1. INTRODUCTION
Multilingual Promise ("we," "our," or "us") is committed to protecting the privacy and security of users ("you" or "your") of the STELAR Coach application (the "App"). This Privacy Policy explains how we collect, use, store, and protect your information when you use our AI-powered coaching platform designed for early childhood educators.
The STELAR Coach App utilizes advanced artificial intelligence to provide personalized feedback on teaching practices through audio recording analysis. We believe that privacy is paramount and strive to use your information only in ways outlined in this policy. We keep your data on your behalf and for your benefit.

2. INFORMATION WE COLLECT
2.1 Information You Provide
When you use our Services, we collect information you provide directly to us:

• Audio Recordings: When you submit recordings through the App, we collect audio files of your teaching interactions with children, voice recordings of adult-child conversations, and background audio from learning environments.

• Account Information: Name, email address, professional role, and organization affiliation.

• Demographic Data: Information collected for program evaluation (age range taught, experience level, primary language).

• Learning Preferences: Selected learning domains and focus areas for coaching.
   

2.2 Automatically Generated Data
From your interactions and recordings, our system automatically generates:

• Text transcripts with speaker identification labels

• Word frequency maps and language pattern analysis

• Performance assessments and rubric scores aligned to learning domains

• Coaching feedback and recommendations

• Usage statistics (recording dates, duration, feature usage)
   

3. HOW WE USE YOUR INFORMATION
We use the collected information for specific, legitimate business purposes:

• Coaching Analysis: To analyze teaching practices and provide AI-generated feedback and rubric scores based on recording evidence.

• Progress Tracking: To maintain your learning history and display progress across different domains in your dashboard.

• Program Evaluation: During the pilot program, we use aggregated data to evaluate program effectiveness and refine coaching methodologies.

• Service Improvement: To improve the accuracy of our AI models and the relevance of coaching feedback.

• Support & Communication: To provide technical assistance and answer your questions through our AI Tutor.
   

4. DATA PROCESSING & LLM TECHNOLOGY
STELAR Coach employs Artificial Intelligence (AI) and Large Language Models (LLMs) to process your audio recordings. When you submit a recording, it is transmitted securely to our LLM processing pipeline, which analyzes speech patterns, generates transcripts, identifies speakers, and produces coaching feedback.
Our processing pipeline includes:

• Automated Transcription: Converting speech to text using advanced recognition models.

• Speaker Diarization: Identifying distinct speakers and labeling them as "Adult" or "Child" without retaining personal identifiers.

• Semantic Analysis: Analyzing the content of interactions to provide pedagogical feedback.

While we take reasonable measures to preserve the privacy and security of data processed through LLMs, by using STELAR Coach, you understand and accept the risks involved with AI technology. We continuously monitor our AI systems for accuracy, fairness, and safety.

5. DATA STORAGE & INFRASTRUCTURE
Your data is stored on Google Cloud Platform (GCP) infrastructure located in US-East region servers. GCP provides enterprise-grade security, encryption, and compliance certifications including SOC 2, ISO 27001, and HIPAA compliance capability.

Our storage architecture ensures:

• Encryption at Rest: All data stored on GCP servers is encrypted using AES-256 encryption.

• Encryption in Transit: All data transmission occurs over secure channels using TLS 1.2 or higher.

• Data Isolation: Customer data is logically separated to prevent unauthorized cross-access.

• Redundancy: Data is backed up to prevent loss due to technical failures.
   

6. DATA RETENTION & DELETION POLICY
Important Notice - Pilot Program
The STELAR Coach App is currently in a pilot phase. We have implemented a phased approach to data retention that balances program evaluation needs with privacy protection.

6.1 During Pilot Phase
Duration: Through [INSERT PILOT END DATE]
During the pilot program, both audio recordings and transcripts are retained in secure storage. This data retention is strictly necessary for comprehensive program evaluation, validating research findings, and improving the accuracy of AI feedback models.

6.2 After Pilot Phase
Effective Date: Following [INSERT PILOT END DATE]
Automatic Audio Deletion
After the pilot program concludes, recordings will be deleted from the App once they are in transcript form. Audio recordings will be automatically deleted within 7 business days after successful transcription. You will receive confirmation when deletion is complete. Transcripts remain in your account to preserve your learning history and progress tracking.
By automatically deleting the raw audio files while keeping the anonymized transcripts, we ensure that biometric voice data is not held longer than necessary for processing.
You will receive advance notification before the transition from Pilot to Post-Pilot data retention policies takes effect.

6.3 Account Deletion
You may request full account deletion at any time. Upon verified request, all personally identifiable information, including transcripts and progress data, will be removed from our active systems within 30 days, unless retention is required by law.

7. PRIVACY PROTECTIONS
We implement specific measures to protect the identities of all individuals recorded:

7.1 Transcript Anonymization
Our AI system is specifically trained to protect privacy through automated redaction:

• Name Removal: The system automatically detects and removes personal names from all transcripts.

• Speaker Labeling: Names are replaced with generic labels such as "Adult" or "Child" to maintain context without revealing identity.

• PII Filtering: We actively filter other potential Personally Identifiable Information (PII) from transcript outputs.
   

7.2 Child Privacy Protection
Since our application involves recordings of educational settings, we take extra precautions regarding children's data. Children are not users of the App; they are incidental subjects of the educational recordings. By removing names and deleting original audio files post-processing, we minimize any potential risk to student privacy.

8. DATA SECURITY
We utilize industry-standard security measures to protect your information:

• Access Controls: Access to data is strictly limited to authorized personnel with a legitimate business need, enforced through role-based access controls (RBAC) and multi-factor authentication (MFA).

• Security Monitoring: Continuous monitoring of our infrastructure for suspicious activities or vulnerabilities.

• Vendor Security: Strict vetting of all third-party vendors and sub-processors to ensure they meet our high security standards.

• Incident Response: A documented incident response plan to address any potential security breaches promptly.
   

9. YOUR RIGHTS & CHOICES
You have significant control over your data:

• Access: You can view your recordings, transcripts, and feedback history through your dashboard.

• Correction: You may update your profile information at any time.

• Deletion: You can request the deletion of specific recordings or your entire account.

• Export: You have the right to request a copy of your data in a machine-readable format.

• Opt-Out: During the pilot phase, you may opt out of having your data included in research analyses without losing access to the coaching services.
   

10. CHILDREN'S PRIVACY
The STELAR Coach App is intended for use by adult professionals. We do not knowingly collect personal information directly from children under 13. While audio recordings submitted by educators may contain children's voices, these are processed as described in Sections 4 and 7, with strict deletion policies to protect privacy. If you believe we have inadvertently collected data from a child outside of these authorized educational contexts, please contact us immediately.

11. INTERNATIONAL DATA TRANSFERS
The STELAR Coach App is hosted on Google Cloud Platform servers located in the United States (US-East region). If you access the App from outside the United States, your data will be transferred to and processed on US-based servers.
We ensure all international transfers comply with applicable data protection laws through standard contractual clauses and adequate safeguards. By using the Services, you consent to the transfer of your information to the United States and its processing as described in this Policy.

12. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. We encourage you to review this policy periodically.

13. STATE-SPECIFIC RIGHTS
California Residents (CCPA/CPRA): If you are a California resident, you have specific rights regarding your personal information, including the right to know what information we collect, the right to delete, and the right to opt-out of the sale of personal information (note: we do not sell your data).
Residents of other states including Virginia, Colorado, and Connecticut may have similar rights under their respective state privacy laws. To exercise these rights, please contact us using the information below.

14. CONTACT INFORMATION
If you have questions or concerns about this Privacy Policy or our data practices, please contact us:
Multilingual Promise
Email: info@multilingualpromise.com
Address: 1187 Coast Village Rd Suite 1 - 467, Santa Barbara CA 93108