ThinkWithMe Privacy Policy

Effective date: September 4, 2026

ThinkWithMe is a guided learning application operated by Independent Holdings, LLC ("Independent Holdings," "we," "us," or "our").

This Privacy Policy describes the information we collect and process through ThinkWithMe, why we use it, when it may be processed by service providers, how we protect and retain it, and the choices and rights available to parents and guardians.

Information for parents and guardians: ThinkWithMe includes a student learning experience that is managed through a parent or guardian account. Student information may be collected and processed when a student uses ThinkWithMe. Where parental consent is required by applicable law, we seek parental consent before collecting personal information from a child for the applicable features.

1. Information Provided by Parents and Guardians

When a parent or guardian creates or manages a ThinkWithMe account, we may collect:

Authentication credentials are processed through our authentication service. ThinkWithMe does not display or provide a user's password to other users.

2. Information Collected or Processed From Students

Depending on the features used, ThinkWithMe may collect or process the following information relating to a student:

ThinkWithMe does not provide a public social network or feature through which students can publicly post personal information or communicate with unrelated users.

3. Homework Images and Camera Access

ThinkWithMe uses camera or photo-library access only when a user chooses to photograph or select homework material for a tutoring session.

Homework images may be transmitted to our backend systems and artificial-intelligence service providers for the purpose of identifying the homework question and providing the requested tutoring experience.

Users should avoid including information that is unnecessary for tutoring, such as faces, home addresses, student identification numbers, or other sensitive personal information, in homework photographs.

4. Voice and Speech Input

ThinkWithMe may allow a student to speak an answer instead of typing it. When this feature is used, microphone input may be processed by speech-recognition technology in order to convert the student's spoken response into text.

ThinkWithMe does not intentionally retain a raw audio recording as part of the student's ThinkWithMe learning history. The resulting text may be processed and retained in the same manner as an answer entered by typing.

Depending on the device and operating system, speech recognition may also involve processing by the device platform or its speech-recognition provider.

5. How We Use Information

We use information only for purposes reasonably necessary to operate, provide, protect, and support ThinkWithMe, including to:

We do not condition a child's participation on providing more personal information than is reasonably necessary for the applicable ThinkWithMe activity or feature.

6. Artificial Intelligence

ThinkWithMe uses artificial-intelligence technology to provide its tutoring functionality.

Homework images, homework text, student responses, and relevant lesson context may be transmitted to an artificial-intelligence service provider when necessary to analyze a question or generate the tutoring interaction requested through ThinkWithMe.

This processing is used to provide the ThinkWithMe learning experience. ThinkWithMe is designed to guide students through reasoning, understanding, and problem-solving rather than simply provide answers.

7. Service Providers and Disclosure of Information

Independent Holdings uses service providers to perform technical functions necessary to operate ThinkWithMe. Information may be disclosed to or processed by these providers when reasonably necessary for them to perform those functions.

These providers may include:

We may also disclose information when reasonably necessary to comply with law, legal process, or valid governmental requests; protect the security and integrity of ThinkWithMe; investigate fraud or abuse; or protect the rights and safety of our users or others.

Independent Holdings does not sell children's personal information.

ThinkWithMe does not use children's personal information for targeted or behavioral advertising.

8. Parental Consent and Control

ThinkWithMe uses a parent-managed family relationship for student access. Where applicable law requires parental consent before personal information is collected from a child, ThinkWithMe requires the applicable parental authorization before enabling that collection.

A parent or guardian may withdraw authorization for a student's connected device. Withdrawal prevents that device from continuing to use the authorized student experience unless it is subsequently authorized again.

Withdrawing device authorization is different from requesting deletion of information already associated with an account. Parents may separately exercise the deletion rights described below.

9. Parents' Rights Regarding Children's Information

Subject to applicable law and appropriate verification of the requesting parent's identity, a parent or guardian may:

Parents may exercise available controls within ThinkWithMe or contact Independent Holdings using the contact information listed below. We may take reasonable steps to verify that the person making a request is the child's parent or guardian before providing access to or deleting information.

10. Data Retention and Deletion

We retain personal information only for as long as reasonably necessary for the specific purpose for which it was collected, to provide requested ThinkWithMe functionality, or as otherwise permitted or required by applicable law.

We maintain retention and deletion processes intended to prevent children's personal information from being retained indefinitely. Temporary content, including stored homework images, may be removed through automated cleanup processes when it is no longer necessary for its intended purpose.

When a ThinkWithMe account is deleted, information associated with that account is deleted or de-identified in accordance with our deletion procedures, except for limited records that we are permitted or required to retain for purposes such as legal compliance, security, fraud prevention, dispute resolution, or financial transaction recordkeeping.

Information retained for one of these limited purposes will not be used for unrelated purposes and will be retained only for as long as reasonably necessary for that purpose.

11. Account Deletion

A parent may request deletion of a ThinkWithMe account and its associated personal information through the account-deletion functionality available in ThinkWithMe.

An account-deletion request can also be initiated using our public account-deletion resource:

ThinkWithMe Account Deletion

Account deletion may include the parent account, associated student profiles, family relationships, learning history, homework information, and other personal information associated with the account, subject to the limited retention circumstances described above.

12. Subscriptions and Purchases

ThinkWithMe may offer paid subscriptions through platform providers such as Google Play and Apple's App Store.

Payment-card and payment-account information is handled by the applicable application-store provider. ThinkWithMe does not directly receive or store a user's complete payment-card information.

We may receive and retain information necessary to verify and manage purchases and subscriptions, such as product identifiers, transaction identifiers, subscription status, purchase or expiration information, and entitlement records.

13. Security

We use administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, misuse, or loss.

Information transmitted between ThinkWithMe and our online services is protected using encrypted network connections.

No electronic system can guarantee absolute security. We periodically review the safeguards appropriate to the information and services we operate.

14. Advertising

ThinkWithMe does not currently display third-party advertising in the application.

ThinkWithMe does not use children's personal information for targeted or behavioral advertising.

15. Location

ThinkWithMe does not require or intentionally collect precise physical location information in order to provide its tutoring functionality.

16. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to ThinkWithMe, our information practices, service providers, or applicable requirements.

The effective date at the top of this policy will identify when the current version became effective. Where required by law, we will provide parents with additional notice and obtain any required consent before materially changing how previously collected children's personal information is used or disclosed.

17. Contact Us

ThinkWithMe is operated by:

Independent Holdings, LLC
United States

Parents and guardians may contact Independent Holdings regarding this Privacy Policy, their child's information, parental consent, or a privacy or deletion request using the contact information published on the Independent Holdings website.