Your data, accountable.

Who we are

The controller of your data.

Counsolero is operated by Counsolero LLC, a California limited liability company with its registered business address at 2018 N St STE N, Sacramento, CA 95816. For purposes of the EU/UK GDPR, the California Consumer Privacy Act ("CCPA"), and other applicable privacy laws, Counsolero LLC is the controller (or "business") responsible for the personal information described in this policy.

For any privacy question, data subject request, or formal complaint, email [email protected]. The Contact page lists our other channels and the path to escalate to a supervisory authority if you are not satisfied with our response.

U.S.-only service. Counsolero is operated from California for U.S.-based students. We do not target, market to, or knowingly accept users from outside the United States. If you are accessing the service from outside the U.S., you do so on your own initiative; see §7 for what that means for your data.

What we collect

What data Counsolero collects.

We collect data tied to your account in five thematic categories. Where noted, specific fields are encrypted individually in our database (field-level encryption); §5 sets out exactly what that does and does not cover.

• Account & identity — your email address (via Clerk), your name if you provide it, your role and account-state flags (school-admin status, sponsored-school link, deletion timestamps, legal-hold flag if applicable). Your name is stored encrypted only. Your email address is held by our sign-in provider, Clerk; in our own database it has been stored encrypted only since 4 November 2026, with a keyed hash used to find your account when you sign in (see §5).
• Academic data — your courses, enrollments, grades (including letter grades and grading-period scores), assignments, your instructors' feedback on your own submissions, course syllabi and calendars, your Canvas to-do list, and uploaded files synced from Canvas with your OAuth consent (detailed in §8), plus any classes, assignments, or grades you enter manually. File content, instructor feedback, rubric assessments, all grades and scores (letter grades, numeric scores and percentages, and grading-period scores on assignments, courses and transcripts), enrollment status, and Canvas course content such as course names, assignment text, announcements, pages and file names are encrypted at rest (see §5).
• AI features — your conversations with the AI counselor, the AI memory built from your course content, AI memory notes about how you study (short preferences you share in chat — see §9), any study resources (quizzes, flashcards, study guides) you keep, and per-call usage metadata (timestamp, provider, model, tokens, cost, latency, success/error). Conversation text, AI-memory passages and AI memory notes are encrypted at rest.
• Sessions & security — session metadata (IP address, user-agent, pages visited, duration), per-event interaction logs, security audit events (logins, deletion requests, token changes), and consent records.
• Payments — for school-sponsored or paid plans only: subscription status, consent record, and Stripe identifiers (subscription, item, invoice). Card numbers never reach our database — Stripe handles them.

Joining the waitlist (before you have an account)

You can join our waitlist without creating an account. Waitlist entries are the main data we hold about someone who is not a user, so they sit outside the five categories above and we describe them separately here. We also hold limited data about other people who are not users: your instructors' names, which Canvas supplies with each course, and, when instructor-feedback sync is on, the Canvas user ID and role (teacher or TA) of each of your instructors and teaching assistants (see §8); the email addresses of people a school administrator invites to be an administrator; and, where a college has turned on the Canvas directory feature, class rosters that can include students who have not created an account (see College-authorized Canvas directories below).

• What you give us — your name and email address, your school or institution, what you are studying, and optionally your education level, expected graduation year, your role (student, teacher, administrator, parent), how you heard about us, and anything else you choose to type in the free-text box. Only name, email, school, and field of study are required. Name and email are encrypted at rest.
• What we record automatically — a one-way hash of your IP address and a truncated browser user-agent string, kept solely to stop automated abuse of the form. The waitlist entry itself never holds your IP address in readable form. Separately, and like any visitor to the site, if requests from your address trip our abuse-prevention limits, that address can appear in readable form in our security logs and, if a temporary block is applied, in the blocklist entry until the block is lifted. Those are site-wide security records, described under Sessions & security above and in §4, not part of your waitlist entry.
• What we do with it — email you a confirmation, tell you when a place opens up, and understand which schools and fields of study we should support first. Nothing else.

We do not sell this data, share it for advertising, use it to profile students, or use it to train AI models. It is not sent to any AI provider. Marketing email about the launch is a separate, unticked opt-in on the form, and every message carries an unsubscribe link.

Joining the waitlist does not create an account, and it does not give us access to any Canvas, school, or academic data — there is nothing to connect until you sign up. To be taken off the waitlist at any time, email [email protected]; see §11.

What we have access to but do not store

The Canvas OAuth scopes you authorize technically permit broader access than we use. We deliberately do not persist other students' content (including peer-review comments other students leave on your work), discussion replies, individual quiz questions or your quiz answers, Canvas Inbox messages, your Canvas activity stream, calendar events from outside your courses (such as your personal Canvas calendar), or your Canvas profile photo. If a future feature would require persisting any additional Canvas surface, we will update this policy in advance (see §15).

Optional personal calendars

If you connect Google Calendar or iCloud Calendar, we read events from the calendars you select, including titles, dates, notes, and locations, to display your schedule. These details can include sensitive information you or an event organizer entered. Google uses its authorization screen; iCloud uses an Apple app-specific password, which we store encrypted with a separate credential key. You can disconnect at any time, which removes the stored credentials. Your events remain with their original provider.

Editing is optional. When enabled, you can create, edit, or delete events in selected calendars from Counsolero. Changes are sent to Google or Apple, and existing guests may receive update or cancellation notifications. A separate AI opt-in allows selected personal calendar details to be sent to our AI provider when you ask about your schedule. AI changes are proposals that need your approval before they are applied. The exception is Auto mode, which is off unless you turn it on. With Auto on, the assistant can create or update entries on your Counsolero calendar without asking. It never does this on a connected Google or Apple calendar. Proposals expire after 15 minutes; their text is encrypted, cleared after a successful change, and expired rows are removed by the daily cleanup. Calendar content is not added to the academic search index. Google event snapshots may be cached for up to 60 seconds; the production cache encrypts these values. Counsolero entries and connection preferences are included in your data export, and account deletion removes the associated records.

Sensitive personal information

Under California's CCPA/CPRA, "sensitive personal information" covers a specific list of categories. The ones we collect are: account credentials (handled by Clerk), contents of communications (your AI chat history and any course content you upload or that we sync from Canvas), and education information (your academic records, which also constitute "education records" under FERPA). We do not collect precise geolocation, biometric or genetic data, government-issued identifiers (SSN, driver's license, passport), or payment-card numbers. We do not ask for health information, racial or ethnic origin, religious beliefs, union membership, or sexual-orientation data, but you may choose to include such details in chats or calendar entries, or they may appear in events synced from a calendar you connect, and they are then handled like the rest of that content. We use sensitive personal information only as necessary to provide the service — you have the right to limit our use of it (see §12).

Sources

We collect personal information directly from you, from third parties at your direction (Canvas, operated by Instructure, Inc., via the read-only OAuth access you authorize — Canvas is the source of your academic data, not a sub-processor that handles data for us; Clerk for authentication; Stripe if you subscribe), and automatically from your device (IP address, user-agent, and similar request metadata). We also collect it directly from you if you join our waitlist before creating an account (see above).

Purposes

Why we use it.

We use your information to:

• Provide the service — display your academic data, power AI study tools, run degree planning, authenticate you
• Process payments and manage subscriptions where you have one
• Protect the service and other users — investigate abuse, detect fraud, maintain the security audit log
• Meet legal and regulatory obligations — respond to lawful requests, and keep consent and AI-disclosure records so that you and your school can audit what we did with your records (FERPA's disclosure record-keeping duty belongs to schools; our records support it)
• Improve and operate the platform — fix bugs, debug issues, plan capacity
• Communicate with you — service notices, security alerts, account-deletion undo links, material policy changes

Where GDPR applies, our legal bases are performance of contract for service-delivery purposes, legitimate interest for security and operations, and legal obligation for compliance retention. We do not process your information for advertising or for any commercial purpose outside the list above.

Retention

How long we keep it.

• Active account data — academic data, chat history, AI memory, study resources, uploaded files, preferences, session activity, Canvas connection: cascade-deleted when your account is hard-deleted after a 14-day grace period
• School-sponsored accounts — if your sponsoring school asks us to end its students' use, an account that is still sponsored 30 days after our email to you is permanently deleted with its data (see Section 6)
• AI memory notes — deleted automatically when a note has not been used for 180 days, when you delete it (or all of them) in Settings → Memory, and with your account. Deleting a conversation does not delete notes saved from it. When the assistant updates a note, you can undo the change for 24 hours; the earlier wording kept for Undo is deleted within 2 days
• Consent records — kept permanently as proof of what you agreed to and as a record you or your school can audit. When your account is hard-deleted, the link to your account is removed. The record keeps the IP address and browser details from when you agreed. A second consent log keeps the email address you used when you agreed.
• Security audit log — retained under a declared policy of up to 3 years for FERPA-relevant actions (e.g. Canvas connect/disconnect, deletion requests, consent, file downloads, chat access) and up to 1 year for other actions, then purged. Entries record the IP address and browser user-agent of the request. When your account is hard-deleted, the link to your account is removed. The IP address and browser details stay until the entry is purged.
• AI interaction metadata — retained under a declared policy of up to 395 days (about 13 months) as a record of disclosures that you or your school can audit (timestamp, provider, model, tokens, cost, latency, success), then purged. Prompt and response text are scrubbed immediately; personal identifiers are removed if your account is hard-deleted before the window elapses
• Payment records — retained as required by tax and accounting law (typically 7 years in the United States); Stripe retains its own copy under its own retention policy
• AI retrieval traces — query text is hashed (not stored in plaintext) and traces are auto-purged after 30 days
• AI retrieval-quality logs — passage references, relevance scores and token counts, with no query text; retained up to 395 days (about 13 months), then purged
• AI memory index — the searchable passages built from your course content are deleted with your account; entries not updated for 730 days (24 months) are also purged by a weekly job
• AI usage counters — the number of AI requests you make each day (no prompt or response text); retained 180 days, then purged
• Login sessions — your signed-in session expires after 14 days without activity. The IP address and user-agent we log for security events follow the security audit log schedule above
• Waitlist entries — kept until you create an account or ask to be removed, or 24 months, whichever comes first, then deleted. This runs as a scheduled purge, not on request only

After hard-deletion, the retained rows above no longer link to your account. Some still hold an IP address, browser details or an email address, and those could identify you. They exist only to prove to auditors that we behaved correctly while your account was active.

Backups. We keep encrypted database backups so we can restore the service after a failure. Deleted data may persist in those encrypted backups for up to 44 days after you ask us to delete your account (the 14-day grace period plus up to 30 days of backup retention) before it is overwritten. We use backups only to restore the service.

Security

How we protect it.

We use industry-standard technical and organizational measures: TLS encryption in transit, HttpOnly and Secure session cookies, CSRF protection, application-level audit logging of security-relevant events, and Content Security Policy plus HSTS in production.

What is encrypted at rest. We encrypt these individually, with keys kept separate from the data, before they are written (field-level encryption): Canvas OAuth tokens, file content, instructor feedback and rubric assessments, all grades and scores (letter grades, numeric scores and percentages, and grading-period scores on assignments, courses and transcripts), enrollment status, Canvas course content (course names, codes and descriptions; assignment, quiz, announcement and discussion text; pages, modules and syllabi; rubric text; file and folder names), your sign-in email address, your name, your student ID, study topics and their scores, profile and planning notes, notifications, the IP address and browser details in our security logs, the names of files you upload, your study preferences, AI conversations, AI memory, AI memory notes, study resources, chat titles, calendar entry titles and notes, connected-calendar credentials, the email address on consent records, and waitlist names and emails. For some identifiers, such as your sign-in email address, your student ID, consent-record, waitlist and school-administrator-invitation emails, we look records up with a keyed hash (a blind index) so the readable value need not be stored for the lookup. Readable copies of the fields we began encrypting on 3 and 4 November 2026 were removed from the live database on those days; compaction of the database files and the expiry of backups taken before then (within 30 days) complete the removal.

What is not. A few values stay readable because our database has to match on them: your Canvas user number, the term on your transcript records, the assignment-group label of each assignment, web addresses (URLs), and file sizes and types. If your college uses the learning-support workspace, a daily copy of your course score is kept for it. Usage metadata and some other technical fields are not field-encrypted either. The search vectors that support AI memory cannot be encrypted and still be searched; since 4 November 2026 they are protected by a separate per-student key that makes them much harder to reverse, but this is not encryption. These values rely on disk-level encryption provided by our hosting provider. Disk-level encryption protects against loss of a physical disk or a stored snapshot; it does not protect against someone who has access to the running database. Field-level encryption protects a copy of the database; because our application holds the keys, it does not protect against someone who takes control of the running application.

No security control is perfect. If you believe you have observed a security incident, report it to [email protected]. Our breach-notification commitments are in §14.

Sub-processors

Who we share it with.

We use the following sub-processors. Counsolero LLC has not negotiated bespoke contracts with any of them; instead, each vendor's own published terms of service and data-protection commitments apply to our use of their service, the same as they apply to every customer who signs up. We do not share your information with any other third party except as described in this policy or as required by law. Canvas is not on this list because it is the source of your academic data rather than a service that handles data for us; see Sources in §2.

• Clerk: authentication. It receives your email address, your name if you give it, and your password or your Google or Microsoft sign-in. It manages your session. If you choose Google or Microsoft to sign in, that provider also learns that you signed in to Counsolero.
• Azure OpenAI — the AI provider serving all of Counsolero's production traffic today. Google Vertex AI is integrated in our code but is not active in production and receives no data. Both publish terms committing not to use customer inputs to train their models (see §9). Microsoft's default abuse monitoring applies. If its checks flag a request, authorized Microsoft staff can review the prompt and response.
• Stripe — payment processing (paid plans only); receives the payment information you enter when subscribing
• Resend — transactional email; receives your email address and the content of service emails we send you
• Sentry — error telemetry; receives application error events — the error type and message, the URL where the error occurred, and a stack trace. We remove email addresses, cookies, authentication headers, request bodies and message content from error events before they are sent. We also remove fields that hold names and grades. This is not perfect. Error text could still contain a short value such as a name. Error events may include internal numeric identifiers (such as user and record IDs). Security-alert events about suspected abuse can also include the IP address involved. We do not send the values of program variables in the stack trace. We do not enable Sentry session replay or Sentry performance tracing
• Fly.io — hosting infrastructure; runs the Counsolero application and database in the United States
• Cloudflare — reverse proxy and DNS in front of our servers; it terminates the TLS connection from your browser, so it is able to see request and response content (such as chat messages and file downloads) in transit before re-encrypting and forwarding to our origin. Cloudflare also runs Web Analytics for us, which loads a small script from Cloudflare on our public pages and the sign-in page
• Upstash — Redis cache and rate-limit store, provisioned through Fly's infrastructure marketplace; temporarily caches some Canvas academic data (such as grades) to improve performance. This cached data is encrypted by us before it is sent, under a key Upstash does not hold, so it is not readable by Upstash. The exceptions are counters used for rate limiting, which hold no personal data
• Google Workspace (Gmail): email for our counsolero.com addresses. It receives the messages you send to our support, privacy, security and similar addresses, including your email address and anything you write or attach. We use it only to read and answer those messages.

School sponsorship. If a school offers to sponsor your access, we ask your permission first. If you agree, we share your email address and the date you joined with that school's administrators. They can see these details in the school portal. They can also block you or end your seat. We do not share your grades, assignments, chats or AI use. If you decline, you stay on the free plan.

If your school ends sponsorship. If your school only ends your seat, you move to the free plan and keep your account. If your school asks us to end its sponsored students' use of Counsolero, we email you at least 30 days before we act. In that time you can download your data, or keep your account by moving to the free plan or paying for it yourself. If you do neither, we permanently delete your account and its data when the 30 days end. Your school has no say over an account it does not pay for.

Optional calendar integrations send authorized calendar requests directly to Google or Apple. They receive the event changes you approve. FullCalendar is bundled in our app and receives no calendar data as a hosted service.

We use Cloudflare Web Analytics on our public pages and the sign-in page. It measures page loads and page speed. Cloudflare describes it as cookieless. We use no advertising services, no tracking pixels and no session replay. We do not sell or share your personal information for cross-context behavioral advertising.

Canvas disconnect

When you disconnect Canvas via the Canvas Connections page, we clear our stored credentials and ask Canvas to revoke your access token. If Canvas does not answer, our copy is still cleared. Previously synced course data remains visible to you so you can reconnect and resume — same model as "signing out of Netflix on a TV." If you want the synced Canvas data removed as well, use Delete My Account, which cascade-deletes the mirror data along with the rest of your account.

Transfers

International data transfers.

Counsolero is a U.S.-only service. Our servers and database are in the United States, and we do not target users outside the U.S. Cloudflare's network is global, so your traffic can pass through a Cloudflare location outside the United States before it reaches our U.S. servers. We have not implemented EU-, UK-, or other non-U.S.-specific data-protection safeguards because we do not serve those markets. If you access the service from outside the U.S. on your own initiative — including from the EEA, the UK, Switzerland, Canada, or elsewhere — your information will be transferred to and processed in the U.S., where data-protection laws may differ from your country's, and you accept that risk.

To the extent our U.S. sub-processors offer transfer mechanisms — such as the EU–U.S. Data Privacy Framework, the European Commission's Standard Contractual Clauses, or the UK International Data Transfer Agreement — those mechanisms apply automatically to our use of their services under their published terms. Counsolero LLC has not separately negotiated SCCs or other transfer-specific contracts with any vendor.

Canvas sync

Canvas data we sync.

When you connect Canvas via OAuth and grant sync consent, we mirror these content categories. Every category below — grades, assignments, instructor feedback, files, page bodies, module structure and progress, announcements, discussion prompts, rubrics, quiz metadata, syllabi, course calendars, and your to-do list — can be turned off individually from the Canvas Settings page; only your basic course list and enrollment status (including course name, term, section, time zone, and instructor names) and your Canvas time-zone setting (so due dates show in your local time) form the always-on connection. Turning off a category stops future syncs; existing data is kept until you delete your account (disconnecting Canvas stops syncing but keeps what was already synced; see §6).

• Grades — your current and final course scores and letter grades, your scores for the current grading period, the course's grading scheme (the cutoffs that map a percentage to a letter), assignment-group weights and drop rules, and your score, grade, and late/missing/excused status on each assignment.
• Assignments — titles, instructions, your due and availability dates (including any extension that applies only to you, which is visible only to you), point values, how each one is graded (points, letter, pass/fail), attempts allowed, lock status, quiz settings such as time limits, and your submission status (including late, missing, resubmission-requested, and points deducted).
• Instructor feedback — comments your instructors and teaching assistants leave on your own submissions, and your rubric assessment (the points and comments for each rubric criterion). Comments written by other students, such as peer reviews, are not stored. To tell instructor comments from classmates' comments, we also store the Canvas user ID and role (teacher or TA) of each instructor and teaching assistant in your courses; no names are stored for this. Feedback text is encrypted at rest.
• Syllabus — the syllabus text your instructor publishes for each course.
• Course calendar — events your instructors put on your courses' calendars, such as exams, class sessions, and office hours. Your personal Canvas calendar is not stored.
• To-do list — the items Canvas shows on your planner and missing-work list (title, course, due date, and whether it is done, late, missing, or graded), including items you have marked complete in Canvas.
• Module progress — which module items you have completed, and module completion status.
• Groups — the names of the course groups you belong to and which course each is in. Who else is in a group is not stored.
• Course home page — the page your instructor sets as the course's front page.
• Course files — files attached to your Canvas courses. File content and file names are encrypted at rest; file size and type are stored unencrypted.
• Announcements — title and body text posted by instructors, and whether you have read them.
• Rubric criteria — names, descriptions, and point ranges.
• Discussion topic prompts — the instructor's prompt text only, not student responses, and your unread count for each topic.
• Quiz metadata — title, due date, point value, and quiz settings such as time limit, attempts allowed, number of questions, and whether it shows one question at a time. Individual question bodies and your quiz answers are not stored.
• Page bodies — HTML content of Canvas Pages in your courses.
• Module structure — module names and the items inside them.

Canvas sometimes shows a course item (such as an assignment, quiz, file, or announcement) to only some students in a class, for example a make-up exam or a section-specific file. To show you only what Canvas shows you, we record which course items your Canvas sync listed for you, when it first and last listed them, and whether a file was locked for you. This record is part of your account. We use it only to decide what you see, never for analytics, and it is deleted with your account.

Deletion: Disconnecting Canvas clears our stored tokens, asks Canvas to revoke them, and deactivates the connection. Synced Canvas content is cascade-deleted when you delete your account. If you want synced Canvas content removed before account deletion, use Delete My Account.

AI

AI and your data.

We do not train AI models on your data

Counsolero never uses your personal information, your Canvas data, your chat history, your uploaded files, or any other content you provide to train, fine-tune, evaluate, or benchmark AI models — ours or anyone else's. The third-party AI providers we use publish terms committing not to use customer inputs for model training; we have not separately negotiated those terms, and they apply to our use of those services the same as they apply to any other customer.

When you chat, the assistant can look up your own grades, assignments, files, calendar and course content to answer you. It chooses what to look up. These lookups stay inside your account. What it reads is sent to Azure OpenAI to write the answer.

Automated decision-making

Counsolero uses AI to generate study materials, summarize academic content, and suggest degree-planning options. These outputs are suggestions for you to consider — not automated decisions that produce legal or similarly significant effects on you under GDPR Art. 22. You can ignore, modify, or override any AI suggestion at any time.

Records of disclosure

For each AI call we make on your behalf, we record per-call metadata (described in §2) so that you and any auditing institution can verify what we did with your education records. See the FERPA Transparency Notice for the full disclosure-log pattern.

AI memory notes

Memory is on by default; you can switch it off at any time in Settings → Memory. While it is on, Counsolero saves short notes (up to 200 characters each, up to 100 notes) about how you study, taken from messages you type to the assistant, so you don't have to repeat yourself. Notes fall into seven kinds: study preferences, goals, schedule, subjects you find easy, subjects you find hard, how you like answers, and other study context — for example "Prefers flashcards over long summaries" or "Works night shifts on weekends". The assistant may also update or remove a note to keep your notes current, and when the 100-note limit is reached the least recently used note is removed. Notes are drawn only from the messages you type, not from the assistant's replies, tool results, synced Canvas content, uploaded files or web pages.

What Memory is designed not to save: health, disability, mental health or medication; family or relationships; finances or details of a job beyond your schedule; religion, politics, sexuality, gender identity or ethnicity; immigration status; discipline or legal matters; anyone else's information; contact details, addresses, ID numbers, passwords or tokens; and grades or scores. Two safeguards apply: the assistant is told not to save these, and a separate filter checks every note before it is stored. No filter is perfect. If a note you did not want is saved, delete it in Settings → Memory, and please don't share anything in chat that you don't want remembered.

How notes are used: only to provide the service to you — to help you in your own later chats. They are not used for profiling, analytics, advertising, model training or school dashboards, and school administrators cannot see them.

Who processes them: while Memory is on, each message you send is also reviewed by an additional request to Microsoft Azure OpenAI — our existing AI provider — in its United States Data Zone, which receives your latest messages and your saved notes and decides whether to save, update or remove a note. This happens even when nothing is saved. Answers that use your notes are generated by Azure OpenAI too. Notes are encrypted at rest.

Your controls: Settings → Memory lists every note. You can edit or delete any of them, delete all of them, or switch Memory off, which stops saving and using notes; notes you already have stay until you delete them or 180 days pass without use. When a chat saves or updates a note, the chat shows it with an Undo button. Deleting a conversation does not delete notes saved from it; delete them in Settings → Memory, or they are deleted with your account. Notes are included in Export My Data. A note not used for 180 days is deleted automatically.

Cookies

Cookies and similar technologies.

Counsolero uses cookies only as needed to operate the service. We do not use cookies for analytics, advertising, profiling, or third-party retargeting.

• Strictly necessary — session cookies set by Counsolero and by Clerk for authentication. Required to function.
• Functional — UI preferences (theme and similar) stored in your browser's local storage on your device. Not shared with us.
• Security — CSRF and similar tokens used to defend against cross-site request forgery. Required to function.

We do not sell or share your personal information, so the Global Privacy Control (GPC) signal is honored automatically by virtue of our data-handling model. A cookie notice is shown on first visit; because we set only the cookies described above, there are no optional cookies to turn on or off.

Do Not Track

Some browsers send a "Do Not Track" (DNT) signal. We do not track you across other websites or online services. We run no advertising trackers on Counsolero. The only analytics we use is Cloudflare Web Analytics, on our public pages and the sign-in page. It measures page loads and speed. We do not change how the service behaves when your browser sends a DNT signal. We do not let any advertising company collect personal information about your activity over time and across websites through Counsolero. The service providers listed in §6 process data only to run the service for us.

Your rights

Your privacy rights.

Your jurisdiction determines which of these rights apply to you. Most users have most of them: access, portability, rectification, erasure, restriction, objection, withdrawal of consent, opt-out of sale or share, limit on use of sensitive personal information, non-discrimination, and the right to appeal a denied request.

How to exercise them

• Access / portability — use the Export My Data page to download a structured archive containing JSON files for each data category in §2 (account profile, courses, grades, instructor feedback, syllabi, course calendars, to-do items, chat history, uploaded-file metadata, preferences, consent history, AI memory, AI memory notes, study resources, AI interaction metadata, and Canvas connection metadata). Raw vector embeddings are internal index data and are not part of the export.
• Deletion — use the Delete My Account page. We deactivate your account immediately, email you an undo link, and hard-delete after 14 days. Legal-hold exception: if a legal hold has been placed on your account (rare — usually a school-level compliance action), the request is rejected; contact support to resolve.
• Waitlist removal — email [email protected]. The Delete My Account page covers accounts, and a waitlist entry is not one, so this is the route until you have signed up
• Disconnect Canvas — use the Canvas Connections page (see §6 for what happens)
• AI provider — the in-chat model picker is visible, but during the current production beta, every request is served by Microsoft Azure OpenAI regardless of the picker selection; there is no alternate provider currently receiving your data to switch to
• Anything else — including rectification, restriction, objection, withdrawal of consent, opt-out of sale/share, limit on use of sensitive personal information, or appeal of a privacy decision: email [email protected]. For appeals of account actions under the User Policy (suspension, termination, etc.), use the appeal procedure in that document instead.

We aim to respond to verifiable requests within the statutory deadline (typically one month for GDPR, 45 days for CCPA, with the legal option to extend with notice). We may need to verify your identity by asking you to confirm details from your account — we do this to protect you against unauthorized requests, not as a barrier.

Our commitments to student data

Consistent with the spirit of U.S. state student-privacy laws — including the California Student Online Personal Information Protection Act (SOPIPA), the Illinois Student Online Personal Protection Act (SOPPA), New York Education Law § 2-d, Colorado's Student Data Transparency and Security Act, and analogous laws in Connecticut, Tennessee, Florida, and other states — Counsolero LLC commits that we will not:

• Sell student personal information
• Use student data for targeted advertising of any kind
• Build a profile of a student for any purpose other than providing the Counsolero service to that student
• Disclose student data to any third party except as described in this Privacy Policy or as required by law

These commitments apply to all students who use Counsolero, regardless of whether any specific state law technically applies to us.

Right to lodge a complaint

If you are not satisfied with our response, you may lodge a complaint with a supervisory authority. Contact information is on the Contact page (Section 4) (EU Data Protection Authorities, UK ICO, the California Privacy Protection Agency, state Attorneys General).

California

California: do not sell or share.

Counsolero does not sell your personal information and does not share it for cross-context behavioral advertising as those terms are defined in California's CCPA/CPRA. We never have, and we will give you 30 days' notice if that ever changes (see §15). California residents have the rights enumerated in §11, including the right to use an authorized agent to submit requests with written authorization. The categories of personal information we collect, the sources, our processing purposes, the recipients, and our retention practices are described in §§2–6.

Children

Children's privacy.

Counsolero is intended for adult students. By accepting our Terms of Service, you confirm you are 18 or older. The service is not directed to anyone under 18, and we do not knowingly collect personal information from anyone under 18.

If you are a parent or guardian and you believe a person under 18 has provided us with personal information, contact [email protected] immediately. We will investigate and, where confirmed, delete the account and personal information promptly and without charge. Where the person is under 13, we also act in accordance with the Children's Online Privacy Protection Act (COPPA) (15 U.S.C. § 6501 et seq.) and 16 CFR Part 312.

Breach response

If something goes wrong.

In the unlikely event of a security incident that compromises your personal information, Counsolero LLC will investigate promptly, notify affected users and the relevant supervisory authorities within the timeframes required by applicable law, work in good faith with affected schools where education records are involved, and publish a post-incident summary describing what happened, what was affected, what we did to remediate, and what we changed to prevent recurrence.

Report suspected incidents to [email protected].

Changes

Changes to this policy.

We may update this Privacy Policy from time to time. When we do, we update the "Last updated" date at the top of this page and bump our policy version, which prompts re-acceptance at your next login. For material changes affecting your data rights, sub-processors, or retention, we will also notify you by email.

For questions about this Privacy Policy, email [email protected] or see Contact.