Privacy Policy - Multi-Headed Learning Engine

1. Introduction

Multi-Headed Learning Engine ("MHLE," "we," "us," or "our") is operated by Cognitive Engine, Inc. We are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service.

Please read this Privacy Policy carefully. By using the Service, you consent to the collection and use of information in accordance with this policy. The privacy contact for all matters in this policy is privacy@mhle.app.

2. Information We Collect

2.1 Information You Provide

Account Information: Email address, password (hashed), and profile details
Content: Notes, courses, uploaded documents (PDFs, images, audio), and other materials you submit
Payment Information: Billing details processed through Stripe (we do not store full credit card numbers)
Communications: Feedback, support requests, and correspondence with us

2.2 Information Collected Automatically

Usage Data: Features used, actions taken, timestamps, and session information
Device Information: Browser type, operating system, device identifiers
Log Data: IP address, access times, pages viewed, and referring URLs
UTM and Referral Attribution: Only after you affirmatively allow optional browser analytics, we record UTM parameters (utm_source, utm_medium, utm_campaign, utm_content, utm_term) and referral codes with a browser visitor ID. You can withdraw that choice at any time; withdrawal deletes the browser identifier and its anonymous attribution history. We do not link pre-consent browsing to an account or share individual attribution records with partners — see §6.4 for details.

2.3 Information from Third Parties

Authentication providers if you sign in through third-party services (e.g., Google OAuth)
Payment status from Stripe
LMS course context, user identity, and role information when you access MHLE via an LTI 1.3 launch from a connected Learning Management System (see §6.5)
Google Classroom course and roster information when an instructor connects their Classroom account (see §6.6)

3. Third-Party AI Processing

IMPORTANT DISCLOSURE: To provide our AI-powered features, we transmit your content to third-party AI service providers. The providers we currently use, and what each is used for, are:

Provider	What we use it for	Their Privacy Policy
OpenAI, L.L.C.	Multi-perspective note analysis, wicked-problem simulations, general text generation	openai.com/privacy
Anthropic, PBC	Learning artifact generation (study plans, concept summaries, synthesis documents)	anthropic.com/legal/privacy
Google LLC (Gemini)	Multimedia analysis, audio transcription, image processing, epistemology tagging	policies.google.com/privacy
Perplexity AI, Inc.	Internet-grounded fact verification (Weekly Pulse feature)	perplexity.ai privacy

When your content is processed by any of these providers:

It is transmitted securely via encrypted connections
Your content is not used to train our models or provider models through our production API use, subject to the providers' applicable API and retention terms
For administrative retention and email-copy workflows, we send only minimized aggregate account activity; direct identifiers, note titles, course titles, and learning content are excluded from those prompts
Third-party providers may retain data temporarily for processing and abuse prevention per their own policies

4. How We Use Your Information

We use collected information to:

Provide, maintain, and improve the Service
Process your content through AI analysis features
Manage your account and subscription
Send transactional emails (account verification, password reset, billing)
Respond to support requests and communications
Monitor and analyze usage patterns to improve features
Detect, prevent, and address technical issues and abuse
Measure marketing effectiveness and calculate partner/ambassador commissions using UTM and referral attribution data
Comply with legal obligations

5. Data Retention

Account Data: Retained while your account is active and for 18 months after your subscription ends or account becomes inactive, for backup, legal compliance, and potential dispute resolution purposes.

Content: Your notes, courses, and uploaded materials are retained until you delete them or close your account. After account closure, content is retained for the 18-month retention period, after which you may request export within 30 days of account termination.

AI Processing: Content sent to AI providers is processed in real-time and not permanently stored by us after processing is complete.

Usage Logs: Retained for up to 12 months for analytics and security purposes.

Legal Holds: In the event of pending litigation, legal disputes, or regulatory investigations, we may retain your data beyond the standard retention period until the matter is resolved, as required by law.

6. Data Sharing and Disclosure

We may share your information as described below. We do NOT sell your personal information to third parties.

6.1 Third-Party Processors

We share data with the following categories of service providers to operate the Service:

Provider / Category	Function	What they receive
AI Providers (OpenAI, Anthropic, Google, Perplexity)	Content analysis and generation (see §3)	Note content, uploaded documents; no payment or billing data
Stripe, Inc.	Payment processing and subscription management	Billing information; no note content or AI outputs. Stripe Privacy
Replit / Cloud Infrastructure	Application hosting, database hosting, compute (US-East region)	All application data stored in our database and file storage
Mailjet (Sinch)	Transactional email delivery (account verification, password reset, billing, consent emails)	Recipient email address and email content. Mailjet Privacy

6.2 Legal Requirements and Business Transfers

Legal Requirements: When required by law, court order, or governmental authority
Business Transfers: In connection with a merger, acquisition, or sale of assets, your data may be transferred to the successor entity subject to the same privacy protections

6.3 Study Groups and Social Features

If you participate in a study group or social learning feature within MHLE:

Other members of your group can see content you post or share within that group (notes, comments, and shared artifacts)
Group chat messages are stored in our database and are accessible to all current group members
Instructors or administrators designated as group admins can view group content and member activity within the group
Your display name and profile are visible to other group members; your email address is not shared
Leaving a group does not automatically delete messages or content you previously posted

6.4 Partner and Referral Attribution

MHLE operates a partner and ambassador referral program. When you sign up via a referral or partner link:

We record the UTM parameters and referral code from your signup link and store them in your account record
This attribution is used to calculate commissions or credit owed to the referring partner or ambassador under their Ambassador Agreement
We share only aggregate or anonymized conversion data with partners — for example, "your referral link generated 12 new signups this month." We do not share your name, email address, or any individual personal data with partners
Partners receive no information about your learning activity, content, or subscription details beyond the existence of a conversion event

6.5 LTI and LMS Data Sharing

MHLE supports LTI 1.3 integration with Learning Management Systems (LMS) such as Canvas, Blackboard, Moodle, and others. When your institution connects an LMS to MHLE:

Data received from the LMS at launch: your name, email address, LMS user ID, course context (course name and ID), and your role in the course (student or instructor)
Grade passback: If an instructor configures grade passback, MHLE will transmit grade or completion data for specific assignments back to the LMS on the instructor's behalf
Data controller relationship: Your institution is the data controller for education records exchanged via LTI. MHLE acts as a processor on the institution's instructions. The institution's own privacy policies and FERPA obligations govern the LMS-side data
Connecting an LMS is an administrator or instructor action; students cannot initiate or modify LTI connections
For institutional customers, the Data Processing Agreement at /docs/legal/dpa governs this data exchange

6.6 Google Classroom Integration

Instructors may connect MHLE to Google Classroom. When connected:

MHLE reads course names, enrolled student email addresses, and assignment information from Google Classroom via the Google Classroom API, solely to provision classrooms and enrollments in MHLE
MHLE may write back assignment completion or grade data to Google Classroom if an instructor enables this feature
This integration is subject to Google's privacy policy and your institution's Google Workspace terms
Instructors may disconnect the integration at any time from the MHLE integration settings panel

6.7 Public Share Links and Portfolios

MHLE allows you to publish content via a public share link. When you activate a share link:

The linked content (notes, artifacts, or portfolio entries) becomes accessible to anyone who has the link, without requiring authentication
Shared pages are marked noindex so they are not indexed by search engines, but they are technically public — anyone with the link can view the content
You control which content is shared and can revoke a share link at any time from your settings; after revocation, the link immediately becomes inaccessible
You are responsible for ensuring that content you share via a public link does not violate FERPA, copyright, or any other legal obligation
MHLE does not display your email address or account details on public share pages

6.8 Parent Portal Access

A verified parent or guardian of a minor student may access the MHLE Parent Portal. Through the portal, a verified parent can see:

Their child's account profile (display name, enrollment status)
Summary engagement data (recent activity, learning health score, streak information)
Enrollment in classrooms and study groups
Parental consent records associated with the account

Parent portal access is scoped strictly to the child's own account. Parents cannot view other students' data. Access is granted only after the parental consent workflow is completed and the parent's identity is verified. Parents can contact privacy@mhle.app to request FERPA-compliant access to the full education record for their child.

7. Data Security

We implement appropriate technical and organizational measures to protect your data, including:

Encryption of data in transit (TLS 1.2+)
Encryption of data at rest (AES-256)
Secure password hashing (bcrypt)
Role-based access controls and authentication
Regular security assessments and automated vulnerability scanning
Annual third-party penetration testing

However, no method of transmission or storage is 100% secure. We cannot guarantee absolute security.

Breach Notification: In the event of a confirmed data breach that poses a material risk to your rights, we will notify affected users within 72 hours of confirming the breach for high-severity incidents. For institutional customers, breach notification obligations are further specified in the Data Processing Agreement.

8. Your Rights and Choices

Depending on your location, you may have the following rights:

All Users:

Access: Request a copy of your personal data
Correction: Update or correct inaccurate information
Deletion: Request deletion of your account and associated data
Export: Download your content in a portable format (within 30 days of account termination)

GDPR Rights (EU/EEA Users):

Right to restrict processing
Right to data portability
Right to object to processing
Right to withdraw consent
Right to lodge a complaint with a supervisory authority

CCPA Rights (California Users):

Right to know what personal information is collected
Right to delete personal information
Right to opt-out of sale of personal information (we do not sell data)
Right to non-discrimination for exercising privacy rights

To exercise these rights, contact us at privacy@mhle.app

9. Cookies and Tracking Technologies

We use the following cookies and tracking technologies when you use the Service:

Session Cookie (session): A temporary cookie that keeps you logged in while your browser is open. It is deleted when you close your browser.
Authentication Token (auth_token): A JSON Web Token (JWT) stored as a cookie that identifies your account on return visits. It expires after 24 hours and is required to access protected pages.
Visitor Tracking Cookie (visitor_id): An optional unique ID set only after you affirmatively allow browser analytics. We use it to understand how visitors find and navigate our site. If you later withdraw consent, we remove the identifier and erase its anonymous attribution history; pre-consent browsing is never linked to your account.

No third-party advertising cookies: We do not use any cookies from ad networks, social media trackers, or cross-site tracking services.

10. Automated Profiling and Behavioral Monitoring

Added in Version 2.0 — July 26, 2026

MHLE uses automated systems to analyze your learning activity while you use the Service. This section explains each system in plain language so you understand what is collected and why.

10.1 Learning Health Score

Our system automatically calculates a "Learning Health Score" (0–100) for each enrolled student every day. The score is based on four things we count automatically: how many notes you have written (up to 20 points), how many times you have used AI analysis features (up to 30 points), how recently you were active (up to 25 points), and the results of your gap analysis (up to 25 points). The score is grouped into three color bands — Emerald (80–100), Amber (50–79), and Rose (0–49).

This score is visible to your enrolled instructors and organization administrators so they can identify students who may need support.

What this means for you: Your instructors can see a daily number summarizing how engaged you are — they use it to decide who to check in with, not to grade you.

10.2 Friction Detection

MHLE automatically watches for three patterns in your usage that suggest you may be stuck or confused: (1) loading the same page three or more times in four hours without taking any action, (2) creating a note but not running an AI analysis within 60 minutes, and (3) bouncing off a feature page in under 30 seconds three or more times in a week. When a pattern is detected, an internal "friction alert" is created and shown to administrators so they can offer help.

What this means for you: If you appear stuck, the system flags it for your support team — the goal is to get you help faster, not to penalize you.

10.3 AI Analysis of Instructor Observations

When an instructor writes an observation about you (for example, in an org classroom), that text may be sent to a third-party AI provider (OpenAI, Anthropic, or Google Gemini) to generate a structured summary, suggested next steps, or impact scores. The analysis is used to help instructors track student progress more consistently. The same third-party AI protections from Section 3 apply: your data is not used to train AI models.

What this means for you: Notes your instructor writes about you may be automatically summarized by AI to help them support you more effectively.

10.4 Cross-Session Visitor Tracking

As described in Section 9, we set a visitor_id cookie before you create an account. This ID is stored in our database and linked to your page views, the marketing content you read, and the traffic source that brought you to the site (for example, a Google search or a referral link). When you sign up, we connect your pre-signup browsing history to your new account. We use this data to measure how well our marketing is working and to improve our onboarding experience.

What this means for you: We remember what you looked at before you created an account, and we tie that history to your account when you sign up.

10.5 Middle School Brain State Collection

For students using the Middle School (ms_early / ms_late) persona, our learning engine may collect self-reported emotional and focus states — such as how energized or distracted a student feels before a learning session. This data is used only to personalize the learning experience for that student in real time and to surface aggregate trends to educators (no individual student is identified in aggregate reports). Middle school accounts require parental or guardian consent before this data is collected (see Section 2 and the parental consent process at registration).

What this means for you: Middle school students may be asked how they feel before a session, and that answer influences what content they see — parents or guardians must approve this before it starts.

11. Automated Decision-Making

Added in Version 2.0 — July 26, 2026

Some of MHLE's features use automated analysis to surface recommendations, alerts, or scores (as described in Section 10). It is important to understand the limits of this automation:

Automated systems assist instructors — they do not replace human judgment. No automated score or alert by itself determines a grade, an enrollment decision, or any other consequential outcome. All such decisions are made by human instructors or administrators who review automated data alongside other information.
You can ask about automated data. If you believe an automated score or flag about you is incorrect, you may contact us at privacy@mhle.app to request a review.
Scores are advisory. The Learning Health Score and friction alerts are tools to prompt a conversation — they are not permanent records of your academic performance.

12. Children's Privacy, FERPA, and State Education Laws

COPPA (Children Under 13)

MHLE supports accounts for users under 13 in compliance with the Children's Online Privacy Protection Act (COPPA). Before a child's account becomes active, a parent or legal guardian must provide verifiable parental consent by clicking a time-limited link sent to the parent email address supplied at registration. The child's account remains in a pending state — and cannot create notes, upload files, or use AI features — until that consent is verified.

What we collect from children

Display name and date of birth (used only to determine COPPA applicability)
Study notes, uploaded documents, and audio recordings
Emotional energy / brain state (ms_last_brain_state) — a self-reported label (e.g., "focused", "tired") selected before each study session. Used only to adjust AI pacing and tone; never used for marketing.
Learning interests (ms_interests) — subject tags chosen during onboarding. Used only to suggest relevant study content; never shared with advertisers.
Usage events (features used) for service improvement
IP address at registration and standard server logs

We do not sell, share, or use children's data for advertising or commercial profiling. Emotional-state and interest data is stored in isolated database columns and is never included in any third-party analytics export.

Parent and guardian rights

Review: Request a copy of all personal information collected about your child — email privacy@mhle.app with subject "COPPA Review Request".
Delete: Request deletion of your child's account and all associated data — email the same address with subject "COPPA Deletion Request".
Refuse or withdraw consent: You may withdraw consent at any time by contacting us; this will deactivate the child's account.

For the complete COPPA disclosure, visit /legal/coppa-disclosure. The registered operator of MHLE for COPPA purposes is Cognitive Engine, Inc.

FERPA (Educational Institutions)

When MHLE is contracted by a school or district, MHLE acts as a "school official" with a legitimate educational interest under FERPA (20 U.S.C. § 1232g). In this context:

The institution is the data controller for student education records; MHLE processes those records only on the institution's behalf and instructions
MHLE does not re-disclose education records except as permitted by FERPA
Students and parents may exercise FERPA rights through their institution's FERPA officer or by contacting privacy@mhle.app

See also the Student Data Transparency Notice for a full plain-language description of student data handling.

Georgia SDPAT and Other State Education Privacy Laws

MHLE complies with the Georgia Student Data Privacy, Accessibility, and Transparency Act (O.C.G.A. § 20-2-666 et seq.) for institutions operating under Georgia state law. MHLE also monitors and works to comply with applicable student privacy laws in other states where we operate. For Georgia-specific disclosures, see the Student Data Transparency Notice at /docs/legal/student-data-transparency.

13. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States. All data at rest is stored in US-East region infrastructure. For transfers from the EEA or UK, we rely on Standard Contractual Clauses (SCCs) as described in our Data Processing Agreement. By using the Service, you consent to the transfer of your information to these countries.

14. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email or by posting a notice on the Service. For paid or institutional accounts, we will provide at least 30 days' advance notice of material changes by email. Your continued use of the Service after changes take effect constitutes acceptance of the updated policy.

15. Contact Us

For questions about this Privacy Policy or to exercise your rights, contact us at:

Privacy: privacy@mhle.app
Support: support@mhle.app
Compliance / Institutional inquiries: compliance@mhle.app
Legal: legal@mhle.app