AI Disclosure and Student Safety Policy

# AI Disclosure and Student Safety Policy

**Product:** Brainrise (the "Service")
**Operator:** Southwest CP Investment LLC, a Texas limited liability company ("Company," "we," "us," or "our")
**Version:** 1.1
**Effective Date:** August 16, 2026
**Last Updated:** 2026-09-08

This AI Disclosure and Student Safety Policy ("AI & Safety Policy") is incorporated into and forms part of the Brainrise Terms of Service ("Terms") and uses the same defined terms, including "Parent," "Student," "User," "Content," "AI Coach," "Company Parties," and "Submissions." By using the Service, you (and, for a Student, the Parent on the Student's behalf) acknowledge and agree to this AI & Safety Policy. It is written to satisfy AI-transparency requirements and to describe the safety design of the Service.

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## 1. You Are Talking to an AI — Clear Disclosure

1.1 **The AI Coach is an automated system, not a human.** The AI Coach ("Chispa") is powered by artificial intelligence (a large language model provided by our AI subprocessor). When you interact with the AI Coach, **you are communicating with software, not with a teacher, tutor, counselor, therapist, or any human being.**

**At the start of every AI Coach session, and at least once every three (3) hours of continued interaction, the Service displays to every user — not only to minors — a clear and conspicuous notification stating that Chispa is a computer program and not a human being, that it does not have emotions, and that it is not capable of a personal relationship. Where the interaction is verbal, the notification is delivered verbally. The notification is presented in a manner designed to be readily noticeable and readily understandable by an ordinary user, and it is not obscured by other content.**

1.2 **No human is monitoring the chat in real time.** The AI Coach operates automatically. Company does **not** promise that any human reviews AI Coach conversations in real time, and you should not expect a human to see, intervene in, or respond to any individual message as it is sent. This disclosure is made so that no User relies on the presence of live human supervision.

1.3 **Purpose of this disclosure.** This Section is provided to comply with laws and best practices requiring that consumers — and especially minors — be told when they are interacting with an artificial-intelligence system rather than a human. This obligation is not limited to minors and does not depend on whether a particular user was in fact misled.

1.4 **Stricter state standards.** **Where a state requires additional or differently-formatted AI disclosure, we give the disclosure that state requires, as and when that requirement takes effect.** Our baseline practice is designed to meet a high standard of transparency.

## 2. AI Outputs May Be Wrong — Do Not Rely on Them

2.1 The AI Coach and all AI-generated explanations are produced by automated systems and **may be inaccurate, incomplete, outdated, biased, or misleading.** AI can "hallucinate" — that is, state false facts confidently, misstate math, grammar, or test rules, invent citations, or give flawed reasoning.

2.2 **AI outputs are study prompts, not authority.** They are not professional, educational, psychological, medical, legal, financial, or admissions advice, and must not be relied upon as such. The Student and Parent are responsible for independently verifying anything important before relying on it. Company disclaims, to the maximum extent permitted by law, all liability for any action taken or not taken in reliance on an AI output. See Terms Sections 9, 10, 12, and 13 and the Educational Disclaimer and Waiver.

2.3 **Practice questions are original.** Practice questions and explanations are original study material created by or for Company and are **not** actual, official, licensed, or previously administered test questions.

## 3. Intellectual-Property and Third-Party Rights in AI Output

3.1 AI-generated text may occasionally resemble existing material. Company does not intend for AI outputs to reproduce any third party's copyrighted work, and such outputs are provided for the User's personal, non-commercial study only.

3.2 **You must not** copy, publish, redistribute, sell, or commercially exploit AI outputs, or present them as your own original authorship in any context where doing so would violate a third party's rights, an academic-integrity rule, or the Terms. If you believe an AI output infringes your rights, contact us under the IP and DMCA Policy.

3.3 Company makes no representation or warranty that any AI output is original, non-infringing, or free of third-party rights, and disclaims all such warranties to the maximum extent permitted by law (Terms Section 12).

## 4. Student Safety by Design

4.1 **No user-to-user contact.** The Service is designed so that **Students cannot contact, message, chat with, or be contacted by other users.** There are no public profiles, direct messages, forums, comment threads, friend lists, or other user-to-user communication channels. The AI Coach chat is strictly between the Student and the automated system. This is a deliberate safety-by-design decision intended to eliminate the risk of grooming, solicitation, bullying, or predatory contact between users. If Company ever introduces any social or communication feature, it will update this Policy and provide appropriate parental controls before doing so.

4.2 **No impersonation.** Because there is no user-to-user contact and the AI Coach is clearly identified as software, the Service is not a venue in which a Student can be deceived by an adult impersonating a peer. Users must not attempt to impersonate Company, its staff, or any other person anywhere in the Service (Terms Section 6).

4.3 **Age-appropriate design.** The Service is subscription-funded, contains no third-party advertising to Students, does not use a known minor's data for targeted advertising, and is gated behind Parental consent (see the Privacy Policy and Parental Consent Form). See also Section 7A of the Privacy Policy (Age-Appropriate Design and Minors' Design Protections).

## 5. Crisis Situations — No Confidentiality; Not a Crisis Service

5.1 **Not a crisis service; reporting.** The Service is not a crisis, counseling, medical, or mental-health service, and the AI Coach is not a therapist or emergency responder. It cannot provide help in an emergency, and Company's automated systems are not a reporting mechanism — no report is generated automatically and no human sees any message in real time. **Separately, Company personnel who review flagged safety events and who form a belief that a child may be abused or neglected will report that belief to the appropriate child-protective authority — in the state where the Student resides where that is known to us, and otherwise to the Texas Abuse Hotline (1-800-252-5400), to the Childhelp National Child Abuse Hotline (1-800-422-4453), or to law enforcement — consistent with any mandatory-reporting duty applicable to that individual, including Texas Family Code § 261.101.** Company trains personnel with access to flagged safety events on this obligation and maintains a record of reports made.

5.2 **No promise of confidentiality; what we keep.** Communications with the AI Coach are **not confidential** and are **not** protected by any doctor–patient, therapist–client, counselor, or other privilege. **As described in the Privacy Policy, AI Coach messages are processed to generate a response and are not stored by Company as a conversation transcript. The only chat content Company retains is a short excerpt (no more than 500 characters) of a message that triggers an automated safety or misuse rule, together with the rule category and a timestamp, retained solely for safety and abuse-prevention review. Safety-rule excerpts may be reviewed for safety and abuse prevention, may be made available to the associated Parent/Account Holder, and, where legally required or where Company believes in good faith it is necessary to prevent imminent harm, may be disclosed to authorities. Company does not retain AI Coach content for troubleshooting, and the Service does not offer a feature that displays stored chat history. If Company ever introduces such a feature, it will update the Privacy Policy and this Policy and obtain any consent required by law before doing so.** **No User should treat the AI Coach as a private or privileged confidant.**

5.3 **If a Student discloses risk of harm — our safety protocol.** Student safety is a priority. If a Student inputs content suggesting **self-harm or suicidal ideation, physical harm to others, financial harm to others, abuse, or other danger to the Student or any other person,** the AI Coach is designed to (a) respond supportively and encourage the Student to seek immediate help from a trusted adult and from professional crisis resources; (b) surface crisis-resource information — **in the United States, call or text 988 (Suicide and Crisis Lifeline), or call 911 in an emergency;** and (c) avoid providing content that encourages or facilitates self-harm. Company maintains a written self-harm and crisis-response protocol describing how these situations are handled, including how the Service refers users to crisis service providers, which is **publicly posted, without any login required, at the Service's `/crisis` page (https://brainriseprep.com/crisis).** Because automated detection is not perfect, Company cannot and does not guarantee that every at-risk message will be detected, classified, or escalated; to the maximum extent permitted by law, and except for any liability that cannot be limited under applicable law, Company is not liable for failing to detect or respond to any particular message. **This limitation reflects the technical limits of automated systems and is not an expression of indifference** — it does not reduce Company's commitment to the safety measures described in this Section and in Section 5A.

5.4 **Parental responsibility.** The Parent remains responsible for the Student's welfare and supervision. Nothing in the Service replaces parental oversight or professional care. If you or a Student are in danger or crisis, **contact 911, 988, or local emergency services immediately** — do not rely on the Service.

5.5 **Legal reporting.** Company may, consistent with law and the Privacy Policy, disclose information to law enforcement or appropriate authorities where it believes in good faith that doing so is necessary to prevent imminent harm or to comply with a legal obligation.

5.6 **The AI Coach does not act as a companion or a counselor.** The AI Coach is instructed **not** to ask unprompted questions about a User's feelings or emotional state, **not** to infer or comment on a User's emotional or mental state, and **not** to hold itself out as able to help with anxiety, stress, or mental health. Its purpose is academic study support. Company does not design or market the AI Coach as a companion, friend, or emotional-support service, and no User should use it as one.

## 5A. Additional Safeguards for Known Minors

For any Student we know to be a minor, Company:

(a) **clearly discloses** that the AI Coach is an artificial-intelligence system and not a human, in the manner described in Section 1 (which applies to every user, whether or not a minor);

(b) **provides periodic break reminders** — during extended AI Coach use, the Service presents a clear notification to a known minor at least once every **three (3) hours** of continued interaction, reminding the Student that they are interacting with AI and encouraging a break;

(c) **maintains and publicly posts** a self-harm and suicidal-ideation response protocol (see Section 5.3), including how the Service responds to signs of such content and refers users to crisis-resource providers such as the 988 Suicide and Crisis Lifeline; and

(d) **institutes and maintains reasonable technical measures designed to prevent** the AI Coach from producing content that encourages self-harm, from producing visual material of sexually explicit conduct, and from stating that a minor should engage in sexually explicit conduct, and does not use the AI Coach to engage a minor in sexually explicit interactions.

(e) **Suitability notice.** Company discloses to every User, and to the Parent of every Student, that **an AI chatbot of this kind may not be suitable for some minors.** The AI Coach is a study tool. It is not a friend, a counselor, or a substitute for a trusted adult, and a Parent who judges that this kind of interaction is not right for their Student should not enable it. The Parent may disable the AI Coach for the Student's Account at any time without affecting any other part of the Service.

Company will provide any report regarding these safeguards required by applicable law, as and when required.

## 6. Prohibited Uses of the AI Coach

Consistent with Terms Section 6, you must not use the AI Coach to generate, solicit, or transmit unlawful, harmful, harassing, sexual, self-harm-promoting, hateful, or infringing content, to attempt to bypass its safety measures ("jailbreaking"), to extract training data or system prompts, or to build or train a competing model or dataset.

## 6A. AI-Generated Imagery and Synthetic People in Our Marketing

6A.1 **The people in our marketing images are not real.** Photographs, illustrations, and character art used on the Brainrise website, in the app, and in Brainrise advertising and social media are generated by artificial intelligence unless a specific image is expressly identified as a photograph of a real person. The individuals depicted — including any recurring characters — **do not exist**. They are not students, not customers, not employees, not instructors, and not test-takers.

6A.2 **Nothing depicted is a testimonial, endorsement, or result.** No AI-generated figure speaks for a real customer. Company does not and will not attach a quotation, a star rating, a score, a score improvement, a claimed outcome, or any other endorsement to an AI-generated person. Any statement of student experience that Company publishes will come from a real, identified person who gave permission, and will be labeled as such.

6A.3 **How we label these images.** Images published by Company that depict AI-generated people carry a visible on-image label (for example, "AI-generated"). Where an image is displayed too small for a legible on-image label, the label appears as adjacent text covering that image or group of images. Images distributed off our website — social posts, advertisements, and downloadable files — carry the label written into the image file itself, so that the disclosure travels with the image.

6A.4 **Scenery and non-human imagery.** Background scenes, environments, textures, and abstract artwork are also AI-generated. They are illustrative and are not photographs of Company's premises, of any real classroom, or of any real location associated with the Service.

6A.5 **No likeness of any real individual is intended.** Company does not direct the generation of images depicting any identifiable real person, and does not use any student's or customer's photograph, face, voice, or likeness in marketing. Any resemblance between an AI-generated figure and a real person is unintended and coincidental. If you believe an image published by Company resembles you or a person you are responsible for, contact us at the address in the Terms and we will review the image and remove it if appropriate.

6A.6 **Video.** Where Company publishes audiovisual material containing AI-generated performers, that material will carry a disclosure appropriate to the medium, presented at the start of the material and in its published description. Company will not publish such material without that disclosure.

6A.7 **This section does not limit Section 2.** Marketing imagery is separate from the AI Coach. Nothing in this section reduces the disclaimers in Section 2 regarding the accuracy of AI-generated study content.

## 7. Acknowledgment

By using the Service, you acknowledge that the AI Coach is an automated system, that its outputs may be wrong and must be independently verified, that AI Coach communications are not confidential and not a crisis service, that the Service contains no user-to-user contact, and that in any emergency you will contact 911, 988, or local emergency services rather than rely on the Service.

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*This AI & Safety Policy is part of the Brainrise legal pack and should be read together with the Terms of Service, the Privacy Policy, and the Educational Disclaimer and Waiver.*