Your records, on the record.

Scope

Records we cover.

Counsolero treats the following data surfaces as education records for FERPA purposes:

• Canvas courses, enrollments, grades, and assignments synced from Canvas LMS with your OAuth consent
• Classes and assignments you enter by hand
• Files you upload to a class
• AI chat conversations and messages
• AI memory — passages we extract from your files, assignments, and chat history to give the AI context
• AI interaction logs — per-call metadata for every AI call we made on your behalf

Canvas access is on-demand with your explicit consent via OAuth2 authorization. Counsolero reads from Canvas only — we do not write back.

U.S.-only service. Counsolero is operated from California for U.S.-based students. We do not target or knowingly accept users from outside the United States.

Directory information

Schools may designate certain categories of education records as "directory information" under FERPA (typically a student's name, dates of attendance, and similar non-sensitive details), making that subset exempt from FERPA's disclosure-consent default. Counsolero LLC does not designate any of your data as directory information. Every category of information described above is treated as protected under FERPA, regardless of how your school designates analogous records.

Storage

How we store them.

• Canvas OAuth tokens encrypted at rest with symmetric encryption; cleared when you disconnect Canvas or delete your account
• All data stored in our application database, with a vector index that supports the AI memory layer
• HTTPS enforced for all data in transit
• Session cookies are HttpOnly and Secure

Internal access

Access to education records inside Counsolero LLC is restricted to the company's founder and the small set of engineering staff who require it to operate, debug, or improve the service. We follow a minimum-necessary principle: a Counsolero employee only views your records when doing so is required to respond to a support request you have made, investigate a security incident, fix a defect you have reported, or comply with a lawful legal obligation. We do not browse student records for analytical, marketing, or research purposes.

Retention

How long we keep them.

Retention matches the Privacy Policy. Per-category summary:

• Account identity: until you delete it, plus a 14-day grace period, then hard-deleted
• Canvas academic data, manual classes, uploaded files, chat history, AI memory, study resources, degree plans: cascade-deleted when the account is hard-deleted at the end of the 14-day grace
• AI interaction log metadata: retained under a declared policy of up to 395 days (about 13 months) as a FERPA record-of-disclosure (timestamp, provider, model, use case, tokens, cost, latency, success), then purged. Prompt and response text are scrubbed before the personal identifier is removed
• Consent records and consent audit log: retained permanently; personal identifier removed on hard-deletion
• Security audit log: retained under a declared policy of up to 3 years for FERPA-relevant actions or up to 1 year for other actions, then purged; personal identifier removed on hard-deletion
• Canvas connection metadata: retained with personal identifier removed on hard-deletion; OAuth tokens were already cleared when you disconnected or at hard-deletion time

Disclosure

Records of disclosure.

FERPA requires institutions to maintain a log of each disclosure of a student's education records. We satisfy that requirement with a dedicated records-of-disclosure log — separate from your chat history — that captures, for every AI call we make on your behalf: the time, which provider (Azure OpenAI or Google Vertex AI), which model, how many tokens were processed, how much it cost, how long it took, and whether it succeeded. This compliance log does not contain what you asked or what the AI said — only the metadata listed above.

Your chat history itself — the prompts you typed and the responses you received — is a separate store, encrypted at rest, and is what powers the chat-history view inside Counsolero. We retain it while your account is active so you can re-read prior conversations, and so the AI memory layer can ground new answers in your earlier work. Both the chat history and the AI memory layer are cascade-deleted when your account is hard-deleted at the end of the 14-day grace period (see Section 3); only the records-of-disclosure log survives — with the prompt and response columns scrubbed and the personal identifier removed.

This is the FERPA records-of-disclosure pattern: the institution must be able to prove it disclosed records correctly even after the underlying records themselves are deleted. The compliance log proves when and to whom each disclosure happened; the chat history that contains the what lives only as long as your account does.

Recipients

Who receives them.

Your education records are shared with the AI sub-processor that actually serves your request. During the current production beta, that is Microsoft Azure OpenAI for every AI request — the in-chat model picker is visible, but a production-wide lock currently overrides its selection so all traffic is served by Azure OpenAI regardless of what you pick. Counsolero LLC has not separately negotiated or signed any bespoke contract with Microsoft; its Data Protection Addendum is incorporated by reference into the standard Microsoft Online Services Terms we accept by using the service, and its FERPA "school official" clause names Azure OpenAI in scope. Azure OpenAI handles your chat messages, RAG-retrieved course materials, query rewrites, study-tool prompts, and agentic reasoning.

Current sub-processors:

• Azure OpenAI — the AI provider serving all production traffic today; receives academic context on every AI request. Microsoft's Data Protection Addendum is incorporated by reference into its standard Online Services Terms, and its FERPA "school official" clause names Azure OpenAI in scope.
• Google Vertex AI — integrated in our code but not active in production; receives zero data today. Google publishes no FERPA-specific commitment for Vertex AI.
• Clerk — receives only your email address for authentication; does not receive academic data.

The in-chat model picker still renders and records your preference, but it does not currently change which provider serves your request — every request is served by Azure OpenAI during this production beta. If that changes, we will update this page and the picker's behavior together. The search-index encoding that powers AI memory stays on an operator-configured provider for technical consistency, independent of the picker.

If Azure OpenAI is temporarily unavailable (automatic failover triggered after repeated errors), Counsolero will either serve your request from an alternate FERPA-approved provider on our operator-controlled allowlist (the AI interaction log records the provider that actually served the request) or fail-closed with an error — Counsolero will not silently route your academic data to a non-approved provider.

Aside from the infrastructure providers that operate the service for us — including our hosting provider, our reverse-proxy/CDN provider, our cache provider, and our error-monitoring vendor, which process data only to keep Counsolero running and never for their own purposes — no other third parties receive your education records, and the AI sub-processors above are the only recipients of your academic content. We do not sell or share your academic data for advertising or analytics.

You are interacting with an AI system

When you use Counsolero's AI features, you are interacting with automated language models, not a human counselor, tutor, or advisor. This disclosure is provided in accordance with Article 50 of the EU Artificial Intelligence Act (Regulation (EU) 2024/1689).

Your data does not train AI models

Counsolero never uses your education records to train, fine-tune, evaluate, or benchmark AI models — ours or anyone else's. The AI sub-processors above publish terms committing not to use customer inputs to train their models and not to retain inputs or outputs beyond the duration of the request; these terms apply to our use of their services the same as to any other customer. This commitment flows through to every category of data described in Section 1 — Canvas grades, assignments, files, chat history, and AI memory embeddings.

No marketing, no behavioral advertising, no sale

Counsolero does not use your education records for marketing or advertising of any kind. We do not build user profiles for behavioral advertising. We do not sell or share your academic data — as those terms are defined under CCPA/CPRA §1798.140 — to or with any third party for any commercial purpose. We do not participate in cross-context behavioral advertising.

These commitments align with the substantive requirements of state student-privacy laws including the California Student Online Personal Information Protection Act (SOPIPA) (with anticipated modernization via Assembly Bill 1159 (CALPIPA) currently advancing through the California Legislature), the Illinois Student Online Personal Protection Act, New York Education Law § 2-d, Colorado's Student Data Transparency and Security Act, and analogous laws in other states. See Section 11 of the Privacy Policy for the full enumerated commitment set.

Law-enforcement and legal-process disclosures

FERPA at 34 CFR § 99.31(a)(9) permits disclosure of education records in response to a lawfully issued subpoena or judicial order. If Counsolero LLC receives a subpoena, court order, search warrant, or other valid legal process compelling disclosure of your education records, we will comply only to the extent legally required. Where permitted by the order or by law, we will notify you in advance so that you have an opportunity to object, and we will narrowly limit disclosure to the specific records compelled. We will not voluntarily disclose your education records to law enforcement absent valid legal process, except in a genuine emergency where disclosure is necessary to protect the health or safety of you or others.

De-identification and aggregation

Counsolero LLC does not de-identify, anonymize, or aggregate your education records for analytics, research, model evaluation, performance benchmarking, or any other purpose outside of providing the service to you. If we ever begin to do so, we will update this Notice in advance and describe the de-identification methodology so that you can evaluate it.

Agentic AI capabilities

Counsolero contains infrastructure for "agentic" AI features — where the AI autonomously decides which of your education records to read in order to respond to your request, rather than working from a fixed set of context we hand to it. This capability is currently disabled by default. If it is enabled for your account in the future, the records-of-disclosure log described in Section 4 will continue to capture every provider call the AI makes; however, the set of records consulted on any given call may be broader than the user prompt alone would suggest. We will update this Notice in advance if agentic AI becomes an opt-in or opt-out user-facing feature.

Your rights

Your rights.

You have full control over your education records in Counsolero:

• You can disconnect Canvas at any time via the Canvas Connections page — this nulls the stored OAuth tokens. Previously synced course data remains visible so you can reconnect and resume. If you want the synced Canvas data removed as well, use Delete My Account
• You can request full account deletion (14-day grace period + undo link) via the Delete My Account page
• You can download a copy of every record tied to your account from the Export My Data page
• You authorized the Canvas connection yourself via OAuth2 — you control it and can revoke it

Complaints

If you believe Counsolero has mishandled your education records, contact [email protected] first; we will investigate and respond. If you are not satisfied with our response, or if you believe your school has mishandled your records via its use of Counsolero, FERPA gives you the right to file a complaint with the U.S. Department of Education's Student Privacy Policy Office (SPPO, formerly the Family Policy Compliance Office). Note that the SPPO investigates schools, not vendors directly — but where a vendor's practices are the underlying concern, the issue can be raised through the school's complaint process.

Vendors

Vendor commitments.

Counsolero LLC has not negotiated bespoke contracts with any of the AI sub-processors named above. We rely on the standard published terms and data-protection commitments each vendor applies to all of its customers, which we have reviewed for the purpose of handling education records:

• Microsoft (Azure OpenAI) — Microsoft's published Online Services Terms and Data Protection Addendum apply to our use of the service
• Google (Vertex AI) — Google Cloud's published Terms of Service and Cloud Data Processing Addendum apply to our use of the service
• Clerk — Clerk's published Privacy Policy and Data Processing Addendum apply to our use of the service

Important note: No formal FERPA "School Official" agreement is in place with these vendors. Counsolero is operated by Counsolero LLC and is an independent third-party tool — not endorsed by, affiliated with, or operating on behalf of Instructure (Canvas) or any educational institution. Counsolero accesses Canvas data only at your individual direction via OAuth, not as a school-designated school official under 34 CFR § 99.31(a)(1)(i)(B). This page provides transparency about how your data is handled so you can make an informed decision about using the service.

Breach response

If something goes wrong.

In the event of a security incident that compromises the confidentiality, integrity, or availability of your education records, Counsolero LLC commits to:

• Investigate promptly — engage the necessary technical and forensic resources to determine the scope of the incident
• Notify affected users — without undue delay and, in any event, within the timeframes required by applicable law (GDPR Art 34 for EU/EEA data subjects; state-specific timeframes for US users, generally 30–60 days depending on jurisdiction)
• Notify regulators — supervisory authorities and state attorneys general as required by applicable law (GDPR Art 33: within 72 hours of becoming aware)
• Notify your school if applicable — for incidents touching education records of identifiable students, we will work in good faith with affected institutions, recognizing that under FERPA the school remains the primary notifier of its own students
• Provide a post-incident summary — describing what happened, what data was affected, what remediation we took, and what changes we are making to prevent recurrence

If you believe you have observed a security incident affecting your account or another user's, report it immediately to [email protected].

Audit access

See your disclosure log.

FERPA gives the holder of an education-records right the ability to inspect the school's record of disclosures of those records. Counsolero mirrors that principle for the disclosures we make on your behalf to AI sub-processors.

Your AI interaction log — included in the Export My Data archive (see Section 11 of the Privacy Policy) — contains the per-call metadata for every AI call Counsolero made on your behalf while your account was active: timestamp, provider, model, use case, tokens, cost, latency, and success/error. Prompt and response text are intentionally excluded from this export — see Section 4.

If you need an attested copy of your disclosure log for a school audit, a FERPA records request through your institution, or another formal purpose, email [email protected].

Changes

Changes to this Notice.

Counsolero LLC reviews this FERPA Transparency Notice at least annually and updates it when our practices, sub-processors, retention, or your rights materially change. The "Last updated" date at the top of this page is the date of the most recent revision. Material changes — including the addition of an AI sub-processor, a change to retention, a change to the records-of-disclosure mechanism, or activation of agentic AI capabilities — will be reflected here, and where the change is significant we will also notify you by email.

Questions about this Notice? Email [email protected] or see Contact.