Privacy Policy
FAST-Action by Cothink LLC
Effective Date: January 21, 2026 | Last Updated: January 21, 2026
1. Introduction
FAST-Action ("Service," "Platform," "we," "us," or "our") is an educational technology service operated by Cothink LLC, a Florida limited liability company. This Privacy Policy describes how we collect, use, disclose, and protect information when you use our web-based platform designed to assist Florida educators in analyzing student assessment data and generating personalized learning plans.
We are committed to protecting student privacy and complying with all applicable federal and state laws governing student data, including the Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. § 1232g, and its implementing regulations at 34 CFR Part 99.
2. FERPA Compliance and School Official Exception
2.1 Designation as School Official
FAST-Action operates under the "School Official" exception to FERPA's general consent requirements, as set forth in 34 CFR § 99.31(a)(1)(i)(B). Under this provision, educational agencies and institutions may disclose personally identifiable information (PII) from education records to contractors, consultants, volunteers, or other parties to whom the agency or institution has outsourced institutional services or functions, provided that:
- The outside party performs an institutional service or function for which the agency or institution would otherwise use employees;
- The outside party is under the direct control of the agency or institution with respect to the use and maintenance of education records; and
- The outside party uses PII from education records only for the purposes for which the disclosure was made.
2.2 Teacher and School Control
The teacher and/or their employing educational institution retain direct control over all student data at all times. FAST-Action serves solely as a processing tool operating under the direction and authority of the educational professional who uploads the data. We do not:
- Access student data for any purpose other than providing the requested educational service
- Make independent decisions regarding the use or disclosure of student data
- Retain student data beyond the scope of the service requested
- Share student data with any third party without explicit authorization from the controlling educational authority
3. Information We Collect
3.1 Student Education Records
When educators use our Service, they may upload or input:
- Student names and identifiers
- Grade levels
- Florida FAST assessment scores (PM1, PM2, PM3)
- Performance levels and achievement data
- Individualized Education Program (IEP) documents and related special education records
3.2 Educator Account Information
We collect the following information from educators who create accounts:
- Email address
- Name (optional)
- Password (stored in hashed format only)
- School or organization affiliation (if applicable)
4. How We Use Information
Strict Prohibition on Commercial Use
WE DO NOT SELL, RENT, TRADE, OR OTHERWISE COMMERCIALLY EXPLOIT STUDENT DATA.
Student information is never used for marketing, advertising, targeted advertising, behavioral tracking, or data mining for purposes unrelated to educational services.
Student data is used exclusively for the following educational purposes:
- Analyzing FAST assessment results to identify student skill levels
- Generating personalized IXL Learning skill recommendations
- Creating individualized Student Success Plan PDFs
- Providing AI-assisted IEP analysis and instructional recommendations
- Supporting differentiated instruction planning
5. Data Security
Encrypted using AES-256 (Advanced Encryption Standard with 256-bit keys)
Protected using TLS 1.3 (Transport Layer Security)
6. Data Retention and Deletion
Users may request deletion of their data at any time. Upon receiving a deletion request:
- All student data associated with the user's account will be permanently removed
- Account information will be deleted
- A confirmation of deletion will be provided
Upon account termination, all associated student data and user information is permanently deleted within thirty (30) days, except where retention is required by law.
7. Florida-Specific Provisions
As a service designed for Florida educators, we acknowledge and comply with:
- Florida Statutes § 1002.22 (Education records and reports of K-12 students)
- Florida Statutes § 1002.221 (Parental consent requirements)
- Florida Administrative Code Rule 6A-1.0014 (Student Records)
8. Contact Information
For questions, concerns, or requests regarding this Privacy Policy or our data practices:
Cothink LLC
Email: alberto@cothink.pro
Website: https://fastixl.com
This Privacy Policy is provided for informational purposes and reflects our commitment to student data privacy. It does not constitute legal advice.
By creating an account or using the FAST-Action Service, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.