Axiom Oracle Privacy Policy

Effective Date: June 16, 2026

1. Who We Are

Axiom Oracle is the brand name (DBA) of AO Tutoring LLC, a Wyoming limited liability company. We operate the website located at axiomoracle.ai and provide AI-powered tutoring services for individuals pursuing legal education.

When we say "Axiom Oracle," "we," "us," or "our" in this policy, we mean AO Tutoring LLC. When we say "you" or "your," we mean you—the person using our services.

2. Scope & Applicability

This Privacy Policy applies to all personal information we collect through:

• SMS / text messaging — Our primary tutoring interface. You interact with our AI tutor by texting a toll-free number. Longer responses are delivered via unique web-view links sent within the conversation.
• The Axiom Oracle web app — Including LSAT and bar prep tools, community discussions, blog content, and account management.
• Any other service, feature, or communication we offer that links to this policy.

Our service is messaging-first by design. You do not need to download a mobile app to use the core tutoring experience—just a mobile phone that can send and receive text messages. The web app provides supplemental tools and community features.

This policy does not apply to third-party websites, services, or platforms linked from our content. Those services have their own privacy policies, and we encourage you to review them.

3. Categories of Personal Information We Collect

3.1 Account & Identity Information

Name, email address, mobile phone number, username, and account credentials (hashed password or authentication tokens). We also collect your self-reported "stage" in the legal-education journey (e.g., prelaw, applying, admitted, 1L, 2L, 3L, bar-prep), which determines the content and features available to you.

3.2 Subscription & Payment Information

Billing name and address, subscription plan selection, transaction history, and payment method details. Full payment card numbers are processed and stored by our third-party payment processor, Stripe. We do not store full credit or debit card numbers on our systems.

3.3 Conversation & Message Content

The messages you send to and receive from our AI tutor via SMS or the web app, including questions, prompts, follow-ups, and any information you voluntarily include in those messages.

3.4 Study & Performance Data

Practice-question responses, scores, progress metrics, study-session data, diagnostic results, and performance analytics related to LSAT prep, law-school coursework, the MPRE, and bar-exam preparation.

3.5 Referral Program Data

Whether you participate in our referral program, your unique referral code, the shareable "score-share" graphic generated for you (which embeds your referral code), and records of referrals made or received. When a new user signs up using your referral code, we associate that sign-up with your account for the purpose of crediting your continued free usage.

3.6 User-Generated Content (Community & Discussions)

Posts, comments, replies, and any other content you submit to community discussion boards, forums, or blog comment sections on the Axiom Oracle web app.

3.7 Technical & Device Information

IP address, device type and model, operating system and version, browser type, unique device identifiers, mobile carrier information, time zone, language preference, referring URL, and general geolocation inferred from your IP address.

3.8 Usage Data

Pages and features accessed, session duration, clickstream data, interaction patterns within the web app, links clicked in SMS-delivered web views, feature usage frequency, and error or crash reports.

3.9 Information from Third-Party Sources

We may receive limited information from third parties, including:

• Twilio (our messaging platform provider): delivery receipts, carrier information, and message-status metadata.
• Payment processor: transaction confirmations and fraud-screening signals.
• Analytics providers: aggregated engagement data associated with device identifiers or IP addresses.

4. How We Collect Your Information

4.1 Directly from You

When you create an account, subscribe, send text messages to our AI tutor, use our web app tools, post in community discussions, participate in the referral program, contact support, or otherwise communicate with us.

4.2 Automatically

When you interact with our services, we automatically collect technical, device, and usage data through server logs, cookies, pixels, and similar technologies on the web app. SMS interactions generate metadata (e.g., timestamps, message-delivery status) collected by our messaging infrastructure.

4.3 From Third Parties

From service providers such as our messaging platform (Twilio), payment processor, and analytics tools, as described in Section 3.9 above.

5. How We Use Your Information

5.1 Operating & Delivering the Service

To create and manage your account; authenticate your identity; deliver AI-tutoring responses via SMS and web views; personalize your experience based on your stage, study history, and performance data; administer subscriptions and process payments; manage the referral program; and provide customer support.

5.2 AI-Powered Tutoring Services

To transmit your messages and study data to third-party AI model providers that generate tutoring responses; to apply your stage and performance context so the AI can tailor explanations, practice questions, and feedback to your level; and to present AI-generated content back to you via SMS or web views.

5.3 Payments & Subscriptions

To process subscription payments, manage billing cycles, issue receipts, handle refunds or disputes, detect payment fraud, and administer referral-program credits.

5.4 Communications

To send you service-related messages (e.g., account confirmations, subscription reminders, tutoring responses); to provide information about new features, content, or study resources; and to respond to your support inquiries.

5.5 Improvement & Operations

To analyze usage patterns, diagnose technical issues, improve AI-tutoring quality, develop new features and study tools, conduct internal analytics, and perform research on aggregated or de-identified data.

5.6 Safety, Security & Legal

To detect and prevent fraud, abuse, or unauthorized access; enforce our terms of service; comply with applicable laws and legal processes; protect the rights, safety, and property of Axiom Oracle, our users, or others; and respond to lawful government requests.

6. AI-Specific Disclosures

6.1 AI Model Providers

We use third-party AI model providers (OpenAI and Anthropic) to generate tutoring responses. When you send a message to our AI tutor, your message content and relevant study context are transmitted to these providers so they can produce a response.

6.2 How AI Processes Your Data

Your conversation messages, along with contextual information such as your stage, recent study activity, and question history, are sent to AI model providers as input. The AI processes this input and returns a tutoring response, which we then deliver to you. We may retain conversation data on our own systems to maintain conversation continuity, enable you to review past interactions, and improve service quality.

6.3 AI Training

Your conversation data is not used to train third-party AI models. Our agreements with AI model providers prohibit them from using your inputs or our users' data to train or improve their general-purpose models. We may, however, use aggregated, de-identified interaction patterns to improve our own prompts, system instructions, and tutoring workflows.

6.4 Automated Decision-Making & Recommendations

Our AI tutor generates content recommendations, practice-question selections, and study-path suggestions based on your stage, performance history, and stated goals. These recommendations are educational in nature. No automated decision with legal or similarly significant effect is made about you solely based on automated processing.

6.5 Quality Review

We may conduct limited human review of a sample of AI-tutoring conversations for the purposes of quality assurance, accuracy monitoring, safety evaluation, and service improvement. Reviewers are bound by confidentiality obligations and access data only as needed for these purposes.

6.6 Non-Reliance / Not Legal Advice

AI tutoring output is educational assistance only. It is not legal advice, does not create an attorney-client relationship, and is not guaranteed to be complete or accurate. AI-generated explanations may contain errors. You should not rely on Axiom Oracle's responses as a substitute for professional legal counsel. Always verify critical information independently and consult a licensed attorney for legal questions concerning your rights or obligations.

6.7 State AI-Specific Disclosures

Where required by applicable state law (including but not limited to Colorado's AI Act effective February 1, 2026), we disclose that our services use artificial intelligence to generate educational content. Our AI system makes content recommendations but does not make consequential decisions concerning your legal rights, employment, housing, insurance, education enrollment, or access to credit. If you believe an AI-driven interaction has produced a materially inaccurate or harmful result, you may contact us at support@axiomoracle.ai to request human review.

7. How We Share & Disclose Your Information

7.1 Service Providers & Sub-Processors

We share personal information with trusted service providers who assist us in operating our business, including:

• AI model providers (OpenAI and Anthropic) — to generate tutoring responses.
• Messaging platform (Twilio) — to deliver and receive SMS messages.
• Payment processor (Stripe) — to process subscription payments.
• Cloud hosting and infrastructure (Render for application hosting; Supabase, on Amazon Web Services, for data storage) — to store and serve our systems.
• Analytics providers — to understand usage and improve our service.
• Customer-support tools — to manage and respond to inquiries.

These providers access personal information only as necessary to perform services on our behalf, are contractually obligated to protect it, and may not use it for their own purposes.

7.2 Legal Requirements

We may disclose personal information if we reasonably believe disclosure is necessary to: (a) comply with applicable law, regulation, legal process, or governmental request; (b) enforce our terms of service or other agreements; (c) detect, prevent, or address fraud, security issues, or technical problems; or (d) protect the rights, property, or safety of Axiom Oracle, our users, or the public.

7.3 Business Transfers

If AO Tutoring LLC is involved in a merger, acquisition, asset sale, financing, bankruptcy, or other change-of-control transaction, your personal information may be transferred as part of that transaction. We will provide notice before your information is transferred and becomes subject to a different privacy policy.

7.4 With Your Consent

We may share your information for purposes not described in this policy if we obtain your explicit consent to do so.

7.5 Aggregated & De-Identified Data

We may share aggregated or de-identified data that cannot reasonably be used to identify you. For example, we may publish aggregate statistics about user performance trends on the LSAT or bar exam.

7.6 No Sale of Personal Information

We do not sell your personal information. We do not share your personal information with third parties for cross-context behavioral advertising. We have not sold personal information in the preceding twelve months.

8. Data Retention

8.1 General

We retain your personal information for as long as your account is active or as needed to provide you with our services. Beyond that, we retain personal information as necessary to comply with legal obligations (e.g., tax and financial record-keeping), resolve disputes, enforce our agreements, and for legitimate business purposes such as maintaining security logs and fraud prevention.

8.2 Account Deletion

When you request account deletion, we will delete or de-identify your personal information within a reasonable timeframe, except for information we are required or permitted to retain under applicable law. Certain data (e.g., de-identified analytics, financial transaction records required for tax compliance) may persist after deletion in a form that is no longer linked to you.

8.3 Conversation Data

AI-tutoring conversation history associated with your account is retained while your account is active so you can review past interactions. Upon account deletion, conversation data is deleted or de-identified in accordance with Section 8.2 above.

9. Your Privacy Rights

9.1 All Users

Regardless of where you reside, you may:

• Access your personal information by logging into your account or contacting us.
• Update or correct inaccurate information in your account settings or by contacting us.
• Delete your account and request deletion of your personal information by contacting us at support@axiomoracle.ai.
• Opt out of promotional communications by following the unsubscribe instructions in those messages or by adjusting notification settings in your account.

9.2 California (CCPA / CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act:

• Right to Know: You may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purposes for collection, and the categories of third parties with whom we share it.
• Right to Delete: You may request deletion of personal information we have collected from you, subject to certain exceptions.
• Right to Correct: You may request correction of inaccurate personal information.
• Right to Opt Out of Sale/Sharing: We do not sell your personal information or share it for cross-context behavioral advertising. No opt-out action is required.
• Right to Limit Use of Sensitive Personal Information: We do not use or disclose sensitive personal information for purposes beyond those permitted under the CPRA without your consent.
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

To submit a request, contact us at support@axiomoracle.ai or 1621 Central Ave #61649, Cheyenne, WY 82001. We will verify your identity before processing your request. You may designate an authorized agent to submit a request on your behalf; we will require verification of both your identity and the agent's authority.

Categories of information collected, purposes, and disclosures are described in Sections 3, 5, and 7 of this policy. We do not sell personal information and have not done so in the preceding twelve months. We do not use or disclose sensitive personal information for purposes that would require us to offer a right to limit under the CPRA.

9.3 Other U.S. States

If you reside in Virginia, Colorado, Connecticut, Texas, Utah, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, or another state with a comprehensive consumer privacy law, you may have similar rights, including the right to access, correct, delete, and obtain a copy of your personal information, and the right to opt out of targeted advertising, the sale of personal information, and certain profiling. We do not engage in the sale of personal information or targeted advertising.

To exercise your rights under any applicable state law, contact us at support@axiomoracle.ai. We honor Global Privacy Control (GPC) signals as a valid opt-out mechanism where required by law.

If we deny your request, you may appeal by contacting us at support@axiomoracle.ai with the subject line "Privacy Rights Appeal." We will respond within the timeframe required by your state's applicable law.

9.4 Users Outside the United States

Axiom Oracle is operated from the United States and is intended for users in the United States. If you access our services from outside the United States, please be aware that your information will be transferred to, stored, and processed in the United States. By using our services, you consent to the transfer of your information to the United States. We do not specifically target users in the European Union, United Kingdom, or other jurisdictions outside the United States, and we do not currently monitor compliance with the GDPR or equivalent non-U.S. data-protection frameworks.

10. Not Directed to Children

Axiom Oracle is designed for adults aged 18 and older (or the age of majority in your jurisdiction) who are pursuing legal education. Our services are not directed to children under the age of 18, and we do not knowingly collect personal information from anyone under 18.

If you believe that a person under 18 has provided us with personal information, please contact us at support@axiomoracle.ai. If we learn that we have collected personal information from a person under 18, we will take prompt steps to delete that information and terminate any associated account.

FERPA does not apply. Axiom Oracle is a private tutoring company. We are not an educational institution, a school official, or a service provider acting on behalf of a school under FERPA. Your study and performance data is governed by this Privacy Policy, not by FERPA.

11. Security Measures

11.1 Technical Safeguards

We implement commercially reasonable technical measures to protect your personal information, including encryption of data in transit (TLS) and at rest, access controls, secure authentication mechanisms, and regular vulnerability assessments.

11.2 Organizational Safeguards

Access to personal information is restricted to personnel who need it to perform their job functions. Employees and contractors with access to personal data are subject to confidentiality obligations.

11.3 Payment Security

All payment processing is handled by Stripe, which maintains PCI-DSS compliance. We do not store, process, or have access to full payment card numbers.

11.4 Breach Notification

In the event of a security breach involving your personal information that triggers notification obligations under applicable law, we will notify you and relevant authorities within the timeframes required by law.

11.5 Limitations

No method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee absolute security. You use our services at your own risk and are responsible for maintaining the confidentiality of your account credentials.

12. Where Your Data Is Stored

Your personal information is stored and processed on servers located in the Northern California region (Amazon Web Services, via Supabase) in the United States. Our service providers, including AI model providers, messaging infrastructure, and payment processors, may process data in additional locations within the United States. We do not intentionally transfer personal information outside the United States for storage.

13. Additional Disclosures

13.1 Do Not Track

Some browsers transmit "Do Not Track" (DNT) signals. At this time, our web app does not respond to DNT signals. However, we honor Global Privacy Control (GPC) signals as a valid opt-out of any sharing for targeted advertising or sale, where required by applicable law.

13.2 Cookies & Similar Technologies

Our web app uses cookies and similar technologies (such as pixels and local storage) for the following purposes:

• Essential cookies: Required for authentication, session management, and security.
• Functional cookies: Used to remember your preferences and settings.
• Analytics cookies: Used to understand how users interact with the web app so we can improve it.

We do not use advertising or behavioral-tracking cookies. You may control or disable non-essential cookies through your browser settings, though doing so may affect certain functionality.

Our SMS-based tutoring does not use cookies. Unique web-view links delivered via text message may use session-based tokens for authentication but do not place persistent tracking cookies on your device.

13.3 Third-Party Links

Our web app, blog posts, or tutoring responses may contain links to third-party websites or resources. We are not responsible for the privacy practices of those third parties. We encourage you to read their privacy policies before providing them with any information.

13.4 SMS Communications

Consent: By providing your mobile phone number and signing up for our service, you consent to receive text messages from Axiom Oracle at that number, including AI-tutoring responses, service notifications, and account-related alerts.

Message Frequency: Message frequency varies based on your usage of the tutoring service. You control how often you receive tutoring messages by how often you text us.

Opt-Out: You may opt out of SMS messages at any time by texting STOP to our toll-free number. After opting out, you will receive a single confirmation message and no further texts unless you re-subscribe. Note that opting out of SMS will prevent you from using the text-based tutoring service.

Help: Text HELP to our toll-free number for support information.

Carriers: Standard message and data rates from your mobile carrier may apply. Carriers are not liable for delayed or undelivered messages.

Third-Party Messaging Infrastructure: Our SMS messages are transmitted through Twilio, a third-party communications platform. Twilio processes your phone number, message content, and delivery metadata in order to deliver messages on our behalf. Twilio's handling of this information is governed by its own privacy policy and our data-processing agreement with Twilio.

13.5 Email Communications

We may send you service-related emails (e.g., account verification, subscription confirmations, password resets). We may also send promotional emails about new features or content. You may opt out of promotional emails by clicking the "unsubscribe" link in any such email. Opting out of promotional emails will not affect service-related transactional emails.

13.6 Notification Preferences

You can manage your communication preferences—including which types of notifications you receive and through which channels—in your account settings on the web app.

14. Referral Program & Score-Share Graphics

When you participate in our referral program:

• We generate a unique referral code tied to your account.
• We create a shareable "score-share" graphic that displays your study achievement (e.g., a practice-test score or milestone) and embeds your referral code.
• When you share this graphic and a new user signs up using your code, we record the referral relationship. This allows us to credit your account with continued free usage as described in our terms.
• Your referral code does not reveal your full name, email address, or phone number to the referred person. The referred user sees only the graphic and the code.
• A new user who signs up via your referral code is treated as a new account holder. Their personal information is collected and handled according to this Privacy Policy. We do not share your personal information with the referred user, or vice versa, beyond the referral-code linkage used for crediting purposes.

15. User-Generated Content in Community Discussions

Our web app includes community discussion forums and comment features. Please be aware:

• Visibility: Posts, comments, and other user-generated content submitted to community discussions may be visible to all registered Axiom Oracle users and, depending on the forum's settings, may be publicly accessible.
• Responsibility: You are responsible for the information you choose to share in community discussions. Do not post personal information you do not wish to be publicly available.
• Moderation: We may (but are not obligated to) review, moderate, or remove user-generated content that violates our community guidelines or terms of service.
• Retention: User-generated content posted in community discussions may persist even after account deletion, in de-identified or archived form, to preserve the integrity of discussion threads for other users.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Effective Date" at the top of this page and provide notice through reasonable means—such as an in-app notification, SMS message, or email—before the changes take effect. Your continued use of our services after the updated policy takes effect constitutes your acceptance of the changes. We encourage you to review this policy periodically.

17. Contact Us

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