AI Addendum
This AI Addendum (this “Addendum”) is issued by K12 Insight, LLC d/b/a Onflo (“Onflo”, “we”, “us”, or “our”). K12 Insight, LLC d/b/a Onflo is a Virginia limited liability company. This Addendum governs the use of AI Agent Services provided by Onflo. This Addendum is incorporated by reference into, and forms a part of, the Master Subscription Agreement between Client and Onflo, available at https://www.onflo.com/legal/cloud-services-msa (the “Agreement”). Capitalized terms used but not defined in this Addendum have the meanings given in the Agreement.
1. SCOPE AND APPLICABILITY.
1.1. Applicability. This Addendum applies to any Client that (a) has subscribed to AI Agent Services under an applicable Sales Order Form (“SOF”), or (b) uses any AI-enabled feature of the Service (as defined in the Agreement). Subject to the applicable SOF, Onflo may provide AI Agent functionality within the Service. In such case, the terms of this Addendum apply to Client’s use of AI Agent Services and any AI-enabled feature of the Service.
1.2. This Addendum supplements, and is subject to, the terms of the Agreement, including the Acceptable Use Policy (available at https://www.onflo.com/legal/acceptable-use-policy) (“AUP”), except to the extent this Addendum expressly provides otherwise pursuant to the order of precedence set forth in the Agreement.
1.3. This Addendum incorporates by reference the AUP, including without limitation Section 3.4 (AI Agent Services) of the AUP, and the terms of this Addendum together with the AUP constitute the complete set of terms governing Client’s use of AI Agent Services.
2. DEFINITIONS.
2.1. “AI Agent” means an automated voice response and conversation system that uses artificial intelligence to process and respond to spoken Communications.
2.2. “AI Agent Services” means the services provided by Onflo that include AI Agent functionality, as subscribed to by Client under an applicable SOF.
2.3. “Voice Data” means spoken words, voice recordings, transcriptions, and associated metadata from Communications.
2.4. “AI Output” means any content, responses, summaries, transcripts, action items, recommendations, or other outputs generated by the AI Agent in the course of providing the AI Agent Services.
2.5. Relationship to Defined Terms in the Agreement. For the avoidance of doubt, “AI Agent Services” as used in this Addendum refers to the specific AI Agent functionality subscribed to under an SOF, and is a subset of, and distinct from, “the Service” as defined in the Agreement, which encompasses all of Onflo’s products and services provided to Client under the Agreement.
3. VOICE DATA.
3.1. Collection and Classification. Client acknowledges and agrees that the AI Agent collects, processes, and stores Voice Data from Communications. Voice Data shall be considered User Data and/or Student Data (as applicable) and shall be subject to all applicable provisions of the Agreement and the Privacy Policy governing such data.
3.2. Consent Requirements. Client represents and warrants that Client has obtained, or will obtain prior to use, all necessary consents required under applicable law for the collection, processing, and storage of Voice Data, including but not limited to consents required under state wiretapping and eavesdropping laws, biometric information privacy laws, and the Children’s Online Privacy Protection Act (“COPPA”) (where applicable).
3.3. Disclosure and Recording Consent.
- Client shall provide clear disclosure to all individuals interacting with the AI Agent that they are communicating with an automated system and that their spoken words will be recorded and processed.
- Client shall obtain all consents required under applicable federal and state wiretapping, eavesdropping, and recording laws (including, without limitation, all-party consent requirements under Cal. Penal Code §632, 720 ILCS 5/26-4, and similar laws) before permitting individuals to interact with the AI Agent.
- Onflo shall implement an audio notification at the start of each AI Agent interaction informing the caller that the interaction is being recorded and processed by an automated system.
3.4. Governance Compliance. Client shall ensure that all Voice Data collected through the AI Agent complies with Client’s data governance policies and applicable law.
3.5. Special Categories of Personal Data. Client shall not use the AI Agent to collect or process special categories of personal data (such as health information, biometric data beyond voice recordings necessary for the Service) without Onflo’s prior written approval and appropriate safeguards.
3.6. Use of Voice Data and AI Agent Improvement. Voice Data will not be used to train or improve foundation AI models. Onflo may use Voice Data solely to operate, maintain, troubleshoot, secure, and improve the AI Agent Services, in accordance with applicable law and the Agreement. Voice Data may be shared with Onflo’s service providers for the purpose of providing the AI Agent Services.
3.7. Student Data Protections Applicable to Voice Data. Voice Data that constitutes Student Data shall be subject to all protections set forth in the Student Data provisions of the Agreement. Voice Data that constitutes User Data (and not Student Data) shall be subject to all protections set forth in the User Data provisions of the Agreement. For information regarding practices that may apply where Voice Data constitutes biometric information, see the Privacy Policy (available at https://www.onflo.com/legal/privacy-policy), Section 10.6.
4. THIRD-PARTY AI PLATFORM REQUIREMENTS.
4.1. Client acknowledges that the AI Agent Services are provided by using third-party artificial intelligence platforms, including large language model providers.
4.2. Onflo shall contractually require all such third-party AI providers to:
- Use Student Data and Voice Data solely for the purpose of providing the Service;
- Refrain from using Student Data or Voice Data to train, improve, or develop their own models or algorithms; and
- Maintain the confidentiality of Student Data and Voice Data in accordance with applicable law.
4.3. Onflo shall use reasonable methods to ensure ongoing compliance with the requirements set forth in Section 4.2.
4.4. AI models and underlying technologies may change over time. Onflo may update, replace, or modify underlying AI providers provided that any such changes do not materially degrade the core features of the AI Agent Services.
5. AI AGENT ACCURACY AND CLIENT RESPONSIBILITY.
5.1. Client acknowledges that the AI Agent is an automated system and may not accurately interpret or respond to all Communications.
5.2. Onflo does not guarantee the accuracy, completeness, or appropriateness of AI Agent responses. AI-generated content is probabilistic in nature and may contain inaccuracies, omissions, or fabricated information. Client is solely responsible for reviewing AI Output before any use, publication, distribution, or reliance thereon, and for correcting any inaccuracies in AI Output.
5.3. AI Output is intended to assist, and not replace, human decision-making. Client shall not use the AI Features, or any Output generated by the AI Features, as the sole or primary basis for any decision that has a legal, material, or similarly significant effect on an individual.
5.4. AI Agent Services depend on third-party AI providers and may experience interruptions or degraded performance outside Onflo’s reasonable control.
6. AI AGENT PROHIBITED USES.
6.1. In addition to the acceptable use requirements in the AUP, Client shall not use the AI Agent to:
- Make automated calls or send messages in violation of the Calling Laws;
- Collect sensitive personal information beyond what is necessary to provide the Service;
- Make decisions with legal or similarly significant effects on students, including but not limited to decisions regarding discipline, academic standing, educational placement, or counseling referrals, without human review; or
- Engage in any deceptive practice by misrepresenting the nature of the AI Agent to recipients;
- Use the AI Agent to generate, distribute, or facilitate child sexual abuse material (CSAM) or content that exploits or endangers minors;
- Use AI-generated predictions regarding student safety, well-being, or harm as the sole basis for disciplinary action, removal from educational programs, or other adverse measures, without independent human review and verification; or
- Use the AI Agent to make predictive inferences about an individual based on protected characteristics (including race, ethnicity, religion, sex, gender identity, sexual orientation, disability, or socioeconomic status) for the purpose of making or influencing decisions about that individual.
7. AI OUTPUT.
7.1. Ownership. As between Client and Onflo, Client owns all right, title, and interest in and to AI Output that is derived from or incorporates Client’s Voice Data or User Data. To the extent any rights in AI Output vest in Onflo by operation of law, Onflo hereby assigns such rights to Client. Client retains ownership of prompts, instructions, and inputs supplied to the AI Agent. The foregoing assignment does not include, and Onflo retains, all right, title, and interest in and to the AI Agent, the AI Agent Services, and the underlying models, algorithms, training data, and methodologies that generate AI Output.
7.2. Disclaimer of Uniqueness and Non-Infringement. AI Output is generated by automated systems and may not be unique. Onflo does not warrant that AI Output is unique, original, or non-infringing of any third-party intellectual property rights. Client is solely responsible for reviewing AI Output before any use, publication, or distribution.
7.3. Indemnification Exclusion. Notwithstanding Section 16.2 of the Agreement, Onflo shall have no obligation to indemnify, defend, or hold harmless Client against any claim that AI Output infringes any third-party intellectual property rights.
8. GENERAL PROVISIONS.
8.1. Governing Law. This Addendum shall be governed by and construed in accordance with the laws of the Commonwealth of Virginia, without regard to its own or other conflict of law principles, consistent with the Agreement.
8.2. Waiver. The failure by Onflo to enforce any right or provision of this Addendum shall not constitute a waiver of that provision or any other provision of this Addendum.
8.3. Severability. If any provision of this Addendum is determined to be invalid or unenforceable by a court of competent jurisdiction, the remainder of this Addendum shall remain in full force and effect.
8.4. Changes to This Addendum. Onflo may, in its sole discretion, modify or update this Addendum from time to time. Onflo may modify the AI Agent Services, and/or this Addendum, as reasonably necessary to comply with applicable laws and regulations. Such modifications to the AI Agent Services shall not be deemed a material change to this Addendum for purposes of the notice provisions of this Section 8.4. If Onflo changes this Addendum in a material manner, Onflo shall update the “Effective Date” at the bottom of this page. Client’s continued use of the AI Agent Services following such update constitutes Client’s acceptance of the revised Addendum. If Client does not agree to any of the terms in this Addendum, Client shall not use or access the AI Agent Services.
8.5. Entire Agreement. This Addendum, together with the Agreement and any other documents incorporated by reference therein, represents the entire agreement between the parties with respect to the AI Agent Services and supersedes all prior agreements relating to such subject matter, whether written or oral.
8.6. Survival. The following provisions of this Addendum shall survive any expiration or termination of the Agreement: Section 3 (Voice Data), Section 4 (Third-Party AI Platform Requirements), Section 5 (AI Agent Accuracy and Client Responsibility), Section 6 (AI Agent Prohibited Uses), Section 7 (AI Output), and this Section 8 (General Provisions).
8.7. Contact. For any questions regarding this Addendum, please contact us at privacy@onflo.com.
Last Updated: June 30, 2026
Effective Date: July 01, 2026