Effective Date: July 30, 2025

Axelo.org (“we,” “us,” or “our”) is a platform that uses advanced AI to connect teenagers (ages 13–19) with licensed therapists, vetted mentors, and secure virtual avatars for mental health and career support. We care deeply about protecting your (and your parents’) privacy and data security. This Privacy Policy explains what information we collect, how we use it, and the steps we take to keep it safe. (One key promise: we do not sell or share your personal data with any third parties for marketing or anything like that.)

1. Scope and Applicability
   This Privacy Policy applies to all personal information collected through our website, mobile app, and any related services (we call all of these the “Platform”). It covers information provided by teen users and their parents/guardians, as well as data generated automatically by the Platform when you use it. Currently, Axelo supports voice and video interactions on the Platform, and we plan to add text-based chat in the future. No matter how you interact with Axelo (voice, video, or text), this Privacy Policy will apply to your data.

2. Information We Collect
   We collect a few types of information in order to provide and improve the Axelo service. Here’s an overview:
   
   2.1 Information Provided by Teen Users
   Account Details: When a teen signs up, we collect things like a screen name or username, their age range, and contact information (such as a phone number or email). This contact info is verified by a parent or guardian during registration.
   What You Share in Sessions: This includes the content you share with Axelo during chats or sessions. For example, you might talk about how you’re feeling (your mental health status), your interests and goals (like career interests or personal goals), or other things on your mind. (Don’t worry, as explained below, we don’t keep full transcripts of these conversations, only brief summaries.)
   
   2.2 Information Provided by Parents/Guardians
   Parent/Guardian Info: We collect a parent or guardian’s name and email address. We also ask for proof that they are your parent/guardian and consent to your use of Axelo (for example, by a signed digital consent form).
   
   2.3 Information Collected Automatically
   Device Information: Like most online services, we automatically receive some technical info when you use Axelo. This includes your device type (e.g. phone or computer), operating system, browser type, IP address, and the dates/times you access the Platform.

   Usage Data: We also collect general data about how you use our Platform, such as which features you use and how you navigate through the app. This information is anonymized and helps us understand engagement (for example, which features are popular) so we can improve your experience. It does not include any personal details about you.

   
   

3. Data Minimization and Storage
   We minimize how much personal data is stored on our servers. We do not record or save any full conversation transcripts, audio recordings, or video recordings of your sessions on the Platform. In other words, your exact voice or video chats with Axelo are not stored by us.
   Instead, after a session, our AI creates a short, anonymized summary of what happened. This summary might note the key topics you talked about, any goals or tasks you set, and how you’re doing. We save these summaries to help maintain continuity between sessions (so you don’t have to repeat yourself and the AI or mentor remembers important things) and to support the AI’s decisions and recommendations going forward. These summaries are also used to help us improve the service.

   Importantly, these session summaries do not contain any direct identifiers about you. They do not include your name, contact info, or other sensitive personal details. The summaries focus on the content of the conversation (for example, “talked about feeling stressed at school and discussed coping strategies”) without attaching it to who you are.

   We keep these summaries only for the purposes of helping you (continuity), improving our AI and platform, training our models to be better, and for required nonprofit reporting to show our impact. We do not use them for any other purpose.

4. Parental Consent and Legal Basis

   Because our users are minors, we require verifiable parental or guardian consent before collecting or using a teen’s personal data. This is to comply with child privacy laws like the U.S. Children’s Online Privacy Protection Act (COPPA) and with international laws like the EU’s General Data Protection Regulation (GDPR). We will not allow a teen to use Axelo unless their parent or guardian has given permission and verified their relationship to the teen.

   Aside from consent, we also rely on a standard legal concept called “legitimate interest” to process data in a safe and beneficial way. In practice, this means we use the anonymized session summaries and usage data to improve the service, ensure user safety, and optimize how the Platform works, in a way that doesn’t override your privacy rights. This legitimate interest is another legal basis that allows us to handle the anonymous data (for example, to make our AI better and help you have a good experience) while still protecting your privacy.

5. How We Use Your Information

   We use the information we collect for a few key purposes:

   To provide and personalize the service: We use your information to match you with appropriate therapists, mentors, or AI avatars and to tailor the support and recommendations you receive. For example, knowing your interests or goals (from session summaries) helps us suggest relevant resources or find a mentor who fits your needs.

   To improve Axelo: We analyze the anonymized session summaries and usage statistics to make our AI smarter and to improve the Platform’s features and user interface. This helps us fix issues, add useful features, and make your experience better over time.

   For nonprofit reporting: As a nonprofit, we sometimes need to report on our overall impact to funders or regulators. We use aggregated, de-identified data for this purpose. These reports might show general trends (for example, how many users we served or overall improvements in well-being) but they do not include anything that identifies you personally.

6. Data Sharing and Disclosure

   Your privacy is extremely important to us. We do not share your personal information or session summaries with advertisers, marketers, or any third-party companies for their own use. We also do not sell, rent, or lease your data to anyone.

   The only times we ever share any data are in the following situations:

   Service Providers (Third-Party Tools): We use a few trusted companies to help us run the Axelo platform, under strict confidentiality and data protection agreements. These partners only process data on our behalf and are not allowed to use it for anything other than providing their service to us. For example:

   Amazon Web Services (AWS): We use AWS to host our servers and store data securely. AWS is a leading cloud provider that adheres to high security standards.

   ElevenLabs: We use ElevenLabs for converting speech to text and text to speech. This allows you to talk to our AI companion or hear its responses in a natural voice. ElevenLabs processes the audio so our AI can understand and respond, but they are not allowed to keep or use your voice recordings.

   Mistral AI (Language Model): Axelo’s AI companion is powered by a large language model called Mistral, which we run on our secure AWS servers. This AI generates the responses during your conversations with Axelo. It operates entirely within our system and does not send your data to any outside AI services.

   Legal Compliance: If we are ever required by law to disclose data, or if it’s necessary to share information to protect someone’s safety (for example, to prevent imminent harm), we may do so. This could include complying with a court order or providing information to law enforcement in an emergency. We will only share the minimum amount of information necessary in such cases.

   Aside from the above, we will not disclose your data to anyone else. We want to reassure you that outside of running the Axelo service and complying with the law, your information stays with Axelo.

7. Data Security Measures

   We use strong security measures to protect your information:

   Encryption: All data sent between your device and Axelo is encrypted in transit (using HTTPS/TLS). This means it’s scrambled so no one else can read or intercept it. Our databases are also encrypted at rest on our servers, so your data is protected even if someone were to gain unauthorized access to the storage.

   Access Controls: The only people who can access personal data or summaries are a few authorized Axelo team members who need it to run the service (for example, for technical support or to improve the AI). We have strict access controls in place: staff must use multi-factor authentication, and we regularly review who has access to what.

   Monitoring & Testing: We continuously monitor our systems for security issues. We also perform periodic security audits and vulnerability tests (including third-party penetration tests) to make sure our defenses stay strong.

   Security Certifications: We are actively working towards achieving SOC 2 certification and HIPAA compliance. SOC 2 is a security audit standard that will verify we have enterprise-grade data protection controls, and HIPAA compliance will ensure we safeguard any health-related information according to medical privacy rules. While we are not yet officially certified, we are putting in place all the requirements to meet these high standards.

8. Data Retention and Deletion

   We do not keep personal data longer than necessary. Our policy is to automatically delete or anonymize session summaries once they are no longer needed for the purposes described (generally, we keep them for no more than two years).

   If a parent or guardian wants us to delete their teen’s data sooner, they can ask us at any time. Upon request, we will delete all of a teen’s stored session summaries within 30 days. This deletion is permanent. Additionally, if you decide to stop using Axelo, you can request (through your parent/guardian) that we delete all your data, and we will do so.

9. Your Rights (for Parents and Teen Users)

   We believe it’s important that you have control over your personal information. Both parents and teen users have certain rights regarding the data we collect:

   Parents/Guardians: As a parent or guardian, you have the right to:

   Delete Data: You can request deletion of your teen’s stored session summaries or other personal data at any time. We will honor this request and erase the data (usually within 30 days, as noted above).

   Withdraw Consent: You can withdraw your consent for Axelo to process your teen’s information at any point. If consent is withdrawn, we will stop collecting any new data from your teen and delete the existing summaries associated with their account.

   Raise Concerns: If you have concerns or complaints about how we handle data, you can contact our Data Protection Officer (privacy officer) or report the issue to the appropriate data protection authority. We will work with you to address the issue.

   Teen Users: As a teen using Axelo, you (with help from your parent/guardian) have the right to:

   Access Your Data: You can ask to see the information we have saved about your sessions, such as the anonymized summaries of your chats. We will show you those summaries in a way you can understand.

   Request Deletion or Limits: If you want something removed or not used, you can request that we delete your session summaries or limit how we use them. (Typically, your parent or guardian will help make this request.) We will comply by erasing or restricting your data as needed.

10. Changes to This Privacy Policy

    We may update this Privacy Policy as our Platform or legal requirements change over time. For example, if we add the text-based interaction feature or if privacy laws are updated, we will revise this policy accordingly. If we make any significant changes, we will notify you in advance. We will send an email notice to parents/guardians and post a notification on the Axelo website/app at least 30 days before any new privacy terms take effect. We encourage you and your parents to review any such changes. Continuing to use Axelo after an updated policy goes into effect will mean that you accept the new terms.

    If you have any questions about this Privacy Policy or how Axelo protects your privacy, please reach out to us!