Prepared 22 Aug 2026 · AcornSmarts (a Black Swan Media Solutions product) · acornsmarts.com · Every technical claim in this pack is verified against the shipped codebase (v2.80.0) and enforced by automated build guards; the verification method is stated beside each claim. Statute references were checked against the official published sources cited at the end. This pack is informational and is not legal advice; the DPA template is a starting point for district counsel.
privacyReceipt.test.ts) locks them against the real network payload builders in the code. If any sync path ever gains a field, the build fails until this document tells the truth. The same regime a district applies to a data inventory, applied by the vendor to itself.| Data | Contents, precisely |
|---|---|
| Grown-up account | The adult's email and display name — the adult's, never the child's. |
| Child identifier | Nickname, grade, avatar emoji. A child's real name never leaves the device (there is no field that carries it). |
| Practice results | Skill id, level, right/answered counts, seconds, and per-question-TYPE tallies (an internal type name plus seen/missed counts — never question text, never a child's answers). |
| Progress numbers | Per-skill level/score/attempts; acorn count, day streak, self-check count, weekly goal; awards list (badge name + emoji). |
| Reading totals | Counts and minutes only — never a single book title. |
| Comfort settings | Practice targets and accessibility display prefs (easy-read, dyslexia-friendly font, text size, high contrast), so a second device is pre-set. |
| Class membership | Which class a child joined by code, plus a last-practiced timestamp (the time only). |
| Writing Coach (paid plans) | When a child taps "Check my writing," that answer's text is transmitted once for automated grading and immediately discarded — never stored server-side, never used to train AI. The coaching the child reads comes from a fixed set of lines authored under human direction and human-reviewed. |
audio: false; frames are processed on the device to read the code and are never stored or transmitted.| Question | Answer | How it's verified |
|---|---|---|
| Advertising? | None, ever. No ad SDKs, no behavioral advertising, no sale of data. | Full dependency list is 7 functional libraries (React, Supabase client, animation, QR, icons). Source audit: zero analytics/tracker/social SDKs. |
| Third-party trackers / analytics? | In the app children use: none. The app at app.acornsmarts.com references no external host — no analytics, no pixels, no CDNs, no cookies; the browser talks only to the app's own domain and its database/functions provider (Supabase). The adult-facing marketing site (acornsmarts.com) uses standard Google Analytics on its marketing pages only — never in the app, and not on the public standards report pages. | Source + markup + live-page audit (v2.81.0), all four surfaces checked individually. |
| Works offline? | Yes — the app is local-first; every question, helper, and printable works with no connection. Only the opt-in cloud dashboard syncs. | Shipped PWA design; the in-app receipt invites families to test in airplane mode. |
| Student enrollment | Done by the family, never by staff — no student personal information passes through staff hands. Teachers see nicknames only. | Join-code flow; server schema stores nickname/grade/avatar only (FERPA note below). |
| Biometrics? Psychological profiling? | No biometric collection of any kind; no emotional-state assessment mechanisms. | Source audit; relevant to K.S.A. 72-6314 prohibitions (below). |
| Deletion | A parent can delete the account in-app; deletion removes the cloud account and its data. Redemption/audit ledgers retain no personal link after deletion. | delete-account function; deletion path exercised in testing 22 Aug 2026. |
| Breach notification | Commitment: affected accounts notified without unreasonable delay upon any confirmed breach of personally identifiable data (see DPA §6). | Policy commitment in this pack; aligns with K.S.A. 72-6318. |
| Data location / subprocessors | One infrastructure provider (Supabase — managed Postgres + auth, US region); one payment processor (Stripe) that sees only the paying adult, never a child; transactional email (Resend) to adults only. Writing Coach grading calls Anthropic's API server-side with the single answer text, which is not retained. | Complete list — there are no other subprocessors. |
Primary path: direct parental relationship. AcornSmarts accounts are created by the parent, for the parent — the child never creates an account and the app requests no contact information from a child. Where the state's ESA program or a district deploys AcornSmarts, enrollment still runs through the family, so the operative consent is the parent's own, not a school's proxy consent.
Where a school authorizes use instead (the FTC's school-authorization pathway), AcornSmarts' standing notice is: (1) it collects the limited child data listed in §1 under the school's authorization; (2) that data is used for the school-authorized educational purpose and no other purpose — no commercial use of any kind; (3) the school may review the information collected and request deletion at any time. These are the three notice elements the FTC's guidance requires of ed-tech operators relying on school authorization.
When a district uses the teacher dashboard, AcornSmarts operates as a "school official" with a legitimate educational interest under the district's direct control for the limited records involved (34 C.F.R. §99.31(a)(1)): the district decides who joins a class, may review everything the dashboard holds, and may end access at any time. The design keeps the FERPA surface deliberately small — the vendor side holds nicknames and counts, not education records in the traditional sense: no real names, no addresses, no demographic data, no assessment answers, no free-text student work stored server-side. The signable DPA below binds AcornSmarts to use-limitation, non-redisclosure, and deletion-on-request, which is the substance districts require of school-official vendors.
| Requirement | How AcornSmarts meets it |
|---|---|
| Kansas Student Data Privacy Act, K.S.A. 72-6312 through 72-6320 (2014) Prohibits unauthorized disclosure of personally identifiable student data, unauthorized biometric collection, and unauthorized psychological/emotional-state assessment; requires breach notification. |
No disclosure of student data to any third party (there is no third party — §2 subprocessor list); no biometric collection exists in the product; no emotional-state assessment mechanisms; breach-notification commitment in DPA §6. The data minimization in §1 means the personally identifiable surface is a nickname. |
| Missouri HB 1490 (2014), §161.096 RSMo — Student Data Accessibility, Transparency & Accountability Requires a public data inventory, FERPA-consistent policies, and privacy/security requirements reflected in vendor contracts; violations by vendors carry civil penalties; Attorney General enforces. |
The §1 data map IS a public data inventory, machine-locked to the code; the DPA template below supplies the contract-level privacy/security terms §161.096 expects districts to obtain from vendors. |
Student Data Privacy Agreement between __________________________ School District ("District") and Black Swan Media Solutions LLC d/b/a AcornSmarts ("Provider").
District: ______________________ Date: ________ Provider: ______________________ Date: ________
privacyReceipt.test.ts fails the build if any sync payload gains a field not listed in §1.Sources verified 22 Aug 2026: K.S.A. 72-6312 (ksrevisor.gov; overview via Justia and the Kansas Attorney General) · §161.096 RSMo / HB 1490 (revisor.mo.gov; bill text at house.mo.gov) · FTC COPPA school-authorization guidance (ftc.gov) · FERPA school-official exception, 34 C.F.R. §99.31(a)(1).