Legal
What we collect across the app and the instructor portal, what happens to it in the AI pipeline, and what you can ask us to do about it.
Effective · Adapt Learning, LLC
Adapt Learning, LLC (“Company,” “Adapt,” “we,” “us,” or “our”) provides an AI-powered adaptive learning platform consisting of the Adapt mobile application (the “App”) and the Adapt Portal web application for instructors and institutions (the “Portal,” together with the App and related services, the “Service”). This Privacy Policy explains what information we collect, how we use and share it, and the choices you have.
By using the Service, you acknowledge this Privacy Policy. If you do not agree, do not use the Service.
For the consumer App, Adapt is the data controller — we decide what personal data is collected and why. For institutional use of the Portal, the Institution is the controller of student and roster data, and Adapt acts as a service provider / processor (“school official”) that processes that data only on the Institution’s documented instructions and under our Data Processing Addendum.
The same person can fall under both roles: when a student uses Adapt for a class assigned by their Institution, we handle that activity as the Institution’s processor; when that same person generates their own personal courses outside of any class, we act as the controller of that activity.
(a) Account & identity. Name and email address; authentication identifiers when you sign in with Google or Apple; and, for Portal users, organization/account/role attributes (accountId, orgId, capability). You may start on the App as an anonymous guest; if you later create an account we link that guest activity to it. We never see or store your plain-text password.
(b) Learning content & inputs. The topics, prompts, questions, and free-text you submit — including answers to interactive cards (quiz, match, Socratic dialogue, reflection/teach-back) and your messages to the AI Learning Coach — and the resulting generated courses, progress, mastery, and engagement signals.
(c) Institutional / classroom data (Portal). Course materials that instructors upload; class rosters uploaded by an Institution (which may include the names and email addresses of students who have not yet registered, so we can send invitations); enrollments and assignments; and messages exchanged between instructors and students.
(d) Subscription & transaction data. Your subscription tier and entitlements (via RevenueCat). Payments are processed by Apple or Google; we do not collect or store your payment card details.
(e) Device & usage data (collected automatically). IP address, device model, operating system version, unique device identifiers, app version, push notification tokens, in-app events and feature usage, and crash and performance diagnostics.
The Service’s core features are powered by Google’s Gemini models accessed through Google’s Gemini Enterprise Agent Platform (formerly Vertex AI). To generate courses and coaching responses, we send the relevant content of your inputs (and, in the Portal, instructor-uploaded materials) to the Gemini Enterprise Agent Platform for processing. Certain course-generation steps also use Google Search grounding to improve factual accuracy.
We do not use your content — and Google does not use content processed through the Gemini Enterprise Agent Platform — to train, fine-tune, or improve foundation models. Content is processed only to provide the Service to you. Institutional content is handled under the additional commitments in our Data Processing Addendum.
We do not transmit your name, email, or password to the AI provider as part of generation requests.
We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We disclose information only:
We do not currently run advertising and do not operate advertising trackers. The App does not prompt for App Tracking Transparency permission. If this changes, we will update this Policy, our app-store privacy disclosures, and (where required) request your consent first.
We retain personal information for as long as your account is active and as needed to provide the Service, then delete or de-identify it within a commercially reasonable period, except where longer retention is required for legal, security, tax, or dispute-resolution purposes. Institutional data is retained per our agreement with the Institution and returned or deleted on termination as described in the Data Processing Addendum.
Access & deletion in-app. You can request access to, or deletion of, your account and associated personal data from within the App (Settings → Account) or by emailing support@adaptlearning.io. Deleting your account removes your personal data as described in Section 7.
Notification controls. You can manage push and email preferences in-app and unsubscribe from non-transactional email.
Regional rights. Depending on where you live, you may have rights to access, correct, delete, port, or restrict processing of your personal data, and to object or withdraw consent. Institutional users should direct student-data requests to their Institution, which we will support as processor.
To exercise rights, contact support@adaptlearning.io. We will not discriminate against you for exercising your rights.
California residents have the rights to know, access, correct, delete, and to opt out of “sale” or “sharing” of personal information, and to limit use of sensitive personal information. We do not sell or share personal information as those terms are defined under the CPRA, and we do not use sensitive personal information for purposes requiring an opt-out. We honor Global Privacy Control signals where applicable. Submit requests to support@adaptlearning.io with the subject “California Privacy Request.” You may use an authorized agent.
Where GDPR or UK GDPR applies, our legal bases are: performance of a contract (providing the Service), our legitimate interests (securing and improving the Service), consent (where requested), and legal obligation. You have the rights described in Section 8 and may lodge a complaint with your supervisory authority. International transfers are protected by appropriate safeguards such as Standard Contractual Clauses.
We use administrative, technical, and physical safeguards — including those provided by Google Firebase and Google Cloud, access controls, App Check, and encryption in transit — to protect personal information. No method of transmission or storage is completely secure. If we become aware of a breach affecting your personal information, we will notify you and any required authorities as required by law.
The consumer Service is intended for users 18 years of age or older, and we do not knowingly collect personal information from anyone under 18 through the consumer App. Where the Service is used by students through an Institution, the Institution is responsible for obtaining any consents required for its students, and Adapt processes such data only as the Institution’s processor. If you believe someone under 18 has provided us personal information through the consumer App, contact support@adaptlearning.io and we will delete it.
We may update this Policy from time to time. We will post the updated version within the Service and revise the “Effective Date,” and for material changes we will provide additional notice where required.
Adapt Learning, LLC
815 Water St, Tampa, FL 33602
support@adaptlearning.io
What we collect, how the AI pipeline handles it, and your rights.
The agreement covering individual use of the app and portal.
Limits of AI-generated study material, incorporated into the Terms.
Every third party that touches data, and what each one does.
Institutions licensing Adapt for their instructors and students are covered by a separate Enterprise Master Services Agreement and a FERPA Data Processing Addendum. Both are available for procurement review — email support@adaptlearning.io.
