Privacy Policy

Information You Provide

Account Registration Information: When you create an account or register for our Services, we collect Personal Information including:

• Student name, age, grade level, and school affiliation
• Parent or guardian contact information (name, email address, phone number)
• Login credentials and account preferences

Onboarding and Preference Data: During initial setup and onboarding processes, we collect:

• Student interests, hobbies, and personal preferences
• Learning style preferences and educational goals
• Academic subject preferences and challenges
• Extracurricular activities and interests

Educational Interaction Data: Through use of Or[b] and our Services, we collect:

• Conversation logs and chat histories with Or[b]
• Academic progress data and assignment completion records
• Assessment results and performance analytics
• Learning pathway selections and content interactions

Information We Collect Automatically

Technical Information: We automatically collect certain information when you access our Services:

• Device information (type, operating system, browser, unique device identifiers)
• IP address and geolocation information
• Session data (time stamps, session duration, feature usage)
• Performance and diagnostic data

Usage Analytics: We collect information about how users interact with our Services:

• Navigation patterns and feature utilization
• Response times and system performance metrics
• Error logs and technical diagnostics

Information from Third Parties

School-Provided Information: We may receive information about students from School Partners, including:

• Student enrollment and roster data
• Educational records as permitted under FERPA
• Academic performance and assessment data
• Classroom assignment and scheduling information

Users Under 13 Years of Age

Stemuli is committed to complying with the Children's Online Privacy Protection Act (COPPA) and protecting the privacy of children under 13. When we choose to make Stemuli available to children under 13, we will not collect personal information from them without appropriate consent or authorization.

Collection Limitations: For children under 13, we:

• Do not collect Personal Information without consent from the child's parent, guardian, or school
• Do not collect Personal Information beyond what is necessary for educational purposes
• Do not use Personal Information for behavioral advertising or marketing
• Do not sell or rent Personal Information to third parties
• Do not create profiles for non-educational commercial purposes

Parental Rights: Parents and legal guardians of children under 13 have the right to:

• Review Personal Information collected from their child
• Refuse to permit further collection of their child's personal information
• Request deletion of their child's Personal Information

Parent Access Process: All parent requests to access, review, correct, or delete Student Data must be submitted to and approved by the School Partner. We direct all parent inquiries to the appropriate School Partner to ensure that only legally authorized individuals receive access to educational records. Once the School Partner authorizes your request, we will fulfill it within 30 days.

School-Based Consent: When our Services are made available to students in an educational setting by one of our School Partners, we rely on the School Partner to obtain appropriate consent and authorization for data collection. School Partners may provide consent on behalf of parents for the collection and use of Personal Information from children under 13 for educational purposes only.

To help School Partners address their obligations to protect their students' data privacy, we have implemented additional controls and procedures for School Partners when they enter into a contract with Stemuli to use our Services for school purposes.

• As between us and the School Partner, Student Data is owned and controlled by the School Partner.
• We collect, maintain, use and share Student Data only for an authorized educational purpose.
• We do not use, disclose, or sell Student Data for any advertising purposes.
• We do not build a personal profile of a student other than in furtherance of an educational purpose.
• We maintain a comprehensive data security program designed to protect Student Data.
• We will clearly and transparently disclose our data policies and practices to our users.
• We will never sell Student Data unless the sale is part of a corporate transaction.

How We Share and Disclose Student Data

We disclose Student Data solely as needed to provide our services on behalf of specific School Partners in accordance with our contracts with those School Partners.

Employee and Agent Confidentiality

All Stemuli employees and agents who have access to Student Data are required to:

• Complete training on FERPA, COPPA, and student data privacy requirements
• Sign confidentiality agreements that specifically address the protection of Student Data
• Comply with all terms of our agreements with School Partners
• Handle Student Data in accordance with our information security policies

How We Remove Student Data

We will not knowingly retain Student Data beyond the time period required to support an educational purpose, unless authorized by the School Partner. Upon request from a School Partner, we will delete Student Data within 60 days.

Data Storage Location

All Student Data is stored exclusively in secure data centers located within the United States. We do not transfer or store Student Data on servers located outside the United States.

Educational Services

We use collected information to:

• Provide personalized AI-powered tutoring and educational support through Or[b]
• Track academic progress and generate performance analytics
• Facilitate communication between students, educators, and parents
• Adapt learning content and recommendations to individual needs
• Support curriculum delivery and educational goal achievement

AI Personalization and Machine Learning

• Customize Or[b]'s conversational responses based on individual learning patterns
• Analyze learning data to improve educational recommendations
• Develop predictive models to identify learning gaps and opportunities
• Enhance natural language processing capabilities for age-appropriate interactions

IMPORTANT: Student conversation data is not used to train general AI models or for any purpose unrelated to providing educational services to the student.

Safety and Security

• Monitor interactions to ensure appropriate educational content and behavior
• Detect and prevent misuse of our platform
• Investigate safety concerns and respond to incidents
• Maintain system security and prevent unauthorized access

Educational Stakeholders

School Partners: We share Student Data with authorized school personnel as necessary to provide educational services, including:

• Academic progress and performance data
• Assignment completion and assessment results
• Learning analytics and engagement metrics
• Safety or behavioral concerns

Parents and Guardians: Parents have access to their child's account information and may review all Personal Information collected about their child.

Service Providers

We may share information with third-party service providers who assist in delivering our Services.

Subprocessor Information: Our current subprocessors include:

• OpenAI, Inc. (AI language models for tutoring responses)
• Anthropic, PBC (AI language models for tutoring responses)
• Neon Database (cloud database and data storage)

Legal and Safety Requirements

We may disclose Personal Information when:

• Required by law, court order, or legal process
• Necessary to protect the safety and security of students, staff, or the public
• Required to investigate suspected illegal activity or policy violations
• Necessary to enforce our Terms of Service or other agreements

Business Transfers

In the event of a merger, acquisition, or sale of assets, Personal Information may be transferred as part of the business transaction, subject to equivalent privacy protections.

Or[b] AI Processing

Our AI-powered learning companion Or[b] processes personal information to:

• Generate personalized educational responses and recommendations
• Adapt conversation style and content to individual learning needs
• Identify learning patterns and suggest targeted practice activities
• Provide real-time feedback and educational support

AI Transparency and Limitations

• AI-generated recommendations support but do not replace human educational judgment
• Teachers and parents maintain oversight of educational decisions
• Students and educators can review and override AI suggestions
• We implement safeguards to prevent inappropriate AI responses

Data Training and Model Development

• Student conversation data is not used to train general AI models or systems
• We may use de-identified, aggregated data for educational AI research
• Any use of student data for AI development is limited to improving educational outcomes
• We maintain strict data governance policies for AI training activities

Security Measures

We implement comprehensive security measures to protect Personal Information, including:

• Encryption of data in transit and at rest using industry-standard protocols
• Written information security policies and procedures
• Multi-factor authentication and access controls
• Regular security audits and vulnerability assessments
• Employee training on data protection and privacy practices
• Incident response procedures and breach notification protocols

Security Audit Rights: School Partners may conduct or request an independent third-party security audit of our data protection practices no more than once per year, or following a data breach incident.

Security Framework Compliance: Our information security program is designed to align with the NIST Cybersecurity Framework Version 2.0.

Data Retention

• We retain Personal Information only as long as necessary for educational purposes
• Student data is typically deleted upon graduation, withdrawal, or account closure
• Parents may request earlier deletion of their child's information
• Legal requirements may necessitate longer retention in specific circumstances

Access and Correction Rights

• Students and parents may request access to Personal Information we maintain
• Users may request correction of inaccurate or incomplete information
• We provide mechanisms for users to update account preferences and settings

Deletion and Portability Rights

• Parents may request deletion of their child's Personal Information
• We provide data export capabilities for account information
• Deletion requests are processed within 30 days unless legally prohibited

Communication Preferences

• Users may control receipt of marketing communications (not applicable to children under 13)
• Educational communications from School Partners may be managed through school policies
• System notifications necessary for service operation cannot be disabled

We, and our third-party partners, automatically collect information through the use of automatic data collection technologies, including cookies, web beacons, pixels, embedded scripts, and logging technologies.

For educational users, we limit tracking technologies to those necessary for educational functionality and do not use them for behavioral advertising.

Users may be able to utilize third-party tools and features to restrict our use of automatic data collection technologies. Please note that blocking automatic data collection technologies may negatively impact your experience using the Services.

Our Services may contain links to third-party websites or integrate with external educational tools. We are not responsible for the privacy practices of these third parties. Users should review the privacy policies of any linked services.

Our Services are designed for users in the United States. If personal information is transferred internationally, we implement safeguards to protect student privacy in accordance with applicable laws.

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. Material changes will be communicated through:

• Email notification to registered users and School Partners
• Prominent notice on our website
• Direct communication through School Partners as appropriate

Continued use of our Services after policy updates requires new parental consent for students under 13 years of age.

Privacy Questions and Requests

Name: Stemuli Studios Inc.
Address: Stemuli Studios Inc., 2001 Ross Ave. #700-177, Dallas, TX 75201
Phone: +1 248-783-6854 or +1 248-STEMULI
Email: [email protected]

We are committed to responding to privacy inquiries promptly and addressing any concerns about our data practices.

The following supplemental disclosures may apply to you depending on your state of residency.

Personal Information Disclosures, Sales and Targeted Advertising

We do not sell personal information, and we do not process or otherwise share personal information for the purpose of targeted advertising or cross-context behavioral advertising.

Sensitive Personal Information

The following personal information elements we collect may be classified as "sensitive" under certain privacy laws:

• Conversation logs and chat histories with Or[b]
• Personal Information collected from a known child under the age of 13

Your Additional U.S. Privacy Choices

Depending on your state of residency and subject to certain legal limitations, you may be able to exercise the following rights:

• Right to Know: Confirm whether we are processing personal information about you
• Right to Access & Portability: Obtain access to personal information we have collected
• Right to Correction: Correct inaccuracies in your personal information
• Right to Deletion: Have us delete personal information we maintain about you

Submitting Privacy Rights Requests: Please submit a request by emailing us at: [email protected]

Nevada Residents

Although we do not currently sell personal information of Nevada residents, you may submit a request to opt-out of any sales by emailing us at: [email protected]

California Residents

California law requires disclosures about personal information categories including:

• Identifiers: name, email address, phone number, and account name
• Customer records: account history
• Education information: student enrollment, educational records, academic performance data
• Sensitive personal information: conversation logs with Or[b] and information from children under 13