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Privacy Policy

Effective date: April 27, 2026 · Last updated: April 27, 2026

Draft notice. This policy describes our current practices as an operational draft. It has not been reviewed by counsel and is not legal advice. School and district administrators evaluating GiftMatch Compass should request an executed data-processing or data-privacy agreement before onboarding students.
On this page 1. Scope 2. Information we collect 3. How we use information 4. AI processing 5. When we share information 6. Schools & student data (FERPA, COPPA, SOPIPA) 7. Retention & deletion 8. Security 9. Your rights 10. Children 11. International users 12. Changes to this policy 13. Contact

1. Scope

This Privacy Policy describes how GiftMatch Compass (“GiftMatch Compass,” “we,” “us”) collects, uses, shares, and protects information when you use GiftMatch Compass (the “service”). It applies to all users, with additional terms for Schools and student users in Section 6.

2. Information we collect

CategoryExamplesSource
Account informationName, email, password hash, optional profile photo, optional U.S. state.You (at signup) or your Google sign-in if you use it.
Assessment responsesYour answers to the 49-question trait assessment and the resulting trait profile.You (when you take the assessment).
Experience contentResume text, job/volunteer/project/education entries you type or upload.You.
Generated outputArchetype profile, narrative, career matches, reflections, and related artifacts personalized to you.Generated by the service from the inputs above.
Feedback“Was this helpful?” ratings and similar in-product feedback.You.
Billing informationFor paid plans, limited billing metadata (subscription status, last-four, country) received from Paddle.Paddle, our payment processor.
Technical informationIP address, user agent, session cookie, timestamps, error logs.Your browser.

We do not intentionally collect government identifiers (SSN, driver’s license, passport), precise geolocation, biometrics, health records, or financial account numbers, and we ask you not to include such data in resume or experience entries.

3. How we use information

We use your information to: (a) create and operate your account; (b) generate your archetype, narrative, career matches, deep dives, and reflections; (c) secure the service and prevent abuse; (d) deliver the plan you purchased and process renewals; (e) respond to support requests; (f) improve the service, including through aggregate analytics (never using covered student data for advertising); and (g) comply with legal obligations.

4. AI processing

To generate narrative content we send relevant portions of your trait profile, archetype profile, and experience entries to third-party large-language-model providers (currently OpenAI and Anthropic) under their enterprise/API terms. These providers process inputs to return output to us and, under the API terms we have elected, do not train their public models on your content. We do not include your email address, password, or billing data in these prompts. Generated output is returned to the service and stored with your account.

5. When we share information

We share information only as follows:

  • Service providers that help us run the service under contract and only for the purposes we authorize — e.g., cloud hosting, email delivery, error logging, the AI providers described in Section 4, and Paddle for billing.
  • Schools that have licensed the service for their students — we share that student’s account and generated output back to the School as authorized in the School agreement.
  • Legal and safety — when required by law, subpoena, or court order, or to protect the rights, safety, or property of users or the public.
  • Business transfer — in a merger, acquisition, or asset sale, subject to the receiving party honoring this Policy for previously collected information.

We do not sell personal information, do not use covered student information for targeted advertising, and do not build advertising profiles from student data.

6. Schools & student data (FERPA, COPPA, SOPIPA)

When a School licenses GiftMatch Compass for its students:

  • FERPA (20 U.S.C. § 1232g; 34 C.F.R. Part 99). To the extent the School discloses education records to us, GiftMatch acts as a “school official” with a “legitimate educational interest,” uses such records only for the educational purposes authorized by the School, is under the School’s direct control with respect to those records, and does not re-disclose them except as the School directs or the law requires.
  • COPPA (15 U.S.C. §§ 6501–6506; 16 C.F.R. Part 312). GiftMatch does not knowingly collect personal information directly from children under 13 outside of a School-authorized deployment. Where a School provides GiftMatch to students under 13, the School provides verifiable parental consent consistent with the FTC’s school-authorization guidance, and GiftMatch limits collection to information reasonably necessary for the educational service.
  • SOPIPA / state student-privacy laws. For student users covered by California’s SOPIPA (Cal. Bus. & Prof. Code §§ 22584 et seq.) and analogous state laws, GiftMatch does not use covered information to target advertising, does not create non-educational profiles, does not sell or rent covered information, and maintains reasonable security practices. Parents and eligible students may request access, correction, or deletion through their School.
  • Data export & deletion. Schools may request export or deletion of their students’ records at any time. On termination of a School agreement, we delete or return covered student data within a commercially reasonable period unless retention is required by law.

If you are a parent or eligible student with questions about a School deployment, contact your School first; they can loop us in under their agreement.

7. Retention & deletion

We keep account and generated content for as long as your account is active. If you delete your account (or a School deletes a student account), we delete the associated records from our primary systems within a commercially reasonable period and purge them from routine backups on our standard backup-rotation schedule. We may retain a narrow set of records longer when required by law (for example, tax records related to a paid subscription).

8. Security

We use commercially reasonable administrative, technical, and physical safeguards, including encrypted transport (HTTPS), hashed passwords, access controls, and audit logging. No system is perfectly secure, and we cannot guarantee that unauthorized access will never occur. If we discover a security incident affecting your information, we will notify you and applicable authorities consistent with law.

9. Your rights

Depending on where you live, you may have rights to access, correct, delete, or export your personal information, to opt out of certain uses, and to appeal a decision we make about a request. To exercise a right, email us from the address on your account, or — if you are a student under a School license — contact your School.

California residents: you may also request a list of the categories of personal information we have collected and shared in the last twelve months. We do not “sell” personal information or share it for cross-context behavioral advertising as those terms are defined under the California Consumer Privacy Act.

10. Children

The direct-signup service is intended for users 13 and older. We do not knowingly collect personal information from children under 13 through direct signup. If we learn we have collected such information without the required consent, we will delete it promptly. Schools may onboard students under 13 only through a signed agreement that provides verifiable parental consent consistent with COPPA.

11. International users

GiftMatch Compass is operated from the United States. If you use the service from outside the U.S., you understand that your information will be processed in the U.S., which may have different data-protection laws than your country. By using the service you consent to that transfer.

12. Changes to this policy

We will update this Policy as the service evolves. When we make material changes, we will revise the “Last updated” date and provide additional notice when appropriate (for example, by email or in-app notice). Material changes to how we handle student data will be communicated to Schools under their agreements.

13. Contact

Privacy questions, data-rights requests, or School/parent inquiries can be sent to the contact address listed on our FAQ page. Please indicate whether you are an individual user, a parent/guardian, or a School administrator so we can route the request appropriately. For data-source attributions and licensing, see the notice on the How It Works page.

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