Multi-Headed Learning Engine (MHLE) — Georgia SDPAT Disclosure
This Student Data Transparency Notice ("Notice") describes how Multi-Headed Learning Engine (MHLE) collects, uses, shares, and protects student data when schools and districts contract with MHLE to provide educational technology services.
MHLE is an AI-powered cognitive learning platform that helps students take better notes, analyze their thinking, and build learning portfolios. When a school or district ("Institution") licenses MHLE, MHLE acts as a school official under FERPA and a school service contractor under Georgia SDPAT. That means we are legally required to protect student data, use it only for the purposes the school authorizes, and never sell or monetize it.
This notice is written in plain language so that parents, students, and administrators can understand exactly what data we handle and why.
MHLE collects four types of student data. We only collect what is necessary to run the platform and deliver the educational service.
Information students enter themselves when using MHLE.
| Data Element | What It Is | Why We Collect It |
|---|---|---|
| Name and email address | The student's display name and school email | Account creation and login |
| Research notes and written content | Text students type into the note editor | Core product feature — the notes are what MHLE analyzes |
| Uploaded documents and files | PDFs, images, or other files students attach to notes | Enables document-based analysis |
| Portfolio entries | Skills and achievements students choose to record | Building a learning portfolio |
| Student interests (middle school) | Topics a student selects during onboarding | Personalizing age-appropriate content |
Data the platform creates automatically as a student uses it.
| Data Element | What It Is | Why We Collect It |
|---|---|---|
| AI analysis results | The platform's multi-perspective analysis of a student's note | Core learning feature — helps students see multiple viewpoints |
| Rigor scores | An automatic score measuring depth of thinking in a note | Shown on the instructor dashboard to flag students who may need support |
| Gap analysis results | Identifies concepts a student has not yet addressed | Helps students self-direct their learning |
| Learning artifacts | Study plans, concept summaries, and synthesis documents generated from notes | Portfolio and study support |
| Health score | A composite measure of a student's recent engagement and note quality | Shown to instructors to trigger early-intervention alerts |
| Gamification data (middle school) | Points, tree stage, and activity milestones | Engagement and motivation for younger students |
| Brain state (middle school) | An emotional state check-in ("focused," "tired," etc.) entered before a Brain Break activity | Learning optimization; never used for disciplinary purposes |
| Exit-ticket responses (Weekly Learning Cycle) | A student's answers and score on a short end-of-lesson formative check, always tied to the student's account (never anonymous) | Shows instructors per-standard mastery so they can adjust instruction; visible only to the student's instructor and institution — never to other students. Collected only from students actively enrolled in an onboarded classroom; never collected on public share links |
Data created by teachers or administrators within MHLE.
| Data Element | What It Is | Why We Collect It |
|---|---|---|
| Instructor observations | Notes, ratings, and tags a teacher attaches to a student's record | Student monitoring and progress tracking |
| Instructor alerts | System-generated notifications sent to a teacher about a student | Flags students whose engagement drops below a threshold |
| Enrollment records | Which classroom a student is enrolled in, and their enrollment date | Institutional record-keeping and course access control |
Data about how a student interacts with the platform.
| Data Element | What It Is | Why We Collect It |
|---|---|---|
| Feature interaction logs | Which buttons a student clicks, which analyses they run | Platform improvement and support troubleshooting |
| Session metadata | Login timestamps and session duration | Security monitoring and usage reporting to the Institution |
| Analysis request history | A log of which AI analyses a student has requested | Helps track progress over time |
Each student can see their own notes, analysis results, gap analysis, and learning artifacts within the MHLE platform. Students cannot see other students' data.
Instructors enrolled in a classroom can see the notes, rigor scores, health scores, and engagement data for students enrolled in that classroom. School administrators designated by the Institution can access Institution-wide reporting. Access is strictly scoped — instructors cannot see data from classrooms they do not teach.
Parents who have completed the parental consent workflow can view their child's engagement data and contact the school. MHLE supports FERPA parental access rights on request through the Institution.
MHLE employees and contractors with a legitimate operational need (e.g., technical support, security incident response) may access student data. All such personnel are bound by confidentiality obligations. Access follows the principle of least privilege — we grant only the minimum access needed for the specific task.
When a student's note is analyzed, the content is transmitted to one or more AI providers to generate the analysis. These providers process data transiently under MHLE's instructions and do not retain it for their own purposes or for model training.
| Provider | Purpose | No Model Training |
|---|---|---|
| OpenAI, L.L.C. | Multi-perspective analysis, simulations | ✅ Confirmed |
| Anthropic, PBC | Learning artifact generation | ✅ Confirmed |
| Google LLC (Gemini) | Multimedia processing, transcription, epistemology tagging | ✅ Confirmed |
| Perplexity AI, Inc. | Fact verification (Weekly Pulse feature) | ✅ Confirmed |
| Provider | Purpose |
|---|---|
| Replit / Cloud Infrastructure | Application hosting and database hosting (US-East region) |
| Mailjet (Sinch) | Transactional email delivery |
| Stripe, Inc. | Payment processing (teacher/administrator accounts only; no student payment data collected) |
No student data is transferred outside the United States except for the transient API calls described above, all of which use US-based API endpoints.
Students (and parents of minor students) have the right to request a copy of the student data MHLE holds about them. Requests should be directed to the Institution, which will coordinate with MHLE.
If student data held by MHLE is inaccurate, students or parents may request a correction through the Institution.
Upon request from the Institution, MHLE will delete all student data associated with a student's account. Students who leave an Institution may also request deletion directly by contacting privacy@mhle.app with verification of their institutional affiliation.
Georgia SDPAT and FERPA allow Institutions to restrict data collection beyond what is needed for the core service. Institutions may contact MHLE to configure data minimization settings for their deployment.
For students identified as under 13 years of age, MHLE requires verified parental consent before the student account is activated. The consent workflow is initiated at registration and records the parent's email address, consent date, and IP address. No data is collected from a minor until consent is confirmed.
To exercise any of these rights:
| Data Category | How Long We Keep It | What Triggers Deletion |
|---|---|---|
| Student account and enrollment data | Duration of the Institution's active contract, plus up to 30 days after contract end | Institution contract termination or deletion request |
| Notes, analysis results, and artifacts | Duration of active enrollment, plus 30 days after account deactivation | Student account deletion or Institution data deletion request |
| Instructor observations and alerts | Duration of the active classroom term, plus 30 days | Classroom deletion or Institution data deletion request |
| Exit-ticket responses (formative assessment records) | Duration of the Institution's active contract, plus up to 30 days after contract end | Institution data deletion request (included in the standard deletion flow and Certificate of Deletion counts) or contract termination |
| Usage logs (session metadata, click logs) | 12 months from collection date | Automatic rolling deletion |
| Security and audit logs | 24 months (required for security incident investigation) | Automatic rolling deletion |
| Parental consent records | Duration of student's account, plus 3 years (regulatory compliance record) | Upon legal retention period expiry |
Upon contract termination, MHLE will:
Institutions may request a data export before termination in JSON or CSV format. Export requests must be submitted at least 15 business days before the scheduled end date.
| Domain | Safeguard |
|---|---|
| Encryption in transit | All data moving between students' browsers and MHLE servers is encrypted with TLS 1.2 or higher. |
| Encryption at rest | All student data stored in MHLE's database is encrypted at rest using AES-256. |
| Access controls | Role-based access control (RBAC) ensures that only authorized personnel can access student data. Access is reviewed quarterly. |
| Authentication | JWT-based session authentication; bcrypt password hashing; multi-factor authentication available for institutional administrators. |
| Audit logging | All access to student data is logged with a timestamp and actor identity. Logs are immutable. |
| Vulnerability management | Automated dependency scanning and static code analysis run on every production deployment. Critical vulnerabilities are patched within 24 hours. |
| Penetration testing | Annual third-party penetration testing; findings remediated within 30 days for critical/high severity. |
| Breach notification | In the event of a confirmed data breach affecting student data, MHLE will notify the Institution within 72 hours of confirmation. |
| Infrastructure isolation | Production, staging, and development environments are fully isolated. No student data is present in non-production environments. |
Full details are available in the MHLE Security Questionnaire and Data Processing Agreement, available to Institutions upon request at compliance@mhle.app.
| Privacy and Compliance | privacy@mhle.app — response within 30 calendar days for rights requests; within 72 hours for breach notifications |
| Security Inquiries | security@mhle.app |
| Legal and Contract Inquiries | legal@mhle.app |
If you believe MHLE has handled student data in a way that violates this Notice, Georgia SDPAT, or FERPA, you may:
MHLE will update this Notice when our data practices change in a material way. We will:
/docs/legal/student-data-transparency at least 30 days before any material changes take effect.Continued use of MHLE by an Institution after the effective date of a material change constitutes acceptance of the updated Notice, unless the Institution objects in writing before the effective date.
| Version | Effective Date | Summary |
|---|---|---|
| 1.0 | July 1, 2026 | Initial release. Covers data categories, permitted/prohibited uses, data subject rights, retention schedule, security measures, and contact information. Drafted to comply with Georgia SDPAT and FERPA. |