Privacy Policy

Last Updated: March 9, 2026

This privacy policy is provided in draft form and has not been reviewed by legal counsel. FERPA and COPPA compliance should be verified by a qualified attorney before publishing.
We collect only what we need to run your lottery. We never sell your data. Student information is handled in accordance with FERPA. Here's exactly what we do and don't do.

1. Who We Are

Marble ("Marble," "we," "us," or "our") is a school enrollment lottery platform operated by [Legal Entity Name], located at [Address]. We provide software that helps schools run fair, transparent, and auditable enrollment lotteries and helps families apply to schools.

For questions about this policy, contact us at: privacy@marbleadmissions.com

2. Who This Policy Covers

This Privacy Policy applies to:

  • School administrators and staff who use Marble to manage enrollment lotteries
  • Parents and guardians who use Marble to apply to schools on behalf of their children
  • Visitors to marbleadmissions.com

This policy does not apply to third-party websites or services linked from our platform.

3. Information We Collect

From Schools and Administrators

When a school is onboarded to Marble, we collect:

  • School name, address, and contact information
  • Administrator names, email addresses, and role
  • Lottery configuration details (grade levels, seat counts, dates)
  • Billing information (processed by our payment processor — we do not store credit card numbers)

From Families (Parents and Guardians)

When a parent or guardian creates an account or submits an application, we collect:

  • Parent/guardian name and email address
  • Child's first name, last name, date of birth, and current grade level
  • Home address (used for geographic eligibility, where applicable)
  • Application history and lottery results
  • Any additional information required by the school for their lottery

Automatically Collected Information

When you use Marble, we automatically collect:

  • IP address and general location
  • Browser type and device information
  • Pages visited and time spent on the platform
  • Actions taken within the platform (for security and audit purposes)

What We Do Not Collect

  • We do not collect Social Security numbers
  • We do not collect financial information beyond what is necessary for billing (handled by our payment processor)
  • We do not collect biometric data
  • We do not use your data to build advertising profiles

4. How We Use Your Information

We use the information we collect to:

  • Create and manage school and family accounts
  • Run enrollment lotteries and generate results
  • Send lottery-related notifications (application confirmation, results, offers, waitlist updates)
  • Generate compliance documentation and audit trails for schools
  • Provide customer support
  • Improve and maintain the Marble platform
  • Comply with legal obligations

We do not use student information for any purpose other than providing the enrollment lottery service.

5. FERPA Compliance

Marble operates as a school official under the Family Educational Rights and Privacy Act (FERPA), acting under the direct control of the school with respect to the use and maintenance of education records. Specifically:

  • Schools that use Marble remain the custodians of their student education records
  • Marble accesses and processes student information only as directed by and for the benefit of the school
  • Marble does not disclose student education records to third parties without the school's authorization, except as required by law
  • Schools are responsible for ensuring that their use of Marble complies with FERPA, including obtaining any necessary consents from parents or guardians

If you are a parent or guardian and have questions about your child's education records, please contact the school directly.

6. Children's Privacy (COPPA)

Marble's platform is directed at schools and parents — not at children. We do not knowingly collect personal information directly from children under 13.

Student information (including a child's name, date of birth, and grade level) is provided to Marble by parents or guardians on behalf of their child, or by schools acting under FERPA. This information is used solely to facilitate the enrollment lottery process.

If you believe we have inadvertently collected personal information directly from a child under 13, please contact us at privacy@marbleadmissions.com and we will delete it promptly.

7. How We Share Your Information

We do not sell your personal information. We do not share your information with advertisers. We may share information in the following limited circumstances:

With schools

Family application data is shared with the school to which a family has applied. This is the core function of the platform.

With service providers

We work with third-party service providers who help us operate Marble (e.g., cloud hosting, email delivery, payment processing). These providers are contractually bound to use your information only to provide services to us and to maintain its confidentiality.

For legal compliance

We may disclose information if required to do so by law, court order, or governmental authority, or if we believe disclosure is necessary to protect the rights, property, or safety of Marble, our users, or the public.

In a business transfer

If Marble is acquired or merges with another company, your information may be transferred as part of that transaction. We will notify users before personal information is transferred and becomes subject to a different privacy policy.

8. Data Retention

School account data

Retained for the duration of the school's active subscription plus 90 days after cancellation, during which data remains exportable. After 90 days, data is deleted unless legally required to be retained.

Family application data

Retained for the duration of the relevant lottery cycle plus 12 months. Families may request deletion of their account and data at any time (see Section 10).

Audit trail and compliance records

Lottery audit trails are retained for a minimum of 5 years to support compliance and legal defensibility. Schools may export their complete audit records at any time.

Billing records

Retained for 7 years in accordance with standard accounting and tax requirements.

9. Security

We take reasonable and appropriate measures to protect your information from unauthorized access, disclosure, alteration, or destruction. These measures include:

  • Encryption in transit (TLS) and at rest
  • Access controls limiting who can view student data
  • Regular security reviews
  • Cryptographically verifiable lottery processes that create tamper-evident records

No method of transmission over the internet is 100% secure. While we work hard to protect your information, we cannot guarantee absolute security.

10. Your Rights and Choices

Access

You may request a copy of the personal information we hold about you.

Correction

You may update or correct your account information at any time through your account settings.

Deletion

You may request deletion of your account and personal information. Note that lottery audit trail records may be retained per Section 8 even after account deletion, as required for compliance purposes.

Data portability

Schools may export their complete data — including all application records, lottery results, and compliance documentation — at any time from their admin dashboard.

Opt-out of non-essential communications

You may opt out of non-transactional emails at any time. You cannot opt out of transactional notifications (e.g., lottery results, offer notifications) while your account is active, as these are core to the service.

To exercise any of these rights, contact us at privacy@marbleadmissions.com.

11. Cookies

Marble uses essential cookies to operate the platform (session management, authentication, security). We do not use advertising cookies or third-party tracking cookies.

You may disable cookies in your browser settings, but doing so may prevent certain features of the platform from functioning correctly.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date at the top of this page and notify active users by email at least 30 days before material changes take effect.

Your continued use of Marble after changes take effect constitutes your acceptance of the updated policy.

13. Contact Us

For privacy-related questions or to exercise your rights:

Email: privacy@marbleadmissions.com Mail: [Legal Entity Name], [Address]

For FERPA-related inquiries about a specific school's student records, please contact that school directly.