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Privacy Policy

Last updated: November 7, 2026

What we collect, why we collect it, who it goes to, how long it's kept, and what you can do about it.

§ 1

Overview

College Captain is operated by Next Gen Solutions LLC, a Massachusetts limited liability company ("we", "us"). This policy explains what College Captain collects, why we collect it, who it is shared with, how long it is kept, and what you can do about it. We collect what the product needs to work and nothing beyond that.

College Captain is built for high school students, and most of the people using it are under 18. That shapes every decision in this document: there are no ads in College Captain, nothing is sold, nothing is shared for anyone else's marketing, and the default on every setting is the more private one.

College Captain is operated from the United States and is intended for users in the United States. If you use it from elsewhere, your information will be processed in the US.

§ 2

Information We Collect

Account information: your name, email address, your birth month and year (asked before your account is created, and used only to work out which protections apply to you), the US state you live in (required if you are under 18, because it decides which state's rules protect you), and whether you signed up with Google or with an email and password. If you are under 18, a parent or guardian's name and email address when you or they add one — needed if you are under 16 or live in Louisiana, optional at 16 and 17 elsewhere. If a parent opens a link a student sent them, the name and email address they type, a one-time code (stored scrambled) and a scrambled form of their network address, used only to limit how many codes can be asked for. If a parent sets College Captain up for their teen: the same from that parent; the password for their parent login, which our sign-in provider stores only in scrambled form; the words of the consent they agreed to, with their version and when; and their teen's first name and email address — the teen's email address is used only to send the invite, and we don't store it. When the teen joins, their answer to whether that person is their parent or guardian, and when they gave it. If someone asks us to stop sending them invites, a scrambled form of their email address, so that we can.

Profile information you provide: your grade, track, GPA, courses and their levels, test scores, activities and hours, awards, mentors and recommenders, the schools you're interested in, essay topics you are considering, how much time you have, and your school year start and end dates.

Activity within the product: which roadmap tasks you complete and their outcomes, your quarterly check-in answers, your conversations with College Captain, including the names, types and sizes of any files you attach and the links to any web pages College Captain cites in a reply, your Positioning Score history, and the tools you use — volunteer hours, documents you upload to the vault, flashcard decks, and similar.

Technical information: your time zone, captured from your browser at signup so dates and reminders show in your local time, and whether you signed in with Google or with a password. Our hosting provider's request logs briefly record the network address and browser type each request came from, for the short period described in section 9. We do not collect precise geolocation, we do not collect biometric identifiers, and we do not build advertising profiles.

Usage records: for each AI request, what kind it was, which model answered, how many tokens it used and what it cost us — never what you wrote — and a monthly total of what your account's AI use cost, which is how the monthly limit in section 5 of our Terms works.

Counts that are not about anyone: each week, how many people signed up from each place we posted a link, how many times the upgrade screen was opened, and how many checkouts were started. These are tallies — a week, what was counted, and a number — with no name, account, email address or device attached, so they cannot be traced back to you.

Creator links: some people who make videos about College Captain are paid a share of the first payment of each subscriber their link or their discount code brings. If you sign up through one of those links, or type one of those codes when you buy a plan, we keep that creator's short code on your account until your first payment, then add one to that creator's count and delete the code; if there is no payment within 90 days, we delete it anyway. The creator never learns who you are. We don't do this for anyone who lives in New York or hasn't told us which state they live in. They still get a code's discount. Paying a creator is not a sale of your information: the creator gets a count and an amount, never who you are. A discount code you use is also part of the record of your purchase that our payment processor keeps, and when a creator is counted for that first payment, the processor's record of it also notes the creator's short code, so a refund comes off what that creator is paid.

Creators (adults only): if you apply to our creator program, we keep your name, email address, the accounts you post from and any others you add, that you confirmed you are 18 or older and agreed to the creator terms (which version, and when), how you heard about the program, the code of a creator who sent you, if any, and a scrambled form of your network address, used only to limit how many applications come from one network and cleared once we decide. If you are approved, we also keep your code and link, a private key for your creator page, the dates of your free Max, the counts and amounts your code has earned (never who the students are), and a record of each payment we make you. Your bank account, tax ID number and tax forms are collected and held by Stripe, not by us.

We do not knowingly collect information from anyone under 13. See section 7.

§ 3

How We Use Your Information

To generate and update your roadmap, to personalize what College Captain says to you, to calculate your weekly Positioning Score, to run the tools you choose to use, to send the emails you have enabled — including, if you subscribe and then don't visit for three weeks, one short reminder, never to a parent and never at night — to take payment if a family subscribes, and to operate, secure and debug the Service, and to meet our legal obligations, including keeping information the law requires us to keep (section 9).

One thing we do only if you choose it: if you write a short quote about College Captain in Settings and tick the box allowing it — and, if you are under 18, your parent or guardian approves it from their account — we may publish that quote on our website and in our marketing, signed with your first name and grade only. You can ask for it to be taken down at any time by emailing team@collegecaptain.com.

Invites. You can share an invite link from Settings. If someone signs up through your link, we record that you invited them, and if they later start a paid subscription you get free Max time. The person who invited you sees only numbers: how many people signed up through their link, how many subscribed, and how much free time they have earned. They never see your name, email address or anything in your account, but if they sent the link only to you, those numbers can tell them you joined or subscribed. We keep the record of who invited whom until either account is deleted, and use it for nothing else.

To understand, as counts across many accounts, how College Captain is used — which features are opened and where people stop — so we can improve it. These are totals, not reports about one student, and we do not look at a named student's account for this.

That is the complete list. We do not use your information for advertising, we do not use it to train anyone's AI models, and we do not use it to build a profile of you for any purpose outside this product.

§ 4

AI Processing

Your profile and conversation context are sent to Anthropic's Claude API to generate responses and calculate your score. Only what is needed for a given request is included: a small always-on profile on every message, and your fuller record when the question or the weekly scoring run actually calls for it.

College Captain also keeps your onboarding answers about your college list and essay topics. They go with your messages in any conversation, and are deleted with your account, not when you delete a conversation.

What College Captain remembers. So that it still knows your plan next month, College Captain can save one short line for something you tell it that matters for planning — what you are aiming at, a commitment that takes your time, a decision you have made. It never saves anything you tell it about your health, a disability, your family's circumstances, your money, your identity, or how you felt on a given day: those stay in the conversation you said them in, which is what you were asked and what you agreed to. Every line is on your Profile under “What College Captain remembers”, where you can read it, delete any of it, or delete all of it, and you can switch the whole thing off in Settings — which stops College Captain reading or adding to it from your next message. Lines are deleted automatically twelve months after they are written, and with your account.

Files you attach. In a conversation with College Captain you can attach up to three PDF or plain-text files to a message — a report card or a course list, for example. The file is sent to Anthropic with that one message so College Captain can read it, and it is not sent again with later messages. We do not keep the file itself: we save only its name, type and size with your message. College Captain's reply, which may quote or summarise the file, is saved in the conversation like any other reply and is kept and deleted the same way (section 9). Photos and other images cannot be attached. Please attach only documents about yourself.

Web search (Max). In an open conversation, and on tasks marked for it, College Captain can look something up on the web when an answer depends on information that changes, such as a deadline, a cost or a program's rules. To do that, College Captain writes a search query based on what you asked and the rest of the conversation, which can include details from your profile. The query goes through Anthropic to the search services Anthropic uses for this — currently Brave Search and TurboPuffer — and the results come back to College Captain. We do not store the queries. We save the links and page titles shown under a reply as part of that conversation. The pages College Captain reads are written by other people and we do not check them.

College Captain is instructed to search for the topic, not for you: it leaves your name, email address and anything about your health or family out of search queries, and names your school or town only when the answer depends on it.

Anthropic is our only AI provider. Nothing you write is sent to any other AI company.

We use Anthropic under paid commercial terms, which do not permit them to train their models on your content. We do not opt in to any programme that would.

Some information is asked for in the moment and never stored at all — for example, whether you prefer working alone or with others. It is used for that conversation only.

§ 5

Automated Decisions & the Positioning Score

The Positioning Score is generated automatically, without a human reviewing it. It is a number from 40 to 100 describing how strong your profile looks relative to your own grade and your chosen track, along with one strength, one gap, and one thing to focus on. It is recalculated weekly from the information already in your profile.

It does not predict admissions decisions, it is not used to decide anything about your account, and nobody outside College Captain receives it — the one exception is the parent or guardian who confirmed your account, until you turn 18: with a guardian login they can see the number and its weekly change, and they receive the latest number in a short monthly email (section 7), which you can turn off in Settings. Nothing about your access to College Captain, your price, or what you are shown depends on it.

If you think your score is wrong, correct the information on your Profile or email team@collegecaptain.com — a score is a description of the information we hold, so correcting the information is usually the fix. You can also ask us to stop calculating it for your account, and we will: email team@collegecaptain.com, and from the next weekly run no new score is calculated until you ask us to resume. Scores already calculated stay in your history unless you delete your account.

Because this is automated processing about a minor, we treat it as profiling under the state privacy statutes that use that term, and we hold it to the limits described above rather than relying on it being benign.

§ 6

Who We Share Information With

We share information with the service providers that make the product work, and with nobody else. Each of our service providers is bound by contract to use it only to provide that service, and is not permitted to sell it or use it for its own purposes.

Supabase — database and authentication. Anthropic — AI processing, including reading files you attach to a message and running web searches; for web search, Anthropic uses search services it has engaged under its own data-processing terms, currently Brave Search and TurboPuffer, and publishes the current list on its subprocessor page (trust.anthropic.com/subprocessors). Google — sign-in, if you chose to create your account with Google. Stripe — payments; Stripe receives billing details directly and we never see or store card numbers. If you pay with Apple Pay, Google Pay, Cash App Pay or Link, that service also handles the payment under its own privacy policy, and Link, Stripe's saved-payment service, keeps your details for other sites only if you choose to save them. Resend — transactional email. Vercel — hosting and request logs, and counts of visits to our public pages (the home page, guides, free tools, pricing, sign-up and our policies): no cookies, and a visitor is counted by a code Vercel discards within a day, so no visit is linked to you. Nothing is counted once you are signed in. Sentry — reports of errors in our own servers, so we find out when something breaks; before a report leaves our servers we remove request contents, account identifiers and email addresses, and nothing you write is included. Cloudflare — our domain; forwarding of email sent to team@collegecaptain.com, which is delivered to a mailbox hosted by Google; and Turnstile, the check on our sign-up, sign-in and password-reset forms that tells people apart from automated scripts. Turnstile reads your IP address and technical details of your browser, only to tell whether a person or a bot is using the form; Cloudflare also uses those signals to improve its bot detection, and not to identify you.

For creators, Stripe also checks identity, collects bank and tax details and makes payouts, under its own agreement and privacy policy. Our database never stores bank or tax numbers; where tax law requires us to report what we paid a creator, the form Stripe prepares for us carries their tax details.

We do not sell your information, we do not share it for cross-context behavioral advertising, and we do not disclose it to data brokers. See section 10.

We may disclose information if we are required to by law, or where disclosure is genuinely necessary to protect someone's safety. If a business transfer ever happened, your information would move with it and this policy would continue to apply until you were notified of a change.

§ 7

Age, and Students Under 18

You must be at least 13 to use College Captain. We ask for your birth month and year on the first signup screen, before your account is created and before any personal question is asked. We do not ask for a full date of birth, and we do not require identity documents from teenagers to determine age — collecting government ID from minors would create a far larger privacy risk than it solves. If the answer means you are not yet 13, no account is created and we keep nothing. Because we have a month rather than a day, College Captain treats you as 13 from the first day of the month after your 13th birthday, and as 18 from the first day of the month after your 18th birthday.

If an account that already exists may belong to someone under 13 — for example, one created by signing in with Google before the age question was answered, or one where a student tells College Captain in the chat that they are under 13 — we pause it while a person checks: no AI chat, no scoring, no automatic emails, and nothing closed automatically. If we learn that an account belongs to someone under 13, we delete it and everything attached to it within seven days of learning — or, if the law requires us to keep it (section 9), as soon as that requirement ends — and we do not use the information in the meantime. If you believe a child under 13 has created an account, email team@collegecaptain.com. We pause that account while a person checks, and remove it if it belongs to someone under 13 — or, if the law requires us to keep it (section 9), as soon as that requirement ends.

If you are under 16, or under 18 and living in Louisiana, a parent or guardian must consent to your use of College Captain. The student adds them from Settings once inside — by entering their email, so we email them a request, or by sending them a link on which the parent confirms their own email with a code — and in Louisiana we also ask for their name and email when the account is created, and the student can add them later instead. A parent can also start, or ask to be linked (next paragraph). While the request is pending the student can finish setting up and is reminded inside it, and an account that has the Free plan from before October 18, 2026 can keep using it, and once we have the guardian's address we re-send the request; the guardian dashboard waits for that confirmation, the student can't start a free trial or buy a plan until the guardian confirms, so a new account stays locked apart from Settings until then; for an account on the Free plan, if 30 days pass without it the AI chat pauses (only the chat) until the guardian confirms; and if 90 days pass without it we close the account and delete its data. We never close it before day 90, and never unless we have first emailed the student a warning that names the closing date at least 7 days ahead; ordinarily we warn on day 60 and again on day 83, and each warning re-sends the request to the guardian. The account is not closed before the date the warning names, and if a warning cannot be sent, the account stays open until one has been. We do not keep information about a student under 16 (or under 18 in Louisiana) that no parent has agreed to. Consent is required whether or not anyone pays, and it is not tied to payment in any way: consenting never starts a trial or a charge. A guardian's consent lasts until the student turns 18.

A parent can set College Captain up for their teen at collegecaptain.com/parent/start. They give their name and email address, confirm the address with a one-time code, choose a password for their parent login, give their teen's first name and email address, and agree to the same consent a parent gives when a student adds them; we keep the words they agreed to, their version, and when. We email the teen an invite and give the parent a link to send them; it works once, for 7 days. The teen signs up as any student does — their own age question, their own account, their own agreement — and is asked whether that person is their parent or guardian. Only if the teen says yes and is under 18 is the account linked to that parent and the parent's consent recorded, as of when the parent gave it; we then email the parent. If the teen says no, or is 18 or older, nothing is linked and we tell the parent nothing about the teen's account. A parent whose student already has an account can use the same invite, which asks the student first, or ask to be linked at collegecaptain.com/parent/ask: we tell the student, and nothing happens unless the student says yes — then the parent is emailed the consent request like any other. What a parent types on either page is cleared 30 days after they typed it, except what becomes their parent login (section 9).

If you are 16 or 17 and do not live in Louisiana, a parent or guardian is optional. You agree to our Terms and this policy yourself — we store the words you agreed to and when — and that consent, not a parent's, is what we rely on to keep your information. We keep reminding you inside the app that you can add a parent or guardian; if one confirms, they have what the next paragraph describes. We treat you as 16 from the first day of the month after your 16th birthday. A student who created an account before turning 16 and has no confirmed parent can agree for themselves once they are 16.

Until the student turns 18, a guardian with a login can see their student's Positioning Score with the short weekly note that comes with it, their roadmap progress (how many tasks they finished each quarter and week, never which tasks), the record a guardian may also download (grades and courses, test scores, activities, awards and volunteer hours), how many messages they have sent this cycle and when they last used the chat, and billing, and can pause the AI chat. They cannot see chat history, check-in answers, or task-level detail. A guardian with a login can also ask Cap, College Captain's AI, questions about their student: Cap answers only from what the guardian can already see, plus general guidance, and never from the student's conversations or check-in answers. We do not store a guardian's questions or Cap's answers once the answer is sent; like the rest of the chat, they are processed by Anthropic to write the answer (section 4). Each question uses one of the student's monthly messages. The guardian who confirmed the account — with or without a login — also receives a short email once a month: the latest Positioning Score, what the student finished on their roadmap that month, what is coming up, and one specific thing the guardian could help with. It never includes conversations, check-in answers or anything College Captain remembers, and it asks nothing of the student. The student can turn it off in Settings, and the guardian can unsubscribe from the email itself. That boundary is deliberate: students tell College Captain things they would not tell a portal their parent can read, and a product that repeated them verbatim would stop being told anything true.

Before the student turns 18, a parent or guardian may review, correct, or request deletion of their student's information at any time, and may withdraw consent at any time — by emailing team@collegecaptain.com from the address we have on file for them, or from their Guardian Portal. Because an email's sender can be forged, we then email the address on file a link to confirm; once it is confirmed, we close the student's account straight away and confirm by email — or, if the law requires us to keep its information (section 9), as soon as that requirement ends. We send that link within ten days of the request, usually within a day. A parent's copy of the student's record — profile, grades and courses, test scores, activities, awards, volunteer hours, Positioning Score history and the consent record — can be downloaded from the Guardian Portal, or asked for the same way, by email from the address on file, and we email a download link to that address. Like the Guardian Portal, it does not include the student's conversations, check-in answers or task-level detail.

When a student turns 18, the guardian's consent and their access to the student's information end, and any pause the guardian put on the chat is lifted. We email the student, and the guardian who confirmed the account, the month before and when it happens. The account and everything in it — including what the student added before turning 18 — stays the student's, and the next time they sign in we ask them to agree to our Terms and this policy themselves; until they do, the AI chat is paused. If the guardian had confirmed the account and the student has not agreed within 90 days of turning 18, we close the account and delete its data — never before those 90 days, and never without first emailing a warning that names the closing date at least 7 days ahead. If no guardian ever confirmed the account and the student never agreed for themselves at 16 or 17, the 90 days described above still count from signup, unless the student agrees for themselves first. After a student turns 18, a guardian cannot close the account or see it, though a guardian who pays for a subscription can still cancel it and can ask us to delete their own information.

You can change the state you live in from Settings when you move. A move that gives an account more protection applies at once: a student under 18 who moves to Louisiana needs a parent's confirmation from then on, with 30 days from the move before the chat pauses. You can correct your birth month in Settings. A correction that gives an account more protection, or the same, applies on your word. If a change would give an account less protection, email team@collegecaptain.com from the address on the account. A correction that gives it less — such as ending a guardian's consent, a birth month that moves a student past 16, or a student under 18 moving away from Louisiana, New York or Colorado — needs a second confirmation: from the parent or guardian on file, or, where there is none, a written statement from the account's own address that a person checks against the account. We never ask for identity documents.

We do not serve advertising to anyone, we do not process anyone's information for targeted advertising, and we do not sell the personal data of any user, minor or otherwise. Several states now prohibit these specifically for users aged 13 to 17; we do not do them for anyone.

If you live in New York and are under 18, we record only the usage College Captain needs in order to work — how many messages you have sent, which your message limit depends on — and none of the other usage records we keep to understand how the product is used. New York's Child Data Protection Act lets a service do more only with your own separate agreement, and we do not ask you for it.

§ 8

Crisis Situations

If a conversation contains a genuine crisis signal, College Captain is instructed to respond supportively and to share crisis resources — the 988 Suicide & Crisis Lifeline and the Crisis Text Line. The full protocol is published at collegecaptain.com/safety.

College Captain does not monitor conversations in real time and is not an emergency service. No person is watching. Two things are automatic: the safety instructions above, and the age check described in section 7 — if you tell College Captain in the chat that you are under 13, that opens a review which a person reads. Nothing else you write is flagged to anyone, and no one at College Captain reads conversations to keep an eye on students. If you are in immediate danger, contact 911 or go to your nearest emergency room.

§ 9

How Long We Keep Things

Account, profile, roadmap progress, check-in answers, score history and conversations: kept while your account is open, because the product's whole function is continuity across four years of high school. Deleted with the account.

What a parent types on a link a student sent them — their name, email address and the scrambled form of their network address — is cleared 30 days after the link was made, whether or not it was used, and the one-time code is deleted as soon as it is used or runs out. A parent who confirms is kept as the guardian on the account, like any guardian. The same goes for what a parent types when they set College Captain up for their teen; the teen's first name they give is cleared as soon as the teen joins, and otherwise 30 days after the invite was made. When a teen joins and confirms that parent, the record of the parent's consent — the words, their version and when the parent agreed — and of the teen's answer is kept with the account, like any guardian's consent, and deleted with it. If no teen joins, the invite and its consent record are deleted 30 days after the invite expires or is cancelled. A parent's own login, with their name and email address, is kept until they ask us to delete it (section 11). If someone asks us to stop sending them invites, the scrambled form of their address is kept for as long as that request stands.

Documents you add to the vault, including each saved draft of an essay: kept until you delete the document or your account. A Word file you download from College Captain is made when you ask for it and is not kept.

You can also delete a single conversation from your list of conversations. It is deleted from our database straight away and leaves the backups described below as they age out. Anything College Captain noted from it stays in the list in Settings until you delete it there, and anything it saved to your record at your request — a score, an activity, an award, a college or a date — stays where you can see and change it.

Creator records: an application we decline is deleted 90 days after we decide. While you are a creator, what you gave us is kept. When the program ends for you, we keep your name, email address, code and the record of what we paid you for seven years after the last payment, because tax law requires it, and delete the rest within 90 days.

Billing records: kept for seven years after the last transaction, because tax and accounting law requires it. This is the one category that survives account deletion, and it is reduced to what those obligations need — amounts, dates, and the payment identifier — not your profile or your conversations.

Your birth month and year: kept while your account is open, used only to work out which protections apply to you and when you turn 18, and deleted with your account. We never send it to our AI provider, never use it for marketing, and never copy it anywhere else — the only place it sits outside our database is the short-lived signup cookie described in section 15, in your own browser, until you finish setting up your account.

When a student turns 18, the record that their parent or guardian consented — who consented, when, and when it ended — stays with the account while it is open, as the record that the student's years under 18 were covered, and is deleted with the account.

When we close or delete an account, or review whether an account belongs to someone under 13, we keep a short record that it happened: a scrambled reference that holds no name or email address, the reason, and the dates. It contains no name, email address, birth date or anything you wrote, and we delete it after five years.

Consent records: the record of a guardian's consent is kept while the account is open and deleted with it. The record of agreement to the subscription's automatic-renewal terms — the wording shown and the time it was agreed to — is kept for three years, or one year after the subscription ends, whichever is longer, because the statutes that require the consent also require the record; a copy is held with our payment processor so that it survives account deletion, alongside the billing records described above.

AI usage records: your account's monthly totals are kept for the current month and the twelve before it, and deleted sooner if you delete your account. Per-request records hold no account identifier and nothing you wrote, and are deleted within thirteen months.

Server and request logs: held by our hosting and database providers for a short, fixed period that is in every case less than 30 days, then discarded.

Anthropic, which processes each AI request, deletes what we send it within 30 days under its standard terms, except content its safety systems flag, which its policies allow it to keep for longer.

Cancelling a trial or a paid plan deletes nothing. When it ends, an account that has the Free plan returns to it and any other account locks; either way its full history is kept, it can still download or delete its data from Settings, and subscribing again picks up where it left off.

Deleting your account from Settings (under "Privacy and data", choose "Delete account") is what erases your data. It is self-serve, immediate, and permanent — except in the rare case described in the last paragraph of this section — and it removes your profile, roadmap progress, chat history, check-ins, documents and score history together. Where our database provider keeps backup copies, they are encrypted, retained for at most 30 days, and never used to restore a deleted record to the live system.

We close accounts on our own in three cases, and all three take the same deletion path. First, an account belonging to someone under 16 — or under 18 in Louisiana — whose guardian has not confirmed it within 90 days, and who has not agreed for themselves after turning 16 (section 7). Second, an account whose student turned 18 after a guardian confirmed it — or after agreeing for themselves at 16 or 17 — if the student has not agreed to our Terms and this policy themselves within 90 days of turning 18 — never sooner, and never without first emailing a warning that names the closing date at least 7 days ahead (section 7). Third, an account without a trial or subscription (a locked account, or one on the Free plan) that nobody has used for twelve months, counting from the last sign-in or the last thing done in it. We never close it sooner than that, and never unless we have first emailed the student — and, for a student under 18, the parent or guardian who confirmed the account — a warning that names the closing date at least 7 days ahead; ordinarily we send two warnings, 30 days and 7 days before. The account is not closed before the date the warning names, and if a warning cannot be sent, it stays open until one has been. Signing in at any point before that date keeps the account with everything in it. An account on a free trial or a paid plan is never closed for inactivity while it lasts.

Occasionally the law requires us to keep information we would otherwise delete. Federal law requires us to preserve for one year what we report to the National Center for Missing & Exploited Children, and a court, a regulator or a law enforcement agency can require us to preserve records. When that happens, we keep the information that requirement covers — which can be everything in an account — and nothing in that account can be deleted, whether by its owner, at the request of a parent or guardian, or by any of the automatic closures above, until the requirement ends. We keep that information secure and limit who can reach it. We may not be able to tell you why a deletion cannot be done. When the requirement ends, the rest of this policy applies again. If the account's owner tried to delete the account in the meantime, we delete it then and confirm by email; anything else they tried to delete, such as a conversation or a document, is not deleted automatically and can be deleted again. The automatic closures above resume, and none happens without a warning sent at least 7 days before it; if the last warning is more than 14 days old, we send a new one first.

§ 10

Sale, Sharing & Targeted Advertising

We do not sell personal information, and we have not in the preceding twelve months. We do not share personal information for cross-context behavioral advertising, and we have not in the preceding twelve months. We do not process personal information for targeted advertising.

Because none of these happen, there is nothing to opt out of. We honor Global Privacy Control signals; there is simply no processing for them to stop.

We do not use personal information for any purpose that would require an opt-out or opt-in under the state statutes listed in section 11, other than the profiling described in section 5, which you can ask us to stop.

§ 11

Your Rights

Wherever you live, you can ask us to: confirm whether we hold information about you and give you a copy in a portable format; correct anything inaccurate; delete your account and its data; and stop the automated scoring described in section 5. Most of this is self-serve — you can edit your profile in the app, change your calendar and notification preferences in Settings, download a copy of your data from Settings (Privacy and data), and delete your account yourself at any time, except in the rare case described at the end of section 9.

Residents of the states that have comprehensive privacy laws — more than twenty as of September 2026, and the list grows each year — have some or all of these rights by law. We do not check which state you live in before honouring them: everyone gets the same rights, the same process and the same response time, and nobody gets a different price or a worse product for using them.

To make a request, email team@collegecaptain.com from the address on the account, or write from a guardian address naming the student. We respond within 45 days and will tell you if we need a permitted extension. We may need to verify that the account is yours before acting on a request about it; for a deletion request we will not ask for more information than the request itself requires.

If we refuse a request, we will tell you so and, unless saying why could interfere with a legal requirement or an investigation, why; either way, you may appeal by replying to that decision. We respond to appeals within 45 days. If an appeal is denied you may complain to your state Attorney General; California residents may also contact the California Privacy Protection Agency.

You may use an authorized agent to make a request on your behalf, with written permission we can verify.

§ 12

Categories, Purposes & Recipients

For the disclosure some state statutes require, in their terms: we collect identifiers (name, email, account ID), customer records (guardian contact details), commercial information (subscription status and history), internet activity limited to your use of this product, inferences drawn from what you tell us (your Positioning Score and its components), and information relating to education — grades, courses, test scores, activities and awards — which you provide to us directly.

We collect all of it from you, or from a guardian on your behalf. The purposes are listed in section 3. The categories of recipients are listed in section 6. The retention periods are in section 9.

We do not ask for the categories some statutes call sensitive — precise location, biometrics, government ID numbers, racial or ethnic origin, religion, health or disability, sexual orientation — and none of them is part of your profile. Two places can still contain them because you choose to put them there: the quarterly check-in asks how stressed you feel, and you may tell College Captain about your health or anything personal in the chat, or in a file you attach. Where you do, we ask for your specific agreement first. Anything you write in your own words — in the chat, or in the written part of a check-in — is never an input to your Positioning Score. The one exception, and we would rather name it than bury it: the stress rating you pick on the check-in's five-point scale is one of the things the weekly score takes into account, because how you are actually coping is part of an honest reading. It is the number, never the words. All of it is used only to shape the conversation and the roadmap otherwise, and all of it is deleted with everything else when your account closes.

§ 13

Education Records

College Captain is a direct-to-family product. We are not a school, we do not contract with schools, and we do not receive records from them. FERPA governs records held by schools and by their contractors, and it does not apply to what you type into College Captain yourself. A school document you choose to attach to a conversation, such as a report card, is something you give us yourself; it does not make College Captain a school record-keeper, and it is handled as described in section 4.

If that ever changes — if College Captain is offered through a school — this policy will change with it, and we will say so before it takes effect.

§ 14

Data Security

Data is stored with row-level security, so from the app a student's records are readable only by that student — plus, for the limited items listed in section 7, their guardian. Billing fields are written only by our own server, from payment events whose authenticity we verify with Stripe, and never by the browser. Documents you add to the vault are stored as text in that same database, under the same row-level security — there are no files sitting on a server that a link could reach. All traffic is encrypted in transit and data is encrypted at rest by our infrastructure providers.

Access to production data is limited to the people who need it to operate the Service, which today is one person.

If a breach affects your information, we will notify you and the relevant authorities as required by law, without undue delay.

No system is perfectly secure, and we cannot guarantee absolute security.

§ 15

Cookies

We set these cookies: the ones that keep you signed in; if you confirm a password-reset link we email you, one that holds an identifier for your account, an identifier for the sign-in that link opened, and an expiry time, signed so it cannot be altered, so that only that sign-in can set your new password — it is deleted as soon as your new password is saved, and in any case after an hour; one that remembers whether you left the side menu open or collapsed (it lasts seven days); one that, while you are signed in, notes that we have already recorded you as active in the last hour, so we don't record it again on every page — it holds only the number 1, nothing about you or what you looked at, and it expires after an hour; if you arrive through a friend's invite link, one that holds that friend's invite code for up to 30 days so the invite counts when you sign up; if you open an invite a parent sent you, one that holds that invite's code for up to seven days, so that when you sign up we can ask whether that person is your parent or guardian and link you if you say yes — it is deleted once you answer or your account is set up; if you follow a creator's short link (collegecaptain.com/c/ and a code), one that holds that creator's discount code for up to 30 days so it is filled in when you buy a plan — it holds nothing about you; if you arrive through a link we posted that says where we posted it (our TikTok, for example), one that holds only the name of that place for up to 30 days, so that when you sign up we can add one to that week's count for it — the name is then deleted, it is never recorded against your account, and the cookie is not set at all if your browser sends Global Privacy Control; if you choose to bring in a document from Google Docs, one that holds a random value for ten minutes so that we can tell it is really you coming back from Google — it holds nothing about you or about the document, and it is sent only to that one page; and, only once you answer the age question — on the signup screen, or when you first set up an account made another way, one that remembers that answer — your birth month and year, signed so it cannot be altered, which is deleted as soon as you finish setting up your account, change your answer, sign out or delete your account, and in any case after two hours. If the answer means we cannot create an account, nothing is kept and you can answer again. Your light or dark theme preference, and the entries you make in the free public tools such as the GPA calculator, are kept in your browser's own storage rather than in a cookie, and never leave your device. When you pay, Stripe's checkout pages set Stripe's own cookies; when you sign in with Google, Google's pages set Google's. There are no advertising cookies, no third-party tracking cookies, and no cross-site trackers. Because of that there is no consent banner — there is nothing to consent to.

Your browser's Do Not Track and Global Privacy Control signals are respected by default, in the sense that we already do not do any of the things they ask us to stop.

§ 16

Changes to This Policy

We may update this policy. The date at the top always reflects the current version. If a change materially affects how your information is handled, we will notify you by email before it takes effect, and where the law requires fresh consent we will ask for it rather than assume it.

§ 17

Contact Us

The controller of your information is Next Gen Solutions LLC, a Massachusetts limited liability company, which operates College Captain. Privacy questions, requests, and appeals: team@collegecaptain.com.

When you email team@collegecaptain.com, your message goes to our own support tool, which runs on Vercel and Supabase, and the founder reads it there. Twice a day that tool sorts new mail and answers it with a reply written with the help of AI (Anthropic, section 6) and signed College Captain. Anything about someone's safety, a child under 13, the law, a security problem or a refund is read and answered by a person instead. A parent's request to withdraw consent is confirmed and carried out as section 7 describes. If you ask whether a reply was written by AI, it will say so. We keep support email for twelve months, then delete it, unless the law requires us to keep it longer (section 9). We aim to reply within two business days.

We do not yet publish a mailing address. Email is the way to reach us and it is monitored: team@collegecaptain.com. If you need to serve a formal legal notice, Next Gen Solutions LLC's registered office and resident agent are on file with the Massachusetts Secretary of the Commonwealth.

Questions about this document? Email us and a person will answer: team@collegecaptain.com