PRIVACY POLICY
Last updated April 19, 2026
This Privacy Notice for 825 Consulting LLC ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:
- Visit our website at http://counselorai.app or any website of ours that links to this Privacy Notice
- Use CounselorAI. CounselorAI is a web-based productivity tool for college counselors. It uses AI to help draft financial aid appeal letters, recommendation letters, waitlist letters, FAFSA action plans, and scholarship match reports. It also includes a financial aid calculator, an award letter decoder (AwardLens), a letter review tool (LetterLens), and a student profile builder. The tool is used by counselors only — students do not create accounts or interact with the platform directly.
- Engage with us in other related ways, including any marketing or events
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at outreach@counselorai.app.
SUMMARY OF KEY POINTS
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.
Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.
Do we collect any information from third parties? We do not collect any information from third parties.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information we collect may include: names, email addresses, job titles, usernames, and contact preferences.
Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information: student data, financial data, health data, and information revealing race or ethnic origin.
Student Data — Important Clarification. CounselorAI does not store student records on any server operated by 825 Consulting LLC. All student profiles and caseload data entered into the CounselorAI workspace are stored locally in the counselor's own browser using browser storage (localStorage). This data is never transmitted to our servers and is not accessible to us. When a counselor uses a generation tool, student context (such as name, school, and circumstances) is transmitted directly to Anthropic's Claude API for the sole purpose of generating the requested document. This transmission is governed by Anthropic's privacy policy and commercial API terms. Anthropic's commercial API does not use submitted data to train AI models. No student information is retained by CounselorAI after the session ends. Counselors are responsible for ensuring they have appropriate authorization to enter student information into any AI-assisted tool.
Payment Data. We may collect data necessary to process your payment if you choose to make purchases. All payment data is handled and stored by Stripe. You may find their privacy notice here: https://stripe.com/privacy.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your IP address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, and other technical information. We also collect information through cookies and similar technologies. The information we collect includes log and usage data, device data, and general location data based on IP address.
Google API
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.
We process your personal information for the following reasons:
- To facilitate account creation and authentication.
- To deliver and facilitate delivery of services to the user.
- To respond to user inquiries/offer support to users.
- To send administrative information to you. Details about our products and services, changes to our terms and policies.
- To request feedback.
- To protect our Services. Including fraud monitoring and prevention.
- To evaluate and improve our Services, products, marketing, and your experience.
- To identify usage trends.
- To comply with our legal obligations.
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the following third parties.
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.
Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice at counselorai.app/privacy.html.
Google Analytics
5. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.
As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.
We provide AI features through Anthropic, PBC ("Anthropic"), using their Claude API. When you use a generation tool, your input (including any student context you enter) is transmitted to Anthropic's API to generate a response. This transmission is subject to Anthropic's Privacy Policy.
No AI Training on Your Data. Anthropic's commercial API does not use inputs or outputs submitted through the API to train or improve its AI models. This means student context, letter drafts, and counselor information you submit through CounselorAI is not used to train Claude or any other AI system. You can verify this in Anthropic's Privacy Policy under their commercial API terms.
You must not use CounselorAI's AI features in any way that violates the terms or policies of Anthropic. You are responsible for ensuring your use complies with applicable privacy laws and any professional obligations you hold regarding student data.
Our AI features are designed for the following functions:
- Generating college-related letters (financial aid appeals, recommendation letters, waitlist letters)
- Analyzing financial aid award letters and comparing cost of attendance
- Generating personalized FAFSA action plans and scholarship match reports
- Reviewing existing recommendation letters against quality rubrics
- Generating student advising profiles for counselor use
All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law. No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information.
Student data is not retained by CounselorAI. As described above, student profiles and caseload data are stored only in the counselor's browser and are not held on our servers. We have no ability to retain, access, or delete this data on your behalf. If you wish to delete student data, you may do so by clearing your browser's local storage or using the delete functions within the CounselorAI workspace.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. You should only access the Services within a secure environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at outreach@counselorai.app.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.
Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us at outreach@counselorai.app.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.
California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.
11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information.
Categories of Personal Information We Collect
| Category |
Examples |
Collected |
| A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name | NO |
| B. Personal information as defined in the California Customer Records statute | Name, contact information, education, employment, employment history, and financial information | NO |
| C. Protected classification characteristics under state or federal law | Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data | NO |
| D. Commercial information | Transaction information, purchase history, financial details, and payment information | NO |
| E. Biometric information | Fingerprints and voiceprints | NO |
| F. Internet or other similar network activity | Browsing history, search history, online behavior, interest data, and interactions with our and other websites | NO |
| G. Geolocation data | Device location | NO |
| H. Audio, electronic, sensory, or similar information | Images and audio, video or call recordings created in connection with our business activities | NO |
| I. Professional or employment-related information | Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us | NO |
| J. Education Information | Student records and directory information | NO |
| K. Inferences drawn from collected personal information | Inferences drawn from any of the collected personal information listed above to create a profile or summary about an individual's preferences and characteristics | NO |
| L. Sensitive personal Information | Citizenship or immigration status, financial information including account access details, health data, national origin, personal data from a known child, and racial or ethnic origin | YES |
We only collect sensitive personal information as defined by applicable privacy laws or the purposes allowed by law or with your consent. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.
We will use and retain the collected personal information as needed to provide the Services. Category L — as long as the user has an account with us.
We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.
Your Rights
You have rights under certain US state data protection laws including: right to know, right to access, right to correct inaccuracies, right to request deletion, right to obtain a copy of your data, right to non-discrimination, and right to opt out of targeted advertising or profiling.
How to Exercise Your Rights
Appeals
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at outreach@counselorai.app. We will inform you in writing of any action taken or not taken in response to the appeal. If your appeal is denied, you may submit a complaint to your state attorney general.
California "Shine The Light" Law
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact details below.
STUDENT DATA & FERPA NOTICE
In Short: CounselorAI does not store student data on our servers. Counselors are responsible for their own compliance with FERPA and applicable privacy laws when using this tool.
Architecture. CounselorAI is designed with a browser-local storage model. All student profiles and caseload information entered into the workspace remain in your browser. This data never passes through servers owned or operated by 825 Consulting LLC. We cannot access, retrieve, or delete it.
AI Processing. When you submit a generation request, student context you enter (name, school, circumstances, financial information) is transmitted to Anthropic's API to produce the requested document. This is a transient processing step — neither CounselorAI nor Anthropic retains this data after the request is fulfilled. Anthropic's commercial API does not train on API inputs.
Counselor Responsibility. CounselorAI is a tool used by education professionals. Counselors using this service are responsible for complying with the Family Educational Rights and Privacy Act (FERPA), applicable state privacy laws, and any professional or institutional policies governing student data. If you work under a school or institution, you should ensure your use of AI-assisted tools is consistent with your institution's data governance policies.
No-Training Guarantee. Anthropic's commercial API terms explicitly prohibit the use of API inputs and outputs for model training. Your student information, letter drafts, and counselor data are not used to train any AI model — by Anthropic or by CounselorAI.
Data Minimization Recommendation. We recommend that counselors enter only the information necessary to generate the requested document. You do not need to include a student's last name, date of birth, Social Security number, or other non-essential identifying information to use CounselorAI effectively.
12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at outreach@counselorai.app or contact us by post at:
825 Consulting LLC
771 Alison Way
San Jacinto, CA 92583
United States
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.