Children, COPPA and FERPA

How Rally works for a school that has to answer to a district privacy review.

Last updated 2026-10-05Applies to rally.sentinelgrid.us

The short version

Rally collects no personal information from students. There is no student account, no email address, no name a child types, and no identifier that follows a student between games. If a teacher adds real names to a report for grading, they are kept encrypted on the teacher's own device and are never sent to Rally. That removes most of what COPPA and FERPA are usually asked about, but it does not remove a school's own obligations, and it is not a substitute for your district's review.

1. COPPA

Rally is used in classrooms, so we treat it as a service directed to children and follow the Children's Online Privacy Protection Act and the FTC's COPPA Rule as amended in 2025. The most important protection is that Rally collects almost nothing from a student:

  • no name: display names are generated by the server, and a student is never asked for one. A teacher may note real names beside them for grading; those stay on the teacher's device and Rally does not collect them (see section 2)
  • no email address, phone number, or physical address
  • no persistent identifier tied to a student across games; the join token works in one game and is stored only as a hash
  • no photograph, audio or video, and no way for a student to upload anything. Game sounds are made by the browser; nothing is recorded
  • no precise geolocation
  • no behavioural advertising, no analytics, and no third-party trackers or fonts: a student's browser talks only to Rally

A student's browser does reach Rally's servers, so Cloudflare sees its IP address in order to deliver the page, and Rally keeps a one-way hash of it for the length of a rate-limit window, and briefly after until housekeeping clears it, to stop abuse. That is support for the internal operation of the service, which the Rule allows without consent, and it is never stored, linked to a student or used for anything else.

Rally is offered to schools for classroom use only. Where students may be under 13, Rally relies on the school's authorisation in place of individual parental consent, as the FTC permits for a service used solely for the benefit of the school and for no commercial purpose. Every teacher confirms this when hosting (see Terms, section 3). In return, SentinelGrid:

  • uses anything from a student only to run the game and show the teacher the results;
  • never uses it for advertising, profiling, building a product for anyone else, or AI training, and never sells or shares it;
  • lets the school review and delete it at any time;
  • deletes every game, and every player row in it, 12 months after the game ends at the latest, or after the shorter period the school has chosen.

A parent who wants to know what Rally holds, or wants it deleted, can ask their child's teacher or school, or write to us at privacy@sentinelgrid.us. Because student rows hold no names, the quickest route is usually the teacher, who can delete the game in one step.

Operator

Rally is operated by Mason Collier, a sole proprietor trading as SentinelGrid, Florida, United States. Mailing address: 3207 Eagle Blvd, Orlando, FL 32804. Telephone: (321) 263-9085. Email: privacy@sentinelgrid.us. No other operator collects information through Rally.

Retention and security

Our retention schedule is in the Privacy Policy, section 7. We keep a written information security programme covering Rally: encryption in transit, hashed credentials, per-player encrypted question packs, and access to data limited to the operator. If a breach ever involved student data, we would tell the affected schools promptly.

2. FERPA

FERPA governs education records. Rally is built so that what it stores is not linked to an identifiable student: a row says BriskOtter47 scored 1,340, and only the teacher in the room knows who that was.

Where a school treats game results as an education record, SentinelGrid acts as a school official with a legitimate educational interest under the direct control of the school: we use the data only to provide the service, we do not redisclose it, and we delete it on the school's instruction.

Names for grading are the school's record, not ours

A teacher can add students' names to a finished game's report and download a grades file. Once a name is beside a mark, that list is very likely an education record. It is created and held by the teacher, on the teacher's device, under the school's control. It is never disclosed to SentinelGrid: the names are not sent to Rally, are not in its database, and are stored in the teacher's browser encrypted (see the Privacy Policy). So for those names SentinelGrid is not a school official, a processor or a recipient, because it never receives them, and a request to inspect, amend or delete them is one for the school.

A school that does not want names added at all can tell its teachers so; nothing in Rally requires it, and Rally works the same without it.

One caveat worth stating plainly. A teacher who types a student's name into a question (“What grade did Jordan get?”) has put personal information into content, and Rally stores content. Nothing in the design can prevent that. Ask teachers not to.

3. Roles

  • The school or district is the data controller for its use of Rally and decides which classes use it. Controlling its own data does not make a school an owner of Rally; SentinelGrid owns the service. See Who owns Rally.
  • SentinelGrid is a processor / service provider, acting on the school's instructions.
  • Cloudflare is a sub-processor providing hosting. See Subprocessors.

4. State student-privacy laws

Many states impose additional duties on operators of school services: no targeted advertising to students, no profiles for non-educational purposes, no sale of student data, deletion on district request. Rally is built to satisfy those by not doing any of it. SentinelGrid will sign a state-required data privacy agreement on request; write to privacy@sentinelgrid.us.

5. Deletion

A teacher can delete a game, every finished game, or a whole question set from inside Rally; that removes every player row in it immediately. A district, school or class administrator granted data management for Rally can set how long finished games are kept for everyone in it (from one day to 12 months) and can delete every finished game in it at once. Names a teacher added for grading are deleted on the teacher's own device: with the report's Delete records button, with the Forget buttons in the names panel, by clearing the browser's data, or automatically after 12 months. A district can also request deletion of a teacher's account and everything attached to it by writing to privacy@sentinelgrid.us.

6. For your review file

Schools evaluating Rally can request a completed privacy questionnaire, a data-flow description, and a copy of the sub-processor list at privacy@sentinelgrid.us.

Not legal advice. These pages describe how Rally actually works and are written to be accurate, but they have not been reviewed by counsel and they do not create an attorney–client relationship. If your district requires a signed data privacy agreement, write to privacy@sentinelgrid.us and we will work through it with your legal team.