FriskOL
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Privacy Policy

Last updated September 18, 2026

Please read this Privacy Policy of FriskOL Co., a Delaware Corporation ("FriskOL," "we," "us," or "our") carefully. By creating an account, enrolling a child, subscribing to the Services, clicking to indicate your acceptance of this Privacy Policy and our Terms of Use, or otherwise accessing or using the Services, you expressly consent to FriskOL's collection, use, storage, processing, de-identification, transmission through cloud service providers, disclosure of information to third-party artificial intelligence service providers as described herein, receipt of AI-generated outputs, and return of such outputs to you through the FriskOL Platform.

FriskOL is an educational technology platform intended to support K–12 learners, including learners with diverse needs, through an AI-powered learning companion ("PhYlo") and connected Teacher, Tutor, Student, and Guardian portals. FriskOL is not a medical, diagnostic, or therapeutic product, and outputs generated by PhYlo or other AI features should not be relied upon as a substitute for a qualified educator's, clinician's or specialist's professional judgment.

The Services are intended for users located in the United States and are designed to operate under United States law. FriskOL makes no representation that the Services are appropriate or lawful for use in other jurisdictions.

1. Who May Use FriskOL

FriskOL is available to learners of all ages. Because some of our learners are children under 13, FriskOL complies with the Children's Online Privacy Protection Act ("COPPA") and uses Kids Web Services (KWS) to manage age verification and parental consent:

  • Learners 13 and older may, depending on account type, create or use an account directly, subject to this Policy and our Terms of Use.
  • Learners under 13 may only use FriskOL after a parent or legal guardian has provided verifiable parental consent through our KWS-powered consent flow, described in Section 4 below.
  • Accounts for children under 13 are always linked to a parent/guardian account, which retains visibility into, and control over, the child's FriskOL activity and data.

2. Information We Collect

Depending on how you use FriskOL, the categories of information we collect may include:

  • Guardian/Teacher/Tutor Account Information — name, email address, login credentials, role (guardian, teacher, tutor, volunteer), and subscription information.
  • Student Information (minimized for children under 13) — first name or display name, grade level, learning goals or areas of focus, and information a parent/guardian or teacher provides to support the child's use of the Services. We collect only what is reasonably necessary for a child to participate in a learning activity, consistent with COPPA's data-minimization principle.
  • Learning & Interaction Data — responses, activity within PhYlo tutoring sessions, progress and engagement metrics, and content generated through use of the platform.
  • Device & Technical Information — device identifiers, browser type, operating system, IP address, and application usage data.
  • Communications — messages with customer support, survey responses, and consent/verification records maintained through KWS.

We do not knowingly collect more personal information from a child than is reasonably necessary for the child to participate in a learning activity.

3. Use of Artificial Intelligence Services

To power PhYlo and deliver personalized, adaptive learning content, FriskOL submits certain learner interaction data to carefully selected third-party AI and cloud infrastructure providers:

  • Google Gemini (via Google Cloud / Vertex AI). AI-powered tutoring, adaptive content, and personalization features are provided through Google Gemini operating within FriskOL's Google Cloud environment. Google's processing of this information is governed by its enterprise cloud agreements, including the Google Cloud Service Specific Terms and Google Cloud Data Processing Addendum.
  • AWS Cloud. FriskOL uses Amazon Web Services for hosting, storage, and processing infrastructure supporting the Platform.

FriskOL does not transmit personally identifiable information to Gemini. Before any learner interaction data reaches Gemini, it is de-identified, so Google does not receive information that identifies a specific child or other user.

Information transmitted to AI and cloud service providers is protected through industry-standard encryption and security safeguards, including encryption in transit and, where available, encryption at rest, along with access controls, logging, and monitoring designed to protect information from unauthorized access, use, or disclosure.

AI-generated outputs may be inaccurate, incomplete, or unsuitable for a particular learner's needs and should be reviewed by a parent, guardian, or educator rather than relied upon without oversight, particularly for learners with diverse needs.

4. Age Verification and Parental Consent (KWS)

FriskOL uses Kids Web Services (KWS), an age-verification and parental-consent platform, to meet COPPA's requirements:

  • Age Gate. When a new account is created, KWS determines whether the user is above or below the age of digital consent based on stated age and location.
  • Consent Management. Where a learner is identified as under 13, KWS runs FriskOL's end-to-end parental consent flow: the parent/guardian receives direct notice of what information will be collected from their child, how it will be used, and to whom it may be disclosed, and must affirmatively provide verifiable consent before the child's account becomes active.
  • Parent Verification. Parent identity verification is conducted through KWS, using the verification method available to and selected by the parent or guardian at the time consent is given.

A parent or guardian who has provided consent may, at any time:

Review the personal information collected from their child; request correction or deletion of their child's personal information; refuse to permit further collection or use of their child's information; and revoke consent, which will result in the child's account being deactivated and associated personal information deleted or de-identified, subject to legal, security, and record-retention requirements.

To exercise any of these rights, a parent/guardian may contact us at friskoling@gmail.com or through the parent controls available in their KWS-linked account.

We do not condition a child's participation in a learning activity on the child disclosing more personal information than is reasonably necessary for that activity.

5. How We Use Information

We may use information collected through the Services to:

  • Provide, maintain, and improve the Platform, including PhYlo and the Teacher, Tutor, Student, and Guardian portals;
  • Personalize and adapt learning content to a student's needs;
  • Manage accounts, subscriptions, and billing;
  • Communicate with guardians, teachers, and tutors regarding the Services;
  • Maintain platform security and detect fraud or misuse;
  • Conduct internal analytics, research, and product development; and
  • Comply with legal obligations, including COPPA and applicable state law.

FriskOL does not use learner data to train, fine-tune, or otherwise improve FriskOL's own models or Google's models. Learner data is used only to generate in-session, personalized learning content and is not repurposed for model training.

6. Disclosure of Information

FriskOL does not sell personal information and does not share personal information for cross-context behavioral advertising as defined under California law. We do not display targeted advertising to children under 13.

We may disclose information to:

  • Cloud hosting and infrastructure providers (Google Cloud, AWS);
  • AI and machine-learning service providers (Google Gemini);
  • Payment processors and billing providers;
  • Customer support and communications providers;
  • Professional advisors, auditors, and legal counsel; and
  • Government authorities, regulators, or courts when required by law.

FriskOL is not sold or distributed to schools or other institutions. Teachers and tutors who use the Platform do so as independent individual users, not on behalf of an institution, and FriskOL does not disclose information to schools or institutions.

7. Data Retention

We retain personal information only for as long as reasonably necessary to provide the Services, support the purposes described in this Policy, and comply with legal obligations. Information belonging to a child under 13 is retained only for as long as reasonably necessary to fulfill the purpose for which it was collected, after which it is deleted or de-identified.

8. Your Privacy Rights

Subject to applicable law, you (or, for a child under 13, their parent/guardian) may have the right to:

  • Confirm whether FriskOL processes your (or your child's) personal information;
  • Access, correct, or request deletion of that information;
  • Obtain a portable copy of certain personal information;
  • Opt out of certain processing activities; and
  • Withdraw consent where processing is based on consent.

To exercise these rights, contact us at friskoling@gmail.com. We may require verification of identity, and, where a request concerns a child's information, verification of parental/guardian status, before responding.

9. California Privacy Rights

Because FriskOL is based in California, California residents have the following additional rights under the California Consumer Privacy Act and California Privacy Rights Act (CCPA/CPRA):

  • The right to know the categories and specific pieces of personal information we collect, use, and disclose;
  • The right to request deletion or correction of personal information;
  • The right to opt out of the sale or sharing of personal information — FriskOL does not sell or share personal information, so there is nothing to opt out of at this time, but we disclose this for transparency;
  • The right to limit use of sensitive personal information, where applicable;
  • The right not to be discriminated against for exercising these rights; and
  • The right to designate an authorized agent to submit requests on your behalf.

Minors under 16. Consistent with CCPA/CPRA, FriskOL does not sell or share the personal information of any consumer we know to be under 16 years of age.

California residents under 18 — Right to Removal ("Eraser Law," Cal. Bus. & Prof. Code § 22581). If you are a registered user under 18 and a California resident, you may request removal of content or information you have publicly posted on FriskOL. Contact us at friskoling@gmail.com to make this request. Removal does not guarantee complete or comprehensive removal from all systems, backups, or archives.

To exercise any California privacy right, email friskoling@gmail.com. We will respond within the time periods required by law.

10. Security

We use administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, or disclosure, including encryption in transit and, where available, at rest, access controls, and monitoring. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes — particularly any change affecting how we collect or use children's information — we will provide notice through the Platform, by email to parents/guardians on file, or through other reasonable means, and will seek renewed parental consent where required by COPPA.

12. Contact Us

For privacy questions, parental consent requests, or general support, contact FriskOL at:

  • Email: friskoling@gmail.com
Questions?

Write to us at friskoling@gmail.com and we'll get back to you.