Turbo AI Privacy Policy

Last Updated: December 1 , 2025

This Privacy Policy (“Policy ”) describes the personal information collected by or on behalf of TurboLearn, Inc. (“ Turbo AI ,” “ we ,” “ us ,” or “ our ”) through our website https://www.turbo.ai/ and turbo.ai (“Sites”) and our mobile application (“App”) and the use of the services available via the same (“Services”), as well as how that information is used and disclosed. If you have questions or concerns about this Policy, please contact us as set forth below.

If you are a California, Maryland, or Montana resident, please see the State Privacy Exhibit section of this Privacy Policy below for additional information that may apply to you.

We may modify this Policy at any time. Changes that in our sole discretion are material changes will be conspicuously posted on the Services or otherwise communicated to you. We do not ordinarily provide notice of a minor change. All changes will be effective immediately upon posting.

1. Information We Collect

We may collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly with you (“ Personal Information ”) when you use our Services. The Personal Information we collect falls into three categories: (1) information you provide to us, (2) information we collect through automated methods, and (3) information we collect from other sources, each further detailed below. We will collect, use, and disclose such Personal Information pursuant to this Policy and applicable law.

Our AI-enabled Services allow you to upload various content (e.g., lecture or meeting audio, PDFs, textbooks, and other documents). You control what you upload. Please use discretion and do not upload sensitive or personal information (e.g., health/medical data, Social Security numbers, driver’s license or passport numbers, financial account details, or passwords). This is for your protection, as nothing is 100% secure on the internet. Please upload with caution.

Information You Provide to Us

We collect Personal Information that you provide directly to us. This may occur in the following ways:

Account Registration: When you register for an account, we will collect your name, email address, and any other information you choose to provide. If you choose to login with your Google account, you will need to provide your log-in information for your Google account through the Services, including your email address and password. We do not retain the Google account credentials that you submit. We maintain only whether Google verifies your account credentials.

Subscription Information: In addition to account registration information, if you purchase a subscription, you will also be required to submit certain Personal Information to facilitate the purchase and use of the subscription.

Order & Payment Data: We use a PCI-compliant payment processor to help us facilitate payment for subscriptions. Turbo AI does not receive your full credit or debit card number or other financial information when you make a payment, and such information is provided directly to our payment processor. However, Turbo AI does receive information about your transaction, subscription purchased, and your contact information (e.g., name and billing address) to administer your subscription.

Service-Related Information: We collect Personal Information that you provide in the course of using the Services or seeking support, such as any Personal Information contained in the content you submit. This includes information submitted to our AI-powered chat bot.

Contacting Us: If you contact us, we will collect and use your name and contact information and any additional Personal Information you provide in your message, if applicable.

Feedback: When you provide comments or feedback about our Services, the content available via our Services, or our products, including reviews (“ Feedback ”), we will collect Personal Information that you submit along with your Feedback.

Data Automatically Collected

We may use automated technologies to collect Personal Information from your computer system or mobile device when you use our Services. This may include the following:

Cookies & Other Tracking Technologies: We may use cookies, web beacons, pixel tags and other tracking technologies (collectively “ Tracking Technologies ”) on our Services. The types of Tracking Technologies we use, and their purposes are further detailed in the How We Use Your Personal Information section below. Most browsers automatically accept Tracking Technologies. You may be able to disable Tracking Technologies by changing your browser settings, depending on your browser, but disabling Tracking Technologies may impact your use and enjoyment of the Services. Not all features or functions of the Services may work properly if you disable Tracking Technologies. You cannot disable all Tracking Technologies, such as those that are essential to the functioning of the Services.

The Tracking Technologies on our Services may collect information such as:

IP addresses assigned to the computers and other devices you use;
your internet service provider
device ID number
approximate geographic location
browser type
Site pages visited
websites you access before and after visiting the Services, and
data related to how and when you use the Services.

Data from Other Sources.

We obtain Personal Information about individuals from other sources, including third parties and existing users of the Services, and we may combine that Personal Information with other data we may already have. We also may receive your Personal Information when a user of the Services sends you content via the Services or when a user uploads content that contains your Personal Information.

2. How We Use Your Information

We use Personal Information that we collect for the following purposes:

As Stated or Agreed to at the Point of Collection: We may use Personal Information for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use Personal Information to respond to your questions, comments, or complaints. We may also use as otherwise requested or consented to by you.

Artificial Intelligence: We may use your Personal Information to further develop our artificial intelligence and improve our Service.

Administration: We use Personal Information for administrative purposes, such as facilitating transactions and subscriptions, managing accounts, to inform our business strategies, and to understand demographics and user preferences.

Management of the Services: We use Personal Information to manage the Services, such as troubleshooting problems, improving content and functionality, training and development (including for training AI tools), conducting statistical and other analyses, and to customize the Services to you and our users. We also use Personal Information to help detect and thwart fraudulent activities.

Feedback: We do not treat Feedback as confidential, and we may use Feedback for any purpose in our sole discretion so long as it does not personally identify you. Feedback may be used without attribution or compensation to you.

Business Analytics: We use Personal Information for business analytics purposes, including consumer and operations research, to assess the effectiveness of our Services, marketing and advertising, and to analyze market trends and customer demand.

Email Communications: We use Personal Information to send you service-related and transactional messages (for example, when your notes or summaries are ready), account or security notices, and updates about our Services, Terms of Service, or this Policy. We may use third-party service providers to deliver these communications. We do not currently send promotional or advertising emails. If we decide to do so in the future, we will provide any notices or obtain any consents required by law, and you may opt out at any time using the unsubscribe link in the email. Opting out of marketing emails does not affect your receipt of transactional or other non-marketing communications.

To Protect Our Rights: We may use Personal Information to protect our legal rights or interests, or those of other parties, including to bring a legal action against you or anyone who may be causing harm to us, our Services, or to other users of the Services. We may also use Personal Information to seek business, financial or legal advice, and to respond to other legal requests.

Create Aggregated and De-Identified Data: We may process Personal Information to create deidentified and aggregated data. Any such deidentified and aggregated data is no longer subject to this Privacy Policy. Turbo AI is the sole and exclusive owner of such de-identified and anonymized information.

How We Use Data Collected by Tracking Technologies:

We use Tracking Technologies to: (i) make our Services function properly, (ii) provide personalized experiences, (iii) tailor our interactions with you, (iv) help with our marketing efforts, (v) provide us with valuable data and statistics about the usage and effectiveness of our Services, and (vi) to help us improve our Services. We also use Tracking Technologies and third-party Tracking Technologies as follows:

Google Analytics: We use Google Analytics to collect and process information about your use of the Services.
Google Ads: We use Google Ads to serve ads across various websites. To opt-out of this type of advertising by Google, to customize your ad preferences, or to limit Google’s collection or use of such data, visit Google’s Ad Settings and follow Google’s personalized ad opt-out instructions.
Google Single Sign On: If you elect to use Google single sign on, these single sign-on features may require us to implement cookies, plug-ins, and application protocol interfaces (APIs) provided by Google to facilitate those communications. In addition, by using these single sign-on features, you allow us to disclose Personal Data with Google. We do not and cannot control any policies or terms of Google. All information you have provided to Google is subject to Google’s privacy policy.
Online Behavioral Advertising: We use third parties and/or service providers to provide interest- based advertising services, including the Social Media platforms above. These services may serve advertisements on our behalf that are customized based on predictions about your interests generated from your visits to websites (including the Services) over time and across different websites. The data collected may be associated with your Personal Information. These advertisements may appear on the Services and on other websites and may be sent to you via email.

To change your preferences with respect to certain online ads or to obtain more information about online behavioral advertising, visit the National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads. Opting-out of targeted advertising does not opt you out of all ads on all devices, just those targeted to you on the devices that you opt-out. PLEASE NOTE : We do not operate or control these third party services, and there may be additional ways for you to opt out of online advertising. By opting out, you will continue to see ads, but ads may not be as relevant to your interests.

DNT Signals: Various browsers (i.e., Internet Explorer, Chrome, Firefox, Edge, etc.) allow a “do not track” (“ DNT ”) setting, which sends a signal to websites visited by an individual about their browser DNT setting. At this time, there is no general agreement on how companies, like us, should interpret DNT signals. Therefore, at this time our Services do not respond to “Do Not Track” signals transmitted by browsers.

3. Retention of Personal Information

We will keep Personal Information for the period necessary to fulfill the purposes described in this Policy, unless a longer retention period is permitted or required by law. We take reasonable steps to delete the Personal Information we collect when: (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining the information, or (3) if you ask us to delete your Personal Information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. We may also decide to delete your Personal Information if we believe it is incomplete, inaccurate, or that our continued storage of your Personal Information is contrary to our legal obligations or business objectives. When we delete your Personal Information, it will be removed from our active servers and databases; however, it may remain in our archives when it is not practical or possible to delete it.

4. Disclosure of Personal Information

We may disclose Personal Information to the following categories of parties, in compliance with applicable laws:

Affiliates: We may disclose Personal Information to our affiliates who have a need to know the information for our business purposes.

Customers: We may disclose Personal Information to organizations and educational institutions with whom you are affiliated in order to enforce our policies and terms.

Third Parties and/or Service Providers: We may disclose Personal Information to third parties and service providers that support our Services (e.g., hosting, management, analytics, troubleshooting, security, advertising, and marketing). We do not operate in-house AI models; instead, we utilize external AI providers (currently OpenAI®, Grok®, Anthropic®, and Modal Labs) to host and process content that powers certain features. When you use our AI-enabled Services, your content (which may include Personal Information) is transmitted to and processed by these providers to fulfill your requests. We take commercially reasonable steps to ensure our vendors, contractors, and business partners provide at least the same level of protection for Personal Information as we do. In some cases, a third-party provider may interact with you directly. To the extent we do not receive, access, or store Personal Information you provide directly to such providers, their collection and use of that data are governed by their own privacy policies and/or terms, which are made available to you as required by applicable laws.

Government Officials / Law Enforcement: We will cooperate with law enforcement and other governmental agencies, and may disclose Personal Information: (i) if we believe in good faith we are legally required to disclose that Personal Information, (ii) if we are advised to disclose Personal Information by our legal counsel, (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Turbo AI or any other party, (iv) or as otherwise appropriate.

Professional Advisors: We may disclose Personal Information to our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to Turbo AI.

Subsequent Owner or Operator: We may transfer your Personal Information to a successor entity or an operator upon a merger, consolidation, acquisition, bankruptcy, dissolution, liquidation or other corporate reorganization, to a purchaser of all or a portion of our assets, or pursuant to a financing arrangement or co-promotional agreement. The Personal Information we have about you may be transferred to parties to the transaction.

Others: We may disclose Personal Information to third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).

5. Children's Information

The Services are not directed at children under 16 years of age. We do not knowingly collect, sell, use, or share Personal Information from children under 16. If we obtain actual knowledge that any Personal Information has been provided by a child under the age of 16 , we will promptly delete that information. If a parent or legal guardian learns that their child provided us with Personal Information without his or her consent, please contact us and we will make commercially reasonable attempts to delete such Personal Information.

6. Data Security

We use commercially reasonable technical and organizational measures to help secure Personal Information against loss, misuse, and alteration appropriate to the type of Personal Information processed. YOU UNDERSTAND THAT NO DATA TRANSMISSION OVER THE INTERNET CAN BE GUARANTEED TO BE 100% SECURE. WHILE WE STRIVE TO PROTECT PERSONAL INFORMATION, WE DO NOT GUARANTEE THE SECURITY OF PERSONAL INFORMATION AND YOU PROVIDE PERSONAL INFORMATION AT YOUR OWN RISK.

7. Access from Outside the United States

If you access the Site from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States, which may have different data protection laws than other countries.

8. Third-Party Websites

The Services may link to, or be linked from, websites not controlled by us. We are not responsible for third parties’ privacy policies or practices. This Policy does not apply to any third-party websites or to any data that you provide to third parties. You should read the privacy policy for each website that you visit.

We are active on social media, including TikTok ® & YouTube® (“ Social Media ”). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Services and our Social Media pages any comments or content that you post on our Social Media pages. Your use of Social Media is governed by the privacy policies and terms of the providers that own and operate those websites and not by this Policy. We encourage you to review those policies and terms.

9. Contact Us

If you have questions or concerns regarding this Policy, contact us at:

Address: 6287 Claridge Ln, Frisco, Texas 75035
Phone: (323) 746 - 1324
Email: contact@turbolearn.ai

STATE PRIVACY EXHIBIT

This State Privacy Exhibit contains additional information for consumers in the following states:

A. California
B. Maryland and Montana

These Sections provide additional terms that apply to consumers of these states. In the event of a conflict between these Sections and the remainder of this Policy, this Section shall take precedence for consumers of these states.

A. NOTICE TO CALIFORNIA CONSUMERS

In this Section only, any capitalized terms not defined in this Policy have the meanings set forth in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act, and including its implementing regulations (the “ CCPA ”).

The Collection, Source, Purpose and Sharing of Your Personal Information.

Categories of Personal Information. In the last twelve (12) months, we have collected the following categories of Personal Information:

Identifiers consisting of: real name, alias, postal address, unique personal identifier, online identifier, internet protocol address (“IP Address”), email address, account name, and other similar identifiers.
Personal Information described in subdivision (e) of Section 1798.80 including: name, address, and phone number.
Commercial Information consisting of: products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet Activity consisting of: browsing history, search history, and information regarding a Consumer’s interaction with an internet website, or advertisement.
Audio, electronic, visual, thermal, olfactory, or similar information.
Education information: defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).
Inferences: Inferences drawn from any of the information identified in Section 1798.140(v)(1) to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Sensitive Personal Information: consisting of your account log-in or debit/credit card number in combination with security or access code, password, or credentials, allowing access to your account.

Categories of Sources from Which Personal Information is Collected: The categories of sources from which your Personal Information is collected are described in Section 1 (Information We Collect).

Purposes for Collecting Personal Information: We use the categories of Personal Information listed above for the business purposes described in Section 2 (How We Use Your Information). We also use the categories of Personal Information listed above for the following business purposes expressly identified by CCPA, which fall under one or more of the following categories below:

Auditing related to counting ad impressions to unique visitors and auditing compliance.
Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes.
Debugging to identify and repair errors that impair existing intended functionality.
Short-term, transient use.
Providing advertising and marketing services (excluding targeted advertising).
Undertaking internal research for technological development and demonstration.
Other purposes as expressly authorized by the implementing regulations of the CCPA.

Categories of Service Providers or Contractors with Whom Personal Information is Disclosed for a Business Purpose: In the last 12 months we have disclosed all the categories of Personal Information listed above for business purposes. The categories of Service Providers or Contractors with whom we disclose Personal Information in the last 12 months are described above in Section 4 (Disclosure of Personal Information).

Categories of Third Parties with Whom Personal Information Sold or Shared.

In the last 12 months we have not Sold or Shared Personal Information for monetary compensation or for other valuable consideration. We do not have any actual knowledge that we have Sold or Shared Personal Information of any individual under the age of 16.

California Privacy Rights.

California Consumers have the right to make the following requests:

Right to Know and Access. You have the right to request that we disclose the following information regarding our collection and use of your Personal Information over the past 12 months: - The categories of Personal Information we have collected about you; - The categories of sources from which we collect the Personal Information about you; - The business or commercial purpose(s) for which the Personal Information was collected, Sold, or Shared; - The categories of Service Providers and Contractors with whom we disclose that Personal Information for a business purpose; - The specific pieces of Personal Information we collected about you in a format easily understandable to the average Consumer; - The categories of Personal Information that we Sold or Shared, and the categories of third-party recipients to whom it was Sold or Shared.
Right to Delete. You have the right to request that we delete any of your Personal Information that we collected from you and retained.
Right to Opt-out of “Sale” and Certain “Sharing” Practices. You have the right to opt-out of the “Sale” and “Sharing” of your Personal Information with third parties, as those terms are defined under CCPA.
Right to Correct. You have the right to request that we correct inaccurate Personal Information that we maintain about you that you can prove is inaccurate.
Right to Limit Use and Disclosure of Sensitive Personal Information. In certain circumstances, a California Consumer has the right to limit the use and disclosure of Sensitive Personal Information.
Right to Non-Discrimination. We will not discriminate against you for exercising any of your rights under the CCPA.

How to Exercise Your California Privacy Rights. To exercise your California privacy rights, you may submit your request to us by contacting us at contact@turbolearn.ai.

Verifiable Consumer Request: In order to verify your request, we may require additional information to allow us to reasonably verify you are the person about whom we collected Personal Information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request. This information may vary depending on the Personal Information we already have. If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request, and let you know why. We may reject or deny your request as permitted or as required by law. We may charge a fee as permitted by the CCPA, such as to process or respond to your request if it is excessive, repetitive, manifestly unfounded, or if we believe the request is fraudulent or submitted for purposes other than exercising applicable privacy rights.

Authorized Agents: You may only make a request to exercise your rights on behalf of yourself, or a parent or legal guardian may make a request on behalf of their minor child. You also have a right to submit requests to exercise your rights under the CCPA through an authorized agent. If an authorized agent contacts us to exercise the above rights, we will need to verify their identity as well as your identity. We will also require proof of your written authorization to the agent to be your agent and to make the specific request submitted, unless the agent is subject to a Power of Attorney under California probate laws. If the agent is a Power of Attorney under California probate laws, we may require evidence of that status.

B. NOTICE TO MARYLAND AND MONTANA CONSUMERS

In this Section only, any capitalized terms not defined in this Policy have the meanings set forth in the Maryland Online Data Privacy Act (“ MODPA ”) and Montana Consumer Data Privacy Act (“ MTCDPA ”).

Maryland Privacy Rights.

Maryland Consumers have the right to make the following requests:

Right to Request Access. The right to request confirmation whether or not we are processing your Personal Data and to access such Personal Data.
Right to Know. You have the right to request a list of specific third parties with whom we have disclosed your Personal Data. If we do not maintain this information in a format specific to you, then you have a right to request a list of the categories of third partis with whom we have disclosed any Consumer Personal Data.
Right to Data Portability. The right to request a copy of Personal Data that you have provided where processing is completed by automated means in a portable, and to the extent technically feasible, readily useable format.
Request to Delete. The right to request deletion of certain of your Personal Data that we have collected, unless retention is required by law.
Right to Correction. Considering the nature and purpose of our processing of Personal Data, the right to request that we correct inaccuracies in your Personal Data.
Right to Opt Out. You have the right to opt out of the processing of Personal Data for purposes of: (a) targeted advertising, (b) the sale of Personal Data, or (c) profiling in furtherance of a decision that produces a legal or similarly significant effect.

Montana Privacy Rights.

Montana Consumers have the right to make the following requests:

Right to Request Access. The right to request confirmation whether or not we are processing your Personal Data and to access such Personal Data.
Right to Data Portability. The right to request a copy of Personal Data that you have provided where processing is completed by automated means in a portable, and to the extent technically feasible, readily useable format.
Request to Delete. The right to request deletion of certain of your Personal Data that we have collected.
Right to Correction. Considering the nature and purpose of our processing of Personal Data, the right to request that we correct inaccuracies in your Personal Data.
Right to Opt Out. You have the right to opt out of the processing of Personal Data for purposes of: (a) targeted advertising, (b) the sale of Personal Data, or (c) profiling in furtherance of an automated decision that produces a legal or similarly significant effect.

How to Exercise Your State Privacy Rights. To exercise your state privacy rights described in this Section, you may submit your request to us by contacting us at contact@turbolearn.ai.

We will not discriminate against you for exercising any of your state privacy rights.

A parent or legal guardian may make a request on behalf of their dependent or non-adult child. An authorized agent may submit a request on your behalf. If we receive a request from an authorized agent, we will need to verify your identity as the data subject and the agent’s authority to act on your behalf. We may deny a request from an authorized agent if we do not have proof that they are authorized by you to act on your behalf or if applicable state law does not permit requests by anyone other than you.

Authentication of Your Request: Once we receive your request, we will contact you to confirm receipt of your request. We will require sufficient information to verify your identity and the authenticity of your request. If you do not provide us with sufficient information, we may request additional information to verify your request. Certain types of requests may require additional verification, as we may be subject to higher standards of authentication for such requests. We may deny a request if you are unable to prove that you are the custodial parent or legal guardian. We may reject or deny your request as permitted or as required by law. We may charge a fee as permitted by applicable law, such as to process or respond to your request if it is excessive, repetitive, manifestly unfounded, or if we believe the request is fraudulent or submitted for purposes other than exercising applicable privacy rights.

Appeal: If we reject or deny your request, you may appeal our decision within a reasonable amount of time after receiving our denial by contacting us at contact@turbolearn.ai.