1.1: Gradient offers an AI-powered educational platform to help teachers efficiently generate, simulate, and adapt course materials. While our platform is built for educators, certain features may include opt-in data from students to enhance adaptive learning and personalization. This notice supplements our privacy policy to explain our data collection practices regarding users under the age of 13.

1.2: We may enter educational partnerships in which student data is collected for simulation, analytics, or educational improvement purposes. In these cases:

• where children interact with Gradient via school-facilitated usage, we rely on schools to obtain parental consent and manage authorization to use our services;
• we require schools to provide parents with our privacy policy and this COPPA notice, and to obtain verifiable parental consent in accordance with COPPA regulations.

1.3: If students access Gradient for personal use or teacher-shared assignments, they must register through an established email provider (e.g. Google), which manages parental verification workflows. This ensures compliance with consent verification and our Terms of Service.

1.4: We require parental consent for the collection, use, or disclosure of children's personal information. Without consent, we do not collect or retain data that is personally identifiable from children, except as necessary for internal operations described below.

1.5: Prior to receiving consent, we may use persistent identifiers (e.g. cookie IDs) solely to support essential internal functions, such as site security, session management, diagnostics, and performance analytics.

1.6: Personal Information We Collect Directly from Children (if applicable through a school partnership or parent consent):

• Name and contact information such as email and username;
• Demographic details including age, grade level, and learning needs if voluntarily provided;
• Profile and usage data related to assignments, assessments, and participation in simulations or learning activities;
• Content generated, submitted, or edited by the child such as responses to assignments, annotations, and document edits;
• Login credentials including usernames and access codes, although passwords remain encrypted and inaccessible to Gradient;
• Device metadata such as IP address, device type, operating system, and browser configuration;
• Usage patterns including pages viewed, time spent, actions taken, and document interaction logs;
• Limited geolocation data, where permitted, to enhance contextual educational feedback (state and country only);
• Academic performance data, if submitted by a teacher or school, in relation to specific assignments or grading feedback;
• Third-party integrations, such as Google or OpenAI, may transmit permitted information if connected to the student's account with proper consent.

1.7: Gradient may send educational emails or automated system messages to users, including children, regarding assignments, progress, or platform use. These communications may be facilitated through vetted third-party vendors acting on our behalf.

1.8: If children engage with collaborative or social learning features, content and profile information may be shared with other users (e.g. student-teacher collaboration spaces), subject to role-based access permissions.

1.9: When used in school contexts, a child's school may have access to and control over the child's profile and data, including the right to review, correct, or delete personal information.

1.10: We share information as needed to operate the service, fulfill user requests, facilitate educator-student interaction, and in some cases, aggregate flashcard or learning materials authored by students for community use. All sharing is within the scope of privacy settings and user role authorization.

1.11: Parental consent is handled through schools or authorized education providers. If consent is not provided in a reasonable time frame, the child's data will be deleted or anonymized. Google or other verifiable platforms may also be used for consent workflows.

1.12: Parents can revoke consent at any time. Doing so will restrict the child's use of Gradient. Parents may also request access to, correction of, or deletion of personal data. We will comply unless data retention is required by law or for security purposes.

1.13: We delete data upon user or school request, or after periods of inactivity, provided no legal or contractual obligations require retention. We use commercially reasonable efforts to remove all personal identifiers from deleted profiles.

1.14: More information on COPPA and your rights can be found at the FTC's website: https://www.ftc.gov/legal-library/browse/rules/childrens-online-privacy-protection-rule-coppa

1.15: For questions, or to request access or deletion of a student's data, contact legal@gradientedtech.com and include "COPPA Question" or "Student Record Request" in your subject line.

1.1: In accordance with SOPIPA, Gradient affirms the following:

• No data is collected for the purpose of targeted advertising;
• No advertising profiles are created for students or teachers;
• Student and teacher data is never sold to third parties for profit;
• Reasonable security practices are implemented to protect all user data;
• Information is disclosed only as required by law, for service maintenance, development, or corporate transactions;
• Information may be shared with educational researchers or analytics processors solely to enhance the educational experience;
• Any data used for ongoing development is de-identified and aggregated.