Innolife Technologies

Privacy Policy

Last updated October 22, 2026 · Effective date to be confirmed

Zengulate is an educational behavior-support and replacement-skill platform developed by Innolife Technologies ("Innolife," "we," "us," or "our"). This policy explains how information may be collected, used, disclosed, and protected when educators, schools, authorized students and other permitted users access Zengulate. Student behavior information may be sensitive, so collection and access should be limited to authorized educational purposes.

1. Scope

This Privacy Policy applies to the Zengulate website and authorized educator and student-facing services, including Support Now, ICARE guidance, RISE skill instruction, behavior observations, intervention records, Check-In/Check-Out (CICO), student performance check-ins, progress monitoring, parent reporting, and AI-assisted educational support. Separate Innolife Technologies products have their own policies.

2. Information we collect

Educator and account information may include names, email addresses, authentication and account details, school or classroom information, and support correspondence. Depending on educator choices, student records may contain aliases, initials or names, grade and class associations, behavior observations, regulation states, CICO goals and ratings, replacement-skill progress, notes, intervention records, parent or guardian contact information, and report content. Student aliases may still be identifiable when combined with other information. Student access, where enabled, uses teacher-managed class codes, aliases and PINs rather than requiring personal student email addresses. Our infrastructure may process IP addresses, device and browser data, authentication activity, and technical logs necessary to operate and secure the service.

3. How information is used

Information is processed to operate the service, authenticate and authorize users, deliver requested instruction and behavior-support tools, maintain records, generate authorized reports, provide requested AI-assisted guidance, communicate about accounts and support, protect the service, and meet applicable legal and contractual obligations. We do not sell student personal information or use student behavior records for targeted advertising.

4. Schools, educators and student records

When a school or district authorizes Zengulate to process educational records on its behalf, the institution retains its applicable rights and responsibilities for those records. Educators must submit only necessary information they are authorized to use. School or district approval, record-access rules, and any data privacy agreement govern institutional use. Zengulate must not be treated as an unrestricted repository for sensitive student information.

5. FERPA and education records

Student information maintained by schools or their service providers may constitute education records under FERPA. Where a school relies on the school-official exception to disclose records to a contractor, the required conditions include direct school control regarding use and maintenance, use and redisclosure restrictions, and a legitimate educational interest. A privacy policy alone does not establish compliance or replace school approval and an appropriate agreement. See the U.S. Department of Education's student privacy guidance linked below.

6. Children's privacy and COPPA

Zengulate is intended principally for educator-managed educational use. Where COPPA applies, Innolife Technologies remains responsible for its applicable obligations, including required notice, consent, protection and rights related to children's information. A school may provide consent on behalf of parents only in legally permitted educational circumstances, for the school's benefit and not unrelated commercial use. Parents seeking access to school-controlled student records should ordinarily contact the school; we will work with authorized schools and requesters as applicable.

7. Artificial intelligence

Some features use AI to draft educator language, support ideas or summaries. Outputs are assistive and must be reviewed by qualified educators; they are not diagnoses, determinations of behavioral function, emergency instructions, or automated eligibility, disciplinary or placement decisions. User-submitted content may be processed by providers needed to deliver the AI feature. Educators should avoid unnecessary student identifiers and sensitive details. Specific AI providers, transmitted fields and retention arrangements must be verified and disclosed before this draft is finalized.

8. Service providers and disclosures

Information may be handled by providers necessary for hosting, authentication, databases, AI functionality, email delivery, security and similar service operations. Disclosures may also be made where required or permitted by law and applicable agreements. The current provider list, purposes, locations and contractual arrangements remain subject to confirmation before final publication. We do not sell student personal information or use it for targeted advertising.

9. Access and security

Each student record can be read and changed only by the educator who created it. An educator may share one student at a time, read-only, with a named colleague, and may also let that colleague enter CICO scores and review past CICO days; every share, view and score entry is recorded in an access log. Shared colleagues may also be allowed to suggest behavior logs, skill data and notes, which become part of the record only when the owning educator adds them, and to edit the active behavior plan. Educators may join a school account with a join code; joining shares no student records, and school leaders see only counts and trends such as staff use, logs per week and students per tier, never student names or notes. Counselors, psychologists and administrators may keep private notes on a student that only the note's author can see; private notes are not shared, not shown to school leaders and not included in a student export. Student portal PINs are stored as salted hashes, repeated wrong PINs lock the account temporarily, and student sessions expire. Family links are random private links whose plain value is not stored and which the educator can turn off at any time. These measures have not yet been independently audited. No online service can guarantee absolute security. Report unexpected access to another educator's records or suspected account compromise through the support channel.

10. Retention and deletion

Information is retained for necessary educational, operational, contractual and legal purposes. An educator can download a student's full record, or permanently delete the student and all related records, from the student's profile; both actions are logged. Student PINs and sign-in tokens are never included in an export. Precise retention periods, backup deletion windows and account-closure procedures are pending operational verification and must be published before this draft is finalized.

11. Parent communications

Authorized educators may send student performance or behavior-support summaries to parent or guardian email addresses, and may give a family a private link to a weekly summary of positive moments and goals and to messages with the educator. Family links never show incident details. Family messages are screened for safety concerns in the same way as student text. The educator must verify the recipient and institutional authorization and limit communication to the information required for its educational purpose.

12. Requests and rights

Contact the school or district for school-controlled educational records, or contact Zengulate support for service or account privacy inquiries. We may coordinate a request with the relevant school and respond as applicable under law and agreements.

13. Changes

We may revise this policy when products, practices or legal obligations change. We will update the publication and revision dates and provide additional notice where required or appropriate for material changes.

14. Contact

Innolife Technologies · Zengulate · https://zengulate.com. Privacy and security requests: use the Contact page or an existing pilot support channel. A verified, monitored privacy email address and the legal entity's contact information must be inserted before final publication.

Official regulatory guidance

U.S. Department of Education — FERPA school-official requirements
FTC — COPPA frequently asked questions, including schools