Privacy Policy

1. Introduction and Company Identity

Campus Companion AI ("Company," "we," "us," or "our") operates the Campus Companion AI platform, including its web application, APIs, and associated services (collectively, the "Platform"). We are committed to protecting the privacy, safety, and security of all individuals who interact with our Platform, with particular diligence toward the protection of minors and student data.

This Privacy Policy ("Policy") describes the types of information we collect, how we use and protect that information, your rights with respect to your data, and the legal framework governing our data practices. This Policy is incorporated by reference into our Terms of Service. In the event of a conflict between this Policy and any other document, this Policy shall govern with respect to privacy matters.

If you do not agree with the terms of this Policy, you must discontinue use of the Platform immediately. Continued use of the Platform following any posted modifications constitutes your acceptance of the revised Policy.

2. Scope and Applicability

This Policy applies to all personal information collected, processed, stored, or transmitted by Campus Companion AI in connection with the Platform, including but not limited to:

• Information provided directly by users (students, teachers, administrators, or parents/guardians);
• Information collected automatically through the use of the Platform;
• Information received from school institutions acting as our institutional customers ("Schools");
• Information received through third-party integrations (such as Google Classroom).

This Policy does not apply to third-party websites, services, or applications that may be linked from the Platform. We are not responsible for the privacy practices of such third parties, and we encourage users to review the privacy policies of any third-party services they access.

3. Information We Collect

We collect the following categories of information:

3.1 Information Provided by Users

• Account Registration Data: First name, last name, school-issued email address, grade level, and assigned role (student, teacher, or administrator).
• AI Tutoring Session Content: Messages, responses, and interactions submitted during AI tutoring sessions. This includes text inputs, uploaded content, and generated outputs.
• Teacher and Administrator Data: Professional email addresses, school affiliation, class rosters, assignment details, and administrative preferences.
• Payment Information: For subscribing institutions, billing contact names and email addresses. Payment card details are processed exclusively by Stripe, Inc. and are never stored on our servers.

3.2 Automatically Collected Information

• Usage Metadata: Session timestamps, AI personality selections, session durations, feature interactions, and page navigation data.
• Device and Technical Data: Browser type, operating system, device type, IP address (truncated where feasible), and general geographic region (country/state level only).
• Log Data: Server logs that record access times, errors, and system events for security and debugging purposes.

3.3 Information We Do Not Collect

We explicitly do not collect and have no legitimate interest in collecting:

• Social Security numbers or government-issued identification numbers;
• Home addresses or precise geolocation data;
• Biometric data of any kind;
• Financial account numbers or full payment card numbers;
• Health or medical records;
• Race, ethnicity, religion, or political affiliations;
• Content from students' personal communications outside the Platform.

4. Legal Basis for Data Processing

Campus Companion AI processes personal data on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our contract with subscribing Schools and to deliver the services requested by users.
• Legitimate Interests: Processing is necessary for our legitimate interests in operating, improving, and securing the Platform, provided these interests are not overridden by the rights and interests of users.
• Compliance with Legal Obligations: Processing is necessary to comply with applicable law, including FERPA, COPPA, and applicable state student privacy statutes.
• Consent: Where required by law, we obtain explicit consent from users or, in the case of minors, from the applicable School acting on behalf of parents/guardians.

5. FERPA Compliance

The Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. § 1232g, and its implementing regulations at 34 C.F.R. Part 99, govern the privacy of student education records. Campus Companion AI acknowledges that student data processed through the Platform may constitute "education records" under FERPA.

Campus Companion AI operates as a "school official" with a "legitimate educational interest" under FERPA, as that exception is defined in 34 C.F.R. § 99.31(a)(1). In this capacity:

• We use student education records solely to provide and improve the educational services contracted by the School;
• We do not re-disclose student education records to any third party without prior written consent from the applicable School, except as required by law;
• We maintain direct control over student education records with respect to their use and maintenance;
• We are subject to FERPA's requirements as specified in the School's policies governing the use of school officials.

Schools retain ownership of all student education records and are responsible for managing parental access rights and consent obligations under FERPA. Campus Companion AI provides reasonable cooperation to Schools in fulfilling their FERPA obligations.

6. COPPA Compliance

The Children's Online Privacy Protection Act (COPPA), 15 U.S.C. §§ 6501–6506, and its implementing regulations at 16 C.F.R. Part 312, restrict the collection of personal information from children under the age of 13.

Campus Companion AI operates under the "school authorization" exception to COPPA's parental consent requirement, as recognized by the Federal Trade Commission (FTC). Under this exception, a school may consent to the collection of personal information from students on behalf of parents where: (a) the operator's service is used solely for educational purposes; (b) the information collected is not used for commercial purposes; and (c) the school has agreed to provide notice to parents on behalf of the operator.

Accordingly:

• We do not knowingly collect personal information from children under 13 without School-provided authorization;
• We collect only the minimum information necessary to provide the educational service;
• We do not use information collected from students under 13 for any commercial purpose, including behavioral advertising;
• Schools are responsible for providing appropriate notice to parents/guardians of students under 13 prior to enrolling those students on the Platform;
• If we become aware that we have collected personal information from a child under 13 without proper School authorization, we will promptly delete such information.

7. State Student Privacy Laws

In addition to federal law, Campus Companion AI acknowledges applicable state-level student data privacy statutes, which may include but are not limited to:

• California: Student Online Personal Information Protection Act (SOPIPA), AB 1584, and the California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA);
• New York: Education Law § 2-d and its implementing regulations;
• Illinois: Student Online Personal Protection Act (SOPPA);
• Texas: Texas Student Data Privacy Act;
• Other States: We are committed to complying with the applicable student data privacy laws of all states in which the Platform is deployed.

Under applicable state laws, Campus Companion AI agrees not to: (a) sell or rent student data; (b) use student data to engage in targeted advertising; (c) build profiles of students for non-educational purposes; or (d) disclose student data except as permitted by law and this Policy.

8. How We Use Information

We use the information we collect solely for the following purposes:

• Service Delivery: To authenticate users, operate the AI tutoring platform, facilitate teacher-student interactions, and provide all contracted features;
• Safety and Moderation: To detect and flag potentially harmful, inappropriate, or concerning content, and to surface such content to authorized school administrators for review;
• Product Improvement: To analyze aggregated, de-identified usage patterns to improve the Platform's functionality, accuracy, and educational value. Individual student data is never used for this purpose without de-identification;
• Communications: To send transactional notifications (e.g., account creation confirmations, security alerts) to authorized users;
• Legal Compliance: To meet our obligations under applicable law and respond to lawful governmental requests;
• Security: To protect the integrity of the Platform, detect fraud or abuse, and maintain system security.

We do not and will not: sell student data; use student data for behavioral or targeted advertising; use student data to build commercial profiles; share student data with third parties for their independent commercial use; or use student data for any purpose inconsistent with the educational mission of the Platform.

9. Disclosure of Information

Campus Companion AI does not sell, rent, trade, or otherwise disclose personal information to third parties, except in the following limited circumstances:

• Service Providers: We may share data with vetted third-party vendors who assist in operating the Platform (e.g., cloud hosting providers, payment processors) under strict contractual confidentiality and data processing obligations. These vendors are prohibited from using the data for any purpose other than providing services to us;
• School Administrators: Student session data is made accessible to authorized teachers and administrators at the student's School in accordance with their FERPA-designated roles;
• Legal Requirements: We may disclose information when required by valid legal process (e.g., subpoena, court order), provided we notify the applicable School to the extent permitted by law;
• Safety Emergencies: We may disclose information to relevant authorities if we have a good-faith belief that disclosure is necessary to prevent imminent physical harm to a student or others;
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of our assets, user data may be transferred as part of that transaction. We will provide notice and, where required, obtain consent prior to such transfer, and any successor entity will be bound by the terms of this Policy.

10. Data Security

Campus Companion AI implements administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, and destruction. Our security measures include, but are not limited to:

• Encryption of all data in transit using TLS 1.2 or higher;
• Encryption of sensitive data at rest using AES-256 or equivalent industry-standard encryption;
• Role-based access controls that limit access to student data to only those personnel with a legitimate need;
• Audit logging of all access to student records;
• Regular security assessments and vulnerability testing;
• Employee training on data privacy and security best practices;
• Vendor security reviews for all third-party service providers who may access personal data.

Important Limitation: No method of data transmission or electronic storage is 100% secure. While we are committed to implementing industry-standard security measures, we cannot guarantee absolute security. In the event of a data breach, we will notify affected Schools and, where required by law, regulatory authorities and affected individuals, within the timeframes required by applicable law.

11. AI Content Safety and Moderation

All AI interactions on the Platform are subject to automated content filtering and safety monitoring. Our AI systems are configured and constrained to:

• Stay within age-appropriate, academic subject matter;
• Decline to provide responses that promote academic dishonesty, self-harm, violence, or other harmful conduct;
• Flag interactions that contain language or topics indicating potential distress, crisis, or safety concerns for review by authorized school staff.

Flagged sessions are made available to school administrators within the Platform's teacher dashboard. Campus Companion AI does not independently contact parents, guardians, or emergency services in response to flagged content — that responsibility lies with the School. Schools must maintain and follow their own protocols for responding to flagged interactions.

Disclaimer: While our AI content filtering is designed to catch harmful or inappropriate interactions, it is not infallible. Campus Companion AI does not warrant or guarantee that all harmful content will be detected and filtered. The Platform is a supplemental educational tool and is not a substitute for human supervision or crisis intervention services.

12. Data Retention and Deletion

We retain personal information only for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law.

• Active Subscriptions: Student and session data is retained for the duration of the School's active subscription;
• Post-Subscription: Upon termination or non-renewal of a School's subscription, all student data associated with that School will be deleted within ninety (90) days, unless an earlier deletion is requested;
• Deletion Requests: Schools may submit a written request for immediate deletion of all associated student data by contacting us at campuscompanionai@gmail.com. We will process verified deletion requests within thirty (30) days;
• Backup Retention: Deleted data may persist in encrypted backup systems for up to an additional thirty (30) days before being purged from all backup media;
• Legal Hold: Notwithstanding the above, we may retain data where necessary to comply with applicable law, resolve disputes, or enforce our agreements.

13. User Rights and School Rights

Depending on your role and applicable law, you may have the following rights with respect to personal data:

• Access: The right to request a copy of the personal data we hold about you or your student;
• Correction: The right to request correction of inaccurate or incomplete data;
• Deletion: The right to request deletion of personal data, subject to applicable legal limitations;
• Portability: The right to receive data in a structured, machine-readable format where technically feasible;
• Restriction: The right to request that we restrict processing of personal data in certain circumstances;
• Objection: The right to object to processing of personal data based on our legitimate interests.

Under FERPA, rights to access and amend student education records are primarily held by the School and, in certain circumstances, by parents/guardians and eligible students. Parents or eligible students wishing to exercise FERPA rights should contact the student's School directly. We will cooperate with Schools in fulfilling such requests.

To exercise any of the rights above, Schools should submit a written request to campuscompanionai@gmail.com. We will respond within the timeframe required by applicable law, and no later than forty-five (45) days from receipt of a verified request.

14. Cookies and Tracking Technologies

Campus Companion AI uses session cookies and similar technologies strictly for the purpose of maintaining authenticated user sessions and ensuring platform functionality. We do not use tracking pixels, third-party advertising cookies, or behavioral tracking technologies.

Users may configure their browser to refuse cookies; however, doing so may prevent the Platform from functioning correctly, as session authentication relies on cookies.

15. Third-Party Integrations

The Platform may integrate with third-party services, including Google Classroom and Stripe. When you authorize such integrations:

• Google Classroom: Access is limited to the scopes explicitly authorized by the School (e.g., course rosters, assignments). We do not access Google account data beyond what is necessary for the integration's educational purpose. Google's Privacy Policy governs Google's data practices;
• Stripe: Payment processing is handled entirely by Stripe, Inc. Campus Companion AI never receives or stores full payment card numbers. Stripe's Privacy Policy governs the handling of payment information.

We are not responsible for the privacy practices of third-party services. We encourage Schools to review the privacy policies of any third-party services authorized for use with the Platform.

16. International Data Transfers

Campus Companion AI is operated from the United States. If you are accessing the Platform from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your jurisdiction. By using the Platform, you consent to such transfers where applicable law requires consent.

17. Disclaimer of Warranties

THE PLATFORM AND ITS SERVICES ARE PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT. CAMPUS COMPANION AI DOES NOT WARRANT THAT THE PLATFORM WILL BE UNINTERRUPTED, ERROR-FREE, OR COMPLETELY SECURE.

CAMPUS COMPANION AI DOES NOT WARRANT THAT ITS AI CONTENT FILTERING WILL DETECT ALL INAPPROPRIATE, HARMFUL, OR UNSAFE CONTENT. THE PLATFORM IS AN EDUCATIONAL SUPPORT TOOL AND IS NOT INTENDED TO SERVE AS A SUBSTITUTE FOR QUALIFIED HUMAN EDUCATORS, COUNSELORS, OR CRISIS INTERVENTION PROFESSIONALS.

18. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, CAMPUS COMPANION AI SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, OR ANY LOSS OF PROFITS, DATA, GOODWILL, OR OTHER INTANGIBLE LOSSES, ARISING OUT OF OR RELATING TO YOUR ACCESS TO OR USE OF (OR INABILITY TO ACCESS OR USE) THE PLATFORM OR THIS PRIVACY POLICY.

IN NO EVENT SHALL CAMPUS COMPANION AI'S TOTAL LIABILITY TO ANY SCHOOL OR USER EXCEED THE TOTAL AMOUNTS PAID BY THAT SCHOOL TO CAMPUS COMPANION AI IN THE TWELVE (12) MONTHS PRECEDING THE EVENT GIVING RISE TO LIABILITY.

19. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

• Post the revised Policy on this page with an updated "Last Updated" date;
• Notify subscribed Schools via email at least thirty (30) days prior to the effective date of any material changes;
• Where required by law, seek renewed consent from affected parties.

Your continued use of the Platform after the effective date of any revised Policy constitutes your acceptance of the changes. If you do not agree to the revised Policy, you must stop using the Platform and notify us to arrange for data deletion.

20. Governing Law and Dispute Resolution

This Policy is governed by and construed in accordance with the laws of the United States and the state in which Campus Companion AI is domiciled, without regard to conflict of law principles. Any dispute arising under this Policy shall be resolved through binding arbitration in accordance with the rules of the American Arbitration Association, unless both parties mutually agree to an alternative dispute resolution mechanism.

Nothing in this section shall prevent either party from seeking injunctive or other equitable relief in a court of competent jurisdiction to protect confidential information or intellectual property rights.

21. Contact Information

For questions, concerns, data requests, or to report a potential privacy issue, please contact us at:

We aim to respond to all privacy-related inquiries within five (5) business days and to resolve all substantive requests within the timeframes required by applicable law.