AlmaPathway Privacy and Data Policy
AlmaPathway LLC
Effective date: October 1, 2026
AlmaPathway helps high-school students connect with alumni from their school for guidance about colleges, majors, and careers, with school counselor oversight. This Privacy and Data Policy explains what information we collect, how we use it, when we share it, and the choices available to schools and users. This policy applies to the AlmaPathway website, application, email-based alumni reply features, and related services. AlmaPathway is designed for high-school users age 13 and older. It is not intended for children under 13.
1. Who uses AlmaPathway
- Students invited or authorized by a participating school.
- Alumni invited or approved to participate in that school's alumni community.
- School counselors and head counselors who administer or oversee the program.
- Authorized AlmaPathway platform administrators who support operation, security, and troubleshooting.
2. Information we collect
Information provided by schools
A participating school may provide limited roster or account information needed to invite and administer authorized students, alumni, and counselors. Depending on the school's program, this information may include a person's name, school affiliation, graduation year, email address, role, counselor assignment, or alumni recommendation. For alumni, a school may also provide a university or college and major or field of study when that information is available.
For alumni invitations, the information provided by a school is generally limited to the alumnus's name, email address, graduation year, and, when available, university or college and major or field of study. University and major information are optional and may be added or corrected by the alumnus after account activation. AlmaPathway does not collect alumni phone numbers or physical addresses through the school roster, invitation, account-creation, or profile process, and it does not maintain dedicated fields for that information. Participating schools should not provide it.
Participating schools are responsible for determining that they are authorized to provide this information and for identifying the individuals who are eligible to participate. AlmaPathway uses school-provided information only to operate and support the participating school's authorized program.
Information provided by users
- Profile information such as short biographies, schools or universities attended or considered, majors or fields of study, industries, interests, activities, and other information a user chooses to add.
- Connection requests, recommendations, messages, and other content created through AlmaPathway.
- For eligible alumni who reply directly to an AlmaPathway message-notification email, the reply text and email information needed to process the reply, such as the sender address, recipient routing address, provider message identifiers, timestamps, and limited technical headers or metadata used for routing, security, automation detection, and troubleshooting.
- Account preferences and authentication information. Passwords are handled through our authentication provider and are not stored by AlmaPathway in readable form.
Information collected automatically
- Technical and usage information needed to operate, secure, and troubleshoot the service, such as IP address, browser or device information, timestamps, logs, and actions taken in the product.
- Security, moderation, email-processing, and operational records created when the service detects, reviews, routes, retries, or responds to activity that may require attention.
3. How we use information
- Provide and operate AlmaPathway, including account access, student-alumni discovery, connection requests, messaging, recommendations, counselor dashboards, and eligible alumni replies sent through email.
- Associate an eligible alumni email reply with the intended existing AlmaPathway conversation and current alumni account using routing and sender-address checks.
- Keep users within the participating school community and enforce role- and school-based access controls.
- Support student safety and platform integrity, including automated moderation, counselor review of flagged activity, abuse prevention, and security monitoring.
- Send service-related communications, such as invitations, account notices, message notifications, moderation notices, email-reply status notices, and other operational emails.
- Maintain, troubleshoot, secure, and improve product functionality, reliability, safety, and user experience.
- Comply with applicable law, school instructions, contractual obligations, and valid legal requests.
Limited use of school-provided information
We use school-provided student and alumni information only to provide, administer, secure, and support the participating school's authorized AlmaPathway program.
We do not use school-provided student or alumni information for fundraising, donation solicitation, targeted advertising, unrelated marketing, unrelated recruiting, data brokerage, or external database enrichment. We do not sell personal information.
4. Student and alumni visibility
Email-address privacy
Stored student and alumni email addresses are not displayed to students, alumni, or through ordinary counselor views. Email addresses are not shown through profiles, search results, recommendations, connection requests, conversations, or moderation views. Authorized head counselors may access email addresses through roster, onboarding, invitation, and account-administration functions when reasonably necessary to administer the participating school's program.
AlmaPathway uses email addresses only as reasonably necessary for authorized program operations, such as sending invitations, activating and authenticating accounts, recovering accounts, delivering service or security communications, sending message notifications, and processing eligible alumni replies by email.
Access by authorized AlmaPathway personnel is limited to circumstances in which it is reasonably necessary to operate, secure, support, or troubleshoot the service, respond to an incident, comply with a valid legal requirement, or carry out the participating school's authorized instructions.
- Students may search for and discover participating alumni within their own school's authorized AlmaPathway community. Search and discovery show only alumni profile information intended for the guidance experience and do not reveal stored email addresses or other private contact information.
- A student may send a connection request inviting an alumnus discovered through that school community to connect. The alumnus decides whether to accept the request. Student-alumni messaging begins only after acceptance and remains within AlmaPathway, subject to the platform's messaging and moderation controls.
- Students do not receive access to alumni communities associated with other schools unless separately authorized through a participating-school relationship.
- When a student contacts an alumnus, the alumnus may see the student profile information needed to understand and respond to the request.
- Counselor recommendations may be visible to the recommended student and appropriate school counselors.
5. Messages, alumni email replies, and counselor oversight
Student-alumni conversations are not intended to be a general-purpose transcript source for counselors. Counselors do not receive routine unrestricted access to complete conversations simply because they are counselors.
Off-platform contact information
AlmaPathway uses automated moderation designed to identify attempts to exchange private off-platform contact information, including phone numbers, physical addresses, and external email addresses. A message identified for this reason is held and is not delivered unless an authorized counselor approves it through the moderation process. References to public professional or social-media profiles are not treated as private contact information, but remain subject to the platform's conduct and safety rules. Attempts to share private off-platform contact information may be retained as part of the applicable message and moderation record.
Alumni replies by email
For certain message notifications sent to eligible alumni, AlmaPathway may provide a reply-by-email option. This feature is limited to replies in an existing accepted student-alumni conversation; it does not allow an alumnus to start a new AlmaPathway conversation by email.
- An email reply is received and processed through our email service provider and AlmaPathway. We use a dedicated reply address and sender-address checks designed to associate the reply with the intended alumnus and conversation and re-check current account, relationship, and conversation state before delivery.
- AlmaPathway extracts the new reply text and may remove quoted prior-message history, standard email signatures, or other email formatting so that the new content can be handled as a normal AlmaPathway message.
- Email replies are subject to the same applicable messaging restrictions and moderation workflow as messages sent through the AlmaPathway website. A reply may be delivered, held for review, or not delivered depending on those controls.
- If a reply is held for review, the student does not see it while it is held. The alumnus may receive an email telling them that the reply is under review and, after review, whether it was delivered or not delivered.
- Attachments and images are not supported. If an alumnus sends text together with an attachment or image, AlmaPathway may process the text but will not deliver the attachment or image and may notify the alumnus that it was stripped. If a reply contains only an attachment or image and no usable text, no message is delivered.
- Students and counselors do not reply to AlmaPathway conversations through email under this feature; they continue to use the AlmaPathway application.
Counselor oversight
- When a message is flagged by moderation, an authorized counselor may receive limited conversation context around the flagged content so the counselor can understand and review the issue.
- Additional context may be made available in bounded increments when needed for a moderation decision, rather than exposing an entire conversation by default.
- Head counselors may receive access to escalated moderation matters as appropriate to their role.
- AlmaPathway platform administrators may access operational data when reasonably necessary for security, troubleshooting, support, email-reply processing, or incident response.
6. Automated and AI-assisted features
AlmaPathway uses automated tools, including artificial intelligence, for limited product functions such as moderation and certain messaging or analysis features. When these features are used, relevant content may be processed by service providers acting on AlmaPathway's behalf.
- AI is used to support product functionality, safety, and moderation; it is not used to create advertising profiles.
- AlmaPathway uses OpenAI API services for certain AI-assisted functionality. OpenAI states that, by default, API inputs and outputs are not used to train or improve its general-purpose models unless the customer explicitly opts in.
- Automated moderation may flag content for review, but school personnel or authorized administrators may be involved in decisions that require human judgment.
- Alumni replies received through email enter the same applicable moderation process as website-originated messages; AlmaPathway does not use AI to interpret email commands or attachments.
7. Service providers and data sharing
We share information only as needed to operate the service, follow school instructions, protect users and the platform, or comply with law. Depending on the feature, service providers may include:
- Supabase - database, authentication, and related backend services.
- Vercel - application hosting and delivery.
- OpenAI - AI-assisted product and moderation functionality.
- Resend - transactional email delivery and, for eligible alumni reply-by-email functionality, receipt and retrieval of incoming reply emails and related email metadata.
- Google - authentication when a school or user uses Google sign-in.
- Microsoft - authentication for eligible users when Microsoft sign-in is available.
When an alumnus uses reply-by-email, the incoming email is processed by Resend before AlmaPathway retrieves the information needed to handle the reply. Provider-side handling and retention are subject to the provider's applicable terms, contractual commitments, and service configuration.
We may also disclose information to a participating school as needed to administer the service; to protect users, investigate abuse, or respond to security incidents; in connection with a business transaction subject to appropriate safeguards; or when required by law or valid legal process.
8. School relationship and student information
Participating schools control important aspects of how AlmaPathway is used for their communities, including participant eligibility, invitations, role assignments, counselor assignments, account activation or deactivation, and program administration.
As described in Section 2, the information a school may provide to AlmaPathway is limited to the roster and account information reasonably necessary to operate the school's authorized program. For alumni invitations, this information is generally limited to the alumnus's name, email address, graduation year, and, when available, university or college and major or field of study. University and major information are optional. AlmaPathway does not request or collect alumni phone numbers or physical addresses through this process.
Each participating school is responsible for determining that it is authorized to provide this limited information and any related instructions to AlmaPathway. When AlmaPathway processes information supplied by a participating school, it does so as a limited-purpose service provider to operate, secure, and support that school's authorized program, subject to this Privacy and Data Policy and any applicable agreement with the school.
AlmaPathway does not obtain ownership of school-provided personal information and does not use that information for purposes unrelated to the authorized program.
FERPA applicability
FERPA applicability depends on the participating school and on the source and status of the specific information involved. FERPA generally applies to educational agencies and institutions that receive funds from programs administered by the U.S. Department of Education. Private elementary and secondary schools generally do not receive that funding and therefore are generally not subject to FERPA.
The school-provided information AlmaPathway may receive is limited to the roster and account information described in Section 2, counselor assignments, and alumni recommendations needed to operate the program. AlmaPathway does not request transcripts, grades, disciplinary records, health records, financial-aid records, or other general education records to operate the service.
If a FERPA-covered school provides any of the limited information described in Section 2 from an education record, AlmaPathway will process that information only to perform the services authorized by the school and as permitted by the applicable school agreement and law. When applicable, the school agreement may establish AlmaPathway as a school official performing an institutional service for which the school would otherwise use its own employees or contractors. The school retains control over the use and maintenance of that information, and AlmaPathway may not use or redisclose it for unrelated purposes.
Regardless of whether FERPA technically applies to a particular school or record, AlmaPathway applies the protections described in this policy to student information. These protections include collecting only information reasonably necessary for the program, limiting use to the authorized educational and mentorship purpose, applying role- and school-based access controls, restricting disclosure, and prohibiting the sale or use of student information for targeted advertising.
9. Children under 13
AlmaPathway is intended for users age 13 and older and is not directed to children under 13. If we learn that we have collected personal information directly from a child under 13 in a manner subject to the Children's Online Privacy Protection Act (COPPA), we will take appropriate steps to stop the collection and delete or otherwise handle the information as required by law.
10. Data retention and deletion
- We retain personal information for as long as reasonably necessary to provide the service, maintain school and account relationships, support safety and security, comply with legal or contractual obligations, and resolve disputes.
- Canonical AlmaPathway messages and related moderation or audit records may be retained while the applicable school or user relationship remains active and for a reasonable period afterward when needed for safety, security, support, or legal purposes.
- For alumni replies received through email, AlmaPathway may temporarily process normalized reply text and maintain limited routing, provider-event, status, retry, and diagnostic records needed to safely deliver or reject the reply, prevent duplicate processing, support moderation, and troubleshoot failures. Terminal internal email-reply processing records and expired, unreferenced reply routes are subject to bounded cleanup after 30 days. Canonical messages, moderation records, and notification audit records follow their normal retention rules.
- AlmaPathway does not intentionally store inbound attachment contents as part of the alumni reply feature. Attachments and images are not delivered into AlmaPathway conversations.
- When a student graduates, the student profile is not automatically converted into an alumni profile. If the former student later participates as an alumnus, the alumni profile is completed separately.
- Schools or users may request deletion or correction of information as described below, subject to legal, security, contractual, and recordkeeping requirements.
11. Security
We use administrative, technical, and organizational safeguards designed to protect personal information. These include role- and school-based access controls, authentication controls, logging, database access restrictions, moderation boundaries, email webhook verification, restricted reply routing, duplicate-processing protections, and security monitoring. No system can guarantee absolute security, and we continue to review and improve safeguards as the service evolves.
For alumni reply-by-email, AlmaPathway uses controls designed to limit replies to the intended existing conversation, including dedicated reply routing, current-state validation, and comparison of the sender address with the alumnus's current registered email address. Unknown, expired, revoked, forwarded or wrong-sender, automated, or otherwise ineligible replies may be suppressed or rejected without disclosing account or conversation details.
12. Your choices and requests
- Users may update certain profile information directly in AlmaPathway.
- Eligible alumni may choose whether to use the reply-by-email option when it is offered; they can always open AlmaPathway and reply through the application instead.
- Students, alumni, parents where legally applicable, and schools may contact us to request access, correction, or deletion of information, subject to identity verification and applicable legal or contractual requirements.
- A participating school may also direct certain account, roster, or program changes for users associated with that school.
- Users may sign out or stop using the service; schools may deactivate or remove access when appropriate.
13. Changes to this policy
We may update this policy as AlmaPathway evolves. If we make a material change, we will update the effective date and provide additional notice when appropriate.
14. Contact us
Questions, requests, or privacy concerns can be sent to:
AlmaPathway LLC