Privacy Policy
- Website
- Telos (https://telosedu.org)
- Operated by
- Brandon Bonner and Rowan Block, general partners doing business as "Telos," a general partnership formed under the laws of South Carolina, United States
- Contact
- support@telosedu.org
- Effective Date
- August 18, 2026
- Last Updated
- August 18, 2026
- Notice Version
- 2026-08-18
1. Introduction
This Privacy Policy explains how we collect, use, share, and protect information when you visit telosedu.org (the "Site") or use our courses, tools, and related services (together, the "Services").
We are based in the United States. If you use the Services from outside the United States, you understand that your information will be transferred to, stored in, and processed in the United States.
By using the Services, you agree to this Privacy Policy. If you do not agree, please do not use the Services.
2. What Information We Collect
2.1 Information You Give Us
- Account information: name, email address, password (stored in encrypted form), and account preferences.
- Profile and learner information: the display name, age range, or grade level you enter for a learner, and any settings you choose.
- Content you submit: answers, written responses, drawings, uploads, chat messages sent to our AI assistant, and any other material you enter into the Services.
- Communications: messages you send us by email, contact form, waitlist form, or support request.
- Parental consent records: when you create an account we record that you affirmed you are the adult responsible for the learners who will use it, the name you gave, the date, the method by which we verified it, and which version of this notice you agreed to. We keep this because the law requires us to be able to show we obtained your consent.
2.2 Information Collected Automatically
When you use the Site, we and our service providers may collect:
- IP address and approximate location derived from it (city or region level).
- Browser type, device type, operating system, and screen size.
- Pages viewed, links clicked, referring website, and time spent on pages.
- Dates and times of access, and error or diagnostic logs.
- Cookies used to keep you signed in and remember your settings (see Section 8).
We use Vercel Analytics to understand how visitors use the Site. Vercel Analytics is privacy-focused: it does not use cookies, does not store an identifier on your device, and does not track you across other websites. It records page views and aggregate usage patterns only. We do not use Google Analytics or any advertising or cross-site tracking service.
2.3 Payment Information
We accept payment for our course and for a NOVA subscription. Payments are processed by Stripe, Inc., and we never see or store your full card number. Your card details go from your browser to Stripe directly.
What we hold on our own systems is only what we need to know what you bought: a Stripe customer identifier, which product you have, its status, when the current period ends, and how many learner seats it covers.
What Stripe holds, under its own privacy policy, includes your name, email address, billing address, the card details you enter, and the transaction record. Stripe uses this both on our instructions and for its own legal purposes — fraud prevention, anti-money-laundering, and financial reporting — for which it is an independent controller and we are not. See Section 6.1.
Sales tax is calculated at checkout from the billing address you give. We keep the address only as part of the transaction record described in Section 9.
2.4 Information We Do Not Intentionally Collect
We do not ask for and do not want to receive sensitive information such as government identification numbers, financial account numbers, health records, biometric data, precise GPS location, or information about race, religion, political opinions, or sexual orientation. Please do not submit this information through the Services.
3. How We Use Information
We use the information we collect for the following purposes:
- To provide the Services: create and maintain your account, deliver course content, save progress, and generate personalized learning activities.
- To communicate with you: send confirmations, receipts, service notices, security alerts, and answers to your questions.
- To send marketing messages: send newsletters or product updates only where permitted by law or where you have opted in. You can unsubscribe at any time using the link in any marketing email.
- To improve the Services: analyze usage patterns, test new features, fix errors, and improve content quality and accessibility.
- To keep the Services safe: detect and prevent fraud, abuse, spam, scraping, and violations of our Terms and Conditions.
- To meet legal obligations: comply with tax, accounting, and other legal requirements, and respond to lawful requests from authorities.
Legal bases (for users in the EEA and UK). We process personal data where: (a) it is necessary to perform our contract with you; (b) you have given consent (for example, for non-essential cookies or marketing email); (c) it is necessary for our legitimate interests in operating and securing the Services, provided those interests are not overridden by your rights; or (d) it is necessary to comply with a legal obligation.
We do not sell your personal information, and we do not share it for cross-context behavioral advertising, as those terms are defined under California law.
4. Artificial Intelligence Features
Parts of the Services use third-party artificial intelligence models to generate lessons, feedback, images, and conversational replies.
- When you use an AI feature, the text or prompt you submit is sent to our AI provider to produce a response.
- We instruct users not to include personal or identifying information in AI prompts, and we ask that learners use first names or nicknames only.
- AI output can be inaccurate or incomplete. It is educational content, not professional advice. Please review Section 6 of our Terms and Conditions.
5. Children's Privacy
Our Services are designed for children's education but are intended to be purchased and managed by a parent, guardian, or teacher, who must be at least 18 years old.
- Accounts must be created by an adult. Children may use the Services only through an account created and supervised by their parent, guardian, or school.
- We ask adults to provide only the minimum information about a child — such as a first name or nickname and an age range.
- We do not knowingly collect personal information directly from children under 13 without verifiable parental or school consent, as required by the U.S. Children's Online Privacy Protection Act (COPPA).
- We do not use children's information for targeted advertising, and we do not sell it.
5.1 How we obtain and record consent
Before a child uses the Services, the adult who owns the account must affirm, at signup and under this notice, that they are the parent, legal guardian, or teacher of the learners who will use it, and must confirm control of the email address they gave us.
Where an account is purchased, the card transaction together with the notice we email you at the moment of purchase serves as our verification. That notice sets out what we collect, that a child's work is sent to the AI provider described in Section 6, and how to review, delete, or withdraw. This is the consent we rely on for that disclosure, and we record which of these methods verified each account and when.
Where a school signs an agreement with us, the school provides consent on behalf of the parents in its role as the holder of the education records.
On free accounts. A free account is verified by the signup affirmation and confirmed email address alone. If you would rather your child's work were not sent to an AI provider at all, do not use the AI features: the course can be worked through without them, and NOVA's memory can be switched off or the tutor left unused. You can also delete anything already sent, at any time, from your account.
We keep a record of each consent — the method, the date, and the version of this notice it was given under — for as long as the account exists, so that we can demonstrate we obtained it. Closing the account deletes that record along with everything else tied to it.
5.2 Your rights as a parent, guardian, or school
At any time you may:
- Review the information we hold about your learner, including their conversations with our AI tutor and what it has remembered about them.
- Delete any of it, or all of it. Deleting your account deletes your learners' work, conversations, uploads, and saved tutor notes with it.
- Withdraw consent and refuse any further collection. We will stop collecting and delete what we hold.
Email support@telosedu.org. We will verify that the request comes from the account holder before acting on it, and we will act within 30 days.
Inside the product, the account holder can also review and delete what the AI tutor has remembered at any time, and can turn that memory off entirely, without contacting us.
If we learn we have collected personal information from a child without the required consent, we will delete it promptly.
6. Third-Party Sharing
We share personal information only as described below. We do not sell it.
6.1 Service Providers (Processors)
We share information with vendors who perform services for us and are contractually required to protect it and use it only for our instructions. These include categories such as:
| Category | Purpose | Example Providers |
|---|---|---|
| Hosting and content delivery | Host and serve the Site | Vercel Inc. |
| Database, accounts, and authentication | Store accounts, learner profiles, and course progress; send sign-in and confirmation email | Supabase, Inc. |
| Outbound email | Deliver account, confirmation, and service email | Resend, Inc. |
| Payments | Take payment, calculate sales tax, store payment methods, issue receipts and refunds | Stripe, Inc. |
| Analytics | Measure Site usage (cookieless) | Vercel Analytics |
| AI processing | Generate lesson content, feedback, and images | Google LLC (Gemini and Imagen APIs) |
Stripe is not only our processor. For fraud prevention, anti-money-laundering checks, and its own financial and regulatory reporting, Stripe decides how it uses your payment data and acts as an independent controller. We have no control over that use and it is governed by Stripe's Privacy Policy rather than this one.
We use the paid tier of Google's Gemini and Imagen APIs. Under those terms, what you and your learners submit is not used to train or improve Google's models. Google processes it to generate the reply and may retain it briefly for abuse monitoring under its own published terms. We do not use your learners' work to train any AI model of our own, and we do not share it with any other AI provider.
6.2 Legal and Safety
We may disclose information if we believe in good faith that it is necessary to: comply with a law, subpoena, or court order; enforce our Terms and Conditions; investigate fraud or security incidents; or protect the rights, safety, or property of our users, the public, or us.
6.3 Business Transfers
If we are involved in a merger, acquisition, financing, reorganization, or sale of assets, information may be transferred as part of that transaction. We will notify you if your information becomes subject to a materially different privacy policy.
6.4 With Your Direction
We share information with others when you ask us to or clearly agree to it.
7. Your Rights
7.1 Rights for Everyone
Regardless of where you live, you may:
- Ask us what personal information we hold about you.
- Ask us to correct information that is wrong.
- Ask us to delete your account and associated data.
- Unsubscribe from marketing email at any time.
To exercise these rights, email support@telosedu.org with the subject line "Privacy Request."
7.2 GDPR Rights (EEA, UK, and Switzerland)
If the GDPR or UK GDPR applies to you, you have the right to:
- Access — obtain a copy of your personal data.
- Rectification — correct inaccurate or incomplete data.
- Erasure — request deletion ("right to be forgotten").
- Restriction — limit how we process your data in certain cases.
- Portability — receive your data in a structured, machine-readable format.
- Object — object to processing based on legitimate interests, and to direct marketing at any time.
- Withdraw consent — withdraw consent at any time, without affecting processing already carried out.
- Complain — lodge a complaint with your local supervisory authority.
7.3 CCPA / CPRA Rights (California)
If you are a California resident, you have the right to:
- Know the categories and specific pieces of personal information we collected, the sources, our purposes, and the categories of third parties we disclosed it to.
- Delete personal information we collected from you, subject to legal exceptions.
- Correct inaccurate personal information.
- Opt out of the sale or sharing of personal information. We do not sell or share personal information, so there is nothing to opt out of; we honor Global Privacy Control signals regardless.
- Limit the use of sensitive personal information. We do not collect sensitive personal information for the purposes that trigger this right.
- Non-discrimination — we will not deny service, charge different prices, or provide a lower quality of service because you exercised a privacy right.
7.4 Other U.S. State Rights
Residents of states with comprehensive privacy laws (including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, and Montana) have similar rights of access, correction, deletion, portability, and opt-out. We apply the protections in this section to all such residents.
7.5 How We Handle Requests
- We will verify your identity before acting, usually by confirming control of the email address on the account.
- An authorized agent may submit a request on your behalf with written proof of authorization.
- We respond within 45 days (extendable by another 45 days where permitted) or within 30 days for GDPR requests (extendable by two months for complex requests).
- Our response is free, unless a request is repetitive or clearly excessive.
8. Cookies and Similar Technologies
8.1 What We Use
- Strictly necessary cookies — keep you signed in, keep your session secure, and remember your cookie choices. The Site cannot function without these.
- Preference cookies — remember settings such as language or display options.
We do not use analytics cookies, advertising cookies, or cross-site tracking cookies. Our analytics provider measures Site usage without cookies or device identifiers.
Because we set only strictly necessary and preference cookies, most cookie-consent laws do not require us to obtain consent before setting them. We still describe them here so you know what is stored.
8.2 How to Control Cookies
- Cookie banner: if we ever add non-essential cookies, we will ask for your consent first where the law requires it, and you will be able to change your choice at any time.
- Browser settings: most browsers let you block or delete cookies. See the "Help" or "Privacy" settings of Chrome, Safari, Firefox, or Edge.
- Analytics: our analytics provider does not use cookies or device identifiers, so there is nothing to opt out of. Blocking it in your browser will not affect how the Site works.
- Do Not Track / Global Privacy Control: we honor Global Privacy Control signals as an opt-out request. Browser "Do Not Track" signals have no agreed standard, so we do not respond to them separately.
Blocking strictly necessary cookies may prevent you from signing in or saving progress.
9. Data Retention
We keep personal information only as long as we need it:
| Data | Retention Period |
|---|---|
| Account and profile data | While your account is active, then deleted or anonymized within 30 days of account closure |
| Learner progress and submitted work | While your account is active, then deleted with the account |
| Work saved under a paused learner sign-in | A course pays for two learner sign-ins. If you refund a course you hold more sign-ins than you have paid for, and the extra ones are paused rather than deleted — the child cannot sign in, and everything they made is kept. Restoring access brings it back unchanged. A sign-in that stays paused for 60 days is deleted, along with the work saved under it. You can see which sign-ins are paused, and the date each is due to be deleted, under Learners in your account. |
| AI tutor conversations | 12 months from the last message in a conversation, then deleted automatically. Deleted sooner if you delete the conversation or the account. |
| Files uploaded to the AI tutor | Deleted with the conversation they were sent in, on the same 12 month schedule. A file you attach but never send is deleted within 24 hours. |
| What the AI tutor remembers about a learner | Until you delete it or close the account. You can view, correct, delete, or switch off this memory in the product at any time. A note tied to a date — a test, a deadline, the unit a class is on — is deleted automatically within 21 days. |
| Record of changes to what the AI tutor remembers | 24 months. This is the log that lets us tell you when the tutor learned something and what it replaced. A memory you correct or delete leaves its earlier version in this log, and earlier versions are removed after 12 months. |
| What the AI tutor has worked out about a learner's skills | An estimate of how well a learner knows a given topic, and which kinds of explanation have worked for them, both derived from their own work. Deleted 24 months after the last activity on that topic, or immediately when you clear the tutor's memory or close the account. |
| How a learner usually asks for help | A count of how often their questions took a recognized shape — for example, sending a photo without a message, or saying they don't know when work gets hard. It is a count of question shapes, never a record of what they typed, and never a judgment about the learner. Deleted 24 months after it was last seen, or immediately when you clear the tutor's memory or close the account. |
| How much practice a learner did each week | A weekly count of attempts, correct answers, hints given, and how many topics were touched. Counts only — never what was asked or answered. It is what lets us show whether a learner is needing less help than they used to. Deleted 24 months after the week it covers, or immediately when you clear the tutor's memory or close the account. |
| Check-in suggestions for grown-ups | When the tutor notices a learner repeatedly stuck on the same step, it records which topic so a parent or teacher can step in — the topic, when it happened, and the specific step that kept going wrong, never what the learner typed. Deleted 6 months after a grown-up marks it handled, 24 months at the latest, or immediately when you clear the tutor's memory or close the account. |
| How a learner writes, so the tutor can match it | A rolling measurement of the shape of a learner's own messages — roughly how long they are, how much punctuation they use, and how often they reach for a subject word. It is what lets the tutor write the way the learner does, and move as they grow. Numbers only: nothing a learner typed is stored, none of it can be turned back into what they wrote, and it is never a score, a reading level, or a comparison with anyone else. Deleted 24 months after the last message, or immediately when you clear the tutor's memory or close the account. |
| Lessons a learner worked through, and how they went | When a learner works a problem with the tutor's interactive lesson, we keep the lesson itself and a record of each step: whether they got it, how many hints they took, how long it took, and — where it matches a list of common mistakes we maintain — which mistake it was. It also includes the sequence of moves they made on the on-screen tools, which is what lets us tell which kinds of explanation actually work. Never what they typed as an answer: the answer is read, marked, and discarded within the request. Deleted 24 months after the lesson, or immediately when you clear the tutor's memory or close the account. |
| Photos of homework sent to the AI tutor's lesson mode | Not retained at all. A photo of a worksheet is read within the request that carries it and is gone when that request finishes. It is never written to storage and there is no way to fetch it back. What survives is the question in words, which is kept with the lesson above. |
| The problem a learner is working on, and what they did with the on-screen tools | When a learner confirms a homework problem, we keep the question in words, the topic it belongs to, and counts of how the session went: how many attempts missed, which tools were shown, and how many times the learner said the help was not working. Alongside it we keep the sequence of moves they made on each tool — where a bar was cut, where a marker was placed, which bucket something went into — with timings. That sequence is what lets us tell which kinds of explanation actually teach, and it is the only record of the attempt: nothing the learner typed is stored with it. None of it is a score, a grade, or a comparison with any other child. Deleted 24 months after the session, or immediately when you clear the tutor's memory or close the account. |
| A teaching method a grown-up has told the tutor about | If you tell the tutor that a learner's teacher does something differently, we keep your description of that method against the topic it applies to, so the tutor explains it your teacher's way rather than its own. It is a setting you made, not something the tutor worked out about the learner, so clearing the tutor's memory does not remove it — you can edit or delete it yourself at any time, and it is deleted with the account. A photo of a method is read within the request that carries it and is never stored; only the words survive. |
| Ready-made lessons kept for speed | Once the tutor has written a lesson for a topic, it keeps a copy so the same learner does not wait for it to be written again. It contains no information about the learner. Deleted 90 days after it was last used, or immediately when you clear the tutor's memory or close the account. |
| Changes to the grown-up settings for the AI tutor | A log of changes to the settings an adult has set — help level, reading level, which topics the tutor should lean towards, and how often it revisits old work — and of when the PIN was set or changed. PIN values are never recorded. Kept 24 months, then deleted. |
| AI usage records (message and token counts) | 12 months |
| Billing and transaction records | 7 years from the transaction. Purchase records, invoices, refunds, and the billing address the tax was calculated from are kept for this period because tax and accounting law requires it, and they are not deleted when you close your account. Stripe keeps its own copy under its own schedule. |
| Stripe customer identifier and entitlement record | While your account is active, then deleted with the account. This is the link between your account and what you bought; the transaction record above survives it without being tied to a live account. |
| Parental consent records | While the account exists, then deleted with it. Where consent was verified by a card transaction, the transaction reference is part of the record above and follows its 7-year period. |
| Marketing email list | Until you unsubscribe, then suppressed to honor your opt-out |
| Support and email correspondence | 2 years after the matter is closed |
| Server and security logs | 90 days |
| Analytics data | Aggregate, non-identifying usage data retained by our analytics provider, currently 12 months |
The periods above are enforced by automated nightly jobs, not by hand: one deletes expired records in our database, one deletes what the tutor has learned about a learner once it is out of date, one deletes the corresponding uploaded files from storage, and one removes learner sign-ins that have been paused past the 60 days above. We keep a log of each run. Closing your account deletes the data tied to it regardless of where it sits in these windows — with one exception, which we want to be plain about: billing and transaction records survive account deletion, because tax and accounting law requires us to keep them. They are records of a payment, not of a learner, and contain nothing about your child.
We may keep information longer where required to comply with a legal obligation, resolve a dispute, or enforce our agreements.
10. Data Security
We use reasonable administrative, technical, and physical safeguards, including encryption in transit (HTTPS), encryption of stored passwords, row-level access controls on our database, access limited to staff who need it, and regular review of our providers.
No method of transmission or storage is completely secure. We cannot guarantee absolute security. If a breach affects your personal information, we will notify you and any regulator as required by applicable law.
11. International Transfers
We are located in the United States and process data there. For transfers of personal data from the EEA, UK, or Switzerland, we rely on the European Commission's Standard Contractual Clauses (and the UK Addendum where applicable) or another lawful transfer mechanism, together with additional safeguards where appropriate. You may request a copy of the relevant safeguards by emailing us.
12. Third-Party Links
The Site may link to other websites we do not control. This Privacy Policy does not apply to them. Please read the privacy policy of any site you visit.
13. Changes to This Policy
We may update this Privacy Policy from time to time. We will change the "Last Updated" date at the top. If the changes are material, we will give you notice by email or a clear notice on the Site before they take effect. Continuing to use the Services after the effective date means you accept the updated policy.
14. Contact Us
Questions, requests, or complaints about privacy:
- Email: support@telosedu.org
- Postal address: Telos, 2314 Santee Avenue, Columbia, South Carolina 29205, United States
- EU/UK representative (if applicable): not currently appointed
We aim to reply to every privacy request within 5 business days.