Children's and Students' Privacy Notice
Information for families about learning records, AI, voice features, and messages.
This Notice explains how Ilmiya, Inc. (“Ilmiya,” “we,” or “us”) processes information about learners using services provided through a school, education organization, tutoring center, or independent educator. We refer to that provider as the school or educator; it is the Customer under the service agreement.
Before student access begins, the school or educator must establish the authorization required for the selected use. Lawful school authorization may apply to eligible school-directed educational services. Where parental consent is required, the school or educator must collect and document it using a legally sufficient process. Ilmiya provides direct notice and supporting tools. Students entitled to act independently retain their rights. This Notice does not establish a direct public signup route for children. Our Global Privacy Policy also covers the public website.
This Notice includes the disclosures relevant to covered collection from children under 13 under COPPA. Its protections for Student Data also extend to other learners within the stated service scope. The applicable law determines each person’s rights and the authorization needed for their use. Reading or accepting this Notice does not waive a child’s rights or create permission for collection.
Read this Notice with the Privacy Policy and Terms of Service. Applicable contractual provisions concerning use of the Services, disputes, and liability remain subject to mandatory law and the DPA. This Notice does not require a child to enter a commercial agreement or make a parent a party to the Customer’s agreement.
For learners
Your school or educator chooses the Ilmiya features you use. Your work, messages, and activity can become part of your learning records. Your educator and other authorized people may be able to see them.
An AI chat can save what you type and the response it gives. If you use a voice feature, your voice and a transcript can also be processed. Share only what you need for the activity. Ask your teacher if you are unsure who can see something, and tell a trusted adult if a message or AI response concerns you.
Who Collects Information About Children
Ilmiya, Inc. supplies the contracted education platform, including selected curriculum and learning materials and the supporting infrastructure. The school or educator may present the service entirely under its own name and branding. Ilmiya’s operator identity and contact details remain available in this Notice; the school’s own notices explain its decisions and practices.
Your school or educator decides why learner information is needed and gives us instructions under the Data Protection Addendum (DPA). We must protect that information and follow the instructions and applicable law. Ilmiya already serves learners in the US, the UK, and countries in Europe and Africa. The applicable privacy laws govern that use. We and your school or educator must check the legal basis, necessary safeguards, and processing locations for existing services as well as new activities. If we choose a purpose of our own, we must meet the controller duties for that purpose; calling ourselves a service provider cannot remove them.
The School and Institution Consent notice explains the authorization process and supplies the direct notice. Your school or educator must deliver the relevant information, obtain the permissions required for the intended features, and retain evidence. Eligible school authorization under COPPA is limited to the disclosed educational purpose. Independent educators and tutoring centers cannot assume that authority solely because they teach children.
Where verifiable parental consent is required, the school or educator administers the required collection, verification and recordkeeping. Ilmiya does not routinely collect or manually review individual family forms. The applicable consent method must meet any operator-receipt requirement, and Ilmiya retains duties imposed directly on it by law.
Voice and AI features are optional. Learners may decline them or leave them inactive and continue using the core learning service. Required feature notices and any additional permissions must be provided before activation. School authorization does not establish every legal basis required in other countries; sensitive information and international transfers require their applicable safeguards.
How Information Is Collected
Collection can occur when a school or educator provisions an account, a family supplies an authorized record, or a learner takes part in an enabled activity. It also occurs through the technical records necessary to deliver and secure that activity. A record generated from work or a conversation, such as feedback or a learning profile, remains protected when it relates to an identifiable learner.
The Customer must explain the selected features before access begins. We do not require every child to provide a personal email address or every category listed below. The fields and permissions must remain limited to the purpose of the approved service.
Information We Collect Directly
Information supplied through an account, assignment, conversation, upload, or support request is collected directly from the person submitting it or from the school or educator acting with authority. The table also identifies records derived from those activities and the operational information explained in the next section, so families can see the complete scope of an enabled feature.
| Feature or activity | Information that can be involved | Purpose |
|---|---|---|
| Account and learning access | Name or username, school or educator, class or roster membership, account identifier, assigned role, and contact details where needed. | Let the right learner access the right learning activity. |
| Approval records | Parent or legal-guardian approval, date, scope, and withdrawal status where supplied to Ilmiya or recorded through an approved process. Your school or educator keeps the supporting evidence. | Confirm that the authorized use is covered and handle changes or withdrawal. |
| Lessons and learning profiles | Work submitted, documents and media, answers, feedback, progress, participation, and assessments or learning profiles derived from those activities. | Deliver learning activities and help your school or educator assess and support learning. |
| Messages and discussions | Message contents, threads, replies, attachments, participants, and related timestamps. | Deliver the communications enabled by your school or educator. |
| AI assistance | Questions and instructions, context selected from the activity, relevant attachments, responses, conversation history where the feature saves it, and embeddings (numeric representations) where used for search or AI. | Provide the authorized AI feature and address support or safety issues. |
| Voice recordings | Raw audio sent through an enabled voice or recitation feature and related activity details. | Process the submitted speech for the requested learning activity. |
| Transcripts and speech feedback | Written transcripts, pronunciation or recitation feedback, and related learning records. | Provide the requested feedback and authorized learning history. |
| Support requests | Messages, attachments, and relevant account or activity details supplied by your school, educator, or family. | Investigate and respond to the request. |
| Service and security operations | Account and technical identifiers, IP addresses, browser or device information, sign-in and error events, and necessary activity logs. Recorded page interactions can also be involved where an approved diagnostic feature enables session replay. | Keep the service working, protect access, and investigate problems within the authorized scope. |
Some records come from the school, independent educator, or parents. Others come from a learner’s use of the service. The table describes categories that enabled features can handle; it does not require every learner to supply every category. We collect only what the authorized activity reasonably requires. Learning information can reveal sensitive details. A faith-related activity may reveal religious beliefs; a support request may reveal health or disability information. These details can also appear in a message or recording. Where EU or UK law applies, the responsible controller needs a special-category condition as well as an ordinary lawful basis. Features involving this information need an appropriate scope and safeguards before they are enabled. A general account-approval checkbox cannot supply a missing legal condition.
Information We Collect Automatically
The service and security information listed above can be generated when a learner signs in or uses an activity. Depending on what the approved function requires, browser and device information can include the browser or operating-system type, device type, and language settings. Activity records can identify the feature used and the time of an event. These details must remain proportionate to authentication, service operation, authorized learning records, or a documented support or security purpose.
Persistent identifiers and diagnostic records must not be used to follow a child’s activity across unrelated websites for advertising or to create an unrelated commercial profile. We do not use unique identifiers to track a child’s activity across third-party apps or websites. A technical identifier does not cease to be personal information merely because it does not display the learner’s name. Optional diagnostics require the conditions below.
Recorded page diagnostics need a defined purpose within the approved service. They must stay off for learners until that purpose and the required safeguards are in place. Any required notice or consent must come before collection.
AI and model training
AI providers can receive the information needed to deliver an enabled feature, subject to the DPA and their contract with Ilmiya. We limit what we send and use coded identifiers instead of direct student identifiers where practicable. A request or recording can still identify you through its contents or links to other records, so the safeguards continue to apply. Providers must not use Customer Data to train their models. Ilmiya does not currently train models using Customer Data.
If Ilmiya later proposes a customer-specific model customization, such as LoRA, it must first explain the data, educational purpose, people who can access the result, retention, and deletion consequences in a separate written proposal. The required school or educator approval and any additional legal consent must come before that processing. This notice does not authorize it in advance.
AI output can be wrong. Educators must review information used for consequential educational decisions. See the Responsible AI Statement.
Voice and recordings
A child’s voice is personal information. Audio, a written transcript, and feedback are separate records. Before collection starts, the feature must explain how each is used and how long it is kept. Recordings may leave the device or be stored unless the feature expressly says otherwise.
A school or educator must arrange required recording notices and permissions, including for other people captured in a classroom or tutoring session. Ordinary audio is not automatically biometric special-category information. Creating a voiceprint for identifying a person requires a separately approved use, an applicable legal condition, and any required specific notice and consent. Ordinary permission to use a voice learning feature does not authorize biometric identification.
Who can see records and messages?
Who can see a record depends on your school or educator’s permissions and the feature you use. Educators and administrators may see education records and AI histories needed for their role. People in a conversation can see what is shared with them. Some school inboxes send a student’s message to a group of staff or administrators. The interface must make the recipients clear before you send it.
Ilmiya staff and contracted providers may access information as needed for authorized support, security, or other lawful service operations, subject to confidentiality and access limits. Your school or educator may be able to see messages on an account it supplies.
We will not make Student Data public on our own initiative. Any feature that permits public publication must identify that audience and have the necessary authorization before disclosure. We do not promise that a recipient cannot copy information they are allowed to see.
How We Use Children’s Information
We use Student Data for the authorized educational service and the support and security needed to deliver it. We do not sell it, use it for advertising, or permit service providers to use it for their own advertising. Learner profiles must serve the authorized educational purpose.
Operational use includes authenticating authorized users, delivering the selected educational activities, resolving a support request, and detecting or preventing unauthorized access. Analysis of service functioning must remain within the approved scope. A general reference to improvement or research does not permit unrelated use of identifiable Student Data or override the AI and model-training restrictions above.
How We Share Children’s Information
Service providers receive only the access required for their agreed functions. Your school or educator’s applicable schedule identifies them; see Subprocessors and Service Providers. A partner receives learner information only if your school or educator has authorized its role and the required terms and safeguards are in place.
Student information is currently hosted, stored and processed in the United States. When learners use the service from another country, their information is transferred to the United States. The Global Privacy Policy and DPA explain the applicable safeguards. A future change in processing country must follow the DPA’s notice requirements.
We may disclose information as legally required or as law permits to address a serious safety or security issue. The DPA restricts these disclosures. A company that acquires Ilmiya must continue the applicable protections for information already collected.
For a legal demand, Ilmiya must examine the request, disclose only what is required, and give the Customer notice where permitted under the DPA. A general wish to enforce terms or investigate a dispute does not authorize unlimited access or disclosure. Safety or security action remains limited to the lawful purpose and appropriate recipients.
De-identified information must meet the applicable legal standard. Removing names alone does not make a voice recording, detailed message, or learning profile anonymous. We will not attempt to identify people again or allow recipients to do so.
Data Retention
Your school or educator directs how long education records are kept for a documented purpose, within the limits of applicable law. Its schedule must explain the purpose and deletion periods or triggers for each enabled category before collection starts. A school or educator may choose the longest period that remains necessary and lawful. Children’s personal information must not be kept indefinitely or after the specific purpose no longer reasonably needs it.
| Record | Retention rule |
|---|---|
| Account, roster, and learning records | Keep for the authorized educational purpose under your school or educator’s lawful schedule, with review of whether retention is still necessary. This includes learning profiles derived from activities. |
| Approval records we hold | Keep only as needed to confirm the authorized use, handle withdrawal or a request, and meet a binding legal recordkeeping duty. Your school or educator has its own duties for the supporting evidence it keeps. |
| Raw voice recordings | Keep only for the speech activity and any specifically documented need to retain its source audio. The feature’s schedule must state the deletion period or trigger. |
| Transcripts and speech feedback | Follow the authorized learning-record schedule, separately from source audio. Keeping a transcript does not by itself justify keeping the audio. |
| Messages and AI conversations | Retain for the authorized communication or learning purpose and your school or educator’s lawful schedule. Closing a login does not necessarily delete a shared thread or education record. |
| Inactive accounts | We recommend that schools and educators review and remove accounts inactive for more than 12 months unless continued access has a documented purpose. This is a recommendation, not a promise of automatic removal. |
| Requests from your school or educator to delete records | Complete a valid, sufficiently specific request from an authorized school or educator contact within 30 calendar days after receipt, or sooner where law requires. This covers the requested records in active systems, relevant providers, and backups. |
| Support and diagnostic records | Keep for the documented support or diagnostic purpose, with a defined deletion period or trigger. A support request does not justify keeping unrelated learning records. |
| Security records | Keep for the period needed to investigate and protect the service, under a defined security retention schedule. |
| After your school or educator’s service ends | Provide a 30-day export period. A restricted recovery copy can remain for a documented lawful transition or recovery need for up to 12 months after expiry or termination, including termination for contract breach. Delete sooner if requested, no longer needed, or required by law. |
| Backups and legal holds | Backups follow the same applicable deletion deadline. A limited copy required by a binding legal obligation stays protected, is used only for that duty, and is deleted promptly when the duty ends. |
The recovery archive supports a defined transition or restoration need within the original authorized use. It does not give permission to keep every child’s record for a full year. Earlier deletion is required when the specific collection purpose no longer reasonably needs the information. A security incident does not itself restart the archive period or permit destruction of evidence.
Removing a person’s account ends that account’s access. Your school or educator can still lawfully need shared messages, assignments, or assessments, so an account request must be distinguished from a request to delete those records. An individual’s rights under applicable law continue to apply. Copies held by recipients are outside Ilmiya’s direct control. We will explain a binding legal retention requirement that affects a valid request. The website enquiry database’s 730-day schedule applies to form correspondence, including a legal or privacy enquiry. It does not extend the retention of the underlying learning records or override an earlier deletion required by law. Correspondence must also be deleted sooner when it is no longer needed and no binding legal duty requires keeping it.
Parents’ Rights to Review, Delete, and Control
Parents and eligible students can contact their school or independent educator or email legal@ilmiya.com to ask about records, request correction or deletion, or stop further collection as applicable law permits. We will verify the requester’s authority and protect other people’s information. Ilmiya will assist your school or educator and respond directly where required by law. Children have privacy rights of their own. Who may exercise them depends on the law and the child’s capacity; parents do not automatically have access to every record. Other rights can include objection, restriction, portability, or human review of a significant automated decision where applicable. The Global Privacy Policy explains response periods, how to raise a privacy complaint, and the right to contact a privacy authority.
If permission for a necessary feature is withdrawn, that feature may stop working. We will explain the effect and handle the affected records under the DPA and applicable law. We will not require a child to provide more personal information than is reasonably needed to take part in an activity.
A parent may also ask which categories of information are collected and how they are used or shared, and may refuse further collection where the law gives that right. The school or educator normally manages the request for records it controls. Contacting Ilmiya directly remains available, including where the responsible institution cannot be reached. Verification must be proportionate, and a request concerning one learner must not expose another learner’s information.
Changes to This Disclosure
You can also write to us at Ilmiya, Inc., 3800 American Blvd West, Suite 1500, Bloomington, MN 55425, USA.
We will provide appropriate advance notice of a material change affecting children’s information. Where fresh consent is required, the change will wait for that consent. Updating this notice does not by itself change your school or educator’s existing instructions or remove legal rights.
If you have a question about this notice or a child’s information, email legal@ilmiya.com or use our legal inquiry form.