Privacy Policy

This Privacy Policy explains how Edula Inc. ("Edula," "we," "us," or "our") collects, uses, discloses, and protects personal information when you use our website at edula.ai, our mobile applications, and related services (the "Services"). It also explains the choices and rights you have. Capitalized terms not defined here have the meanings given in our Terms of Service.

Edula Inc. is a Delaware corporation. Edula is the "controller" or "business" responsible for your personal information under this Privacy Policy.

1. Our Key Commitments

Because many of our users are high school students and their families, we have made the following commitments, which apply to every user in every state:

• Not for children under 13. The Services are not directed to children under 13, and we do not knowingly collect personal information from them. We ask for grade level, not birth date, and we delete information if we learn it came from a child under 13 (Section 7).

• We do not sell personal information. We do not sell personal information for money or other valuable consideration.

• No targeted advertising to students. We do not "share" personal information for cross-context behavioral advertising, and we do not use students' personal information to serve targeted advertising. We do not use third-party advertising cookies or pixels on logged-in pages.

• No sale of students' data to colleges or recruiters. We do not disclose a student's personal information to colleges, universities, Opportunity providers, or Counselors unless the student (or parent) directs us to, for example by requesting a Counselor match or choosing to apply to an Opportunity through the Services.

• Limited collection. We collect only the information reasonably necessary to provide the Services you request, and we do not require more personal information than is reasonably necessary for a student to participate in an activity.

• No AI training on identifiable student data without consent. We do not use identifiable personal information of students to train general-purpose AI models. We may use de-identified or aggregated data to improve our matching.

2. Scope

This Privacy Policy applies to personal information we collect through the Services and through our communications with you (for example, email and customer support). It does not apply to:

• information collected by Counselors, Institutions, or Opportunity providers when you deal with them directly, which is governed by their own privacy policies;

• third-party websites, apps, or services linked from the Services; or

• personal information we process on behalf of a school or district under a written agreement, which is governed by that agreement and applicable student-privacy laws such as FERPA.

3. Information We Collect

We collect a limited amount of personal information. Much of it is optional, and you can use many features without providing it.

We do not collect precise geolocation, biometric identifiers, Social Security numbers, government ID numbers, or date of birth. Please do not share information about other people (for example, siblings or classmates) or sensitive information we do not ask for.

4. How We Use Information

We use personal information to:

• Provide the Services — create and manage accounts; generate college matches, roadmaps, and Opportunity suggestions; match students with Counselors and enable communication and scheduling; process payments; and provide customer support.

• Personalize the Services — tailor Content, recommendations, and reminders to a student's grade, goals, and interests.

• Communicate — send account, transactional, security, and service messages; send marketing about Edula's own products to adults and, where permitted, to students who have not opted out (never on behalf of third parties).

• Keep users safe — screen Counselors, monitor for fraud, abuse, and inappropriate contact with Minors, enforce our Terms, and comply with reporting obligations.

• Improve the Services — analyze usage, test features, fix errors, and improve our matching models, using de-identified or aggregated data where practicable.

• Comply with law — meet legal, tax, accounting, and regulatory obligations, respond to lawful requests, and establish or defend legal claims.

We use optional sensitive information only to provide features you request and never to infer characteristics for advertising.

How our AI matching works. Our matching and roadmap features use automated processing, including machine-learning models, to compare the information about the student with information about colleges, Opportunities, and Counselors and to rank suggested matches. The main factors are stated interests and goals, academic information you provide, preferences, grade level, and, for Counselors, expertise, availability, and price. Matches are suggestions only; Edula does not make admission, eligibility, or selection decisions about anyone, and no match is shared with an Institution without your direction. You may edit your profile at any time to change your matches, or contact us to ask questions about how matching works or to request review by a person.

De-identified information. We may create de-identified or aggregated information that cannot reasonably be linked to you. We maintain it in de-identified form, will not attempt to re-identify it, and contractually require recipients to do the same.

5. Cookies, Analytics, and Similar Technologies

We and our service providers use cookies, local storage, SDKs, and similar technologies to keep you logged in, remember preferences, secure the Services, and understand how the Services are used.

• Strictly necessary — required for login, security, and core features. These cannot be turned off.

• Functional — remember settings such as language and dashboard views.

• Analytics — help us measure usage and improve the Services (for example, Google Analytics), configured so the provider acts as our service provider and does not use the data for its own advertising).

• Advertising — On public marketing pages only, we use limited advertising technologies to measure our own ad campaigns; these are never loaded on logged-in or student pages, and you can opt out as described below.

You can control cookies through our cookie settings link and your browser settings. Blocking some cookies may affect how the Services work.

Do Not Track and Global Privacy Control. Some browsers offer a "Do Not Track" ("DNT") signal. Because there is no common industry standard for DNT, the Services do not respond to DNT signals. We do honor the Global Privacy Control ("GPC") signal as a valid request to opt out of any sale, sharing, or targeted advertising for that browser (and, if you are logged in, your account), in every state.

Third-party tracking. Except as described in this Section, we do not allow third parties to collect personal information about your online activities over time and across different websites when you use the Services.

6. How We Disclose Information

We disclose personal information only as described below:

• At your direction. When you request a Counselor match, book Counselor Services, message a Counselor, or choose to apply to or express interest in an Opportunity, we share the information needed for that purpose (for example, your name, grade, goals, and profile details you choose to include) with that Counselor or provider. Counselors are contractually required to use it only to provide Counselor Services to you.

• Parents and linked accounts. A parent or guardian who manages or is linked to a student's account can view the student's profile, matches, roadmap, and Counselor activity.

• Service providers. We use vendors to host data, process payments, send communications, provide customer support, run analytics, provide AI model processing, perform background checks on Counselors, and provide security. They may use personal information only to perform services for us, under written contracts that restrict other use.

• Legal and safety. We may disclose information if we believe in good faith it is required by law, subpoena, or court order; to protect the safety of any person, especially a Minor; to report suspected child abuse or exploitation; to investigate fraud or security issues; or to enforce our Terms.

• Corporate transactions. If Edula is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, personal information may be transferred as part of that transaction, subject to this Privacy Policy's commitments (including our no-sale and no-targeted-advertising commitments), and we will notify you of any change in the entity responsible for your information.

• With your consent. We may disclose information for other purposes with your consent (or a parent's consent, where required).

We may disclose de-identified or aggregated information (for example, overall trends in students' college interests) that does not identify any individual.

We do not sell personal information, and we do not share personal information for cross-context behavioral advertising or targeted advertising.

7. Children Under 13

The Services are designed for high school students, their parents and guardians. The Services are not directed to children under 13, and we do not knowingly collect, use, or disclose personal information from children under 13 in compliance with the Children's Online Privacy Protection Act (COPPA) and the FTC's COPPA Rule.

• Grade, not age. We do not ask for a date of birth. In our matching workflow we ask for the student's current grade level and display a notice that the Services are not intended for children under 13.

• If we learn a child under 13 has provided information, we will promptly delete it and close the account, unless we are permitted by COPPA to keep limited information (for example, to send a notice to a parent or to protect a child's safety).

• Parents: if you believe your child under 13 has provided us personal information, contact us at support@edula.ai and we will delete it.

8. Teen Users and Minors

Many of our users are minors. In addition to the commitments in Section 1, we apply these protections to all minors, in every state:

• We do not sell their personal information, use it for targeted advertising, or use it for profiling that produces legal or similarly significant effects.

• We collect only the personal information reasonably necessary to provide the features they use, and we do not use design features intended to significantly increase or extend their use of the Services.

• Default settings are the most privacy-protective available (for example, profiles and reviews are not public by default).

• A parent or guardian must consent to a Minor's use of paid features and Counselor Services, as described in our Terms of Service.

• We do not allow direct messaging between students and unrelated adults other than Counselors engaged with parental consent, and Counselor communications are subject to the safety rules in our Terms of Service.

• Consistent with California Business and Professions Code § 22581, a registered user under 18 may remove, or ask us to remove, content or information they posted publicly on the Services by or emailing support@edula.ai. Removal may not ensure complete removal (for example, if another user has reposted it), and we may keep content where the law requires.

• We do not market or advertise to Minors products or services that California or other state laws prohibit marketing to minors.

Parents and guardians may contact us at any time to review, correct, or delete their Minor child's personal information, or to close the child's account, as described in Section 10.

9. Data Retention

We keep personal information only as long as reasonably necessary for the purposes described in this Privacy Policy, then delete or de-identify it. Our general retention periods are:

We may keep information longer where required by law, to resolve disputes, or to enforce our agreements.

10. Your Privacy Choices and Rights

Wherever you live in the United States, you may make the following requests about your personal information (and a parent or guardian may make them for a Minor child):

• Access and know — confirm whether we process your personal information and obtain a copy of it, including the categories of sources, purposes, and recipients.

• Portability — receive your information in a portable, commonly used format.

• Correction — correct inaccurate information. Most profile information can be edited directly in Account Settings.

• Deletion — delete your personal information, subject to legal exceptions.

• Opt out — opt out of any sale, sharing, targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects. (We do not engage in these activities, but you may still submit a request.)

• Limit or withdraw consent for sensitive information — withdraw consent to our processing of optional sensitive information at any time; we will stop using and delete it.

• Marketing — unsubscribe from marketing emails using the link in each email, and reply STOP to text messages.

• List of third parties — where state law provides this right, request a list of the specific third parties (other than individuals) to which we have disclosed personal information.

How to submit a request. Email support@edula.ai. We will verify your identity by matching information you provide with information in our records, and we may ask a parent for additional information to confirm their relationship to a Minor. You may use an authorized agent; we may ask the agent for proof of authorization and ask you to verify your identity directly. We will respond within 45 days, and may extend this by up to another 45 days where permitted by law, with notice to you.

Appeals. If we deny your request, you may appeal by replying to our decision or emailing support@edula.ai with "Appeal" in the subject line within sixty (60) days. We will respond in writing within 60 days (45 days in some states) and explain the reasons for our decision. If you are not satisfied with our appeal decision, you may contact your state Attorney General.

No discrimination. We will not deny you services, charge you different prices, or provide a different quality of service because you exercised your privacy rights.

11. Security

We maintain a written information security program with administrative, technical, and physical safeguards appropriate to the sensitivity of the information, including encryption in transit and at rest, access controls and multi-factor authentication for staff, vendor security review, logging and monitoring, and employee training. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. If a data breach affects your personal information, we will notify you and regulators as required by applicable state and federal law.

12. Data Location

The Services are intended for users in the United States, and we store and process personal information in the United States.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated version with a new "Last Updated" date. If we make material changes, we will notify you by email before the changes take effect, and where required by law we will obtain your consent (or a parent's consent) before using personal information in a materially different way than described when it was collected.

14. Additional Disclosures for California Residents

This Section supplements the rest of this Privacy Policy and is our notice at collection under the California Consumer Privacy Act, as amended ("CCPA").

Categories collected and disclosed in the last 12 months.

We collect these categories for the purposes in Section 4 and retain them as described in Section 9. We do not sell or share (for cross-context behavioral advertising) personal information, and we have no actual knowledge of selling or sharing personal information of consumers under 16. We use sensitive personal information only for purposes permitted under Cal. Code Regs. tit. 11, § 7027(m), such as providing the features you request, so we do not offer a separate right to limit its use.

Your California rights. You have the rights described in Section 10, including to know, delete, correct, and opt out of sale or sharing, and not to receive discriminatory treatment for exercising them. Edula's matching does not make significant decisions about consumers as defined in the CCPA regulations; update this paragraph before January 1, 2027 if that changes.

Shine the Light. California Civil Code § 1798.83 permits California residents to request information about disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.

15. Other U.S. State Privacy Rights

Residents of states with comprehensive consumer privacy laws — including Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia — have the rights described in Section 10, including the right to appeal. Because we extend these rights and our protections for Minors to all U.S. users, you may use the same request process wherever you live.

• Minors' data. In states that restrict processing of minors' data (for example, Connecticut, Colorado, Maryland, Oregon, and others), we do not sell, target advertising to, or profile users we know (or willfully disregard) are under 18, and we process Minors' data only as reasonably necessary to provide the Services.

• Consumer health data. We do not collect "consumer health data" as defined in Washington's My Health My Data Act or similar laws.

• Nevada. We do not sell covered information as defined in Nevada Revised Statutes Chapter 603A. Nevada residents may submit an opt-out request to support@edula.ai.

16. Contact Us

For questions or requests about this Privacy Policy or our privacy practices, email us at support@edula.ai.