Privacy Policy
Effective Date: [DATE]
Last Updated: [DATE]
PANCE Agent (“PANCE Agent,” “we,” “us,” or “our”) is operated by PANCE Agent LLC, an Ohio limited liability company. This Privacy Policy explains what information we collect, how we use it, who we share it with, and what rights you have regarding your information. It applies to all users of the PANCE Agent platform, including students, faculty, and program directors.
By creating an account or using the PANCE Agent platform, you agree to the practices described here.
Contents
- 1. Who We Are and How to Contact Us
- 2. The Two Types of PANCE Agent Users
- 3. Information We Collect
- 4. How We Use Your Information
- 5. Legal Basis for Processing
- 6. How We Share Your Information
- 7. AI Data Flows
- 8. FERPA — Student Education Records
- 9. Data Retention
- 10. Data Security
- 11. Your Content — Uploaded Materials
- 12. Cookies
- 13. Email Communications
- 14. Children
- 15. Your Privacy Rights
- 16. Data Breach Notification
- 17. Changes to This Policy
- 18. Contact
1. Who We Are and How to Contact Us
PANCE Agent provides an AI-powered study platform for Physician Assistant students preparing for the PANCE board examination. We are headquartered in Ohio.
Privacy inquiries: questions@panceagent.com · panceagent.com
2. The Two Types of PANCE Agent Users
How your information is handled depends on your relationship with the platform:
Individual users (self-pay students and faculty using individual accounts)
You have a direct account relationship with PANCE Agent. Your study data, progress, and account information are private to you. Your school’s faculty and program directors have no access to your individual account data through PANCE Agent.
Institutional users (Subsidized or Full Pay programs)
Your school has contracted with PANCE Agent and has authorized the sharing of certain student performance data with designated faculty and program directors through the Faculty Portal. This relationship is governed by your school’s agreement with PANCE Agent and by FERPA, as described in Section 8.
All schools must complete a School Authorization Agreement before any of their students may access PANCE Agent. This agreement establishes the terms under which student data may be handled.
3. Information We Collect
3.1 Information You Provide Directly
Account information: First name, last name, email address, and password. Program directors who execute a School Authorization Agreement also provide their professional title and institutional affiliation.
School affiliation: Your PA program, selected from our directory at account creation and stored as a permanent association with your account.
Uploaded content: Lecture materials in PDF, PowerPoint, or Word format that you upload for use in study sessions. By uploading content, you represent that you have the right to use that material in connection with PANCE Agent’s services.
Communications: Emails and support or bug-report submissions, including any information you include in them.
3.2 Information Generated Through Your Use
Study session data: Questions presented to you, your responses, and correctness evaluations.
Mastery and performance data: Per-topic mastery scores across PANCE Blueprint categories, calculated from your session activity and maintained over time.
AI conversation transcripts: Your full conversational exchanges with the AI tutor, stored to maintain session continuity and support spaced-repetition functionality.
Generated study content: AI-produced topic lists, quiz questions, and summaries derived from your uploaded materials.
Bug reports: Optional written comments, interface screenshots, and session metadata if you use the bug report feature.
3.3 Information Collected Automatically
Session cookies: Strictly necessary secure session tokens that maintain your authenticated session. See Section 12.
Log data: IP address, browser type, operating system, pages accessed, and request timestamps, used for security monitoring and platform administration.
4. How We Use Your Information
We use the information we collect to:
- Provide, maintain, and improve the Service
- Conduct AI tutoring sessions and calculate mastery scores
- Diagnose technical issues and respond to bug reports
- Detect and prevent unauthorized access, fraud, and abuse
- Send transactional emails (account creation, password resets, authorization notifications)
- Comply with applicable law and respond to legal process
We do not sell your personal information, use your information for advertising, or use your information to train Anthropic’s or OpenAI’s general AI models.
5. Legal Basis for Processing
Contractual necessity: Processing your account information, uploaded content, session data, and study results is necessary to provide the Service under our Terms of Service.
Legitimate interests: Processing log data and technical information for security monitoring and fraud prevention.
Legal obligation: Responding to verified legal process and fulfilling data breach notification obligations.
FERPA (institutional users): For students whose schools hold a Subsidized or Full Pay agreement, the school has designated PANCE Agent as a school official with a legitimate educational interest under 34 C.F.R. § 99.31(a)(1). Processing of education records is conducted pursuant to that designation and the school’s written agreement.
7. AI Data Flows — What Happens When You Use the Platform
During upload and synthesis: Your uploaded content is sent to OpenAI’s Embeddings API (for vector representations) and to Anthropic’s Claude (for topic list and study plan generation). Neither provider retains this content for model training.
During intake and review sessions: Each message you send is transmitted to Anthropic’s Claude with relevant context from your uploaded materials and session history. Claude generates the tutor’s response, which is returned to you and stored in your conversation history.
You are always interacting with an AI. PANCE Agent’s tutor is an artificial intelligence system, not a human. Every response during a study session is AI-generated. The AI tutor is not a licensed clinician, educator, or PA.
8. FERPA — Student Education Records
For students at schools holding a Subsidized or Full Pay agreement, this section describes how we handle student education records under the Family Educational Rights and Privacy Act, 20 U.S.C. § 1232g.
PANCE Agent as school official: Your school has designated PANCE Agent as a school official with a legitimate educational interest under 34 C.F.R. § 99.31(a)(1). This designation is established in the School Authorization Agreement.
What constitutes education records: Your name, email address, study session activity, mastery scores, and at-risk status as maintained by PANCE Agent constitute education records within the meaning of FERPA.
How your school accesses your records: Faculty and program directors designated in the Faculty Portal may view your mastery scores, session activity, and at-risk status for the purpose of monitoring and supporting student performance.
No redisclosure: PANCE Agent does not disclose your education records to any party other than your school’s authorized faculty and the subprocessors in Section 6.1.
Your FERPA rights are administered by your educational institution. To inspect your education records or request corrections, contact your program director or registrar.
Self-pay students: FERPA’s school official framework does not apply to individual self-pay accounts. Self-pay student data is not accessible to school faculty through PANCE Agent.
9. Data Retention
Account data: Retained for the duration of your account and a reasonable period after closure for legal compliance.
Study session data and scores: Retained for the duration of your account. Deleted upon account closure or upon your request.
Uploaded content: Retained for the duration of your account. Permanently deleted when your account is closed or upon your request.
AI conversation transcripts: Retained for the duration of your account. You may delete individual conversations through the platform interface.
School authorization records: Retained for a minimum of seven years for legal compliance, regardless of whether the school’s relationship with PANCE Agent continues.
10. Data Security
We implement administrative, technical, and physical safeguards designed to protect your information, including:
- Encrypted data transmission (TLS) between your browser and our servers
- Encryption of data at rest in our database infrastructure
- Row-level security controls limiting database access to authorized operations
- Secure session token authentication
- Access controls limiting personnel access to user data
No security measures are perfect. In the event of a data security incident affecting your personal information, we will notify affected individuals and relevant authorities as required by applicable law. We maintain a written information security program updated on a regular basis.
11. Your Content — Uploaded Materials
You retain ownership. You retain all copyright and other intellectual property rights in the materials you upload. PANCE Agent does not claim ownership of your uploaded content.
Limited license to provide the service: By uploading content, you grant PANCE Agent a limited, non-exclusive license to store, process, index, retrieve, and use your uploaded content solely to provide you with the AI tutoring service. This license does not extend to sharing your content with other users or commercializing your content.
Your representation: By uploading content, you represent that you have the right to use that material in connection with this service.
Content isolation: Your uploaded content is used only to generate study sessions for your own account. No other PANCE Agent user has access to your uploaded files or content derived from them.
PANCE Agent has registered a designated DMCA agent with the U.S. Copyright Office and maintains a notice-and-takedown process for copyright infringement claims. See our Copyright Policy for details.
13. Email Communications
PANCE Agent sends the following transactional emails (cannot be opted out of while your account is active):
- Account creation confirmation
- Password reset links
- School authorization notifications
- Security alerts relating to your account
We do not send marketing or promotional emails without separate opt-in consent. All emails from PANCE Agent originate from the panceagent.com domain.
14. Children
PANCE Agent is designed for adult graduate-level students enrolled in Physician Assistant programs. PA programs require a bachelor’s degree as a prerequisite, and our users are uniformly adults. The platform is not directed to children under 13, and we do not knowingly collect personal information from anyone under 13.
If you believe a person under 13 has created an account, please contact us at questions@panceagent.com and we will promptly investigate and delete the account if confirmed.
15. Your Privacy Rights
15.1 Rights Available to All Users
Regardless of your state of residence, you may:
- Request a copy of the personal information we hold about you
- Request correction of inaccurate account information
- Request deletion of your account and associated personal data
- Request your study data in a portable format
Contact questions@panceagent.com to exercise any of these rights. We will respond within 45 days and may ask you to verify your identity before processing your request.
15.2 California Residents (CCPA/CPRA)
California residents have the right to know, delete, correct, and port their personal information, and to opt out of the sale or sharing of personal information for cross-context behavioral advertising. We do not sell or share personal information for advertising purposes, so no opt-out mechanism is required. Personal information processed as student education records pursuant to FERPA and a school authorization agreement is exempt from CCPA/CPRA to the extent required by Cal. Civ. Code § 1798.145(e). To submit a California privacy rights request, contact questions@panceagent.com. We will respond within 45 days.
15.3 Other State Privacy Rights
Residents of Virginia, Colorado, Connecticut, Texas, Oregon, Montana, New Hampshire, New Jersey, and other states with comprehensive consumer privacy laws have similar rights. To exercise these rights, contact questions@panceagent.com.
AI and automated processing (Connecticut residents): Consistent with Connecticut’s data privacy requirements, we disclose that PANCE Agent uses personal information in connection with AI-powered features. Your uploaded content and conversation data are processed by Anthropic’s Claude and OpenAI’s Embeddings API under service provider agreements and are not used to train those providers’ general-purpose AI models.
16. Data Breach Notification
In the event of a security breach involving your personal information, we will notify affected individuals and relevant regulatory authorities as required by applicable law. For any incident affecting student education records processed on behalf of an institutional customer, we will notify the school promptly so the school can fulfill its own notification obligations.
17. Changes to This Policy
We may update this Privacy Policy from time to time. When we make material changes, we will update the “Last Updated” date and notify you by email or prominent platform notice. Your continued use of the platform after a policy update constitutes your acceptance. If you do not agree, you may request account deletion.
18. Contact
For questions, requests, or concerns about this Privacy Policy or our data practices:
PANCE Agent
questions@panceagent.com
panceagent.com
For school-specific data handling inquiries related to FERPA or a school authorization agreement, program directors may contact us at the same address with the subject line “School Data Inquiry.”