Privacy Statement

Zeteo Education, Inc. (“Zeteo,” “we,” or “us”) is built on the principle of transparency. Zeteo respects the privacy of individuals who visit our website at https://www.zeteoED.com (our “Website”) and who interact with our platform and services (collectively, the “Services”).

This Privacy Statement explains how we collect, use, disclose, and protect Personal Information, and the choices you have regarding your information. “Personal Information,” as used in this Privacy Statement, means any information that can be used to identify an individual or a household.

Our Services are designed to support students, teachers and their schools in the pursuit of better educational attainment. We take our responsibility to protect student data seriously. We do not:

• sell student data
• send targeted advertising to students
• create student profiles except for educational purposes designated by the school or educational institution that uses our platform; or
• use student work to train external, third-party Large Language Models (LLMs).

Our Services are designed to comply with FERPA, COPPA and U.S. state standards to protect student data and educational records.

We may collect your Personal Information when you:

• Visit our Website;
• Use our Services; or
• Contact Us.

Integrating with Learning Management Systems: When you access or use our Services through a learning management system integration, we may receive information about you, including education records protected under the U.S. Family Education Rights and Privacy Act, in our role as a service provider acting at the direction of your educational institution.

Personal Information we collect may fall into any of the following categories:

• Identifiers such as your first and last name, email address, user account name, or other similar identifiers;
• Protected characteristics (applicable when provided to Zeteo by your educational institution) such as your gender, age, race, or other protected classifications under applicable law;
• Audio, electronic, or similar information such as metadata collected by our platform that reflects time on task and student electronic tool and educational software usage as needed to provide analytics data about you to your educators;
• Education information such as your year in school, education history, and assignment completion data, to the extent your educational institution applies our Services to this data; or
• Communications. When you contact us, we may maintain a record of that communication including any Personal Data you provide in the communication.

You may choose not to provide Personal Information or withdraw any consent you may have provided to our processing your information at any time, although it may affect our ability to provide you with relevant information or Services.

Information collected through use of our platform

Your school or educational institution uses the Zeteo platform only for courses or assignments selected by your educators. Zeteo does not store the text of student writing during the drafting process. During the student drafting process, the platform captures only process metadata, including keystroke timing, segment type, edit counts, and pasting - not the actual words typed. Text of student writing is captured only when a student submits a final written assignment. Final submitted written assignments are retained for a maximum of 180 days and may be deleted earlier upon request from your school or educational institution.

The Zeteo platform also includes an Assignment Feedback feature that allows teachers to send written feedback to students about a specific assignment review, and allows students to respond within that same assignment context. These messages are stored with the relevant final assignment record and are visible to the student, the assigning teacher, and authorized school or educational institution. Assignment Feedback is limited to communication about a specific assignment. Zeteo does not provide general-purpose messaging, direct messages, group chats, or open-ended communication between users outside of the assignment review workflow.

Information we may collect automatically

Website Analytics Data: Our Website does not set cookies, but does automatically collect aggregate visitor analytics data that do not involve cookie-based tracking. The cookieless analytics tool we use does not track individual end users or site visitors. The aggregate analytics data collected helps us analyze trends and administer our Website. This information may include the following categories of Internet or other electronic network activity information:

• Browser type and settings
• Referring website
• Country of origin of Website visitors
• Device type (i.e. desktop/laptop/mobile)
• Pages visited, load times, time spent, and number of visitors to our Website

Services Interaction Data: We collect information about your interaction with certain components of our Services, including our platform. On our Website, this information includes pages viewed, time spent on a page, and load times. When you use the Zeteo platform, we collect information about your interactions with educational features so we can support teacher assessments and educational measurements. This includes the educational resources accessed, time spent on assignments, pages viewed, paste events, edit counts, segment types, and other process metadata generated during your work.

Information collected from Third Parties

To better provide our Services fully integrated with software provided to you or your educators by your educational institution, we may combine the Personal Information we collect about you through one source (such as your school) with additional Personal Information obtained from other sources, such as LMS providers with which your educational institution has contracted to support you.

When your educational institution integrates our platform with other software it uses —such as a Learning Management System — we may receive Personal Information about you from your educational institution to allow our platform to connect your work to the right account. Zeteo does not use cross-site Internet tracking, advertising identifiers, or device fingerprinting to identify you.

In addition to the uses described above, we may use information that we collect about you for any of the following purposes:

• To provide our Services, including to allow teachers and your educational institutions to assess student work, monitor student progress and monitor academic integrity, and to provide real-time Socratic “Nudges” via the Help button on our platform.
• To improve and optimize our Services
• To communicate with you and respond to your inquiries and requests
• To send administrative messages (such as policy updates or security notices)
• To monitor and protect the security and integrity of our Website and Services
• To carry out our contractual obligations and enforce our contractual rights.
• For any other purpose with your consent.

We may use aggregated, de-identified data (that can no longer be associated with you) for research, statistical purposes, product improvement and to publish aggregated outcome data demonstrating educational impact of our Services.

Our legal basis for collecting and using your Personal Information depends on the Personal Information concerned, the specific context in which we collect it and how it is to be used. In most contexts, Zeteo acts as a processor or service provider for a data controller educational institution. In those situations, we process Personal Information only on documented legally-compliant instructions from the controller entity.

In the limited situations where Zeteo acts as a data controller, we process your Personal Information under one or more of the following bases:

• Consent
• Where necessary to perform a contract
• Compliance with our legal obligations, and
• Legitimate interests where doing so does not outweigh your rights and freedoms, such as to protect the integrity of our software and platform, protect our intellectual property or the intellectual property of educational institutions, provide and improve our Services, and to ensure compliance with applicable laws.

If you provided consent for a specified use of your Personal Information, you may withdraw consent at any time. If you withdraw your consent, it will not affect the lawfulness of any processing based on your consent before you withdrew it. Where applicable, we may ask for your consent to processing at the point where you provide your Personal Information.

We may disclose your Personal Information for any purpose with your consent. We will not disclose your Personal Information to third parties for their own marketing purposes without your consent.

We may share your Personal Information with third parties for the following limited purposes:

A. Third-Party Service Providers

We may share your Personal Information with third-party service providers to help us operate our Website and provide you our Services. These third parties include providers of enterprise-grade Artificial Intelligence tools (such as Google Gemini) that help power our platform. Data sent to these APIs is encrypted and governed by “No Training” agreements to ensure student work remains the property of students and/or their educational institution.

A current list of our sub-processors is maintained at https://www.zeteoed.com/subprocessors and is updated as our vendor relationships change. We will notify schools of material changes in advance.

Some of our service providers may engage their own service providers or business partners to further assist us. In these instances, the receiving party is not permitted to retain, use or disclose Personal Information for any purpose other than for performing the specific business purpose on our behalf. We require each service provider to be bound by contractual clauses to protect your Personal Information in compliance with data protection legislation and to limit the receiving party from retaining, using or further disclosing the Personal Information for any purpose other than for performing the specific business purpose on our behalf.

B. Where Required by Law or for other Protective Reasons

We may disclose Personal Information when we believe disclosure is necessary to:

• Comply with applicable law, regulation, or legal process
• Respond to lawful requests from public authorities
• Protect the rights, safety, and security of Zeteo, our users, or students
• Prevent fraud, abuse, or security incidents
• Enforce our agreements and policies

C. In the Context of a Merger, Acquisition or Sale

We may share your Personal Information with potential transaction partners, service providers, advisors and other third parties in connection with negotiation or completion of a corporate transaction in which Zeteo is acquired by or merged with another company or in which we sell or transfer all or a portion of our assets or business.

Some web browsers may give you the ability to enable a “Do Not Track” (DNT) setting that tells a website that a user does not want their online activity to be tracked. This DNT signal is different from disabling certain forms of tracking by declining cookies in your browser settings, as browsers with DNT enabled still have the ability to accept cookies.

Our Website does not currently deploy tracking cookies and does not respond to DNT. If we do so in the future, we will describe our approach in this Privacy Statement. For more information about DNT, visit www.allaboutdnt.com.

Likewise, our Website does not take action in response to Global Privacy Control (GPC) signals because our Website does not currently deploy tracking cookies. GPC is a specification designed to allow Internet users to notify businesses of their privacy preferences, such as whether or not they want to be tracked or have their personal information sold or shared with third parties for targeted advertising. Because we do not engage in the practices that GPC is designed to address, there is no activity on our Services for a GPC signal to disable. If our data practices change in the future, we will update this Privacy Statement and honor applicable opt-out signals.

We retain Personal Information only for as long as reasonably necessary for the purposes for which it was collected, including to provide our Services. This retention will continue in accordance with our retention practices and legal requirements as necessary, for example, to comply with our legal obligations, resolve disputes, and enforce our agreements.

Zeteo does not store the text of student writing during the drafting process. During the student drafting process, the platform captures only process metadata, including keystroke timing, segment type, edit counts, and pasting - not the actual words typed. This process metadata and AI interaction logs are retained for no longer than 180 days from data creation. Text of student writing is only captured when a student submits a final written assignment. Final submitted written assignments and Assignment Feedback messages are retained only for a maximum of 30 days after the duration of a school or educational institution’s contract with Zeteo, and may be deleted earlier upon request from your school or educational institution.

We may anonymize your Personal Information (so that it can no longer be associated with you) for research, statistical purposes, product improvement and to publish aggregated outcome data demonstrating educational impact of our Services.

The security of your Personal Information is important to us. We follow generally accepted standards to protect your Personal Information from misuse, interference and loss, as well as from unauthorized access, modification and disclosure. We have implemented technical, administrative and physical security measures to protect your Personal information, including:

• Using encryption at rest and in transit when collecting or transferring sensitive Personal Information;
• Limiting access to the information we collect about you;
• Applying credential revocation procedures when we have personnel changes;
• Ensuring that we and our service providers have appropriate security safeguards to keep Personal Information secure; and
• Where required by law, destroying or de-identifying Personal Information.

To keep our platform running smoothly, we use a developer error-monitoring service to detect platform errors, crashes, and performance issues so they can be fixed promptly. The monitoring service is triggered only when the platform encounters an error or performance problem; it does not record general user activity or browsing behavior. As an added precaution, error reports are configured to scrub personally identifiable information before transmission. Error logs are retained for 90 days.

While we strive to protect your information, no data transmission over the Internet is 100% secure and, consequently, we cannot guarantee or warrant absolute security of any information you transmit over our Website.

Our Services are only provided to children with parental or guardian consent, typically by consent provided to a child’s school or educational institution, in accordance with applicable law. If you believe that a child has provided their information to Zeteo without parental or guardian consent, please contact us at privacy@zeteoed.com, so that we can take steps to delete it.

Consistent with FERPA and state student privacy laws, Zeteo does not direct targeted advertising to students based on their data, does not sell student data, and does not create student profiles except for educational purposes designated by the school or educational institution that uses our platform.

Data collected on our Website:

Depending on where you live, you may have certain rights with respect to Personal Information collected on our Website.

A. U.S. State Privacy Rights (Including California)

Certain U.S. state laws may provide residents with rights such as:

• The right to know what Personal Information is collected
• The right to access Personal Information
• The right to delete Personal Information (subject to exceptions)
• The right to correct inaccurate Personal Information
• The right to opt out of certain processing, such as targeted advertising (where applicable)
• The right to direct that your Personal Information not be sold (where applicable)
• The right to direct that your Personal Information not be shared with third parties for targeted advertising purposes (where applicable)

Zeteo does not sell or share Personal Information with third parties for monetary consideration. Zeteo also does not share Personal Information for targeted advertising purposes.

B. EU/UK/Swiss Rights

If you are located in the EU, UK, or Switzerland, you may have the right to:

• Access your Personal Information
• Request correction (rectification) of inaccurate information
• Request deletion of your information
• Restrict or object to certain processing
• Request portability of your information
• Withdraw consent where processing is based on consent
• Lodge a complaint with a data protection authority

You also have the right not to be discriminated against for exercising your rights.

To make a request regarding your privacy rights, please contact us by email at privacy@zeteoed.com with the subject line “Privacy Rights.” When you make a request, we will validate your request by verifying your identity (for example, by confirming that the email you use to make a request matches an email address we have collected about you). If you have questions or requests related to your rights under U.S. state privacy laws, you (or your authorized agent) can also contact us at privacy@zeteoed.com. If you disagree with the decision made on your request, you can ask us to reconsider it by responding to our email.

Data collected on our Platform:

Administrators at your school or educational institution have service controls that can allow you to manage personal information, including limiting its further collection or use, on our platform. If you or your child uses our platform at school, contact your administrator to:

• Access your personal information
• Limit access to features or Services
• Revoke parental consent to use our Services
• Delete your or your child’s Personal Information from the Services

We may modify this Privacy Statement from time to time. We will notify you of changes by posting changes on the Website or by other appropriate means and the effective date of the updated policy.

Should you have any questions or concerns about this Privacy Statement, our privacy practices or how to exercise your privacy rights, please contact us by email at privacy@zeteoed.com or by phone at (301) 882-9589.

You can also contact us by postal mail at: