Modali Ed System
Privacy Policy & Data Charter
At Modali (ModaliEd) by LiquidVisuals, we believe every mind learns differently, and every learner's data deserves absolute confidentiality, security, and ethical stewardship. This policy articulates our strict adherence to international student privacy standards, zero-commercialization commitments, and institutional data ownership.
1. Zero Commercial Data Exploitation Pledge
Modali is built exclusively for educational diagnostics, differentiated instruction, and individualized learner growth. We reject the monetization of student academic, cognitive, or behavioral records. We make the following immutable promises:
We will never sell, lease, license, or trade student personal records, assessment responses, or diagnostic profiles to data brokers, marketers, or advertisers.
Modali is 100% ad-free. We do not track student browsing habits to serve behavioral advertisements or marketing campaigns within or outside the platform.
Student diagnostic data is never fed into, harvested by, or used to train open public artificial intelligence foundation models without explicit district authorization.
2. Information Collected & Processed
In accordance with data minimization principles, Modali only collects information strictly necessary to compute psychometric profiles, generate UDL accommodations, and maintain classroom rosters:
Student name (or anonymous pseudonym/alias for guest test-takers), student institutional ID, developmental grade band (Early Primary K–2, Junior Elementary 3–6, Middle School 7–9, Senior Secondary 10–12), birth month/year (for age-normed psychometric calibration), and classroom join code affiliation.
Student rating selections (Likert scale 1 to 5) across the 100 developmental indicators, completion timestamps, and respondent context (student self-report, teacher rating, or parent observation).
Computed 8-Pillar raw & z-scores, 13 subscale index scores, developmental threshold classifications, Tiered Intervention Index (TII), MAA adaptive response trajectories, identified cognitive/sensory strengths, areas of high support need, and recommended Universal Design for Learning (UDL) instructional accommodations.
User interface language selection (English, Tagalog/Cebuano, Spanish, French, Korean, Japanese, Chinese), regional accent preference, synthesized voice persona gender, and text simplification toggles.
Name, institutional email address (via Google Identity Services OAuth 2.0 or local authentication), role designation (Teacher, School Administrator, Superadmin), assigned school name, class roster definitions, and Professional Learning Community (PLC) intervention tracking notes.
3. How We Use Educational Data
Data processed by the Modali Ed System is used solely for legitimate educational interests authorized by the participating school, educator, or student:
Translating indicator ratings into 8-Pillar psychometric profiles and developmental radar charts (aligned with the Ontario *Learning for All* Appendix B Student Profile framework) to highlight strengths and high-support pathways.
Aggregating student data into class-level matrices (Appendix A Class Profile) to assist classroom teachers in designing Universal Design for Learning (UDL) lessons, flexible grouping, and tiered instructional adjustments.
Enabling educators and school specialists to track Tier 1 (Universal), Tier 2 (Targeted), and Tier 3 (Intensive) interventions within PLC (Professional Learning Community) and LAC (Learning Action Cell) workflows.
Verifying authorized session tokens, guarding against brute-force attacks, enforcing role-based permissions, and maintaining system operational audit trails.
4. Statutory & International Standards Alignment
Modali is engineered to comply with major educational privacy statutes and data protection acts across North America, the Philippines, the United Kingdom, and international school networks:
Under the Family Educational Rights and Privacy Act (FERPA), Modali operates as a "School Official" with legitimate educational interests. Student educational records are under the direct control of the educational institution. We do not re-disclose student records without written parental consent or statutory exemption.
Under the Children's Online Privacy Protection Act (COPPA), schools and school districts act as agents for parents, providing consent on their behalf for educational software used in the classroom. Modali does not condition student participation on disclosing more personal information than necessary.
Fully aligned with the National Privacy Commission (NPC) principles of Transparency, Legitimate Purpose, and Proportionality, as well as DepEd Order No. 40, s. 2012 (Child Protection Policy) and DepEd Order No. 35, s. 2016 (Learning Action Cells). Student data is treated as sensitive personal information with strict confidentiality.
For Cambridge, COBIS, CIS, and International Baccalaureate (IB) institutions, Modali complies with EU/UK General Data Protection Regulation requirements. Our lawful basis is legitimate educational interest / public task. Data subjects maintain the right of access, rectification, erasure, and data portability.
5. Role-Based Access Control (RBAC) & Security
Data is strictly partitioned based on the principle of least privilege through automated Role-Based Access Control:
Students can strictly view their own diagnostic results, personal developmental radar charts, and activities assigned to their joined class. They cannot view peer scores.
Teachers can only view students enrolled in their assigned classes, synthesize their own Class Profiles, and generate tiered flexible groups for their cohorts.
School Administrators (Principals, Special Ed Coordinators) oversee classes, teachers, and aggregate institutional matrices within their specific school entity.
Restricted exclusively to authorized technical maintainers for system integrity, database maintenance, account vetting, and server security audits.
- TLS 1.3 / HTTPS Encryption: All data in transit between client browsers and Modali servers is encrypted using modern cryptographic cipher suites.
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Secure Session Tokens: Session cookies utilize
HttpOnly,SameSite=Lax, and cryptographic hashing. - Prepared Statements: All database queries utilize parameterized PDO SQL statements preventing SQL injection vulnerabilities.
- Guest Walk-in Testing Mode: Walk-in diagnostic testers can evaluate the system anonymously without storing permanent personally identifiable information (PII).
6. Retention, Portability & Right to Erasure
We retain student data only as long as an active educational engagement exists, or as mandated by school district archiving policies:
Class rosters and assessment records are retained throughout the school academic year to facilitate longitudinal MTSS/UDL trajectory monitoring and progress tracking.
Teachers and administrators can export individual Student Profiles, printable PDF reports, Class Profile Matrices, and bulk ZIP archives at any time for school archiving.
Schools or authorized parents may request permanent deletion of student assessment records at any time. When an account or class is deleted, associated records are expunged from primary operational tables.
7. Student & Parental Rights
Parents, legal guardians, and eligible students (age 18+) have fundamental rights regarding their diagnostic educational records:
- Right to Inspect & Review: Parents and students may inspect and review the student’s diagnostic scores, radar graphs, and UDL recommendations through their teacher or student portal.
- Right to Seek Amendment: If an educational record is inaccurate or misleading, parents or students can request an amendment or retake the diagnostic assessment.
- Right to Revoke Consent: Parents may request that their child cease using the platform by contacting their classroom teacher or school administration.
8. Data Protection Inquiries & Contact
If you have questions, statutory audit requests, or concerns regarding student data privacy in the Modali Ed System, please contact our designated Data Protection Officer and Lead Architect: