Mulholland
Privacy Policy

COPPA Compliance Notice:

Mulholland is committed to protecting children’s privacy and complying with the Children’s Online Privacy Protection Act (COPPA) and its 2025 amendments. We collect personal information from children under 13 only with verified parental consent. Parents have the right to review, delete, and control their child’s information at any time.

Mulholland, Inc. (“Mulholland,” “we,” “our,” and/or “us”) values the privacy of individuals who use our application, websites, and related services (collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and disclose information from users of our Services (“Users”). By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service (https://marzy.com/terms).

This Privacy Policy does not apply to the extent we process information in the role of a processor or service provider on behalf of our customers (for example, on behalf of your school). In that context, our customers are the data controllers and their privacy policies will apply to the processing of your personal information. We are not responsible for the privacy or data security practices of our customers, which may differ from those explained in this Privacy Policy.

Information We Collect about Account Holders

We may collect a variety of information from or about you or your devices from various sources, as described below.

A. Information Provided to Us by Account Holders.

Registration and Account Information. When you sign up for an account, we ask you for information such as your name, email address, and phone number, and what type of account you are registering for (e.g., personal, parent or legal guardian account for a child, etc.). If you sign up using a third-party account, we will also receive information from that third-party account such as your name and email address, and a unique identifier associated with your account.In some cases, we may also receive your profile picture or other basic account information you authorize the third-party provider to share with us. If you are a parent or legal guardian who has registered in order to set up a child profile, you may choose to provide information about your child such as their learning preferences (e.g., preferred topics and subjects) and health and medical information.

Parent Portal. If you have registered for an account so that your child can use the Marzy app, we will collect any information you choose to provide us within the parent portal.

Communications. If you contact us directly, we may receive additional information about you, such as your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide. When you communicate with us online, third party vendors receive and store these communications on our behalf. When we send you emails, we may use embedded pixels or other technologies to track information about your receipt and interaction with our emails, such as whether and when you open them, whether you access any links included in our emails, how long you read our emails, whether you forward our emails and to whom, and your Device Information (described below), to learn how to deliver a better customer experience and improve our Services.

Payment Information. If you make a payment on our Services, your payment-related information, such as credit card or other financial information, is collected by our third-party payment processor on our behalf.

B. Information We Collect When You Use Our Services.

Device Information. We receive information about the device and software you use to access our Services, including IP address (which can be used to infer your general location information), device type, device identifiers, web browser type and version, operating system version, phone carrier and manufacturer, application installations, mobile advertising identifiers, push notification tokens, and accelerometer data which reflects the movement of the device.

Usage Information. We automatically receive information about your interactions with our Services, like the pages or other content you view, referrer information (the website you visited before coming to our Services), and the dates and times of your visits.

Marzy Interactions. If you choose to interact with Marzy, we will collect audio and video recordings of those interactions.

Coaching Sessions. We will receive any information you choose to provide during a coaching session.

Information from Cookies and Other Tracking Technologies. We and our third-party partners collect information about your activities on our Services using cookies, pixel tags, SDKs, or other tracking technologies. Our third-party partners, such as analytics, advertising, and security partners, may also use these technologies to collect information about your online activities over time and across different Services.

Third-Party App Usage Information. We may access and collect information about your use of other apps on your device to help support self-regulation, executive functioning skills, and healthy device usage. The information we collect may include the names of the apps accessed and how long and frequently you use them. We do not collect information about your activities within these third party apps (e.g., content viewed).

C. Information We Receive from Other Sources.

Information from Third-party Services. If you choose to link our Services to a third party service in order to share information with us (e.g., school records) then we will collect the information provided to us by that third-party service. If you wish to limit the information available to us, you should visit the privacy settings of your third-party accounts to learn about your options.

How We Use the Information We Collect

We use the information we collect:

• To provide, maintain, improve, and enhance our Services;
• To train, develop, and improve the artificial intelligence, machine learning, and models that we use to support our Services;
• To personalize your experience on our Services such as by providing tailored content and recommendations;
• To understand and analyze how you use our Services and develop new products, Services, features, and functionality;
• To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
• For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you;
• To generate anonymized or aggregate data containing only de-identified, non-personal information that we may use for any lawful purposes such as to publish reports;
• To facilitate transactions and payments;
• To send text messages and push notifications;
• To find and prevent fraud and abuse;
• To monitor, detect, and respond to trust and safety issues that may arise;
• For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
• For other purposes for which we provide specific notice at the time the information is collected.

How We Disclose the Information We Collect

Affiliates. We may disclose any information we receive to our current or future affiliates for any of the purposes described in this Privacy Policy.

Vendors and Service Providers. We may disclose any information we receive to vendors and service providers retained in connection with the provision of our Services.

Third-Party AI and Communications Services

Marzy uses several third-party services to power its features and enable real-time conversations:

Conversational AI (Anthropic Claude):

• We use Anthropic PBC’s Claude AI to understand your child’s speech and generate intelligent responses
• When your child speaks to Marzy, audio recordings are sent to Anthropic for speech recognition and conversation processing
• Anthropic retains this data for up to 30 days for service quality and debugging, then automatically deletes it
• Anthropic does not use your child’s data to train their AI models
• We have a Data Processing Agreement with Anthropic ensuring COPPA compliance
• For more information: Anthropic’s Privacy Policy

Voice Generation (ElevenLabs):

• We use ElevenLabs’ text-to-speech technology to generate Marzy’s voice
• Only text is sent to ElevenLabs (not recordings of your child’s voice)
• ElevenLabs converts this text into Marzy’s spoken responses
• Your child’s voice recordings are never sent to or processed by ElevenLabs
• For more information: ElevenLabs Privacy Policy

Real-Time Communications (LiveKit):

• We use LiveKit’s infrastructure to enable smooth, real-time voice conversations
• Audio data is encrypted in transit
• LiveKit retains data only as long as we instruct (up to 90 days)
• We have a Data Processing Agreement with LiveKit
• For more information: LiveKit Privacy Policy

Data Processing Agreements: We maintain Data Processing Agreements with all third-party providers that handle personal information, ensuring compliance with COPPA, GDPR, and CCPA.

Analytics Partners. We use analytics Services such as Google Analytics to collect and process certain analytics data. You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partners/.

Advertising Partners. We work with third-party advertising partners to collect and process your information in order to show you ads that we think may interest you. Some of our advertising partners are members of the Network Advertising Initiative (https://optout.networkadvertising.org) or the Digital Advertising Alliance (https://optout.aboutads.info) and serve ads through cookie-based technologies. Please visit their opt-out pages to learn about how you may opt out of receiving certain web-based personalized ads from member companies. These opt-outs will apply only to our third-party advertising partners that are members of these organizations. These opt-outs will not apply when our partners serve ads through non-cookie based technologies.

As Required By Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services.

Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.

Consent. We may also disclose your information with your permission.

Your Choices

Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional email messages from us, you will continue to receive administrative messages from us.

Third Parties

Our Services may contain links to other websites, products, or Services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party Services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

Security

We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.

Children’s Privacy

We comply with the Children’s Online Privacy Protection Act (COPPA). We collect personal information from children only with verified parental consent, and parents may review or delete their child’s data at any time by contacting us. 

We do not sell children’s data or use advertising or tracking for commercial purposes.

We may collect the following information from your child when they use the Marzy app:

• Audio and video recordings of your child as they speak with Marzy and when they participate in a live coaching session with one of our coaches. Our AI service provider also collects this information.
• Information about your child’s interactions on the Marzy app, like the pages or other content they view, exercises they complete, and the dates and times of their visits.
• Information about your child’s device, such as browser type, the nature of the device from which the child is using the Marzy app, and accelerometer data which reflects the movement of the device.
• Information about your child’s use of other apps on their device, such as the names of the apps accessed and how long and frequently they use them.
• Persistent identifiers associated with your child’s device, such as IP address and mobile device identifiers.

We use the information we collect from your child for the following purposes:

• To provide, maintain, improve, and enhance the Marzy app;
• To understand and analyze how your child uses the Marzy app and develop new products, services, features, and functionality;
• To personalize your child’s experience on the Marzy app such as by providing tailored content;
• To train, develop, and improve the artificial intelligence, machine learning, and models that we use to support our Services;
• To provide your child with information that they request and otherwise provide customer support;
• To provide push notifications;
• To generate anonymized, aggregate data containing only de-identified, non-personal information that we may use for any lawful purposes such as to publish reports;
• To find and prevent fraud and abuse;
• To monitor, detect, and respond to trust and safety issues that may arise; and
• For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

We disclose the information we collect from your child in the following circumstances:

• We provide you with information about your child’s use of our Services, including providing you with transcripts and summaries of your child’s interactions with Marzy.
• We share information with third-party service providers (e.g., analytics providers, data storage and processing facilities) that assist us in providing the Marzy app.
• We disclose audio and video data related to your child’s interaction with Marzy to Anthropic PBC, which provides the AI technology that powers Marzy’s conversations. Anthropic retains this data for up to 30 days and then automatically deletes it. Anthropic does not use your child’s data to train their AI models.
• We may share information with an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
• We may share information if we believe that doing so is legally required, or is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others, or otherwise to help protect the safety or security of the Marzy app and other users of the Marzy app.

Requests to Access and Delete a Child’s Information

If you would like to review or delete the personal information we have collected from your child, or refuse to permit further collection or use of your child’s information, you can do so by sending an email to privacy@mulholland.ai. If you have any questions please contact us at privacy@mulholland.ai; 9062 Rosecrans Avenue, Bellflower, CA 90706; or (818) 495-8499.

International Visitors

Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the U.S. for storage and processing. We may also transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including personal information, on or to the Services, you consent to such transfer, storage, and processing.

Changes to this Privacy Policy

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or disclose personal information previously collected from you through the Services, we will notify you through the Services, by email, or other communication.

Contact Information

If you have any questions, comments, or concerns about our processing activities, please email us at privacy@mulholland.ai.