1. Scope and Account Roles
This Policy applies to information processed through our public website, contact and demo forms, authentication flows, dashboards, and product modules, including CV analysis, interview practice, speech coaching, work simulations, and curriculum-linked experiences.
If you use the Services through a school, district, employer, nonprofit, or other organization, that organization may control parts of the data you submit or that we process on its behalf. In those cases, we act under our agreement with that organization and its instructions, and certain access, correction, export, or deletion requests may need to be directed to the organization first.
2. Information We Collect
We collect personal information in a few different ways: from you directly, from the organization that gives you access, from your use of the Services, and from technical systems needed to keep the platform secure and functional.
- Account and roster data, such as your name, email address, user ID, organization or school affiliation, class or program assignment, and sign-in credentials.
- Profile information you choose to provide, such as grade level, transition goals, education details, interests, accommodation-related preferences, or other optional profile fields.
- User-submitted content, such as resumes, CVs, uploads, answers, notes, reflections, goals, prompts, selections, coursework, and educator feedback.
- Audio and communication data, including recordings, speech samples, transcripts, and related communication-coaching outputs.
- Performance and progress data, including completion records, scores, rubric outputs, recommendations, readiness indicators, and similar module results generated inside the Services.
- Technical and usage data, such as IP address, browser type, device information, session timestamps, error logs, security events, and feature usage telemetry.
- Cookies and similar technologies used for sign-in, session continuity, preference storage, security, and product analytics.
3. How We Use Personal Information
We use personal information only for legitimate business, educational, and platform operations purposes, including to:
- Create, authenticate, maintain, and support accounts.
- Deliver the Services you request, including speech analysis, transcript generation, scoring, simulations, recommendations, and educator or administrator reporting.
- Personalize experiences, track progress, and provide feedback tied to learning, transition, or workforce-readiness goals.
- Maintain reliability, debug issues, prevent misuse, investigate fraud, and protect the safety and security of the Services.
- Communicate with you about support, product operations, policy updates, and service-related notices.
- Comply with legal obligations, enforce agreements, and protect our rights, users, and property.
4. What We Do Not Do
We do not sell personal information. We do not use student data for targeted advertising. We do not build student marketing profiles. We do not claim ownership of student submissions or student records beyond the limited rights needed to operate the Services.
If we use de-identified or aggregated information to improve our product, reporting, or operations, we do so in a manner designed to avoid reasonably identifying an individual.
5. How We Share Information
We share information only as needed to operate the Services, support the organization that uses them, or comply with law.
- Service providers and subprocessors that help us with hosting, infrastructure, storage, analytics, communications, customer support, and security.
- AI, transcription, or communication vendors only to the extent needed to deliver features you or your organization request.
- Your school, district, employer, or program administrator when your account is organization-managed or when reporting is part of the Services they purchased.
- Government authorities, courts, regulators, or other parties when we believe disclosure is required by law or reasonably necessary to protect rights, safety, or the integrity of the Services.
- A successor entity in a merger, financing, acquisition, or asset sale, subject to confidentiality and continued data-protection obligations.
6. Cookies, Logs, and Similar Technologies
We use cookies and comparable technologies to keep users signed in, remember preferences, measure feature usage, maintain security controls, and understand performance. We also maintain application and system logs to detect unauthorized access, investigate incidents, and keep the Services available and stable.
You can adjust some cookie controls through your browser settings, though disabling certain cookies may limit sign-in or product functionality.
7. Student Data, FERPA, and COPPA
When we process data on behalf of a school or educational program, we do so for school-authorized educational and service-delivery purposes only. We remain responsible for our own compliance with applicable law, including COPPA, and we support school partners in meeting their obligations under FERPA and other applicable requirements.
- For school-managed accounts, schools or programs may be the primary contact for requests involving student records, corrections, exports, or deletion.
- We do not knowingly collect personal information directly from a child under 13 outside an authorized school, program, parent, or guardian context.
- If a parent or guardian believes a child provided information outside an authorized context, they may contact us and we will work to investigate and address the request.
ThorneAI is responsible for its own compliance with the Children's Online Privacy Protection Act (COPPA). When we operate under a school or program agreement, we work with those partners in a manner consistent with the Family Educational Rights and Privacy Act (FERPA), though each party remains responsible for its own legal obligations under applicable law.
8. Retention, Deletion, and De-Identification
We retain personal information only for as long as reasonably necessary to provide the Services, maintain customer accounts, preserve progress and reporting history, comply with legal obligations, resolve disputes, and enforce agreements. Retention periods may vary by product, customer contract, and data type.
When data is no longer needed, we delete it, anonymize it, or de-identify it using commercially reasonable processes.
9. Security and Data Location
We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, loss, misuse, disclosure, or alteration. No security measure is perfect, and we cannot guarantee absolute security.
We primarily use service providers and infrastructure located in the United States, and personal information may be processed in the United States or in other jurisdictions where our providers operate, subject to appropriate safeguards.
10. Texas Privacy Rights
If you are a Texas resident, applicable Texas law may give you certain rights regarding your personal data. Depending on the context and any statutory exemptions that apply, these rights may include the right to confirm whether we process your personal data, access it, correct inaccuracies, delete data, obtain a portable copy, or opt out of the sale of personal data, targeted advertising, or certain profiling activities.
We do not sell personal data and we do not use student data for targeted advertising. To submit a privacy request, email [email protected] with enough information for us to verify your request. If your account is managed by a school, district, employer, or other organization, we may direct you to that organization first when it controls the underlying data.
If we deny a request that is subject to appeal under applicable law, you may reply to our decision and ask us to review it again. If an appeal is denied, you may have the right to complain to the Texas Attorney General.
11. Changes to This Policy
We may update this Policy from time to time to reflect product, legal, or operational changes. When we do, we will post the updated version on this page and revise the "Last updated" date above. Material changes will take effect according to the notice provided with the update.
12. Contact
For privacy questions or requests, contact us by email at [email protected] or through our Contact page.
You may also write to us at 13111 Westheimer Rd. Suite 124, Houston, TX 77077 or call 832-559-2304.
