Pearl Education’s Products, the Pearl Student Support Platform (web app) and the Pearl mobile app, include a limited set of in-product AI features, offered under the name Sparks. This page describes where and how AI is used in the Products, consistent with Pearl’s customer agreements. Sparks has two capabilities: (1) nightly program insights and alerts for administrators, and (2) natural-language questions and analytics over the Customer’s own data. Sparks is built for program administrators (and, where applicable, instructors); students do not interact with AI features in the Products. Together with the other pages in this section, this disclosure constitutes Pearl’s published AI documentation referenced in MSA §7.1.

Where AI Is Used in the Products

1. Program Insights and Alerts for Administrators

Pearl uses AI to help program administrators identify students who may need attention — for example, by surfacing patterns in attendance, session completion, or engagement data. These AI-assisted insights and alerts (part of Sparks) are generated nightly, delivered to Customer’s administrators within the platform, and operate exclusively on Customer Content associated with that Customer’s own program (MSA §7.1(a)).

Insights and alerts are advisory. They are presented to administrators and instructors for their professional review and judgment; they do not automatically trigger any action on a student’s account.

2. Natural-Language Questions and Analytics Over Customer Data

Administrators can use natural-language queries to explore and analyze their program data within the Products — for example, asking how a cohort is progressing or comparing session participation across sites. The feature returns answers as data and charts, operates over the Customer’s own data only, and does not combine or cross-reference data from other customers (MSA §7.1(b)).

How AI Features Process Data

AI-enabled features process Customer Content solely on Customer’s behalf to provide the Services. Outputs generated by AI features are provided for Customer’s use as part of the Services (MSA §7.1). Pearl does not use AI-enabled features to process Customer Content for Pearl’s own benefit beyond what is expressly permitted in the customer agreements (see AI Data Handling).

AI features are subject to the same contractual data protections — including the limits on use of Student Data set out in MSA §5.7 and DPA Article IV — as all other product features. Customer Content remains the property of and under the control of the Customer (MSA §4.1; §5.2).

What AI Does Not Do in the Products

• No student-facing AI. Sparks is built for administrators and instructors. Students do not chat with, query, or otherwise interact with AI features in the Products.
• No autonomous decisions about students. AI-generated outputs (such as attendance alerts or program summaries) are surfaced to administrators and instructors for review. Pearl does not use AI to make final, binding, or automated consequential decisions about students without human review.
• No advertising or commercial profiling. AI features in the Products do not serve targeted or behavioral advertising and are not used to create commercial profiles of students (MSA §5.7; DPA §4.2).
• No training on identifiable Student Data. Pearl does not use identifiable Student Data, curriculum content, session recordings, or other Customer Content to train AI models. For details, see AI Data Handling.

Additional AI Documentation

• AI Data Handling — how Customer Content is protected when AI features process it, and what Pearl does and does not do with that data
• Responsible AI Principles — Pearl’s guiding principles for AI development and deployment in K-12 contexts
• AI Risk and Bias Review — Pearl’s governance approach to AI risk, fairness, and human oversight

Questions about Pearl’s AI practices can be sent to responsibleai@poweredbypearl.com, which routes to Pearl’s privacy team (privacy@poweredbypearl.com).