Transparency Notice

## Why This Notice Exists

This notice explains, in plain language, what information Multi-Headed Learning Engine
(MHLE) processes, why it is processed, when AI providers receive content, who may access the
information, and what choices are available. It supplements the controlling
[Privacy Policy](/privacy), institutional agreements, and the detailed
[Student Data Transparency Notice](/docs/legal/student-data-transparency).

## Information MHLE May Process

The categories depend on the account, role, age, organization, and features used.

| Category | Examples | Primary Purpose |
|---|---|---|
| Identity and account | Name, email, role, organization, date of birth, authentication records | Create and secure accounts; determine applicable age controls; provide role-based access |
| Educational content | Notes, documents, images, audio, courses, standards, assignments, instructor observations | Provide learning, classroom, portfolio, coaching, and analysis features |
| AI output | Analyses, summaries, embeddings, simulations, recommendations, assessments, generated materials | Return requested educational assistance and support retrieval or progress features |
| Institutional records | Classroom membership, enrollments, pacing guides, outcomes, LMS identifiers | Deliver organization, instructor, coach, and integration functions |
| Collaboration | Group messages, shared notes, playlists, public links, contribution records | Provide user-directed sharing and collaboration |
| Usage and diagnostics | Feature events, page activity, device/browser information, IP address, errors | Secure, operate, troubleshoot, and improve the service |
| Subscription records | Plan, Stripe identifiers, transaction and consent records | Administer subscriptions, invoices, and recurring-billing obligations |
| Privacy and compliance records | Consent, requests, audit events, complaints, retention or legal-hold state | Honor rights, document actions, and meet legal or contractual requirements |

## How Information Is Used

MHLE uses information to:

- Provide requested educational and administrative functions.
- Authenticate users and enforce permissions.
- Personalize presentation and AI assistance according to role or learning profile.
- Run requested AI analysis, generation, transcription, speech, embedding, and verification.
- Support instructors, coaches, parents, and institutions where authorized.
- Operate permitted sharing, study-group, portfolio, and public-link features.
- Process subscriptions and communicate service or account information.
- Prevent abuse, investigate incidents, test reliability, and restore service.
- Respond to privacy, legal, copyright, compliance, and customer-support requests.

## Artificial Intelligence Processing

When a user invokes an AI-enabled feature, MHLE may send the minimum content needed for that
operation to an AI provider. Depending on the feature, this may include note text, document
excerpts, audio, text to be spoken, instructor-entered observations, or a factual claim to
verify.

MHLE's current production policy is not to use customer or student content to train
general-purpose AI models. Provider API processing is different from model training. See the
[AI Transparency Statement](/trust/customer-assurance--ai-transparency-statement) and
[Data & Training Policy](/trust/customer-assurance--data-training-policy).

AI output may be inaccurate or incomplete. It is an assistive educational tool and should
not be the sole basis for grading, discipline, admissions, eligibility, or another
high-impact decision.

## Who May Receive or Access Information

Access may include:

- The user who created or received the information.
- Authorized instructors, coaches, parents, or organization administrators.
- Other users selected through group, sharing, playlist, portfolio, or public-link settings.
- MHLE personnel and contractors with a business need and appropriate authorization.
- Service providers needed for hosting, storage, caching, email, payments, integrations,
  support, security, or requested AI processing.
- Authorities or other parties when disclosure is required by law or needed to protect
  rights, safety, or service integrity.

The current service-provider categories are listed in the
[Subprocessor List](/trust/subprocessors).

## Student and Child Data

For institution-managed education records, MHLE processes data under the institution's
instructions and applicable agreement. A covered institution relying on FERPA's
school-official exception remains responsible for the conditions of that exception,
including direct control and permitted-use limitations.

For users identified as under 13, MHLE restricts account functionality until the applicable
parental, guardian, or school authorization process is completed. Parents may request access,
correction, or deletion through the institution or **contact details withheld pending approval**.

MHLE's published policies prohibit selling student data, using it for targeted advertising,
or using it to train general-purpose AI models.

## Retention and Deletion

Information is retained according to its purpose, account state, contract, legal
requirements, and the schedules described in the Privacy Policy and Student Data
Transparency Notice. Users and institutions may request deletion through applicable account
tools or **contact details withheld pending approval**. Some records may be retained when necessary for security,
fraud prevention, legal claims, statutory duties, or documented legal holds.

## Choices and Rights

Depending on the relationship and applicable law, users, parents, or customers may be able
to:

- Access or obtain a copy of information.
- Correct inaccurate information.
- Request deletion.
- Restrict optional sharing or visibility.
- Change communication preferences.
- Object to or opt out of certain processing where applicable.
- Contact the institution concerning education records.
- Ask MHLE how a specific AI or subprocessor flow operates.

MHLE may verify identity and authority before completing a request.

## Contact

- Privacy or rights requests: **contact details withheld pending approval**
- Institutional compliance: **contact details withheld pending approval**
- Security: **contact details withheld pending approval**
- Contracts: **contact details withheld pending approval**

## Review Note

This notice remains **Draft** pending legal review, reconciliation with contractual
retention terms, confirmation of contact inboxes, and leadership approval.