts: unique logins per person, no shared passwords, two-factor authentication on Genius SIS, Zoom, Slack and Google/Microsoft accounts.
-
Devices: Student data is not downloaded to devices unless needed for a task, and deleted afterward.
-
Sharing: student files are shared by restricted link, never as public links or email attachments to outside addresses.
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Offboarding: accounts are removed from every system in section 3 on the staff member's last day.
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Access review: each August, the Head of School reviews who has access to each system.
5. How long we keep data
We keep data only as long as the table says, then delete it or reduce it to anonymous statistics. The Academic Coordinator runs the deletion each July.
Record
Kept for
Then
Final transcript and diploma record
Permanently
Kept: graduates need it for college, NCAA and employment verification
Other academic records (grades, attendance, coursework)
3 years after the student leaves
Deleted from Genius SIS
Edmentum coursework and progress
1 year after the student leaves
Deletion requested from Edmentum
Zoom class recordings
90 days
Auto-deleted in Zoom settings
Slack messages
90 days
Auto-deleted by workspace retention setting
Support and wellbeing notes
Until the student leaves, plus 1 year
Deleted
Applications from students who did not enroll
1 year after the decision
Deleted
Transfer transcripts in the Transcript Evaluator
1 year after the decision
Deleted
Staff records
1 year after employment ends
Deleted
Billing and tax records
7 years
Deleted
6. Rights, breaches and responsibilities
Your rights. Students, parents and staff can ask to see, correct, delete, restrict or export their data, or object to how we use it. Email support@polarisglobalacademy.com with "Privacy request" in the subject. We reply within one month and do not charge. Parents act for students under 16; students 16 and over can make requests themselves. Some records, such as final transcripts, we must keep even if deletion is requested, and we will explain why.
Complaints. Anyone can complain to the data protection authority in their country (for example, the ICO in the UK or their national authority in the EU). We ask that you contact us first so we can fix it.
Automated decisions. The Transcript Evaluator suggests credit awards, but a staff member reviews and approves every evaluation. No decision about a student is made by software alone.
Data breaches. Any staff member who suspects lost, stolen or exposed data tells the Head of School the same day. We assess it within 24 hours and, where there is a risk to people, notify the relevant authority within 72 hours and tell affected families without delay. Every breach is logged, even minor ones.
Staff responsibilities. All staff are required to read this policy and complete privacy training when they join. Breaking this policy may lead to disciplinary action.
Review. This policy is reviewed every August and whenever we add a new system. Next review: August 2027.
Data Transfer
We may sell, transfer or otherwise share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. Your consent to this Privacy Policy followed by your submission of Personal Information represents your explicit agreement to that transfer.
Supervision
It is the responsibility of parents and legal guardians to supervise children while attending PGA and teach them about security and privacy. We recommend that parents and educational institutions provide the following information to all children: Kids’ Rules for Online Safety.
Notice Regarding Changes to the Privacy PolicySupervision
It is the responsibility of parents and legal guardians to supervise children while attending PGA and teach them about security and privacy. We recommend that parents and educational institutions provide the following information to all children: Kids’ Rules for Online Safety.
Your enrollment with Polaris Global Academy is conditioned on and deemed to constitute your acceptance of these terms. Changes to this policy may be required to keep up with changing technology and threats, and as new or changed services are released. We expect most such changes to be minor, but there may be cases where changes may be more significant. In such cases, we will provide advanced notice to users who are affected. We encourage all users to return to and review this Privacy Policy frequently. Posting a modified Privacy Policy on this website will give effect to the revised terms, and your continued use of this website indicates your acceptance of any revised terms. If you do not agree to a revised policy, please refrain from using this website.
Enrollment with Polaris Global Academy includes an option to receive periodic email updates about Polaris Global Academy and other services and products that might be of interest to users of Polaris Global Academy.
Although we make concerted good faith efforts to maintain the security of personal information, and we work hard to ensure the integrity and security of our systems, no practices are 100% immune, and we can’t guarantee the security of information. Outages, attacks, human error, system failure, unauthorized use or other factors may compromise the security of user information at any time. If we learn of a security breach or other unauthorized disclosure of your PII, we will attempt to notify you so that you can take appropriate protective steps by posting a notice on our homepage or elsewhere in our Service and we will send an email to you at the email address you have provided to us.
If you are a parent, legal guardian or eligible student and an unauthorized disclosure of your student’s PII records occurs, we will notify you by email at the email address we have on record for you.
When you enroll with Polaris Global Academy you consent to our privacy practices and agree to accept the responsibilities outlined in this statement.
Contact Us
If you have questions or comments regarding our Privacy Policy, or need any other assistance with your enrollment at Polaris Global Academy, please contact us at:
Polaris Global Academy
1768 Park Terrace
West Atlantic Beach, Florida 32233
support@polarisglobalacademy.com