QLM Quantum Learning Back to home

Privacy Policy

Effective Date: March 19, 2026

This Privacy Policy (“Policy”) describes how Quantum Learning Machines (“QLM,” “we,” “us,” or “our”) collects, uses, discloses, and otherwise processes personal information in connection with our websites, applications, and services, including but not limited to SAT Mastery, ACT Mastery, AP Mastery, and Foundation Mastery (collectively, the “Services”). By accessing or using any of our Services, you (“you,” “your,” or “User”) acknowledge that you have read, understood, and agree to be bound by this Policy in its entirety. If you do not agree, you must immediately cease all use of our Services.

1. Information We Collect

1.1 Information You Provide Directly

We may collect the following categories of personal information when you create an account, subscribe to communications, contact us, or otherwise interact with our Services:

  • Identity Information: Full name, username, and profile details.
  • Contact Information: Email address and any other contact information you provide.
  • Account Credentials: Passwords and authentication tokens used to access your account.
  • Payment Information: Billing address and payment method details, which are processed by our third-party payment processors and are not stored directly on our servers.
  • User Content: Any content you submit through the Services, including responses to assessments, study preferences, notes, and communications with us.
  • Communications: Records and content of correspondence when you contact us via email or other channels.

1.2 Information Collected Automatically

When you access or use our Services, we automatically collect certain information, including:

  • Usage Data: Pages visited, features used, assessment interactions, study session duration, performance data, click patterns, navigation paths, and other behavioral analytics.
  • Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers, and language settings.
  • Log Data: IP address, access times, referring URLs, error logs, and server interaction records.
  • Location Data: Approximate geographic location derived from your IP address.
  • Cookie and Tracking Data: Information collected through cookies, web beacons, pixels, local storage, and similar technologies as described in Section 7 below.

1.3 Information From Third Parties

We may receive information about you from third-party sources, including authentication providers (such as Google or Apple sign-in), analytics services, and publicly available sources, and we may combine this information with other information we collect about you.

2. How We Use Your Information

We use the information we collect for the following purposes:

  • Service Delivery: To provide, operate, maintain, personalize, and improve our Services, including delivering adaptive learning content, generating diagnostic assessments, tracking progress, and producing performance analytics.
  • Communication: To send you service-related notices, product updates, promotional materials, and educational content. You may opt out of promotional communications at any time.
  • Analytics and Research: To understand how our Services are used, measure effectiveness, conduct internal research, and develop new features and products. This may include aggregated and de-identified data analysis.
  • Safety and Security: To detect, prevent, and address fraud, abuse, security incidents, and technical issues.
  • Legal Compliance: To comply with applicable laws, regulations, legal processes, and governmental requests.
  • Personalization: To tailor content, recommendations, study plans, and user experience based on your interactions, performance data, and preferences.
  • Account Management: To create and manage your account, process transactions, and provide customer support.

3. How We Share Your Information

We may share your personal information in the following circumstances:

  • Service Providers: We share information with third-party service providers who perform services on our behalf, including but not limited to Supabase (database and authentication infrastructure), analytics providers (such as Google Analytics, Mixpanel, or similar services), cloud hosting providers, email delivery services, and payment processors. These providers are contractually obligated to use your information only as necessary to provide services to us.
  • Legal Requirements: We may disclose your information if required to do so by law, regulation, legal process, or governmental request, or when we believe in good faith that disclosure is necessary to protect our rights, your safety, the safety of others, investigate fraud, or respond to a government request.
  • Business Transfers: In connection with any merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the acquiring entity or successor.
  • Aggregate and De-identified Data: We may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you with third parties for any purpose, including research, analytics, benchmarking, and product improvement.
  • With Your Consent: We may share your information with third parties when you have given us explicit consent to do so.

We do not sell your personal information to third parties.

4. Data Retention

We retain your personal information for as long as your account is active or as needed to provide you with our Services. We may also retain and use your information as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and for legitimate business purposes, including analytics and product improvement. When personal information is no longer needed for any of these purposes, we will delete or de-identify it in accordance with our internal data retention schedules. Aggregated, anonymized, or de-identified data that cannot be used to identify you may be retained indefinitely.

5. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights with respect to your personal information:

  • Access: You may request a copy of the personal information we hold about you.
  • Correction: You may request that we correct inaccurate or incomplete personal information.
  • Deletion: You may request that we delete your personal information, subject to certain legal exceptions and retention requirements.
  • Portability: You may request a machine-readable copy of your personal information.
  • Objection and Restriction: You may object to or request restriction of certain processing of your personal information.
  • Withdrawal of Consent: Where processing is based on your consent, you may withdraw consent at any time without affecting the lawfulness of prior processing.
  • Opt-Out of Communications: You may opt out of promotional emails by following the unsubscribe instructions in those emails or by contacting us directly.

To exercise any of these rights, please contact us at hello@quantumlearningmachines.com. We will respond to your request within the timeframe required by applicable law. We may require verification of your identity before processing your request.

6. Data Security

We implement commercially reasonable technical, administrative, and organizational security measures designed to protect your personal information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee absolute security. You acknowledge and agree that any transmission of personal information is at your own risk, and QLM shall not be liable for any unauthorized access, use, or disclosure of your information that occurs despite our commercially reasonable security measures.

7. Cookies and Tracking Technologies

We use cookies, web beacons, pixels, local storage, and similar tracking technologies to collect information about your interactions with our Services. These technologies serve the following purposes:

  • Essential Cookies: Required for the operation of our Services, including authentication, session management, and security.
  • Analytics Cookies: Used to collect information about how you use our Services, which pages you visit, and how you interact with features, in order to improve performance and user experience.
  • Functional Cookies: Used to remember your preferences, settings, and choices to enhance your experience.
  • Marketing Cookies: Used to deliver relevant advertisements and measure the effectiveness of our marketing campaigns.

Most web browsers are set to accept cookies by default. You can usually modify your browser settings to decline cookies or to alert you when cookies are being sent. Please note that disabling cookies may affect the functionality of our Services. By continuing to use our Services, you consent to our use of cookies and similar technologies as described in this Policy.

8. Children’s Privacy (COPPA Compliance)

QLM provides educational products that may be used by students under the age of 18. We comply with the Children’s Online Privacy Protection Act (“COPPA,” 15 U.S.C. §§ 6501–6506) and other applicable laws regarding children’s privacy.

Users Under 13

Students under 13 cannot create accounts directly. A parent or guardian must create an account on their behalf using the Parent/Guardian role. We do not knowingly collect personal information from children under 13 without verifiable parental consent.

Users Ages 13–17 (Minors)

Students ages 13–17 must obtain verifiable parental consent before accessing learning features. We collect only the information necessary to provide the educational Services from minors, including:

  • Name, email address, and date of birth
  • Practice session data, question responses, and time spent
  • Skill mastery levels and score predictions
  • AI tutor conversation context (anonymized before processing)
  • Error patterns and learning trajectory data

We do not use personal information of minors for marketing purposes unrelated to our educational Services.

Parental Rights

Parents and guardians of minor students have the right to:

  • Review all personal information collected from their child
  • Request correction of inaccurate information about their child
  • Request deletion of their child’s personal information
  • Refuse further collection or use of their child’s data
  • Revoke consent at any time (account will be suspended and data deleted)
  • Request a copy of their child’s data in a portable format

To exercise these rights, contact us at hello@quantumlearningmachines.com or use the account settings page. We do not condition a child’s participation in any activity on the disclosure of more personal information than is reasonably necessary to participate in that activity.

Analytics for Minors

We disable third-party analytics tracking (including Google Analytics) for all authenticated minor users. No behavioral tracking or advertising data is collected from minors.

9. Student Education Records (FERPA Compliance)

QLM complies with the Family Educational Rights and Privacy Act (“FERPA,” 20 U.S.C. § 1232g) when operating on behalf of educational institutions. When a school or district licenses QLM Services, the following applies:

Education Records Maintained

  • Diagnostic assessment results and score predictions
  • Practice session history and question-level performance
  • Skill mastery profiles and progress data
  • Error classification and learning trajectory data
  • Weekly progress reports and goal completion data

Parent and Student Rights

Parents of students under 18 (and eligible students 18 and older) have the right to inspect and review education records, request amendments to records believed to be inaccurate, consent to disclosure of records to third parties, and file complaints with the U.S. Department of Education. These rights transfer to the student at age 18.

Directory Information

We do not designate any student information as directory information. All student data requires consent for disclosure.

Third-Party Disclosures

Student education records are disclosed to the following third parties under signed Data Processing Agreements:

  • Supabase (database hosting) — stores all student data with row-level security
  • Anthropic (AI provider) — receives anonymized learning context for AI tutoring (student names and emails are stripped before transmission)
  • Stripe (payment processing) — receives billing data only, no education records

Data Retention and Deletion

Student education records are retained only as long as the student maintains an active account or as required by the institution’s data retention policy. Upon account deletion or consent revocation, all personally identifiable education records are deleted within 30 days. Anonymized aggregate data may be retained for service improvement.

10. AI Data Processing

QLM uses artificial intelligence to provide personalized learning experiences. Here is how AI features use your data:

  • AI Explanations and Tutoring: Learning context (skill mastery levels, estimated scores, recent performance) is sent to Anthropic’s Claude API to generate personalized explanations and guidance. Your name, email, and identifying information are never shared with AI providers. All data is anonymized before transmission.
  • Adaptive Learning: Skill mastery calculations run on our servers and are not shared with external AI providers.
  • Data Minimization: Only the minimum learning context necessary for AI-powered features is transmitted. We maintain a strict allowlist of fields that may be sent to external providers.
  • Audit Trail: Every data disclosure to an AI provider is logged in our FERPA-compliant audit trail, including the data categories sent, the provider, and the timestamp.

AI Features for Minors

AI-powered features are only available to minor students after verifiable parental consent has been granted. The consent form explicitly describes AI data processing. Parents may opt out of AI features at any time by contacting us at hello@quantumlearningmachines.com.

AI Limitations

AI-generated explanations, hints, tutoring responses, score predictions, and study recommendations are provided for educational assistance and should not be considered a substitute for professional instruction. AI outputs may contain errors, inaccuracies, or misleading information. QLM does not guarantee the accuracy, completeness, or reliability of any AI-generated content. You are solely responsible for evaluating and verifying any AI-generated content before relying on it.

11. International Data Transfers

Our Services are operated from the United States. If you are located outside the United States and choose to use our Services or provide information to us, you acknowledge and agree that your personal information will be transferred to, stored, and processed in the United States and potentially other countries where our service providers operate. These countries may have data protection laws that differ from those of your jurisdiction. By using our Services, you consent to such transfers. We will take commercially reasonable steps to ensure that your information receives an adequate level of protection in the jurisdictions in which we process it.

12. Third-Party Links and Services

Our Services may contain links to third-party websites, services, or applications that are not operated or controlled by QLM. This Policy does not apply to any third-party services. We are not responsible for the privacy practices, content, or security of any third-party services. We encourage you to review the privacy policies of any third-party services you access through our Services.

13. Limitation of Liability for Data Handling

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, QLM, ITS PARENT COMPANIES, SUBSIDIARIES, AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, LICENSORS, SUPPLIERS, AND THEIR RESPECTIVE SUCCESSORS AND ASSIGNS (COLLECTIVELY, THE “QLM PARTIES”) SHALL NOT BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, PUNITIVE, OR EXEMPLARY DAMAGES ARISING OUT OF OR RELATED TO ANY DATA BREACH, UNAUTHORIZED ACCESS, DATA LOSS, DATA CORRUPTION, OR ANY OTHER DATA-RELATED INCIDENT, REGARDLESS OF THE CAUSE OR THE FORM OF ACTION, WHETHER IN CONTRACT, TORT (INCLUDING NEGLIGENCE AND GROSS NEGLIGENCE), STRICT LIABILITY, PRODUCT LIABILITY, OR OTHERWISE, EVEN IF THE QLM PARTIES HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES OR COULD HAVE FORESEEN SUCH DAMAGES. THIS LIMITATION APPLIES TO ALL CLAIMS ARISING OUT OF OR RELATED TO THIS PRIVACY POLICY OR OUR DATA HANDLING PRACTICES, INCLUDING BUT NOT LIMITED TO CLAIMS RELATED TO THE COLLECTION, USE, STORAGE, PROCESSING, DISCLOSURE, TRANSFER, RETENTION, OR DELETION OF YOUR PERSONAL INFORMATION. IN NO EVENT SHALL THE QLM PARTIES’ TOTAL AGGREGATE LIABILITY FOR ALL DATA-RELATED CLAIMS EXCEED THE LESSER OF (A) THE TOTAL AMOUNT YOU HAVE ACTUALLY PAID DIRECTLY TO QLM IN THE TWELVE (12) MONTHS IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM, OR (B) ZERO DOLLARS ($0.00).

14. Release of Claims

TO THE MAXIMUM EXTENT PERMITTED BY LAW, YOU HEREBY RELEASE, WAIVE, AND FOREVER DISCHARGE THE QLM PARTIES FROM ANY AND ALL CLAIMS, DEMANDS, DAMAGES, LOSSES, COSTS, EXPENSES, AND LIABILITIES OF EVERY KIND AND NATURE, WHETHER KNOWN OR UNKNOWN, SUSPECTED OR UNSUSPECTED, DISCLOSED OR UNDISCLOSED, THAT HAVE ARISEN OR MAY ARISE FROM YOUR USE OF THE SERVICES OR ANY DATA HANDLING PRACTICES DESCRIBED HEREIN. IF YOU ARE A CALIFORNIA RESIDENT, YOU EXPRESSLY WAIVE THE PROTECTIONS OF CALIFORNIA CIVIL CODE SECTION 1542, WHICH PROVIDES: “A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS THAT THE CREDITOR OR RELEASING PARTY DOES NOT KNOW OR SUSPECT TO EXIST IN HIS OR HER FAVOR AT THE TIME OF EXECUTING THE RELEASE AND THAT, IF KNOWN BY HIM OR HER, WOULD HAVE MATERIALLY AFFECTED HIS OR HER SETTLEMENT WITH THE DEBTOR OR RELEASED PARTY.” YOU EXPRESSLY WAIVE ANY SIMILAR STATUTE OR COMMON LAW PRINCIPLE IN ANY APPLICABLE JURISDICTION.

15. Indemnification

You agree to indemnify, defend, and hold harmless the QLM Parties from and against any and all claims, demands, actions, suits, proceedings, investigations, losses, damages, judgments, fines, penalties, liabilities, costs, and expenses (including reasonable attorneys’ fees, expert witness fees, and court costs) arising out of or related to: (a) your use of or access to the Services; (b) any personal information you provide to us or through the Services; (c) your violation of this Privacy Policy or any applicable law, regulation, or third-party right; (d) any dispute between you and any third party relating to your personal information or our handling thereof; (e) any claim that our processing of your data in accordance with this Policy caused harm to any third party; or (f) your failure to comply with any data protection obligation applicable to you. This indemnification obligation is unconditional, shall survive the termination of your account and your use of the Services indefinitely, and shall apply regardless of the form of action or the legal theory asserted.

16. No Guarantee of Data Accuracy or Completeness

QLM makes no warranty or representation regarding the accuracy, completeness, currency, or reliability of any data or personal information stored, processed, or transmitted through the Services. You acknowledge that data may be subject to errors, omissions, corruption, unauthorized modification, or loss, and that QLM shall have no liability for any inaccuracies in data, regardless of cause. You are solely responsible for maintaining independent backups of any data you consider important.

17. No Guarantee of Deletion

While QLM will make commercially reasonable efforts to honor deletion requests in accordance with applicable law, you acknowledge and agree that: (a) deleted data may persist in backup systems, disaster recovery archives, and cached copies for a reasonable period; (b) aggregated, anonymized, or de-identified data derived from your personal information may be retained indefinitely; (c) data shared with third-party service providers prior to deletion may not be retrievable; and (d) QLM shall have no liability for any failure to completely delete data from all systems, backup media, or third-party systems.

18. Changes to This Privacy Policy

We reserve the right to modify, update, or replace this Privacy Policy at any time, at our sole discretion, with or without prior notice. Changes will be effective immediately upon posting the revised Policy on our website with an updated effective date. Your continued use of the Services following the posting of any changes constitutes your acceptance of such changes. It is your sole responsibility to review this Policy periodically. We may, but are not obligated to, notify you of material changes via email or through a notice on our Services.

19. Do Not Track Signals

Some browsers transmit “Do Not Track” (DNT) signals to websites. Due to the lack of a common industry standard for interpreting DNT signals, our Services do not currently respond to DNT signals. We will continue to monitor developments in DNT standards and may update our practices accordingly.

20. California Privacy Rights

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”), including the right to know what personal information we collect, the right to delete your personal information, the right to opt out of the sale or sharing of your personal information, and the right to non-discrimination for exercising your privacy rights. We do not sell personal information as defined by the CCPA/CPRA. To exercise your California privacy rights, please contact us at hello@quantumlearningmachines.com.

21. Dispute Resolution for Privacy Claims

Any dispute, claim, or controversy arising out of or relating to this Privacy Policy or our data handling practices shall be resolved exclusively through final and binding individual arbitration administered by the American Arbitration Association (“AAA”) in the State of Delaware, in accordance with the Terms of Service. You waive any right to participate in a class action, class-wide arbitration, or representative proceeding relating to data privacy claims. Any claim must be brought within one (1) year of the date on which the claim accrued, or such claim is permanently barred.

22. Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the State of Delaware, United States of America, without regard to its conflict of laws principles. To the extent permitted by applicable law, the provisions of this Policy that are most protective of QLM shall prevail in the event of any conflict with any other applicable law or regulation.

23. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Quantum Learning Machines
Email: hello@quantumlearningmachines.com

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