Privacy Policy

This Privacy Policy describes how Aspen ESA, LLC ("Aspen ESA," "we," "us," or "our") collects, uses, and protects information when you use our products and services (the "Service"). By using the Service, you agree to this Privacy Policy.

Who we are

Aspen ESA, LLC is an Arizona-formed limited liability company. Our business address is on file with the Arizona Corporation Commission (Business ID 25056450). You can reach us anytime at hello@aspenesa.com.

What we collect

We collect the following categories of information:

Account information — your email address, name, and authentication information. Passwords for email/password accounts are hashed, not stored as readable passwords. Apple and Google sign-in provide account identifiers and the profile information you authorize. Aspen currently offers free community access and does not offer new subscriptions. Historical Stripe, Apple, or Google billing records may remain for previous purchases; we do not store your full card number.

Kid profile information — optional student profiles may include a name (first name is sufficient), grade, school setting, ESA status and optional award amount, learning preferences, accommodations or disability information, and notes you provide. You do not have to add a student to get started. This information is provided by you, the adult account holder, not collected directly from children. Please avoid unnecessary sensitive details.

Receipts and supporting documents — photos and metadata of receipts you upload, including vendor name, purchase date, amount, and category. We use AI image analysis to extract this information. You may also choose to add notes.

Eligibility checks — text descriptions, photos, or product URLs you submit to check whether a purchase is ESA-eligible. We retain a record of each check (item, verdict, citations, your notes) so you can reference your history later.

Chat conversations — your messages and Aspen's responses are stored to maintain conversation context within a chat session. Past chats are accessible from your account history.

Usage data — pages you visit, features you use, error reports, device/browser information, and similar technical data. Website analytics may use cookies and online identifiers; this data is not necessarily anonymous. We also keep account-linked AI usage and cost records to enforce individual and shared capacity limits. Unauthenticated checks may retain a hashed network identifier, submitted content, and results for abuse prevention and later saving to an account.

Communications — support messages, feedback, and account-deletion requests, including the requesting account, account email, and request date.

How we use your information

We use the information above to:

• Provide the Service (answer questions, organize receipts, generate eligibility guidance, and manage account and deletion requests)
• Improve the Service over time (identify bugs, refine the eligibility engine, expand the curriculum directory)
• Communicate with you about your account, historical billing, deletion requests, and important Service updates
• Enforce our Terms of Service and prevent abuse
• Comply with legal obligations

Who we share your information with

We do not sell your personal information. We share information only with categories of third-party service providers necessary to operate the Service:

• AI and search providers — Anthropic processes relevant text, images, and student context for answers and image analysis. Its commercial API does not use customer inputs for general model training by default. Voyage AI processes search text to retrieve relevant handbook passages. Voyage's training and retention controls require an organization-level opt-out; they are not a no-training default. Provider processing and retention terms apply, including security, abuse-prevention, and legal exceptions. Avoid unnecessary personal information in search queries.
• Hosting, authentication, and storage providers — including Vercel and Supabase, host the application, accounts, database, and uploaded files. Authorized administrators also maintain encrypted recovery copies, including off-site storage such as Google Drive. Backups can contain account, student, receipt, and conversation data and are restricted to recovery/administrative purposes.
• Payment services and app stores — Stripe, Apple, and Google may retain and process historical purchase, renewal, cancellation, and refund records under their own policies. Making Aspen free or deleting an Aspen account does not itself erase those records or cancel a subscription.
• Email and communication providers — send transactional emails (account verification, password reset, billing notices).
• DNS and domain providers — provide domain and email routing services.
• Error monitoring providers — collect error reports so we can fix bugs you encounter.
• Analytics providers — including Google Analytics on the website, process usage and technical information to help us understand how the Service is used.

Aspen does not train its own AI models on private chat content, eligibility checks, or kid profile data. Third-party processing is described above.

We may also share information when required by law (subpoena, court order, regulatory request) or to protect our legal rights, the safety of our users, or the integrity of the Service.

If you choose to publish a review or share a chat or eligibility result through a public link, that selected content becomes accessible to others. Downloaded exports and copies shared outside Aspen are controlled by their recipients; deleting Aspen's copy cannot remove those independent copies.

In the event of a merger, acquisition, or sale of assets, your information may transfer to the acquiring entity, subject to your continued protections under this Privacy Policy.

How we use AI with your data

Aspen ESA is built on AI. When you ask Aspen a question, send a chat message, or run an eligibility check:

• Your input is sent to one or more third-party AI model providers for processing
• Aspen's response is generated based on the Arizona ESA Parent Handbook (which we have indexed), our system prompts, and your kid profile context (when relevant)
• Anthropic's commercial API does not train general models on customer inputs by default; Voyage's separate opt-out controls and both providers' processing and retention terms apply

We do not train our own models on your private account content. Authorized administrators may review conversations, checks, and feedback to provide support, investigate safety issues, and improve prompts and retrieval. This is different from training a provider's general models. Any material change to these data uses will be explained before it takes effect, with consent where required.

How long we keep your information

• Active account data: retained as long as your account is active
• Deletion requests: processed manually. We aim to delete the account and associated live application data within 30 days of a verified request, or sooner when required by applicable law, and send a completion email. Submitting a request is not immediate deletion. We may contact you if ownership verification or a legally permitted exception is needed.
• Receipts and uploaded files: kept with your active account and removed from live storage during account deletion. Keep your own copies of important records.
• Recovery backups: encrypted snapshots can retain deleted data until rotation, for no more than 90 days after live deletion, unless a specific legal preservation obligation applies. They are not used to return deleted accounts to active service. Deletions must be reapplied before a restored system is made available.
• Historical billing and limited security/deletion records: retained only as needed for accounting, legal obligations, fraud prevention, and evidence that a deletion request was completed. Processors and app stores may retain their own records. These exceptions do not authorize keeping all account content indefinitely.
• Aggregated statistics: may be retained after they no longer identify an individual. Cookie identifiers and account-linked logs are not treated as anonymous merely because a name has been removed.

Your rights

You can:

• Access your data — view it directly in the app, or request an export by emailing privacy@aspenesa.com
• Correct your data — edit profile, kid, receipt, and other fields directly in the app
• Delete your account and associated data — choose Request account deletion in Account, or visit aspenesa.com/delete-account. Sign in and confirm the request; an administrator processes it and sends completion confirmation. You do not need to email support when using this signed-in flow. If you cannot access your account, email hello@aspenesa.com for ownership verification and assistance.
• Restrict processing — contact us to discuss
• Object to certain uses — contact us to discuss

If you're an Arizona resident, California resident (CCPA), or in a jurisdiction with similar data protection laws, you may have additional specific rights. Contact us and we'll honor them within the timeframes required by law.

Children's data

Aspen ESA is intended for use by parents, not by children directly. The kid profile information you enter is provided by you about your child — we do not collect information directly from children, do not allow children to create accounts, and do not knowingly market to children.

If you believe a child has created an account or submitted information directly to us, please contact us immediately at privacy@aspenesa.com and we will delete it.

Security

We use industry-standard security measures to protect your data:

• All connections to our servers use TLS encryption (HTTPS)
• Passwords are hashed; we never store plaintext passwords
• Your data is stored in encrypted Supabase databases with row-level security policies that prevent users from accessing each other's data
• Full payment card details are handled by the applicable payment service or app store, not stored by Aspen
• Administrative tools are restricted to authorized administrators; recovery exports are encrypted and access-restricted

No system is 100% secure. If you believe your account has been compromised, contact us immediately.

International users

Aspen ESA is designed for and marketed to families in Arizona, USA. If you access the Service from outside the United States, your information will be transferred to and processed in the United States. By using the Service, you consent to this transfer.

We are not currently structured to comply with GDPR (Europe), so we do not knowingly serve users in the European Economic Area or United Kingdom. If you are in the EEA or UK, please do not create an account.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we'll notify you by email and update the "Last updated" date at the top. Continued use of the Service after a change constitutes acceptance.

Contact

Questions about this Privacy Policy? Email hello@aspenesa.com.