Privacy Policy

Please click here to view the previous version of our Privacy Policy.

This Privacy Policy describes how Boom AI, Inc. ("Boom AI," "we," "us," or "our") processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, social media pages, marketing activities, live events, and other activities described in this Privacy Policy (collectively, the "Service")).

Boom AI provides enrollment, persistence, retention, and student success support to educational institutions by combining Adaptive Artificial Intelligence (AI), machine learning, and SMS text messaging to automatically deliver personalized proactive and reactive engagement via an institutionally branded texting bot. This Privacy Policy does not apply to information that we process on behalf of our business customers (such as educational institutions) while providing the Boom AI platform and services to them. Our use of information that we process on behalf of our business customers may be governed by our agreements with such customers. If you have concerns regarding your personal information that we process on behalf of a business customer, please direct your concerns to that enterprise customer.

Our websites, products, and services are designed for our business customers and their representatives. We do not offer products or services for use by individuals for their personal, family, or household purposes. Accordingly, we treat all personal information we collect as pertaining to individuals in their capacities as representatives of the relevant enterprise and not their individual capacities.

1. Personal Information We Collect

1.1 Information You Provide to Us

Personal information you may provide to us through the Service or otherwise includes:

• Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.
• Demographic data, such as your city, state, country of residence, postal code, and age.
• Profile data, such as the username and password that you may set to establish an online account on the Service, date of birth, redemption code, biographical details, photograph or picture, links to your profiles on social networks, interests, preferences, and any other information that you add to your account profile.
• Job application data, such as professional credentials and skills, educational and work history, LinkedIn profile page, personal website, authorization to work in the U.S., immigration status, criminal history, and other information that may be included on a resume or curriculum vitae as well as in a cover letter. This may also include diversity information that you voluntarily provide.
• Communications data based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Relationship data, such as familial or other relationship to third parties whose personal information you may provide to us.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

1.2 Student Data Provided by Institutions

Institutions provide Boom AI with student data to enable predictive analytics and retention services. This data may include:

• Academic records: GPA, credits attempted and completed, course enrollment, grades
• Enrollment and registration behavior: term-over-term registration, withdrawal history
• LMS engagement metrics: login frequency, assignment submissions, content interactions
• Financial aid status and standing
• Advising and support service interaction history
• Demographic information (as permitted by the institution and applicable law)
• Student identifiers used by the institution (e.g., student ID numbers)
• Phone numbers for SMS outreach (provided by the institution under their authority)

Student data is provided by institutions under their authority as the data controller. Boom AI processes this data as a data processor or "school official" under FERPA on behalf of the institution.

1.3 Third-Party Sources

We may combine personal information we receive from you with personal information we obtain from other sources, such as:

• Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
• Private sources, such as data providers, social media platforms, and data licensors.
• Our affiliate partners, such as our affiliate network provider and publishers, influencers, and promoters who participate in our paid affiliate programs.
• Marketing partners, such as joint marketing partners and event co-sponsors.

1.4 Automatic Data Collection

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications, and other online services, such as:

• Device data, such as your computer or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state, or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Communication interaction data such as your interactions with our email, text, or other communications (e.g., whether you open and/or forward emails) — we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

1.5 Cookies and Similar Technologies

Some of the automatic collection described above is facilitated by the following technologies:

• Cookies, which are small text files that websites store on user devices and that allow web servers to record users' web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both "session cookies" that are deleted when a session ends, "persistent cookies" that remain longer, "first party" cookies that we place, and "third party" cookies that our third-party business partners and service providers place.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
• Session replay technologies may be used to record and replay your interactions with our website to improve our services.
• Third-party chatbot technologies may be used on our website to provide automated customer support and engagement.

1.6 Data About Others

We may offer features that help users invite their contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.

2. How We Use Your Personal Information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

2.1 Service Delivery and Operations

We may use your personal information to:

• Provide, operate, and improve the Service and our business;
• Personalize the service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
• Establish and maintain your user profile on the Service;
• Facilitate your invitations to contacts who you want to invite to join the Service;
• Enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
• Communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
• Communicate with you about events or contests in which you participate;
• Understand your needs and interests, and personalize your experience with the Service and our communications; and
• Provide support for the Service, and respond to your requests, questions, and feedback.

2.2 Research and Development

We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services.

2.3 Marketing and Advertising

We, our service providers, and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

• Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Your Choices section below.
• Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications, and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms.

2.4 Service Improvement and Analytics

We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service (including which pages are most and least visited and how visitors move around the Service), as well as user interactions with our emails, and to develop new products and services.

2.5 Compliance and Protection

We may use your personal information to:

• Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations, or requests from government authorities;
• Protect our, your, or others' rights, privacy, safety, or property (including by making and defending legal claims);
• Audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• Enforce the terms and conditions that govern the Service; and
• Prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

2.6 Recruiting

We may use personal information, such as information submitted to us in a job application, to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics.

2.7 With Your Consent

In some cases, we may specifically ask for your consent to collect, use, or share your personal information, such as when required by law.

2.8 Aggregated, De-Identified, and Anonymized Data

We may create aggregated, de-identified, and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified, and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

2.9 Cookies and Similar Technologies

In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:

• Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password-protected areas of the Service.
• Functionality. To enhance the performance and functionality of our services.
• Advertising. To help our third-party advertising partners collect information about how you use the Service and other online services over time, which they use to show you ads on other online services they believe will interest you and measure how the ads perform.
• Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here.

3. How We Share Your Personal Information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

• Affiliates. Our corporate parent, subsidiaries, and affiliates.
• Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research, and website analytics).
• Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.
• Business and marketing partners. Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.
• Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.
• Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
• Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Boom AI, financing of Boom AI, public stock offerings, or the sale, transfer, or merger of all or part of our business, assets, or shares). We may also disclose your personal information to an acquirer, successor, or assignee of Boom AI as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

We do not sell, rent, or trade personal information for monetary consideration. We do not sell student educational records as defined under FERPA under any circumstances.

4. SMS Messaging and Phone Number Use

Boom AI uses SMS (text messaging) to send service-related communications to students on behalf of their institution. These messages are transactional and informational in nature and include advising reminders, deadline alerts, engagement check-ins, and support resource referrals.

Consent and Opt-In

Boom AI sends SMS messages only to students who have provided a phone number to their institution and for whom the institution has authorized outreach. Students consent to receive service-related messages as part of their institutional enrollment and communication agreements, or through an explicit opt-in process. Consent is not a condition of enrollment. No messages are sent without institutional authorization.

Message Frequency and Rates

Message frequency varies based on student risk signals, institutional workflows, and active outreach campaigns. Message and data rates may apply depending on the student's mobile carrier and plan.

Opt-Out and Help

• To stop messages: Reply STOP to any message. You will be immediately removed from future outreach.
• For help: Reply HELP or contact support@boomai.app.

Phone Number Privacy

Phone numbers collected by Boom AI or provided by institutions are used solely to deliver service-related messages. We do not sell, rent, or share phone numbers with third parties for marketing purposes. SMS is used strictly as a service and support channel.

Boom AI's SMS infrastructure is powered by Twilio and complies with A2P 10DLC carrier registration requirements and applicable TCPA and FCC regulations.

5. FERPA Compliance

Boom AI is designed to help institutions comply with the Family Educational Rights and Privacy Act (FERPA). Our commitments under FERPA include:

• School Official Status: Boom AI operates as a "school official" with a legitimate educational interest as defined under FERPA, acting under the direct control and authority of the institution.
• Data Use Limitation: We use student educational records solely to perform services for the institution and do not use student data for any commercial or secondary purpose. Student data is never used for advertising, model training sold externally, or any commercial purpose.
• No Unauthorized Disclosure: We do not disclose personally identifiable student information to any third party without authorization from the institution, except as required by law.
• Institution Control: Institutions retain full ownership of their student data and may request correction, deletion, or export at any time.
• Data Deletion: Student data is deleted within 30 days of contract termination. Backups deleted within 90 days.
• Breach Notification: We notify institutions within 72 hours of discovering a confirmed or suspected breach affecting student records.
• Louisiana Student Privacy Act: Boom AI complies with La. R.S. 17:3913 et seq. for all LCTCS and Louisiana institution data.
• FERPA DPA: Full Data Processing Agreement available at boomai.app/legal/ferpa.

6. Subprocessors

We use the following subprocessors to provide the Service. Each is bound by data processing agreements no less protective than this policy:

7. Your Choices

Access or Update Your Information

If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

Opt-Out of Communications

You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails. Additionally, if you do not wish to receive phone calls or text/SMS messages from us, you can opt out by contacting us at the provided contact details, or by replying STOP to any SMS message.

Cookies

Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. You can also configure your device to prevent images from loading to prevent web beacons from functioning.

Advertising Choices

You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:

• Browser settings. Changing your internet web browser settings to block third-party cookies.
• Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
• Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising:
  • Google: https://adssettings.google.com/
  • Facebook: https://www.facebook.com/about/ads
• Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:
  • Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
  • Digital Advertising Alliance: optout.aboutads.info
  • AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
• Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes. We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.

Do Not Track

Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

Declining to Provide Information

We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Delete Your Content or Close Your Account

You can choose to delete certain content through your account. If you wish to request to close your account, please contact us.

California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including:

• The right to know what personal information we collect and how it is used
• The right to delete personal information we have collected
• The right to opt-out of the sale or sharing of personal information (Note: Boom AI does not sell personal information)
• The right to non-discrimination for exercising your privacy rights

To submit a California privacy rights request, contact us at support@boomai.app with the subject line "California Privacy Rights Request."

8. Other Sites and Services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications, or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use.

9. Security

We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. These include TLS 1.2+ encryption in transit, AES-256 encryption at rest, role-based access controls (RBAC), continuous security monitoring, regular third-party security assessments, and employee data privacy and security training. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.

10. International Data Transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

11. Data Retention

We retain information for as long as necessary to fulfill the purposes described in this Policy and to comply with legal obligations:

• Institutional User Data: Retained for the duration of the active service agreement plus 90 days after termination
• Student Data: Retained only for the duration of the service agreement; deleted from primary systems within 30 days of contract termination, and from backups within 90 days. Written certification of deletion provided upon request.
• Usage and Technical Data: Retained for up to 24 months for product improvement and security purposes
• Legal and Compliance Records: Retained as required by applicable law, typically 7 years

12. Children's Privacy

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child's parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

13. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

14. How to Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us: