FERMI - COPPA NOTICE TO PARENTS

1. Who We Are

Fermi AI Inc. (Delaware, USA) operates the Fermi service: an AI-powered STEM tutoring platform for K-12 students. This Notice describes the personal information we collect from children under the age of 13, how we use that information, and the rights you have as a parent or legal guardian.

For questions, exercising rights, or any concerns about your child's information, contact us at:

• Email: compliance@fermi.ai
• Mail: Fermi AI Inc., 809 Cuesta Dr, Suite B PMB 1203, Mountain View, CA 94040, United States

2. When This Notice Applies

This Notice applies whenever Fermi collects personal information from a child under 13 in the United States. There are two paths through which a child may use Fermi:

• Through a school: When your child uses Fermi as part of a school program, the school provides consent on your behalf under the FTC's school authorization framework. The school is responsible for obtaining your consent (or providing notice to you) consistent with its own policies and applicable law.
• Direct sign-up: If your child wishes to use Fermi outside of a school context, we will not create an account for the child without your verifiable consent first.

3. What Personal Information We Collect from Children

We collect the following categories of personal information from children under 13:

• Account information: name, email address, password, grade level, date of birth.
• Homework and study content: photos of handwritten work, problem-solving attempts, notes, and uploads the child creates while using Fermi.
• Voice data: audio recordings of voice queries during tutoring sessions. Audio is transcribed and analyzed for safety signals (e.g., indicators of self-harm or abuse), then deleted within 30 days. Transcripts are retained with the child's record.
• Usage and learning data: time spent on tasks, mastery progress, hint interactions, and other interactions with the platform.
• Device data: IP address, browser type, operating system, device model.
• Approximate location: country and region, derived from IP address.

4. How We Use Children's Information

We use the information described above only to:

• Deliver the tutoring service, including personalized learning paths, hints, and explanations.
• Track learning progress and provide feedback to the child and (where applicable) the school.
• Conduct safety review of interactions, including automated and (where flagged) human review for indicators of self-harm, abuse, or harm to others.
• Maintain and secure the platform.
• Comply with legal obligations.

We do NOT use children's information for:

• Advertising of any kind, including targeted or behavioral advertising.
• Building behavioral profiles for marketing or engagement optimization.
• Training AI models — even in de-identified form.
• Sale or rental to third parties.

5. Third Parties That May Process Children's Information

To deliver the service, we engage third-party sub-processors (for example, cloud hosting, AI inference, error monitoring). Each sub-processor is bound by a written agreement that prohibits using your child's information to train AI models, for advertising, or for any non-educational purpose. A current list of all sub-processors is published at fermi.ai/subprocessors.

6. How We Obtain Verifiable Parental Consent

For direct sign-ups (not through a school), we obtain verifiable parental consent before any account is created and before any personal information is collected from your child. We use the following methods, consistent with FTC-approved methods under 16 C.F.R. Section 312.5:

• Payment-card $0 authorization. We send the parent a link to complete a $0 charge authorization through our payment provider. Your card is not actually charged; the verification confirms you are the cardholder. This is the fastest method.
• Signed consent form. If you cannot use a payment card, you can download, sign, and return a consent form by email or mail.

Until parental consent is verified, the child's account is held in a pending state and no personal information is collected.

7. Your Rights as a Parent

As the parent or legal guardian of a child under 13 using Fermi, you have the right to:

• Review the personal information we have collected about your child.
• Request correction of inaccurate information.
• Request deletion of your child's account and all associated personal information, including voice audio and transcripts.
• Refuse further collection or use of your child's information.
• Withdraw consent at any time. If you withdraw consent, we will stop collecting new information and will delete the child's account on request.

To exercise any of these rights, email compliance@fermi.ai from the email address you used to provide consent. We will acknowledge your request within 5 business days and complete it within 30 calendar days. Where verification is needed, we may ask for additional information to confirm your identity before acting.

8. Data Retention and Deletion

• Voice audio: deleted within 30 days.
• Personal Account data: deleted within 30 days of an account-deletion request or account closure (backups cleared within an additional 30 days).
• Inactive child accounts: auto-purged after 24 consecutive months of inactivity.
• De-identified, aggregated data may be retained for research and service improvement.

9. Where to Get More Information

For our complete data practices, see our Privacy Policy. For information about COPPA generally, the Federal Trade Commission publishes guidance for parents at ftc.gov/coppa.

If you have a complaint or concern about how Fermi handles your child's information that we have not resolved, you may contact the FTC at reportfraud.ftc.gov.