IQnition Privacy Notice

Version 1.0 · Effective Date: September 1, 2026 · Last Updated: August 19, 2026

Operator: Prompt Xchange LLC, doing business as IQnition (“IQnition,” “we,” “us”). Address: 166 Geary St., Ste. 1500, #1668, San Francisco, CA 94108. Privacy contact for all regions, including Canada: support@iqnition.ai.

1. Scope and Roles

This Privacy Notice applies to IQnition’s websites, mobile applications, APIs, and related services (the “Service”). IQnition is an AI-powered study companion for students in grades 3–12. It provides Socratic AI tutoring, adaptive quizzes, AI-generated study plans, and a parent dashboard that lets guardians track a student’s progress.

IQnition (operated by Prompt Xchange LLC) acts as the controller or business for all personal information collected through the Service. Unlike enterprise platforms that process data on behalf of business customers, IQnition is a direct-to-consumer service: we determine the purposes and means of processing for account, learning, billing, and technical data.

The Service supports three types of users:

• Guardians (parents/caregivers) — create and manage the family account, subscribe to plans, create child profiles, and view student progress through the parent dashboard.
• Students (13 and older) — hold their own authenticated accounts, subject to guardian oversight where part of a family plan.
• Children (under 13) — do not hold their own accounts. A guardian creates the child’s profile and the child signs in using a 6-digit device code issued by the guardian. Children are never asked to provide an email address, password, or contact information. See Section 3 (Children’s Privacy).

IQnition is a consumer service purchased by families. It is not currently offered under contract to schools or school districts and does not act as a “school official” under FERPA. If school or district offerings launch, they will be governed by separate terms.

2. Information We Collect

2.1 Account and Profile Information

From guardians and students 13+: name, email address, password credentials (managed by our authentication provider), plan selection, and family membership. From guardians about each child: the child’s first name or nickname, grade level, subjects of interest, and an optional avatar. Device codes for child sign-in are stored only in hashed form.

2.2 Learning and Study Content

Messages exchanged with the AI tutor (questions, answers, hints, and explanations), problems submitted to the AI solver, quiz questions, answers, scores, and confidence ratings, study plans and study plan session records, session summaries and “session memory” used to personalize future tutoring, mastery and progress data, and feedback ratings on AI responses.

2.3 Safety and Parental Notification Information

To comply with youth-safety requirements (including California SB 243), the Service screens student messages for indicators of self-harm, violence, and age-inappropriate content. When triggered, the Service records the alert type, detected keywords, timestamp, and related metadata, displays crisis resources to the student (including the 988 Suicide & Crisis Lifeline in the U.S.), and delivers an alert to the guardian’s in-app inbox. The Service also records continuous-use time to deliver break reminders to minors and notify guardians after extended sessions.

2.4 Technical and Usage Information

IP address, browser, device type, operating system, application version, language, time zone, approximate region, identifiers, pages and features used, session counts and active time, AI usage metrics (token counts, latency, model, quality ratings), errors, crash data, and security events. Cookies, local storage, SDK events, logs, and diagnostic information.

Product analytics are configured to exclude the content of tutoring conversations: raw AI prompts and responses are intentionally not logged to analytics systems. Behavioral analytics are disabled for child (under-13) sessions.

2.5 Billing and Transaction Information

Plan type, subscription and trial status, purchase channel, transaction identifiers, renewal status, currency, taxes, invoices, and payment status. Payment cards are processed by our payment provider (Stripe); IQnition does not store full payment-card numbers.

2.6 Communications and Support

Support requests, email, surveys, bug reports, attachments, and records of privacy, legal, or security requests.

3. Children’s Privacy (COPPA and Equivalent Canadian Requirements)

IQnition is designed for use by minors and takes children’s privacy obligations seriously.

Parental consent. A child under 13 can use the Service only after a guardian creates the family account, creates the child’s profile, and issues the child a device code. Account creation and profile setup by the guardian constitute the mechanism through which we obtain verifiable parental consent to the collection and use of the child’s information as described in this Notice. [Confirm final consent flow with counsel — see launch item M3.]

Limited collection. We collect from children only the information reasonably necessary to provide the study companion: the profile details their guardian supplies, their learning and study content, safety-screening records, and technical data needed to operate and secure the Service. Children are not asked for email addresses, phone numbers, precise location, or other contact details.

No advertising to children. We do not serve third-party advertising, do not use children’s information for targeted advertising or profiling for commercial purposes, and disable third-party behavioral analytics for child sessions.

Parental rights. A guardian may review the child’s information through the parent dashboard, request a copy of the child’s information, refuse further collection, or request deletion of the child’s profile and associated data at any time via account settings or support@iqnition.ai. If consent is withdrawn, the child’s access to the Service ends.

Guardian visibility. Guardians on the family account can see the child’s study activity, progress, quiz results, and safety alerts. Students and children are informed within the product that guardians can view this information.

Retention and third-party disclosure limits. Consistent with the FTC’s amended COPPA Rule (2025), IQnition retains children’s personal information only as long as reasonably necessary for the purposes collected (see Section 11), maintains a written children’s data retention policy, and does not disclose children’s personal information to third parties for their own purposes; disclosures are limited to service providers processing on IQnition’s behalf and the child’s own guardian.

4. AI Transparency and Youth Safety (California SB 243 and Similar Laws)

IQnition’s tutor is an AI chatbot, and IQnition complies with California’s companion chatbot law (SB 243, effective January 1, 2026) and similar AI-safety requirements for services used by minors:

• AI disclosure. The Service clearly and conspicuously discloses to all users — and by default to minors — that tutoring responses are artificially generated by an AI system and not by a human.
• Break reminders. Minor users receive a reminder to take a break after every three hours of continuous use, with a notification to the guardian.
• Self-harm and crisis protocols. The Service maintains protocols to detect indications of suicidal ideation or self-harm, prevent the AI from producing content encouraging self-harm, refer the user to crisis service providers (including the 988 Suicide & Crisis Lifeline), and alert the guardian.
• Content protections for minors. The Service maintains reasonable measures to prevent the AI from producing sexually explicit or otherwise age-inappropriate content to minors, and blocks such content in student input and AI output.
• Reporting. IQnition maintains the records of crisis-referral notifications and safety protocols needed to meet annual reporting obligations to California’s Office of Suicide Prevention beginning July 1, 2027.

The personal information generated or processed by these safety features is described in Section 2.3 and is used only for the safety, guardian-notification, and reporting purposes described in this Notice. Under California law (as amended by AB 1008), AI-generated output that identifies or is reasonably linkable to a user is treated as personal information and receives the same protections as other personal information under this Notice.

5. AI Processing and Model-Training Commitments

IQnition transmits student questions, tutoring context (including session memory), quiz-generation inputs, study-plan inputs, and (when the learner uploads one) images and syllabus documents to contracted AI providers to generate tutoring responses, quizzes, study plans, and structured extractions. IQnition uses a single AI aggregator sub-processor, OpenRouter.ai, which routes each request to a specific upstream model based on the learner’s grade band and the task: OpenAI GPT (via Microsoft Azure) for grades 3–8 tutoring, DeepSeek (via DeepInfra) for grades 9–12 and adult-learner tutoring, and Google Gemini (via Google Vertex) for any image or photo processing including syllabus scanning. All three upstream routes are US-hosted, and IQnition uses Zero Data Retention (ZDR) endpoints where the upstream provider offers them.

IQnition does not use identifiable student content — tutoring conversations, quiz responses, study plans, or profile data — to train general-purpose foundation models, and relies on contractual terms under which its AI providers do not use API-submitted data to train their models. A separate, affirmative, written opt-in from the guardian (or student 18+) would be required for any program involving identifiable content for training or evaluation.

IQnition may use de-identified or aggregated metrics (for example, token counts, latency, and quality ratings) to evaluate and improve quality, safety, cost, and educational effectiveness.

AI tutoring output is generated by a machine and may contain errors. The Service does not use AI to make legal or similarly significant automated decisions about students, such as admissions, grading of record, or eligibility determinations.

6. Sources of Information

We receive information directly from guardians and students; from guardians about their children; automatically from devices and use of the Service; from our payment provider regarding transaction status; and from service providers acting on our behalf. We do not purchase student data from data brokers.

7. Uses of Information

IQnition uses personal information to:

• provide, personalize, operate, host, and improve the Service, including generating tutoring responses, quizzes, study plans, session summaries, and progress reports;
• authenticate users, manage family accounts and child device codes, enforce plan entitlements, process payments and trials, and provide support;
• route content through contracted AI, hosting, and cloud providers to deliver requested features;
• operate youth-safety features: screen for self-harm, violence, and age-inappropriate content, display crisis resources, deliver guardian alerts and break reminders, and maintain records required for safety-law reporting;
• measure performance, reliability, usage, quality, safety, and feature adoption using privacy-protective analytics that exclude tutoring content;
• protect users and the Service, prevent fraud and abuse, investigate incidents, enforce agreements, and maintain audit logs;
• send transactional, security, billing, and service communications, and, where permitted and only to guardians and adult users, marketing communications;
• comply with law, respond to valid legal process, establish or defend claims, and meet accounting, tax, and recordkeeping obligations; and
• support financing, merger, acquisition, reorganization, or asset transfer subject to confidentiality and applicable law.

We do not use children’s personal information for marketing.

8. Disclosures and Service Providers

IQnition discloses personal information to contracted service providers for hosting and infrastructure (Railway), database, authentication, and storage (Supabase), AI inference (OpenRouter.ai as the aggregator sub-processor, routing to Microsoft Azure OpenAI, DeepInfra/DeepSeek, and Google Vertex/Gemini — see Section 5 for the routing detail), payments (Stripe), analytics and crash reporting (configured to exclude tutoring content and disabled for child sessions), email delivery, support, security, and professional services. Providers process information solely to perform services on our behalf and are contractually restricted from using it for other purposes.

Within a family account, student and child information (progress, activity, quiz results, safety alerts) is disclosed to the account’s guardian(s) as a core feature of the Service.

Information may be disclosed when reasonably necessary to comply with law or legal process; protect users, IQnition, or the public — including disclosure of safety-alert information to emergency services where there is risk of serious harm; investigate fraud or abuse; or enforce agreements.

Information may be disclosed under confidentiality protections in connection with a financing, merger, acquisition, bankruptcy, reorganization, sale of assets, or similar transaction. A successor must honor this Notice or provide required notice and choices before a material change.

9. No Sale or Cross-Context Behavioral Advertising

IQnition does not sell personal information for money or other valuable consideration and does not share personal information for cross-context behavioral advertising, as those terms are defined by applicable U.S. state privacy laws. This commitment applies to all users and is absolute for information about children and students.

IQnition does not use tutoring conversations, quiz data, study plans, or safety records for any third-party advertising. It may promote its own plans or features contextually within the Service to guardians and adult users.

If these practices change, IQnition will update this Notice and implement legally required opt-out or opt-in controls before the change applies.

10. Cookies and Analytics

IQnition uses necessary cookies and similar technologies for authentication, security, preferences, consent records, subscription status, and core functionality. Child device-code sessions use local storage on the device solely to maintain the child’s sign-in state.

Subject to consent requirements, we use limited analytics and diagnostics to understand feature use and reliability. Analytics are configured to exclude tutoring conversation content, student free-text input, and safety-alert content, and behavioral analytics are disabled for child sessions. Session replay tools, if used, must mask all student content.

Where required, non-essential technologies remain disabled until consent. Users may change choices through cookie settings or browser/device controls. IQnition will honor legally recognized opt-out preference signals (such as Global Privacy Control) where required.

11. Retention and Deletion

IQnition retains information only for the period reasonably necessary for the disclosed purpose, legal obligations, security, dispute resolution, and enforcement.

• Account, profile, and learning data are retained while the account is active. Guardians may delete a child profile, and any user may request account deletion, via account settings or support@iqnition.ai.
• Tutoring session content and session memory are retained to provide continuity of tutoring while the profile is active and are deleted or de-identified within [90] days of profile deletion. [Confirm retention periods.]
• Safety-alert records may be retained longer where required for statutory reporting obligations (for example, SB 243 annual reporting) or to protect users.
• Billing records are retained as required by tax and accounting law.
• Data for inactive child profiles is deleted or de-identified after [24] months of inactivity. [Confirm.]

Deletion from active systems may take time to propagate to encrypted backups. Backups are isolated from routine use and expire on the applicable schedule unless preservation is legally required.

12. Security

IQnition uses safeguards designed to protect personal information, including row-level security and least-privilege access controls in its database, role-based access, encryption in transit, appropriate encryption at rest, hashed storage of child device codes, secure authentication, logging, vendor review, incident response, and vulnerability management.

No method of transmission or storage is completely secure. Users should protect credentials and device codes and promptly report suspected compromise. IQnition will investigate incidents and provide notices required by law.

13. International Transfers

IQnition and its providers process information in the United States. For Canadian users, this means personal information is transferred to and stored in the United States, may be subject to lawful access by U.S. courts, law enforcement, and national-security authorities, and is protected by contractual and organizational safeguards with our service providers. By using the Service, Canadian users are informed of, and guardians consent to, this cross-border processing.

14. Privacy Rights

Depending on location and relationship to IQnition, individuals (and guardians on behalf of their children) may have rights to access, correct, delete, port, restrict, object, withdraw consent, or receive information about processing and disclosures.

Requests may be submitted through account settings or support@iqnition.ai. IQnition may verify identity and, for requests concerning a child or student on a family account, verify the requester’s guardian relationship. An authorized agent must provide legally sufficient authorization.

IQnition will acknowledge and respond to a verifiable privacy-rights request within the period required by applicable law — generally within 45 calendar days for requests under U.S. state privacy laws such as the California Consumer Privacy Act (extendable by an additional 45 days where reasonably necessary, with notice), and within 30 calendar days for access requests under Canadian law — unless a different period applies.

IQnition will not discriminate against anyone for exercising a privacy right. Some information may be exempt, and limited records may be retained where law permits or requires (for example, safety-alert and consent records). Where applicable, a denied request may be appealed by emailing support@iqnition.ai with “Privacy Appeal” in the subject line.

15. U.S. State Disclosures

If IQnition is subject to the California Consumer Privacy Act as amended, California residents may have rights to know, access, correct, delete, and obtain a portable copy of covered information; opt out of sale or sharing; and limit certain uses of sensitive personal information. IQnition does not sell or share personal information for cross-context behavioral advertising and does not knowingly do so for any consumer under 16.

Categories collected may include identifiers; customer records; commercial and subscription information; internet or electronic activity; audio, visual, and electronic information; education-related information; inferences related to learning progress; account credentials; and the contents of tutoring communications.

California student privacy (SOPIPA). Because IQnition is designed and marketed for K–12 study purposes, it honors the requirements of California’s Student Online Personal Information Protection Act: IQnition does not use covered student information for targeted advertising, does not build profiles of students for non-educational purposes, does not sell student information, and discloses it only as permitted (service providers, legal requirements, safety, and guardian access).

California AI laws. IQnition operates the minor-safety and AI-disclosure features required by California SB 243 as described in Section 4, and treats AI-generated data that is linkable to a user as personal information under the CCPA as amended by AB 1008. IQnition does not use a student’s personal information to train foundation models (Section 5).

Minors under other state laws. Residents of other states with comprehensive privacy or minors’ privacy laws may have similar rights. For all users known to be under 18, regardless of state, IQnition applies the following protections, consistent with laws such as the New York Child Data Protection Act, the Texas SCOPE Act, and state age-appropriate design laws (California, Maryland, Nebraska, Vermont): no sale of personal information; no targeted advertising; no processing beyond what is reasonably necessary to provide the Service and its safety features (or otherwise consented to by the guardian); default-high privacy settings; guardian tools to review, manage, and delete a minor’s information; and no design features intended to extend use — the Service instead delivers break reminders to minors.

IQnition does not use personal information for solely automated decisions producing legal or similarly significant effects. Where a state grants teens (for example, ages 13–17) the right to consent or object to certain processing, IQnition honors those rights for the teen or their guardian as applicable.

16. Canada

IQnition complies with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial private-sector privacy laws, including Quebec’s Law 25.

Canadian users (and guardians on behalf of children) may request access and correction, withdraw consent subject to legal and contractual limits, and challenge our compliance. Consent for the collection and use of a minor child’s information is obtained from the guardian as described in Section 3. Privacy inquiries and accountability requests for Canada may be directed to support@iqnition.ai. IQnition remains accountable for personal information transferred to service providers, including those outside Canada (see Section 13).

For Quebec users: IQnition’s person in charge of the protection of personal information can be reached at support@iqnition.ai. IQnition does not use personal information to make decisions based exclusively on automated processing that produce legal or similarly significant effects, and does not use biometric identification.

Users may complain to the Office of the Privacy Commissioner of Canada or the applicable provincial privacy regulator (for Quebec, the Commission d’accès à l’information).

17. Privacy Changes and Contact

IQnition may update this Notice as practices, law, vendors, or the Service change. Material changes will receive additional notice — and, for changes affecting children’s information, renewed guardian consent — where required.

Privacy contact for all regions, including Canada: support@iqnition.ai. Mailing address: Prompt Xchange LLC, 166 Geary St., Ste. 1500, #1668, San Francisco, CA 94108.

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