Privacy Policy

Overview

Hologram Learning Inc. ("Hologram," "we," "us," or "our") is committed to protecting the privacy of students, educators, and schools that use our platform. This Privacy Policy describes how we collect, use, disclose, and safeguard information in connection with our services.

Student data is the most sensitive data in education. We treat it accordingly. We do not sell student data. We do not use student data for advertising. We use student data only to provide the educational services your school has contracted for.

FERPA Compliance

Hologram operates as a "school official" under FERPA (the Family Educational Rights and Privacy Act, 20 U.S.C. § 1232g) with a legitimate educational interest in the education records provided by our school and district partners. We:

• Maintain education records for a minimum of 7 years as required by FERPA
• Provide full audit logs with correlation IDs for all access to student education records
• Respond to data access requests within 30 days
• Provide complete data deletion upon school request, including AI interaction history and mastery records

COPPA Compliance

For students under 13, we comply with the Children's Online Privacy Protection Act (COPPA). Specifically:

• Schools provide consent on behalf of parents for the collection of personal information from students under 13, consistent with COPPA's school consent exception
• AI tutoring sessions for students under 13 include additional content guardrails reviewed by our education team
• Voice features and persistent identifiers for under-13 students require verified parental consent
• We do not collect more information than is necessary to provide educational services

GDPR Rights

For users in the European Economic Area (EEA), you have additional rights under the General Data Protection Regulation (GDPR), including the right to access, correct, and delete your personal data. Our data deletion pipeline covers all user data including student mastery records, AI interaction history, and behavioral telemetry.

To exercise your GDPR rights, contact us at privacy@hologramlearning.com.

Data We Collect

We collect only the data necessary to provide our educational services:

• Account data: Name, email address, school affiliation, role (teacher/student)
• Assignment submissions: Student work submitted through the platform
• Mastery data: AI-derived mastery scores per learning standard (not raw behavioral telemetry)
• AI interaction logs: Records of AI tutoring sessions, retained for FERPA compliance

We do not collect or store raw behavioral telemetry such as mouse movements or keystroke timing. We store only derived cognitive scores.

Contact Us

If you have questions about this Privacy Policy or your data rights, contact our privacy team at privacy@hologramlearning.com.

Hologram Learning Inc.
privacy@hologramlearning.com