Heliomath Privacy Policy

1. Who we are

Heliomath is an educational mathematics service operated by Heliomath PBC (formerly Grokkoli, PBC), a public benefit corporation incorporated in the State of Delaware, United States.

Heliomath PBC
8 The Green, Suite D
Dover, DE 19901
United States
privacy@heliomath.com · +1 702-720-6456

In this policy, "Heliomath," "we," "us," and "our" mean Heliomath PBC. "You" means the person reading this policy — usually a parent, legal guardian, teacher, or school administrator.

Contact for privacy matters: privacy@heliomath.com, or write to us at the address above.

Where the law of your country requires us to designate a local representative or a data protection officer in your jurisdiction, their contact details are published at heliomath.com/legal/contacts.

2. How Heliomath is provided, and what that means for your data

Heliomath reaches learners through three distinct channels, and the answer to "who decides what happens to this data" differs between them.

Family accounts. A parent or legal guardian creates an account, adds one or more learner profiles, and pays for the subscription directly. In this arrangement Heliomath determines the purposes and means of processing, and is therefore the entity responsible for that data under applicable data protection law.

School and institutional accounts. A school, district, ministry, or other institution provisions accounts for its students, typically without any payment or account creation by a parent. In this arrangement the institution determines which students use the Service and what student information is provided to us, and we process that information to deliver the Service to the institution and its students.

Educator accounts. An individual educator, tutor, microschool, or other small programme creates an account and adds learners who are not their own children. In this arrangement the account holder decides which learners use the Service and is responsible for obtaining the consent of each learner's parent or guardian; we determine the purposes and means of processing in the same way as for family accounts.

Where applicable law distinguishes between a "controller" and a "processor" (or equivalent terms), the allocation of those roles for an institutional deployment is set out in the written agreement between Heliomath and the institution. Nothing in this policy overrides that agreement or any obligation that applicable law places on us directly.

3. Information we collect

3.1 Information you give us

Account holder information. When a parent, guardian, teacher, or administrator creates or manages an account, we collect name, email address, username and password, and — for paid family and educator accounts — billing information processed by our payment provider. We do not store full payment card numbers. If you ask us to give another person access to your learners' information, we collect that person's email address from you.

Learner information. For each learner using the Service we collect a profile name and a grade level. Where an institution provisions accounts, we may also receive a student identifier assigned by the institution, and a class or teacher assignment.

Communications. If you contact support, respond to a survey, or otherwise write to us, we keep that correspondence and any information in it.

3.2 Information we generate as you use the Service

Learning and activity information. Responses to problems, time taken, sequences attempted, progress against learning objectives, and content submitted within the Service.

3.3 Information collected automatically

IP address, device and browser type, operating system, device identifier, and timestamps of access. We may use IP address to infer approximate region in order to align content with local educational standards.

3.4 Information we do not collect

We do not ask for, and do not require, a learner's date of birth, home address, telephone number, photograph, biometric identifiers, or precise location.

We do not ask for or store clinical, diagnostic, or medical information about a learner, including diagnosed learning disabilities, individualized education program records, or assessment results produced outside the Service. Heliomath adapts to a learner's demonstrated performance within the Service; it does not require, and is not designed to receive, a diagnosis. If you or your institution believe such information needs to be shared with us, contact us first — in most jurisdictions this category of information carries additional legal requirements and we will want to address them before receiving it.

4. How we use information

We use the information described above to:

• provide, operate, and maintain the Service, including personalising the sequence of instruction for each learner;

• create and manage accounts, and authenticate users;

• report learner progress to the parent, guardian, teacher, or institution responsible for that learner;

• provide customer support and respond to your requests;

• detect, investigate, and prevent fraud, abuse, and security incidents;

• comply with legal obligations and enforce our Terms of Service;

• improve the Service, including evaluating whether it is working, and conducting research into how learners acquire mathematical understanding; and

• communicate with account holders about the Service, including changes to it.

We do not use learner information to build advertising profiles, and we do not use it for any purpose unrelated to education and the operation of the Service.

Artificial intelligence and model training. We do not use learner information to train artificial-intelligence models that are made available to third parties or outside the Heliomath service. We do use learner information to improve how Heliomath itself teaches — the models that select and sequence instruction within the Service are our own, and they stay within it.

5. Automated personalisation and how it works

Heliomath personalises instruction automatically. Because some data protection laws require us to explain this, here is what the system does.

What it observes. A learner's answers within the Service, whether they were correct, how long they took, which representations and problem types they have seen, and patterns in the errors they make.

What it decides. Which problem, which visual representation, and which learning objective to present next, and when to revisit material previously covered.

What it does not decide. It does not diagnose a learning disability or any medical or psychological condition. It does not assign a grade or a school mark. It does not determine placement into or out of any educational programme, class, or support service, and it does not make any decision that produces legal effects for a learner or similarly significantly affects them.

Human oversight. A teacher or account holder can see what the system has presented and can direct a learner to different material. Decisions with consequences for a learner outside the Service are made by the learner's teachers and school, not by Heliomath.

Your options. Where applicable law gives you the right to object to automated processing or to request human involvement, you may contact us using the details in Section 1. Personalisation is integral to the Service, so in practice we will discuss with you whether the Service can be provided in a modified form or whether it should be discontinued for that learner.

6. Our legal basis for processing

Where the law of your jurisdiction requires us to identify a legal basis for processing personal data, we rely on one or more of the following, depending on the information and the circumstances:

• Consent — of the account holder, or of a parent or legal guardian in respect of a learner, where consent is the applicable basis.

• Performance of a contract — to provide the Service you or your institution have signed up for.

• Legitimate interests — to secure the Service, prevent fraud and abuse, and improve how the Service teaches, where those interests are not overridden by your rights.

• Legal obligation — where we are required by law to process or retain information.

• Research — where permitted by applicable law, for scientific or statistical research into learning, using information that has been de-identified wherever possible.

Where consent is the basis for processing, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before you withdrew it, and may mean we can no longer provide the Service.

7. Children and parental consent

Heliomath is built for children, and most learners using it are minors. We take the following approach wherever we operate.

Who must consent. Before we collect personal information from a learner, we require the consent of a parent or legal guardian — or of another person who holds parental responsibility for that child under the law of their jurisdiction — where the learner is:

• under 13 years of age; or

• below the minimum age at which an individual may consent to the processing of their own personal data under the law of their jurisdiction, where that age is higher than 13.

Because that threshold varies — it is 13 in some jurisdictions and 16 or higher in others — we apply whichever standard is more protective of the learner.

Who may give that consent. Consent must come from a parent, legal guardian, or other holder of parental responsibility, unless the law of the learner's jurisdiction expressly permits a school or educational authority to provide or convey it on their behalf. Where such delegation is permitted and an institution provides consent on that basis, the institution warrants to us that it has the authority to do so. Where such delegation is not permitted, we require consent to be obtained from the parent or guardian directly, and we require evidence that it was obtained before a learner account is created.

Learners aged 13 to 17. A learner under 18 may use the Service only with the involvement of a parent or legal guardian, or as part of an educational programme directed by their school or another educational provider.

Withdrawal. A parent, guardian, or institution acting on their behalf may withdraw consent at any time by contacting us. On withdrawal we will stop processing that learner's personal information and delete it in accordance with Section 11.

If we learn we have information we should not have. If we become aware that we have collected personal information from a learner without the consent required by their jurisdiction, we will stop processing it, delete it, and notify the account holder or institution.

8. Cookies and similar technologies

8.1 Inside the Heliomath learning application

Within the learning application — every page a learner sees, and every account provisioned by a school or institution — we use cookies for two purposes only:

Purpose	What it does
Authentication and security	Keeps you signed in, protects your account from unauthorised access, and helps us detect fraud.
Product features	Remembers which learner is currently working so the Service presents the right material.

We do not operate advertising or marketing technology of any kind inside the learning application, and none on any account provisioned by a school or institution.

8.2 On our marketing pages and during signup

This section covers our public marketing pages and the signup and payment steps that follow — everything that happens before a learner profile exists. It does not describe the learning application, and no learner is involved in any of it.

On those pages we use analytics and advertising measurement tools provided by Meta, TikTok, Google Analytics, and Google Ads, to understand how visitors find us and whether our advertising reaches families who go on to subscribe. When a subscription begins, we also send those providers a one-way cryptographic hash of the email address used, so that the provider can confirm one of our advertisements led to a subscription.

The person concerned at every one of these steps is an adult creating or paying for an account. A learner profile can only be added after signup is complete, so no learner exists in our system while any of this takes place. These tools do not operate within the learning application, and they do not operate on accounts provisioned by a school or district.

You can control cookies through your browser or device settings. Disabling cookies used for authentication will prevent the Service from working.

9. How we share information

We do not sell or rent personal information, and no learner information is ever shared for advertising.

Nothing about a learner — no name, no profile, no answers, no progress, no record of anything they did inside the Service — is provided to an advertising or analytics company, for any purpose. That is true of every account, whether a family created it or a school provisioned it, and there is no advertising or marketing technology of any kind inside the learning application. We do not permit anyone we work with to use learner information for their own purposes.

The analytics and advertising measurement tools described in Section 8.2 operate on our marketing pages and during signup, before any learner profile exists. The person concerned is always an adult creating or paying for an account, never a learner. Those providers are configured to process what they receive only to report results to us, and not for their own advertising purposes.

We share information only as follows.

Service providers. We use third parties to host the Service, process payments for family and educator accounts, send transactional email, and provide customer support tooling. They receive only what they need to perform that function, and they are bound by written contracts that require them to process the information only on our instructions and to protect it. A current list of these providers is available at heliomath.com/legal/subprocessors.

Schools and institutions. Where an institution has provisioned a learner's account, we share that learner's progress and activity information with the institution and its authorised staff.

Parents and guardians. We share a learner's progress and activity information with the account holder responsible for that learner.

Other people you authorise. An account holder can give another person access to their learners' progress and activity information — for example, a parent sharing with their child's teacher, or a teacher sharing a class with a colleague. The person you name must accept the invitation from their own account before anything becomes visible to them, and you can remove that access at any time. For educator and institutional accounts we allow this only where both accounts share the same organisational email domain, or where both are assigned to the same school or district in our systems; we do not allow it between unrelated domains or between accounts on shared consumer email services. For institutional accounts, an administrator can see and remove every access grant on that account, including grants they did not make.

Aggregated and de-identified information. We may share information that has been aggregated or stripped of identifiers such that it cannot reasonably be used to identify an individual — for example, average progress by grade level — including with researchers studying mathematics learning.

Legal and safety. We may disclose information where we reasonably believe it is necessary to comply with applicable law or legal process, to enforce our Terms of Service, to investigate fraud or a security incident, or to protect the rights, property, or safety of any person.

Business transfers. If we are involved in a merger, acquisition, financing, or sale of assets, personal information may be transferred as part of that transaction. We will notify affected account holders and institutions before any such transfer takes effect, and the information will remain subject to a policy no less protective than this one.

10. Where information is stored, and transfers between countries

We store and process personal information in the United States, where our primary hosting region is located in Oregon, and with the service providers described in Section 9.

We also use content delivery networks to cache images and other static assets closer to where they are viewed, so that pages load faster. These networks do not carry personal information.

Where the law of a learner's country requires that their personal data be stored within that country, or requires authorisation before it may be stored elsewhere, we will make the Service available in that country only once we have arrangements in place that satisfy that requirement. If you are an institution and you are subject to such a requirement, contact us before provisioning accounts so that we can confirm what is in place.

Where we transfer personal information across borders, we do so on a lawful basis under the applicable law, which may include the consent of the individual or their parent or guardian, the necessity of the transfer to provide the Service, or an authorisation obtained from the relevant authority. Any party authorised to receive personal information for transfer outside its country of origin is bound by a written contract setting out each party's responsibilities.

11. How long we keep information

We keep personal information only for as long as it is needed for the purposes described in this policy, and then delete it in a manner that prevents it from being reconstructed.

Cancelling a subscription is not the same as deleting your information. When you cancel a subscription, paid access ends. Your account and your learner's records stay as they are, so that you can subscribe again later and pick up where your learner left off — families do this often, and losing everything in between would not serve them. We do not keep them indefinitely, though. Where an account has had no activity for 24 consecutive months and has no active subscription, we dissolve it automatically, as described next.

Dissolving an account. You can ask us to dissolve an account at any time, whether or not you currently have a subscription, by writing to privacy@heliomath.com. When an account is dissolved we permanently destroy the information that identifies a learner and their account holder: first name, family name, and email address. These fields are overwritten, not hidden or marked inactive, and the original values are not kept anywhere. There is no key, mapping, or copy that would allow them to be recovered — not by us, and not by anyone else.

Dissolution takes effect immediately in our active systems and is complete across our backups within 15 days. A dissolved account cannot be restored.

Where a learner's account was provisioned by a school or district, any identifier assigned by that institution — such as a Clever or ClassLink ID — and any sign-in record linking the account to that provider are deleted outright rather than overwritten, so that no mapping between our records and the institution's records remains.

What we keep afterwards, and why. We retain the remaining learning records — the problems attempted, whether the answers were correct, the time taken, and the grade level — to study how children acquire mathematical understanding and to improve how Heliomath teaches.

Because those identifiers have been destroyed everywhere they appeared — and because we check that they have — what remains cannot be traced back to a learner. We hold no key, no mapping, and no archived copy that would allow it. That is why we retain these records without a time limit. We do not attempt to re-identify them, and we do not combine them with other information in order to do so.

If you would rather we did not keep them. If you prefer that we delete a learner's learning records outright rather than retain them in this de-identified form, tell us at privacy@heliomath.com and we will. Ask us when you request dissolution, or before. Once an account has been dissolved we can no longer find that learner's records — not because we are unwilling, but because nothing remains that connects them to a person.

Correspondence with us. We correspond with parents, guardians, and school staff — never with learners directly. We keep that correspondence for the duration of our relationship with the account holder or institution and for three years afterwards, so that we have a record of what was asked and what we did about it. Occasionally a teacher or parent writes to us about a particular child by name; where that happens, the name stays in the message as part of the record rather than being edited out of it. We ask school staff to refer to learners by their account identifier rather than by name when writing to us, and we do not copy learner names from correspondence into our systems.

Category	Retained
Account holder name and email	Kept for as long as the account exists. Permanently destroyed when the account is dissolved — on request, or automatically after 24 consecutive months with no activity and no active subscription; complete across backups within 15 days
Learner first name	Kept for as long as the account exists. Permanently destroyed when the account is dissolved — on request, or automatically after 24 consecutive months with no activity and no active subscription; complete across backups within 15 days
Institution-assigned identifiers (Clever, ClassLink, student number)	Deleted when the account is dissolved, or when the relationship with the institution ends, whichever is first
Learning records, after dissolution has removed the identifiers	Retained without a time limit; these records no longer identify a learner
Support correspondence with parents, guardians, and school staff	For the duration of our relationship with the account holder or institution, and three years afterwards
Security and access logs	24 months
Payment and billing records	Held by our payment provider under its own retention policy; we do not store payment records in our systems
Record of consent	Recorded on the account record and kept with it. The identifying fields on that record are destroyed when the account is dissolved, as described above

Where an institution has provisioned accounts, deletion follows the institution's instructions and the agreement between us, and may occur sooner than the periods above.

We may retain information for longer where we are required or permitted to do so by law — for example to comply with a legal obligation, to establish or defend a legal claim, or to comply with an order of a court or a competent authority. Information that has been aggregated, so that it no longer relates to any individual learner, is not subject to these periods.

12. How we protect information

We maintain technical and organisational measures appropriate to the risk, including encryption of data in transit and at rest, access controls limiting staff access to what their role requires, logging of access to and disclosure of personal information, separation of environments, and periodic review of our security practices.

No system is completely secure, and we do not promise that information will always remain secure. Please use a strong, unique password and do not share your credentials.

13. If there is a data breach

If personal information is affected by a security breach, we will notify the relevant supervisory authority within the time required by applicable law, and — where the breach is likely to result in a high risk to the rights and freedoms of affected individuals — we will notify those individuals and, where applicable, the institution that provisioned their accounts. Some jurisdictions require notification within a short fixed period, and our internal procedures are set to the shortest applicable deadline.

14. Your rights

Depending on the law of your jurisdiction, you may have some or all of the following rights in relation to personal information about you or about a learner for whom you are responsible:

• Access — to obtain confirmation that we process the information, a copy of it, and information about its sources and recipients.

• Rectification — to have inaccurate or incomplete information corrected.

• Erasure — to have information deleted.

• Restriction — to have us limit how we use information while a question about it is resolved.

• Objection — to object to processing, including processing based on our legitimate interests.

• Portability — to receive information you provided to us in a structured, commonly used, machine-readable format, and to have it transmitted to another provider where technically feasible.

• Automated decisions — to be protected from decisions based solely on automated processing that produce legal or similarly significant effects, and to request human involvement.

• Withdrawal of consent — where processing is based on consent.

• Succession — where the law of your jurisdiction provides for it, to designate how information should be handled after your death.

How to exercise them. Contact us using the details in Section 1, or — if a learner's account was provisioned by a school or institution — contact the institution, which can also pass a request to us. You may also review and update much of this information yourself in the Service, under "Learners," "Learning Objectives," "Learning Progress," "Account Settings," and "Subscription."

Our response. We will respond within 30 days of receiving a request, or sooner where applicable law or an agreement with your school or institution requires it. If we need more time or cannot fulfil a request, we will tell you why. We may need to verify your identity, or your authority in respect of a learner, before acting. We do not charge for this.

If we say no. If we decline a request, we will tell you why, and you may appeal by writing to privacy@heliomath.com with "Appeal" in the subject line. We will review the decision afresh and respond within 45 days with our decision and our reasons. If we deny the appeal, we will tell you how to complain to your state attorney general or your data protection authority.

We will not treat you differently for asking. Exercising any of these rights will not cause us to deny you service, charge a different price, or provide a lower quality of service.

Institutional accounts. Where a school or institution provisioned a learner's account, we may be required to direct certain requests — particularly deletion — to that institution, and we will tell you when that is the case and who to contact.

15. Cancelling and deleting

You may cancel a subscription at any time from "Subscription." Cancelling ends paid access and stops billing. It keeps your account and your learner's records, so that you can subscribe again later without starting over — it does not delete anything.

If you want your information destroyed, ask us to dissolve the account: write to privacy@heliomath.com, and see Section 11 for what dissolution removes and what it leaves behind. An account with no activity for 24 consecutive months and no active subscription is dissolved automatically. A dissolved account cannot be restored.

For accounts provisioned by a school or institution, cancellation and deletion are handled by the institution under our agreement with it.

16. Complaints

If you have a concern about how we handle personal information, please contact us first using the details in Section 1 — we would rather hear about it and fix it.

You also have the right to lodge a complaint with the data protection or privacy authority in your country or region, where one exists. We will tell you how to reach the relevant authority if you ask.

17. Links to other sites

Our website may link to sites we do not operate. This policy does not apply to them, and we are not responsible for their content or their privacy practices.

18. Changes to this policy

We update this policy from time to time. When we do, we revise the "Last updated" date above. Where a change materially affects how we handle personal information, we will notify account holders and institutions before it takes effect. Where applicable law requires fresh consent for a change, we will obtain it.

19. Contact us

Heliomath PBC (formerly Grokkoli, PBC)
8 The Green, Suite D, Dover, DE 19901, United States
privacy@heliomath.com · +1 702-720-6456

Data protection officers and local representatives, where required by the law of your country: heliomath.com/legal/contacts