Privacy Policy

1. Who We Are

Elevated Students is a DBA (doing-business-as) name of Elevated Environments LLC ("Elevated Students," "Elevated," "we," "our," or "us"). Elevated Students operates an AI-enabled family coaching and student development service offered directly to families. Our service helps parents and their teens understand how a teen is developing and build the skills, habits, and relationships that matter most during the adolescent years, including college and future planning and college application support.

Our service is delivered through a parent portal and a student portal that provide developmental and interest assessments, a "Living Portrait" of the teen and family, prioritized guidance ("Your Path"), coaching recommendations, and interactive AI agents. These include an AI discovery agent for students, an AI coaching agent for parents, and an AI assistant agent for advisors and coaches. Where a family engages our coaching service, a personal coach (a human) works with the parent and teen.

Our service is advisory, developmental, and guidance in nature. We do not provide clinical diagnoses, psychological evaluations, medical or mental health treatment, or family therapy. All insights, observations, portraits, and recommendations generated by our platform are intended to support family and coaching decisions, not to replace professional judgment or licensed care.

Our principal place of business is in Utah. For privacy-related questions, please contact:

Privacy Officer, Elevated Students (Elevated Environments LLC)

Email: privacy@elevatedstudents.ai

Website: www.elevatedstudents.ai

Mailing address: Elevated Students, c/o Elevated Environments, 7533 S Center View Ct Ste R, West Jordan, UT 84084

2. Scope of This Policy

This Privacy Policy explains how we collect, use, store, share, and protect personal information when you access or use the Elevated Students platform and website (collectively, the "Services"). It applies to:

• Parents and legal guardians who create and hold an Elevated Students account ("Account Holders" or "Parents");
• Students aged 13 and older who are authorized by their Parent to participate, and who use the student portal ("Students");
• Co-parents or other family members a Parent authorizes to participate;
• Advisors and coaches who provide services to families through our platform;
• Visitors to our website at www.elevatedstudents.ai.

Our Role as a Business / Data Controller

In the Elevated Students direct-to-family service, we collect personal information directly from Parents and Students and determine how it is used to provide the Services. Accordingly, Elevated Students acts as a business and data controller with respect to the personal information processed through the Services. Where a family also engages an advisor or coach through Elevated Students, that advisor or coach is an independent data controller with respect to the information they collect and hold to provide their own advisory or coaching services. In that case, Elevated and the advisor are separate, independent controllers, each responsible for the information it holds, and the two operate under a data sharing agreement. A request you make to Elevated (for example, to delete data) applies to Elevated's records and does not by itself bind the advisor's separate records, and the reverse is also true.

3. The Parent-First Authorization Model

Elevated Students is built so that a Parent is in control of a minor teen's participation:

• Step 1: Parent account. A Parent or legal guardian creates an account first. During sign-up, the Parent reviews and agrees to our Service Platform Terms and Conditions and this Privacy Policy.
• Step 2: Authorization. The Parent authorizes their teen (aged 13 to 17) to participate, and consents to our collection and use of the teen's personal information as described in this Policy. The Parent may also authorize a co-parent.
• Step 3: Student assent. After the Parent's authorization, the Student creates their own portal access, reviews age-appropriate terms, and agrees to provide their personal information and to our use of it to generate their portrait and discovery insights.

We do not create a Student account or collect a Student's information for the Services until the Parent has authorized that Student's participation, except for the limited account and device information necessarily generated when the Student signs in.

4. Information We Collect

4.1 Account Registration and Profile Information

When a Parent, co-parent, or Student creates or uses an account, we collect registration and profile information, which may include:

• Name, email address, phone number, and general location (for Parents and co-parents);
• The Student's first name or preferred name, age or date of birth, grade level, school name, and graduation year;
• Relationship information (for example, parent, co-parent, guardian);
• Payment and billing information, processed through our payment provider (we do not store full payment card numbers).

4.2 Student, Parent, and Family Information

To provide the Services, we collect and generate information about the Student and family, which may include:

• Developmental and personal assessments and surveys: personality assessments, emotional intelligence (EQ) and social-emotional inputs, executive function inputs, interest inventories, strengths and growth-area inputs, and similar assessments completed by the Parent, Student, or co-parent;
• Intake and conversation inputs: responses you provide during onboarding and throughout your use of the Elevated portal. These responses may be provided by chat or by voice conversation, whether in response to an AI agent’s questions, reflections, or other exchanges, or as part of Parent, Student, or advisor inquiries and communications. They include onboarding conversations (the "core read"), portal questions, reflections, and goals;
• Living Portrait and derived content: portraits for each participant and the family view, prioritized guidance ("Your Path"), and related developmental observations and recommendations;
• College and future planning information (where relevant): interests, target directions, activities, achievements, and planning documents;
• Coaching records: session scheduling, coach notes, meeting transcripts, session summaries, action items, and progress or milestone tracking;
• Communications and documents you submit to us or your coach in connection with the Services;
• Any other personal and planning information you choose to enter about the Student, the family, or the development process.

4.3 Voice Session Data

Some parts of the Services may use voice interactions, including AI-guided intake conversations and, where a family uses coaching, voice-enabled or recorded coaching sessions. The Platform uses voice features, and this section applies to those voice sessions. Where voice sessions are conducted:

• Audio may be recorded to generate transcripts and summaries used within the platform. We do not create or store a voiceprint or any other biometric identifier from voice, and we do not analyze voice for emotion, mood, or tone; audio is captured only to produce a transcript and is automatically deleted within 30 days by our voice vendor;
• For sessions facilitated through the Elevated Students platform, we provide an automated in-session notification at the start of the session that it is being recorded;
• For all voice sessions, and specifically for any session that involves a minor Student, the authorizing Parent’s consent to recording is obtained at the time of account formation, before the service is used, and the Student separately consents to recording during onboarding. Every participant is notified at the start of each session that it is being recorded and may decline to participate (see Appendix A);
• The Account Holder does not determine how long voice transcripts are retained. Voice transcripts and summaries are retained while the account is active and are deleted when the account is closed (see Section 7).

4.4 Platform Interaction and AI Agent Data

When you use our platform or visit our website, we automatically collect or receive:

• Log data: IP address, browser type and version, operating system, pages visited, time and date of access, and referring URL;
• Device information: device type and unique device identifiers;
• Usage data: features used, session duration, and navigation patterns;
• AI agent interactions: when Parents, Students, or advisors interact with our AI discovery agent, AI coaching agent, or AI assistant agent, the questions asked, information provided, requests made, and any data entered during the interaction may be captured and become part of the family's data record;
• Cookies and similar technologies (see Section 10 and our Cookie Policy).

4.5 Information from Third-Party Sources

We may receive limited information from authentication providers (for example, Google) if you use single sign-on to access the platform, and from marketing or referral sources through which a family learned about Elevated Students, subject to applicable opt-out rights.

5. How We Use Personal Information

5.1 Platform Operation

• Creating and managing Parent, co-parent, and Student accounts and the parent and student portals;
• Processing intake and assessment information and generating the Living Portrait and family view;
• Generating developmental assessments and observations, prioritized guidance ("Your Path"), coaching recommendations, and discovery insights, which may be delivered to Parents, Students, or advisors, in different parts of the portal or through our AI agents;
• Observing behavioral trends and assessing how they may relate to a Student's situations, growth, and development opportunities;
• Supporting college and future planning, including college-application support, where relevant to the Student's goals;
• Reviewing and drafting communications between Students, Parents, and coaches or advisors;
• Where an advisor or coach is engaged, supporting the coaching relationship and enabling the advisor to provide their own coaching and advisory recommendations (which may be in addition to Elevated's portal recommendations);
• Enabling AI agent interactions in which users ask questions, provide information, or request insights;
• Enabling voice sessions and generating transcripts and summaries (where voice features are used);
• Providing customer support and responding to inquiries;
• Sending transactional communications (account confirmations, billing notices, policy updates).

5.2 Service Improvement (De-identified and Aggregated Data Only)

Elevated does not build, train, or maintain artificial intelligence models. We use third-party AI providers to deliver features such as our AI agents, and we do not use personal information to train any AI model. We may use de-identified and aggregated data for product and service improvement, including improving the portal, the assessments, and the quality of the guidance the service provides. "De-identified" means information processed so that it cannot reasonably be used to identify a natural person, and we maintain appropriate safeguards against re-identification.

All of our third-party AI and other service providers are on contractual terms that prohibit them from using the information we transmit to them to train or improve their own models. We do not use identifiable Student or family personal information for any purpose other than providing the Services to that family.

5.3 Safety and Legal Compliance

• Detecting and preventing fraud, security incidents, and unauthorized access;
• Complying with applicable laws, regulations, and legal process;
• Enforcing our Terms and Conditions and other agreements;
• Protecting the rights, property, and safety of Elevated Students, our users, and the public.

Our safety practice reviews information shared through the platform, including chats and voice-session transcripts, for signs that a Student or another person may be at risk of harm, and routes any concern to a trained member of our team who reviews it and decides what to do. This is not real-time monitoring and not an emergency service, and we do not guarantee that we will identify every concern; in an emergency, always call 911 or 988. The review is limited to risk of harm. Because Elevated is developmental and not clinical, we do not monitor for, diagnose, or treat mental-health or therapy needs, and we make no clinical notifications. A person, not an automated system, makes any decision to notify a family or an authority, and we may be required by law to report suspected child abuse or neglect.

5.4 Developmental Insights and Behavioral Observations

As part of providing the Services, our platform generates data-derived analytical indicators, including developmental insights, discovery insights, and behavioral observations, to support the family, coaching, and development process. These outputs are derived from information entered into the platform and are intended to support parent, student, and coach decision-making. They may relate to how a teen is wired, strengths and growth areas, learning and executive-function characteristics, social-emotional development, interests and goals, and which developmental practices matter most and in what order. AI-generated outputs may contain errors or omissions and should be considered together with your own knowledge of your teen and, where applicable, your coach's judgment.

Within a family, Elevated shares what it learns about how each person is wired and what helps, rather than a full record of the conversation.

Developmental observations and recommendations, whether generated by AI or provided by a human, may be incomplete, wrong, or inaccurate. The Services are designed on the assumption that people review the observations and recommendations, validate key assumptions before acting on them, monitor and adjust their actions as they work with the Services, and provide feedback on outcomes. On request or on its own, the Service can surface questions to help you validate assumptions and proposed actions before you rely on them. The Services are intended to support your decisions, not to replace your own judgment or, where applicable, your coach's judgment.

Generating these insights involves analyzing information about the Student to understand and describe how the Student is developing. This analysis is a form of profiling, and it is an essential and intended part of the Service. We are explicit about it here because we believe families should understand it: this profiling exists only to deliver personalized developmental guidance to the Student and family, it is surfaced transparently to the Parent and Student through the portal, and it is never used for advertising, sold or shared, or applied for any purpose outside the Services delivered to that Student and family.

These insights and observations are:

• Proprietary analytical outputs generated by our platform, used solely to deliver and improve the Services;
• Developmental and guidance in nature; they do not constitute clinical diagnoses, psychological evaluations, definitive assessments, or determinations about any individual;
• Surfaced through the portal experience to support family and coaching decisions;
• Not sold or shared, not used for advertising, not used for employment, credit, insurance, or eligibility decisions, and not used for any purpose unrelated to the family coaching and development Services.

See Section 9 for information on your rights regarding these outputs.

6. How We Share Personal Information

6.1 We Do Not Sell or Share Personal Information

We do not sell, share, rent, or trade personal information to any third party for monetary or other valuable consideration, and we do not share personal information for cross-context behavioral advertising. This applies to Student and family information, Parent information, and website visitor data. We do not disclose a family's Student, parent, or family content outside that family, except to an advisor or coach the family has authorized to work with them (see Section 6.3) and to the service providers described in Section 6.2 who process data on our behalf.

6.2 Service Providers and Subprocessors

We share personal information with third-party service providers ("Subprocessors") who process data on our behalf to help us deliver the Services. All Subprocessors are subject to written data processing agreements and are prohibited from using the data for any purpose other than providing services to us. Our current Subprocessors are listed in Section 11.

6.3 Advisors and Coaches (Independent Controllers)

Where a family engages an advisor or coach through Elevated Students, that advisor or coach is an independent data controller with respect to the information they collect and hold to provide their own advisory or coaching services to the family. Elevated and the advisor share the family's information with each other only as authorized by the family and only to serve that family, and the sharing is governed by a data sharing agreement between Elevated and the advisor. As independent controllers, Elevated and the advisor are each responsible for the information each holds, including its security, retention, and response to your rights requests about that party's own records. Advisors and coaches are bound by confidentiality obligations and may not use family information for any purpose other than serving that family, and may not sell or share it. We do not share one family's information with another family. You may also enter a separate agreement directly with your advisor or coach that governs their services to you.

6.4 Business Transfers

If Elevated is involved in a merger, acquisition, asset sale, corporate restructuring, or similar transaction, personal information may be transferred as part of that transaction. We will provide notice before your personal information is transferred and becomes subject to a different privacy policy.

6.5 Legal Requirements

We may disclose personal information if we believe in good faith that disclosure is necessary to: (a) comply with a legal obligation or valid legal process; (b) protect the safety of any person; (c) prevent fraud or security threats; or (d) protect our legal rights.

7. Data Retention

We retain personal information for as long as it is needed to provide the Services and for the periods described below, subject to legal retention obligations. You may request deletion at any time. Because we cannot deliver the Services without the underlying information, a request to delete that information may require closing the account (see Section 9).

Upon account termination, the Account Holder has 30 days to export their data. Following that window, data is securely deleted from our active systems (deletion from backups may take up to an additional 60 days). We may retain de-identified, aggregated information indefinitely for service improvement.

8. Data Security

We implement industry-standard administrative, technical, and physical safeguards to protect personal information against unauthorized access, disclosure, alteration, and destruction, including:

• Multi-factor authentication (MFA) required for platform administration and personnel access;
• Encryption in transit using TLS 1.2 or higher for all data transmission;
• Encryption at rest using AES-256 for stored personal data;
• Role-based access controls limiting data access to authorized personnel;
• Secure deletion procedures at the end of the applicable retention period;
• Annual security policy review and written acknowledgment by all personnel with access to personal data;
• Security monitoring maintained through our cloud infrastructure providers.

Our full security program is described in our internal Written Information Security Policy (WISP). In the event of a security incident involving personal information, we will notify affected Account Holders (and, where required, affected Students and applicable regulators) without undue delay and within the timeframes required by applicable law.

9. Your Rights and Choices

9.1 Rights for All Users

Subject to applicable law, you have the right to: access the personal information we hold about you; request correction of inaccurate information; request deletion of your information, subject to legal retention obligations; and opt out of marketing communications at any time via the unsubscribe link in any email or by contacting privacy@elevatedstudents.ai.

Deletion and account closure. Elevated cannot provide the Services without access to the Student and family information that powers them. Where we can honor deletion of specific information without ending the Services, we will. Where the information is essential to the Services, deleting it may require closing the account, and on closure we delete your information subject to the legal retention obligations described in Section 7 (for example, billing records).

Developmental Insights and Observations. The insights, observations, and portraits described in Section 5.4 are proprietary analytical outputs delivered through the portal experience, not separately provided as raw data exports. You may request access to your underlying personal information, including assessment responses, transcripts, and other source data you entered, and we will provide it upon a valid request. Requesting deletion of underlying source data will be honored and will functionally remove the basis for any derived insights associated with that data.

9.2 California Residents (CCPA/CPRA)

California residents have rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), including the right to know, the right to delete, the right to correct, the right to opt out of sale/sharing (we do not sell or share personal information), the right to limit use of sensitive personal information (we use it only as necessary to provide the Services), and the right to non-discrimination for exercising these rights.

We honor recognized opt-out preference signals, including the Global Privacy Control (GPC). Because we do not sell or share personal information for cross-context behavioral advertising, a GPC signal does not change our practices, but we treat it as a valid opt-out of any such sale or sharing. To exercise your California rights, contact privacy@elevatedstudents.ai. We will respond within 45 days and may extend by an additional 45 days with notice.

9.3 How Parents and Students Exercise Rights

• Minor Students. While the Student is a minor (under 18), the authorizing Parent may exercise access, correction, and deletion rights over the Student's information by contacting us or using in-portal tools. Students may also contact us directly and we will assist as appropriate.

Access to a Student's underlying records. Because the Parent is the account holder and the Student's legal guardian, the Parent may request access to the Student's information, including original documents, chat, meeting, and communication transcripts, and other inputs, and Elevated may be legally obligated to provide them. When Elevated discloses this kind of underlying information in response to a request, Elevated intends to notify the account, though it does not guarantee or commit to doing so, and it may not provide notice where the law prohibits it or where notice could create a risk to someone's safety.

• Students who reach 18. When a Student reaches the age of 18, the Student may assume control of their own information and account and may exercise their own access, correction, and deletion rights directly. See Section 13 on the age-18 transition.

10. Cookies and Tracking Technologies

We use cookies and similar technologies on our website and platform. Some are essential for the site and platform to function, including maintaining your session and security. We also use cookies to understand how our site is used and to support scheduling and support tools. We do not use advertising or retargeting cookies, and we do not use cookies to sell data. For more detail, see our Cookie Policy at elevatedstudents.ai/cookie-policy. We use a single analytics provider (Google Analytics) to understand how our website and portal are used. We do not currently use advertising, retargeting, or session-replay tools. If we introduce advertising or additional marketing analytics in the future, we will update this Policy and our Cookie Policy before doing so and will describe the tools, what they receive, and your choices.

11. Third-Party Subprocessors

We use the following third-party service providers to help operate our platform. All Subprocessors are bound by data processing agreements and may only process personal information as directed by us and for the purposes described below:

Note on Workflow Automation (n8n). n8n GmbH is a German company whose cloud infrastructure is located in the European Union. Personal information processed through n8n may be transferred to and processed in the EU. We have executed a Data Processing Agreement with n8n incorporating appropriate safeguards and minimize the personal information transmitted through it.

Note on Development Personnel. Our software development partner SCVsoft supports the Elevated Students platform. SCVsoft's personnel located in Argentina process meeting transcripts and provide limited, as-needed operational support, and do not access the full Living Portraits or the chat, conversation, and messaging inputs of Elevated Students students and families. All such personnel are bound by non-disclosure agreements and are required to comply with the same security standards as US-based personnel. Argentina maintains a comprehensive data protection framework (Law 25.326) recognized as providing adequate protection.

Note on Subprocessor Management. The infrastructure, database, and certain AI subprocessors that support the core meetings platform are engaged and managed by our development partner SCVsoft under our data processing agreement with SCVsoft. The website, analytics, advertising, application development, and workflow automation subprocessors are engaged and managed directly by Elevated Students, including the AI providers we call directly through our workflow automation under our own agreement with those AI providers. In each case, the subprocessor is bound by a written data processing agreement.

Note on AI Providers. Our AI providers (including OpenAI, Anthropic, and Google) process information only to deliver platform features such as our AI agents. All of our AI providers, and our other Subprocessors, are on contractual terms that prohibit them from using the information we transmit to them to train or improve their own models. Elevated does not build, train, or maintain its own AI models.

We will notify Account Holders of material additions to this Subprocessor list as soon as reasonably practicable, and in any event within 30 days after the new Subprocessor begins processing, by posting an updated policy on our website. We may not always be able to give advance notice, and we need time to update the posted policy after a change.

12. Educational Records and FERPA

The Family Educational Rights and Privacy Act (FERPA) primarily governs educational records held by schools and educational institutions. Elevated Students is a service used directly by families, not a school or educational institution, and does not typically hold "education records" as defined by FERPA. Information you choose to enter that is derived from a student's school records is treated as family information under this Policy.

13. Minors, Parental Authorization, and the Age-18 Transition

Minimum age. Elevated Students is intended for students aged 13 and older. We do not knowingly permit accounts for, or knowingly collect personal information from, children under the age of 13. If we become aware that we have inadvertently collected information from a child under 13, we will promptly delete it. Use of the Services with a child under 13 is prohibited.

Parental authorization for minors. For a Student aged 13 to 17, the authorizing Parent consents to our collection and use of the Student's personal information as described in this Policy. The Parent may withdraw authorization or request deletion of the Student's information at any time.

Minors and our most-protective standard. Our approach to minors is to design to the most protective standard, not the minimum required. Because Elevated Students is intended for and knowingly used by Students aged 13 to 17, we do not rely on any actual-knowledge or likely-to-be-accessed threshold; we apply heightened protections to every Student under 18, regardless of the state in which they live. In practice this means that we collect only the personal information reasonably necessary to provide the Service; we do not serve targeted or behavioral advertising to minors and do not sell or share their personal information; we do not profile a minor except as necessary to deliver the developmental service the family has requested, and never for advertising or any purpose outside the Service; we set minor accounts to the most protective configuration by default; we avoid design that encourages compulsive use or that pressures a minor to weaken their privacy or to share more than necessary; we give the Student and Parent age-appropriate, understandable explanations of what we collect and why; and we assess features that affect minors for their impact and for the best interests of the Student. This standard is designed to meet or exceed the children's and minors' privacy laws that apply to a service like ours, including the Children's Online Privacy Protection Act for children under 13, the minor provisions of the California Consumer Privacy Act and comparable comprehensive state privacy laws such as those in Colorado and Connecticut, and the state age-appropriate design code laws, including those in California, Maryland, Nebraska, Vermont, and South Carolina. Where a particular state gives a Student or Parent a right beyond this baseline, we honor that right for residents of that state.

California minors (CCPA and the California Age-Appropriate Design Code). For Students under 18 who are California residents, we provide enhanced protections. We do not sell or share the personal information of a Student under 18, and we do not use a minor Student's personal information for targeted advertising. As described in Section 5.4, the Service does involve profiling of the Student, meaning automated analysis of the Student's information to describe how the Student is developing. This profiling is an essential and disclosed part of the Service and is used only to deliver personalized developmental guidance to the Student and family. We do not profile a minor Student for any purpose outside the Services, and we do not use profiling for advertising, sale, or sharing. We configure minor accounts with protective defaults, provide age-appropriate transparency to the Student and Parent, collect only the information reasonably necessary to provide the Service, and design the Service in a manner consistent with the best interests of minor users. Because we do not sell or share personal information, opt-in requirements that would otherwise apply to selling or sharing a minor's data are not triggered by our current practices. We apply these minor protections to all Student users regardless of the state in which they reside, consistent with comparable minor-protection requirements in states such as Colorado, Connecticut, and New York.

14. International Users

Elevated Students is based in the United States and our Services are directed to users in the United States. If you access our Services from outside the United States, your personal information will be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your country. We do not currently offer our Services to users in the European Union or European Economic Area as a primary market. For information about transfers related to Argentina-based development personnel and EU-based workflow automation, see Section 11.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the revised policy on our website with an updated effective date. For material changes, we will provide additional notice by sending an email to the address associated with your account. Your continued use of the Services after the effective date constitutes acceptance of the changes. If you do not agree, you must stop using the Services.

16. Contact Us

For questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact:

Privacy Officer, Elevated Students (Elevated Environments LLC)

Email: privacy@elevatedstudents.ai

Website: www.elevatedstudents.ai

Mailing address: Elevated Students, c/o Elevated Environments, 7533 S Center View Ct Ste R, West Jordan, UT 84084

Response Time: Within 45 days of receipt (CCPA requests), or within 30 days for general requests.

Appendix A: Recording Consent Detail

This appendix supplements Section 4.3 where voice features are used. Recording laws vary by state. Where a voice session is facilitated through the Elevated Students platform, we provide an automated notification at the start of each session that it is being recorded, and any participant may decline to participate in a recorded session. For any session involving a minor Student, the authorizing Parent consents to recording at onboarding, and the Student separately consents to recording during onboarding and is reminded at the start of each session that the session is being recorded. Recordings are used to generate transcripts and summaries and are retained consistent with Section 7. You may not separately decline recording within a voice session, because recording is part of the voice feature. Where a non-voice option such as text chat is available for a given interaction, you may use it, though some features may require voice.