---
title: "Global Privacy Policy | Ilmiya"
description: "How Ilmiya collects, uses, shares and protects personal information, including student records and your privacy rights."
url: "https://ilmiya.com/privacy-policy/"
language: "en"
---
# Global Privacy Policy
How Ilmiya collects, uses, shares and protects personal information, including student records and your privacy rights.
## Introduction
Our [Trust Philosophy](https://ilmiya.com/trust-philosophy/) explains the principles that guide how we build Ilmiya. This Policy provides the detail about our handling of personal information.
Ilmiya, Inc. (“Ilmiya,” “we,” or “us”) provides curriculum and learning materials alongside education software and infrastructure. Institutions can deliver these services under their own branding. Ilmiya also operates this website. This Policy describes the personal information we process, the purposes for which it is used, and the rights available to individuals. Acceptance of a service agreement or use of a website does not replace consent where consent is required.
This Policy applies to our public website and to the personal information Ilmiya handles in connection with its applications, curriculum and contracted education services. A school, tutoring center or other Customer may present the learning environment entirely under its own name. This Policy explains Ilmiya’s part in providing that environment; the Customer’s privacy notice explains its educational purposes, family contacts and decisions.
Read this Policy together with the [Children’s and Students’ Privacy Notice](https://ilmiya.com/privacy-disclosure/), [School and Institution Consent](https://ilmiya.com/parental-consent/) and [Cookie Notice](https://ilmiya.com/cookie-notice/). The [Terms of Service](https://ilmiya.com/terms-of-service/) govern access to the public services. The Customer’s Agreement and DPA govern instructed processing of Customer Data. This Policy does not expand the purposes authorized by those documents.
## Our core principles
**Institution direction.** The institution chooses the educational services and controls access to its learning environment. We process its records under documented lawful instructions, including when its service uses Ilmiya-supplied curriculum or its own branding.
**A defined educational purpose.** Student information supports the learning and administration the institution authorizes. We do not sell it or use it for advertising. Supplying curriculum does not grant us a separate right to reuse identifiable learning records for research or model training.
**Meaningful choices.** Required notices and permissions come before the relevant collection. AI and voice remain optional, with access to core learning preserved. We help institutions respond when families exercise their privacy rights.
**Clear information.** Our notices explain what the selected services collect and why. They identify provider involvement and the retention arrangements that apply, so institutions can give families accurate information under their own brand.
**Protection with accountability.** The DPA sets safeguards for access, security and handling by contracted providers. Ilmiya remains responsible for its obligations under that agreement; institutions manage the permissions and educational decisions within their control.
## Definitions
The following terms help explain this Policy. Contract terms have the meanings given in the applicable Agreement and DPA.
- **Services** means the Ilmiya website, applications, curriculum, learning tools and education infrastructure covered by this Policy, including services delivered under a Customer’s branding.
- **Personal Data or personal information** means information that identifies or can reasonably be linked to an individual, alone or with other information. A coded identifier remains personal information when it can be linked back to a person.
- **Usage Data** means information generated when someone uses the Services, including activity records, device information and diagnostics.
- **Cookies and similar technologies** means cookies, local browser storage and related technologies used to operate a feature, remember a choice or measure website activity.
- **Customer** means the school, education organization, tutoring center or educator that contracts for the Services. A **User** is an individual who uses them.
- **Customer Data** means information processed for the Customer under its Agreement. **Student Data** includes personal information about a learner in that environment, including submitted work and learning records.
- **Controller** means the person or organization that determines why and how personal information is processed. Ilmiya acts as controller for the business and website activities it determines. A Customer normally controls its educational processing.
- **Processor** means an organization that processes personal information on a controller’s behalf. A **Subprocessor** is another processor engaged in that chain. Ilmiya’s role depends on the actual arrangement described below.
- **Data subject** means the individual the personal information concerns. A parent, guardian or authorized representative may exercise rights for that individual where the applicable law permits.
## Who decides how information is used?
For website enquiries and our business relationships, Ilmiya decides how information is used. This includes responding to a demo request, communicating with a customer, and protecting this website.
Our customers include schools, other education organizations, and independent educators. We use **Customer** for the school, organization, or educator that has an agreement with us. An independent educator entering the agreement must have legal capacity to contract.
Your school or educator normally decides which learning services you use and why your information is needed. Ilmiya acts as a processor for that instructed processing, or as a subprocessor where the Customer itself processes for another institution. We follow the authorized instructions under the [Data Protection Addendum](https://ilmiya.com/data-protection-addendum/) (DPA), and the institution’s own privacy notice also applies. Ask your school or educator about those choices, or contact us for help reaching the right person. Before enabling student access, the Customer must establish lawful school authorization or obtain and document the parental or other permission required for the intended use. Ilmiya supplies the direct notice; the Customer is responsible for delivering it and administering legally required consent. Our templates and notice builder support that work. An independent educator or tutoring center does not acquire a school’s authority to consent merely by providing education.
Ilmiya offers its services globally under a common set of agreements. Features are available across countries within the purchased service. Applicable mandatory law, including lawful trade restrictions, continues to govern each party’s activities. EU GDPR and UK data protection duties apply where their requirements are met. These documents preserve the rights individuals have under applicable law.
Our role follows what we do with information. If we decide to use information for a purpose of our own, we must meet the controller duties for that use. We cannot borrow a school’s legal basis or treat its agreement as permission for our own purposes. The DPA does not authorize us to reuse Student Data for unrelated product development.
## Information Collection and Use
We collect information from people who use or contact the Services, from the Customer and its authorized users, and from the operation of the selected features. For example, an institution may supply a roster, a learner may submit work, and a service may record progress or an error. An authorized integration may supply information that the Customer instructs it to share. The categories and purposes below identify the relevant uses.
We limit collection to the disclosed purpose and the selected service. Required information is identified in the relevant form or activity. If necessary information is not supplied, we may be unable to answer a request, establish access or provide that activity. Optional information and optional features remain subject to the choices described in this Policy. A general account relationship does not authorize every possible data category.
## Types of Data Collected
| Category | Examples and sources | Why we use it |
| --- | --- | --- |
| Enquiries and business contacts | Name, work email, telephone, institution, role, enquiry, and preferences that you provide in a form or correspondence. | Reply to requests, provide support, manage our relationship, and send marketing communications where permitted and chosen. |
| Legal and privacy enquiries | Name, email, topic, optional organization, request details, the enquiry reference, and any information later needed to verify identity or authority. You provide the details; our form supplies the reference. | Respond to rights requests, complaints, and legal questions. We do not use these enquiries for marketing. |
| Website and security information | Pages and interactions, browser and device details, referrer and campaign details, approximate country, anti-bot results, and technical diagnostics. | Operate and protect the website, investigate errors, and understand website use under your privacy choices. |
| Customer administration | Authorized contacts, account records, contracts, billing details, payment status, and approval records where supplied to Ilmiya or recorded through an approved process. | Supply and administer the agreed services, confirm authorized use, and meet legal recordkeeping requirements. |
| Customer and learning records | Profiles and rosters, assignments, uploaded documents, assessments, progress, learning profiles derived from activity, attendance or other education records where those features are enabled. The Customer, authorized users, and use of the service supply this information. | Deliver the education and administration that the Customer authorizes. |
| Messages and AI interactions | Messages, chat threads, attachments, prompts, context supplied to an AI feature, generated responses, and related activity records. | Deliver enabled communication or AI features, maintain the relevant history, and provide authorized support and security. |
| Voice and media | Audio submitted through enabled voice or recitation features, transcripts, feedback, and media uploaded by authorized users. | Deliver the selected activity, such as transcription, recitation feedback, or a voice response. |
| Service diagnostics | Account or organization identifiers, page addresses, IP addresses, device details, errors, and activity or replay captured by the enabled diagnostic service. | Monitor the service, investigate faults, and protect access, within the authorized scope. |
What we collect depends on the features you use. Each category above applies only when the approved activity needs it. Your school or educator must approve a learning feature, and any required notice or consent must come before collection.
Learning records can reveal sensitive information. For example, a faith-related activity may reveal religious beliefs, and a request for learning support may reveal health or disability information. A message or recording can contain those details too. Where the GDPR or UK GDPR applies, this information needs a valid special-category condition as well as an ordinary lawful basis. The school or educator must identify the condition for the use it controls; Ilmiya must do so for any use it controls. A general account-approval checkbox does not establish that condition.
Our website form database uses a salted IP-derived value for abuse prevention instead of storing the raw IP address. Network providers necessarily receive technical connection information when delivering the website. We do not describe those network operations as anonymous.
### Personal and account information
Contact and account information may include a person’s name or username, email, institution, role and the credentials or access identifiers needed for the selected service. Business contacts may also supply a telephone number, postal address and billing details. Institutions decide which student profile fields they need within the authorized service. We do not require a child to provide business billing details simply to participate in learning.
### Usage and connection information
Browsers and applications send technical information when they connect, including an IP address, browser or operating-system details, request time and the resource requested. Activity records may show the feature used, work submitted and progress within the Customer’s learning environment. The website’s diagnostic and optional measurement purposes remain separate from the Customer’s educational records.
### Location information
Approximate location can be inferred from technical connection information. Our website clock can use the browser’s time-zone setting, and prayer times use a city the visitor selects and saves. Those utilities do not request device geolocation. A time zone or selected city does not establish a person’s precise current location. Where another selected service requests device location, its notice and required permission must precede collection; location permissions can be managed through the device or browser.
### Cookies and similar technologies
Necessary session and security functions support access and protect the Services. Preference storage remembers choices a visitor makes. Optional analytics and marketing remain subject to the [Cookie Notice](https://ilmiya.com/cookie-notice/) and available controls. Blocking necessary storage may prevent a requested function from working. Refusing optional measurement does not authorize collection through another route.
## Use of Data
We use personal information for the purposes described for its category and the selected service. Those purposes include:
- Providing the contracted learning environment, curriculum activities and institution-authorized administration.
- Supporting the interactive features a user or Customer selects, and keeping the relevant work, progress or communication history.
- Responding to support requests and providing account, subscription, renewal and service-change notices.
- Administering the Customer relationship, billing and payment status, and exercising contractual rights within the applicable data protections.
- Detecting faults, protecting accounts and investigating misuse or security incidents.
- Understanding public website use through the permitted measurement choices and improving the relevant service within the authorized purpose.
- Responding to legal enquiries, privacy requests and binding legal requirements.
- Sending permitted business marketing and honoring objections or withdrawal of consent.
We explain a materially different purpose before using information for it and obtain any required authorization. Service improvement does not create permission to use identifiable Student Data for unrelated research, general model training or advertising. Necessary service notices continue where required even if a business contact opts out of promotional communications.
## Why we can use information
Where the GDPR or UK GDPR applies, the basis must match the purpose. For information we control, the following rules apply:
| Purpose | Lawful basis |
| --- | --- |
| Respond to a business enquiry or communicate with an organization’s contacts | Our legitimate interest in responding to the request and managing the business relationship, after considering the person’s rights. If you personally seek or enter a contract with us, necessary steps for that contract can instead apply. |
| Provide and administer a service you contract for personally | Performance of that contract, limited to what it requires. An institution’s contract does not make every student’s information necessary for a contract with that student. |
| Protect the website and investigate faults or misuse | Our legitimate interest in keeping the service secure and reliable, subject to necessity and the person’s rights. |
| Send optional marketing or use optional website measurement | Consent where required. Where the law permits business marketing without consent, our legitimate interest in communicating relevant services, with a right to object and any required opt-out. The Cookie Notice explains website controls. |
| Handle legal and privacy enquiries | The applicable legal obligation when responding to a statutory request or complaint. For other correspondence, our legitimate interest in addressing the enquiry, after considering the person’s rights. |
| Keep records or make disclosures required by law | The applicable legal obligation, limited to the information and period it requires. |
For education records a Customer controls, that Customer must identify and explain its lawful basis. School authorization or parental consent must be appropriate to the processing involved; neither establishes a legal basis for every possible use of information. Ilmiya follows the Customer’s lawful instructions under the DPA. Any special-category condition must be identified separately. We must explain a new purpose and its basis before starting it, and obtain consent where required.
## AI, recordings, and messages
When you use an approved AI feature, its AI provider can process your request and the context needed to answer it. We limit that information to what the feature needs and use coded identifiers instead of direct student identifiers where practicable. Content can still identify a learner or be linked to their records. Prompts, audio, transcripts, and embeddings (numeric representations used for search or AI) remain protected when they contain or can be linked to personal information. The DPA’s restrictions apply to these providers. Our providers must not train their models using Customer Data, and Ilmiya does not currently train models using Customer Data. Any proposed customer-specific customization, including LoRA, requires a separate written opt-in describing its purpose, data, access, retention, and deletion, with a lawful basis and any additional notices or authorizations required by law. It is not authorized by this policy in advance.
Voice and AI services are optional; learners may decline them and retain the core learning service. Required feature notices and permissions must precede activation. Voice features can involve a recording, a transcript, and a response or assessment. They are separate records and can have different retention periods. Device microphone permission lets an application access a microphone; it does not replace consent that recording or children’s privacy laws require. An ordinary voice recording is not automatically biometric special-category data. Using technical processing to identify a person from their voice can make it so. A feature that creates voiceprints for identification requires a separate assessment and the necessary legal condition, notice, and consent where required before it is offered.
A feature that keeps message or AI chat history stores it as part of the service. Who can see it depends on your school or educator’s permissions, who receives the conversation, and any authorized support or safety review. Your school or educator may be able to see messages and AI chats on an account it supplies. Our staff and providers may access them only for authorized service, security, and legal purposes.
The [Children’s and Students’ Privacy Notice](https://ilmiya.com/privacy-disclosure/) explains the safeguards for learners. Our [Responsible AI Statement](https://ilmiya.com/responsible-ai-statement/) explains the role of human review and the limits of AI outputs.
## Retention of Data
We keep information for a defined purpose and delete it when it is no longer needed, subject to a specific legal retention duty. Our website form system is configured to delete enquiries after 730 days and clear the stored abuse-prevention fingerprint and browser information after 30 days. Necessary records held elsewhere, such as contracts, billing records, or correspondence about a continuing relationship, follow the applicable purpose and legal retention requirement.
For Customer-controlled education records, the Customer sets a retention schedule for its documented educational or operational purpose, subject to applicable law. That schedule must separately address voice recordings, transcripts, chat and AI histories, and backup copies. Customers may retain records for the longest period that remains necessary for that purpose and is lawful. Children’s personal information cannot be retained indefinitely or after it is no longer reasonably necessary for its specific collection purpose.
We recommend that Customers review and remove accounts inactive for more than 12 months unless continued access serves a documented purpose. Closing a person’s account does not automatically delete shared messages, assessments, submitted work, or other records the Customer still lawfully controls. The Customer can give separate instructions covering those records, and individual rights under applicable law remain available.
We complete a valid, sufficiently specific deletion request from an authorized Customer contact within 30 calendar days after receipt, or earlier when the law requires. The DPA applies that deadline to active systems, relevant service providers, and backups, with a limited exception for records a binding legal obligation requires us to preserve. We promptly seek any clarification needed and explain a retention exception that affects the request.
When a Customer’s service ends, including termination for a contract breach, the DPA provides a 30-day export period. A restricted recovery copy may then remain for a documented lawful transition or recovery need within the original authorized purpose, for no more than 12 months after service ends. It is deleted earlier on a valid Customer request, when the need ends, or when the law requires. This period does not permit retaining a child’s information after the specific purpose no longer reasonably requires it. A security incident alone does not restart the period. Any legally required preservation is limited to the affected records and duty.
## Transfer of Data
Customer Data, including student learning records, is currently hosted, stored and processed in the United States. Customers and users outside the United States transfer their information there to use the Services. We do not currently offer local-country data residency. Any future addition of a processing country will follow the notice and safeguard requirements in the DPA.
A restricted international transfer requires a valid legal route. Depending on the transfer, this may be an applicable adequacy decision or properly completed contractual safeguards with the required transfer assessment and additional protection. EU contractual clauses alone do not cover a UK restricted transfer; an applicable UK route is also needed. Where contractual safeguards are required, they must be agreed separately for the relevant data flow. This privacy policy does not itself create those transfer terms.
The DPA governs safeguards for Customer Data transferred to the United States. Contact [legal@ilmiya.com](mailto:legal@ilmiya.com) for the safeguards relevant to your records, including a copy of applicable transfer terms subject to necessary redactions that preserve their meaning.
The DPA prohibits starting or continuing a restricted transfer without the required protection.
For a transfer subject to Swiss data protection law, the selected safeguard must also meet that law, including any required Swiss adaptations. A person’s use of the website or acknowledgement of this Policy does not, by itself, establish a lawful transfer safeguard.
## Disclosure of Data
We share information with providers that perform necessary hosting, security, communications, and other services for the relevant purpose. The [Subprocessors and Service Providers](https://ilmiya.com/sub-processors-list/) page lists the providers we use and their purposes. Payment services can also process billing information under their own applicable terms.
Your school or educator controls who can see its records, and enabled features share information with the recipients selected. Connecting another service may involve a separate provider. The [Third-Party and Integrations Policy](https://ilmiya.com/third-party-integrations-policy/) explains those connections.
We may disclose information when law requires it, to address a serious security or safety issue where law permits, or in a corporate transaction with appropriate confidentiality and continuing privacy protections. The DPA governs these disclosures for Customer Data. An acquisition does not give the successor permission to use previously collected Student Data for unrelated purposes.
We do not sell Customer Data or use it for advertising. Website marketing technologies have their own data flows and privacy choices, described in the Cookie Notice. We will honor any applicable right to opt out of sale, sharing, or targeted advertising; a label such as “analytics” does not override that right.
### Law enforcement and government requests
We assess requests for a valid legal basis and the authority of the requesting body. We challenge an unlawful demand where available legal grounds permit it. When a demand concerns Customer-controlled records, we seek to direct the requester to the Customer where lawful. If disclosure is legally compelled, we notify the affected Customer and provide the demand unless the law prohibits it, so the Customer can seek a protective order or other remedy. We disclose only the information the binding requirement calls for and preserve applicable confidentiality and security protections.
### Corporate transactions
A merger, acquisition, financing or sale of assets may require limited disclosure to advisers or a prospective successor under confidentiality and purpose limits. A successor receiving personal information must continue to protect it under the applicable commitments. A transaction does not authorize an unrelated use of Student Data or remove notice, consent or contractual requirements.
### Authorized recipients and other disclosures
Information may be shared with the Customer’s authorized staff and the recipients of a selected communication or collaboration feature. An affiliate or contractor receives access only for its authorized role and subject to appropriate obligations. We may also disclose information at a person’s lawful direction or with valid consent. A safety or rights-protection disclosure must have a legal basis and be limited to the need; it is not a general permission to circulate education records.
## Security of Data
We use safeguards appropriate to the information and the risks, including access controls and encryption. The DPA sets the minimum contractual safeguards for Customer Data. We maintain safeguards proportionate to the processing risks and review them as the service develops.
Our security programme addresses confidentiality, integrity and availability throughout the service lifecycle. Responsibilities include secure infrastructure and software development, risk assessment, vulnerability management and incident response. The DPA’s security annex supplies the contractual requirements for Customer Data.
**Infrastructure and resilience.** We use cloud and service providers with physical and technical protections appropriate to their work. Infrastructure controls address unauthorized access, service disruption and denial-of-service attacks. Recovery and continuity measures remain subject to the retention and deletion commitments in the DPA.
**Encryption.** Personal information is protected in transit and at rest using the measures required by the DPA. Access to credentials and encryption material is restricted to the personnel and systems that require it.
**Access control.** We use least-privilege access for systems we manage. The programme covers account provisioning and removal, authentication, privileged access, user identification, and access logging and monitoring. Authorized personnel must protect confidentiality and use access only for their assigned work. Customer administrators remain responsible for permissions and devices within their control.
**Monitoring and response.** We investigate suspected unauthorized access and respond to incidents under the DPA and applicable law. Security measures cannot guarantee that an incident will never occur; this does not reduce our contractual safeguards or legal duties. Report a suspected exposure through [legal@ilmiya.com](mailto:legal@ilmiya.com) without including passwords or unnecessary student records in the initial message.
## Your Rights Under the GDPR
Where the EU GDPR or UK GDPR applies to the relevant processing, individuals have rights subject to that law’s conditions and exceptions. These include access to their information and processing details, correction of inaccurate or incomplete information, erasure, restriction, and objection to applicable processing. Portability covers qualifying information in a structured, commonly used and machine-readable format. Consent can be withdrawn for future use without affecting processing that was lawful before withdrawal.
A person may object at any time to direct marketing, including related profiling. For processing based on legitimate interests, an objection is assessed under the applicable statutory test. Rights relating to significant automated decisions, including the applicable safeguards and human review, remain available. Ilmiya’s AI tools support institutional decisions; the [Responsible AI Statement](https://ilmiya.com/responsible-ai-statement/) explains the required human oversight.
Use [legal@ilmiya.com](mailto:legal@ilmiya.com) or the [legal inquiry form](https://ilmiya.com/legal-inquiry/) to make a request. For records the Customer controls, we assist the Customer and route the request appropriately. We do not use that arrangement to avoid a duty that applies directly to Ilmiya. The request procedures below explain verification, timing and complaints.
## Your Rights Under CalOPPA
The California Online Privacy Protection Act addresses transparency for covered websites and online services. This Policy identifies the information collected, its sources and purposes, and the recipients or recipient categories involved. The website’s Legal Center and privacy links make this Policy available without signing in. You may browse public pages without creating an account, although the technical connection and privacy-choice processing described above can still occur.
You can request correction of information by contacting [legal@ilmiya.com](mailto:legal@ilmiya.com). Material changes are handled as described in **Changes to This Privacy Policy**. Optional third-party measurement and marketing can involve activity across visits and services when enabled; their controls are explained in the Cookie Notice.
**Do Not Track and Global Privacy Control.** Our website recognizes these browser signals and disables optional analytics and marketing. Necessary security and a function you request can still operate. You may also use the site’s cookie settings to refuse or withdraw optional processing. Enabling a privacy signal does not prevent the network requests needed to deliver a page.
## Your Rights Under the CCPA
The California Consumer Privacy Act, as amended by the California Privacy Rights Act, provides rights where its scope and conditions are met. Ilmiya’s role for Customer-controlled information may be that of a service provider or contractor; the DPA restricts that use. The rights in this section apply to covered processing without implying that every institution is a business subject to the CCPA.
You may request information about the categories and specific pieces of personal information held about you, their sources, collection purposes and recipients, including categories disclosed for a business purpose or sold or shared where applicable. You may ask for deletion, correction of inaccurate information, and the available portable copy. Applicable rights also include opting out of sale or sharing and limiting certain uses or disclosures of sensitive personal information. The collection table, sharing provisions and provider information in this Policy describe the relevant categories and purposes.
We do not sell Customer Data or use Student Data for advertising. Optional public-website marketing is subject to the Cookie Notice, privacy signals and any applicable sale, sharing or targeted-advertising opt-out. A contractual label does not remove those rights. Sensitive learning information remains limited to the authorized educational purpose and the other uses the law permits.
Submit a request through [legal@ilmiya.com](mailto:legal@ilmiya.com) or our [legal inquiry form](https://ilmiya.com/legal-inquiry/). We use verification proportionate to the request, permit authorized agents as the law requires, and explain a lawful refusal. An opt-out of sale or sharing does not require the same identity verification as access to specific records. We do not require a new account solely to exercise a privacy right.
For covered requests to know, correct or delete, the usual response period is 45 calendar days. A permitted extension must be explained within the initial period. The ordinary allowance for a request to know is twice in a 12-month period without charge; we will not apply that allowance to restrict a different right or a broader entitlement under applicable law. Where deletion is required, we direct the applicable service providers to act as required. The shorter contractual deletion deadline in the DPA remains applicable to a valid Customer instruction.
We will not discriminate against a person for exercising a protected right. If necessary processing ends, a feature that depends on it may become unavailable; that consequence does not justify a penalty or refusal to honor a right.
## Your choices and rights
To ask about your information or request access, correction, or deletion, write to [legal@ilmiya.com](mailto:legal@ilmiya.com). Depending on the laws that apply, you may also be entitled to a copy in a usable format, restrictions on processing, an objection to certain uses, or an appeal of a decision about your request. You may also have rights concerning significant automated decisions, including a right to challenge a decision and obtain human review. EU and UK rules differ; the rights provided by the law that applies to you remain available.
We will verify identity in a way proportionate to the request, respond within the applicable deadline, and explain any lawful limit. For GDPR and UK GDPR rights requests, the usual response period is one month; any extension or pause must meet the applicable legal rules and be explained. We will not penalize you for exercising a protected privacy right. An authorized representative may act for you where the law allows and appropriate authority is verified.
Where we rely on consent, you can withdraw it for future processing without affecting processing that was lawful before withdrawal. You can object to direct marketing at any time. Use an email’s unsubscribe option to stop marketing messages, or contact us. Necessary service notices may continue. Requests concerning education records usually go through the school or independent educator that controls them; we will assist that Customer and respond directly when the law requires us to do so.
### Other applicable U.S. and international rights
The rights provided by another applicable privacy law remain available, including qualifying access, correction, deletion, portability, targeted-advertising or profiling opt-outs, and appeals. To appeal a decision on a privacy request where that right applies, reply to the decision or email [legal@ilmiya.com](mailto:legal@ilmiya.com) with the request reference and the reason for the appeal. We will review it, explain the result within the applicable deadline and identify any further complaint route required by law. An appeal does not remove the right to contact a competent regulator. This common process is available without requiring a separate public policy for each state.
## Privacy complaints
If you think we have handled your information incorrectly, email [legal@ilmiya.com](mailto:legal@ilmiya.com) and explain the concern. You do not need to use legal terms. Where UK law requires us to handle the complaint as controller, we will acknowledge it within 30 days, investigate without undue delay, keep you informed, and explain the outcome without undue delay. A rights request keeps its own legal deadline.
If the complaint concerns records controlled by your school or educator, we will help route it and assist their response. We remain responsible for our own handling of information. You can complain to the [UK Information Commissioner’s Office](https://ico.org.uk/make-a-complaint/) or the competent authority in your country where that right applies. This complaint route does not remove your right to seek a legal remedy.
## Service Providers
We engage service providers for the functions described in this Policy, including hosting, storage, security, communications, diagnostics, payments and authorized AI processing. The [Subprocessors and Service Providers](https://ilmiya.com/sub-processors-list/) register identifies the current providers, their functions and relevant service scope. A listed provider does not receive every category of information for every Customer.
Providers acting on our behalf receive information only as needed for their contracted function and must protect it under the applicable agreement. They may not use Customer Data for their own advertising, unrelated purposes or model training. The DPA governs subprocessor authorization, advance notice of changes, objections and Ilmiya’s responsibility for their performance. Coding a name or using an embedding does not remove these restrictions where the information remains personal.
A provider independently selected by the Customer has the role described in the [Third-Party and Integrations Policy](https://ilmiya.com/third-party-integrations-policy/). A payment processor may also have independent responsibilities under law for payment administration and fraud prevention. We explain those roles in the relevant context; an independent-service label does not excuse a processor we have engaged from the DPA.
## Analytics
Public website analytics follow the consent choices below. Customer learning activity and support diagnostics remain subject to the Customer’s instructions and the DPA. Enabling public website measurement does not authorize tracking within a learner’s institution-managed environment.
## Development Tools
We use service and development tools to operate the Services, investigate faults, protect access and maintain the software. Access to personal information through these tools remains limited to the relevant purpose and authorized personnel. A development or diagnostic purpose does not authorize copying Student Data into unrelated environments, exposing it to unauthorized recipients or training models on it.
## Cookies and website measurement
We use browser storage to remember privacy choices and support necessary website functions. The website also supports PostHog analytics, including sampled session replay with form fields masked, and HubSpot marketing tools. The [Cookie Notice](https://ilmiya.com/cookie-notice/) explains the categories, purposes, and available choices. Use **Open cookie settings** on the Cookie Notice page to change your choice.
Our website recognizes Global Privacy Control and Do Not Track signals by disabling optional analytics and marketing. Necessary security and requested functions can still operate. School learning records are not used for advertising, and the marketing website’s measurement tools must not be treated as authorization to track learners inside school services.
## Behavioral Remarketing
Any permitted remarketing concerns visitors to the public marketing website. It is subject to the Cookie Notice and consent where required. Student Data, children’s activity and activity in Customer learning environments must not be used to build advertising audiences or target advertisements.
Refuse or withdraw optional marketing through the Cookie Notice’s settings. Browser privacy signals described above also disable optional marketing on this website. Business email recipients can use the unsubscribe link or contact [legal@ilmiya.com](mailto:legal@ilmiya.com). Where a third-party advertising service offers its own controls, those controls apply to that service; changing them does not replace a choice made with Ilmiya. The provider register identifies the current services, so this section does not imply use of a previously listed advertising vendor.
## Payments
Paid subscriptions and other commercial transactions may use a payment processor. Payment card details are provided directly through the processor’s payment interface. Ilmiya does not request full payment card numbers or card security codes through its support, legal or contact forms. We may receive the transaction reference, payment status, billing contact and other records needed to administer the Agreement, reconcile payments or meet legal requirements.
The applicable processor’s privacy information explains its handling of payment information and any independent purposes required for payment services. The [provider register](https://ilmiya.com/sub-processors-list/) identifies the current payment service. Payment-security standards apply to the parties and activities within their scope; this Policy does not claim an independent Ilmiya certification. An institution that charges its learners remains responsible for its own payment terms and notices.
## Links to Other Sites
The Services may link to websites or applications operated by others. Following a link takes you to that provider’s service, where its privacy notice and controls apply. Review that information before supplying personal information or connecting an account. Our inclusion of a link does not give the provider access to Customer records.
A selected integration can exchange information only within its authorized scope. The [Third-Party and Integrations Policy](https://ilmiya.com/third-party-integrations-policy/) explains the Customer’s role and the provider distinction. Ilmiya remains responsible for the duties that apply to providers it engages on its own behalf.
## Children’s Privacy
Our sales and demo enquiry forms are for adults asking about our services. Children use Ilmiya through an approved Customer arrangement. The Customer must arrange and document lawful school authorization or the required parental consent before enabling the relevant use. Students who can legally act for themselves approve their own use. Ilmiya remains responsible for the duties the law places on it as an operator, including required notice and verifiable parental consent where applicable. The [Children’s and Students’ Privacy Notice](https://ilmiya.com/privacy-disclosure/) and [School and Institution Consent](https://ilmiya.com/parental-consent/) explain how this works. We do not offer children a direct public signup through these notices. Please keep children’s personal information out of sales forms. If a child submits it, contact us so we can handle it appropriately.
The direct notice explains the selected data categories and purposes, provider involvement, family choices and the applicable retention arrangements. Our [notice builder](https://ilmiya.com/consent-builder/) and one-page template let an institution prepare that information under its own name. The institution delivers the notice and administers required consent, withdrawal and records through its process. These resources do not collect completed family forms for Ilmiya.
Parents and eligible students may request access, correction or deletion through the institution or contact Ilmiya for assistance. We apply the duties that govern the request and avoid disclosing another learner’s records. Required consent must cover a material new collection or use before it begins. Declining optional voice or AI does not remove access to the core learning service.
## Website Connection Tools
The optional speed test sends generated sample traffic between your browser and the test provider when you start it. It does not use the contents of your files or form entries. The provider receives the technical connection information needed to deliver the test, including an IP address and request metadata. Measurements remain in the page’s memory; the website does not save them to an Ilmiya account. You can stop the test at any time.
While a page is visible, small requests check whether it can reach the website. These checks contain no form data. The connection-recovery game runs locally and does not send gameplay or scores to Ilmiya. The [provider register](https://ilmiya.com/sub-processors-list/) and the safeguards in this Policy cover the service providers involved.
## Changes to This Privacy Policy
We will publish the date of each effective revision. Before a material change affects an existing use of personal information, we will provide appropriate advance notice and obtain fresh consent where required. A policy update cannot expand the instructions in an existing DPA or retroactively authorize an incompatible use.
We retain the substance of protections applicable to information already collected unless a lawful change and any required notice or authorization permit otherwise. Before a material revision takes effect, notice may be provided through the service or to the Customer’s designated contact. The Customer must communicate relevant changes to its users when responsible for doing so. A change to this notice does not, by itself, amend a signed contract.
## Contact Us
You can also write to us at Ilmiya, Inc., 3800 American Blvd West, Suite 1500, Bloomington, MN 55425, USA.
Send privacy questions or requests to [legal@ilmiya.com](mailto:legal@ilmiya.com) or use our [legal inquiry form](https://ilmiya.com/legal-inquiry/).
[All legal documents](https://ilmiya.com/legal/)[Contact legal](https://ilmiya.com/legal-inquiry/)
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