When you use Khan Academy's AI tutor Khanmigo, your questions and the AI's answers are recorded and may be used to improve the AI system.
This analysis describes what Khan Academy's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
AI conversation data may include sensitive academic questions, personal disclosures, or learning difficulties that users share in an educational context, and the use of this data to improve AI models raises questions about retention, access, and whether child users' conversations receive appropriate protections.
Interpretive note: The policy's characterization of how AI conversation data is used for improvement is broad; it is unclear whether this includes use in model retraining, human review, or sharing with AI infrastructure subprocessors, creating interpretive uncertainty about the full scope of AI data processing.
Every conversation with Khanmigo is recorded and may be used to improve AI features; users including students and minors should be aware that AI chat interactions are not private and are retained for product improvement purposes.
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"When you use Khanmigo or other AI-powered features, we collect information about your interactions with these features, including the questions you ask and the responses you receive. This information may be used to improve our AI features and the quality of responses.— Excerpt from Khan Academy's Khan Academy Privacy Policy
REGULATORY LANDSCAPE: AI interaction data from student users engages FERPA (if collected in an institutional context), COPPA (for users under 13), and emerging AI governance frameworks. The EU AI Act classifies AI systems used in education as high-risk, which may impose transparency and human oversight requirements for EU-facing deployments. The FTC has signaled scrutiny of AI data practices under its unfair and deceptive practices authority. GOVERNANCE EXPOSURE: High. The use of AI conversation data from student users, including potentially sensitive academic disclosures, for model training or improvement purposes raises significant compliance questions under FERPA (which restricts use of education records beyond the stated educational purpose) and COPPA (which requires parental consent for collection of personal information from users under 13, including conversational data). The policy's language that this data 'may be used to improve AI features' is broad and may require more specific disclosure. JURISDICTION FLAGS: EU users are subject to GDPR requirements for lawful basis in processing AI interaction data; the EU AI Act imposes additional requirements for high-risk AI in educational settings. California students are protected by SOPIPA, which restricts use of student data for purposes beyond educational service delivery. Illinois and New York impose student data protection requirements that may limit use of AI conversation data for model training. CONTRACT AND VENDOR IMPLICATIONS: Institutional purchasers of Khanmigo should ensure data processing agreements explicitly address AI conversation data: whether it is used for model training, how long it is retained, whether it is shared with AI infrastructure subprocessors, and whether students' conversations can be accessed by Khan Academy staff. Human review of AI conversations for safety purposes should be disclosed. COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether the use of Khanmigo conversation data for AI improvement constitutes a use beyond the original educational purpose under FERPA, and whether additional parental or student consent is required. The retention period for AI conversation logs should be defined and aligned with data minimization principles.
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AI conversation data may include sensitive academic questions, personal disclosures, or learning difficulties that users share in an educational context, and the use of this data to improve AI models raises questions about retention, access, and whether child users' conversations receive appropriate protections.
Every conversation with Khanmigo is recorded and may be used to improve AI features; users including students and minors should be aware that AI chat interactions are not private and are retained for product improvement purposes.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Khan Academy.