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Fenton ("we," "us," or "our") is committed to protecting your privacy, especially the privacy of children using our service. This Privacy Policy explains how we collect, use, disclose, and protect personal information, including information from children under the age of 13, in compliance with the Children's Online Privacy Protection Act (COPPA) and other relevant privacy laws.

By using Fenton, you consent to the data practices described in this policy. If you are a parent or guardian of a child under 13, please review this policy carefully and provide consent where required.

1. Information We Collect

We collect information directly from users, through automated means, and potentially from parents/guardians:

Account Information (via Google Sign-In): Name, email address, Google profile picture URL.
Age/Grade Information: We ask for age (or birthdate) during sign-up for age verification. We collect grade level to personalize the learning experience.
Parent/Guardian Information (If Applicable): If parental consent is required, we collect the parent's email address and potentially information needed for verification (e.g., via Stripe transaction details - we do not store full credit card numbers). Parents may also provide their name if creating a parent account.
Usage and Performance Data: Questions attempted, answers provided, performance scores (confidence levels), skills practiced, hints requested, chat interactions with the AI tutor, session duration, features used.
User-Generated Content: Feedback submitted through forms (general or evaluation feedback), chat messages.
Technical Data: Standard web logs including IP address, browser type, device information, operating system, timestamps. We use Firebase services which may collect their own analytics data (refer to Google's policies).
Persistent Identifiers: User IDs (Firebase UID, email), potentially cookies or similar technologies used by Firebase or Google for session management and analytics.
Newsletter Preference (Parents): If a parent opts in to our newsletter.

2. How We Use Information

Providing the Service: To authenticate users, personalize math problems and difficulty, track progress, provide feedback and tutoring.
Parental Consent: To manage the age verification and parental consent process required by COPPA.
Communication: To respond to feedback and support requests. For parents who opt-in, to send newsletters or service updates.
Improvement: To analyze usage patterns, identify areas for improvement, train our AI models (using de-identified interaction data where feasible), debug issues, and enhance the user experience.
Security and Compliance: To maintain platform security, prevent fraud, and comply with legal obligations.

AI Training Note: Interactions like answers and chat messages may be used to improve the underlying AI models (e.g., Google Gemini via Vertex AI). We strive to minimize the use of directly identifying personal information in AI training data where possible.

3. Children's Privacy (COPPA Compliance)

Fenton is directed towards children, including those under 13. We comply with COPPA as follows:

Age Gate: We implement an age gate during registration.
Verifiable Parental Consent (VPC): Before collecting, using, or disclosing personal information from a child we know to be under 13, we obtain VPC through methods such as:
- A nominal charge ($1.00 USD) verification via Stripe (we do not store the full credit card number).
- A parent creating their own verified Fenton account and providing consent for their linked child.
- (Other methods may be added in the future as permitted by the FTC).
Direct Notice: Parents receive direct notice about our data practices during the consent process.
Parental Rights: Parents/guardians have the right to:
- Review the personal information we have collected from their child.
- Request deletion of their child's personal information.
- Refuse further collection or use of their child's information.
- Consent to collection and use for internal purposes but not disclosure to third parties (unless integral to the service).
To exercise these rights, please contact us at [Your Support Email/Link to Parent Portal]. We will require verification of your identity.
Data Minimization: We collect only information reasonably necessary for a child to participate in the Fenton tutoring service.
Data Security: We use reasonable measures (encryption, access controls via Firebase/Google Cloud) to protect children's data.
Data Retention: We retain children's data only as long as necessary to provide the service or as required by law. Data is deleted upon verified parental request or account deletion.

4. Information Sharing and Disclosure

We do not sell personal information. We may share information under the following circumstances:

Service Providers: With third-party vendors who help us operate the service (e.g., Google Cloud for hosting, database, AI; Stripe for payment verification). These providers are contractually obligated to protect the data and use it only for the services they provide.
AI Processing: Interaction data is processed by the underlying AI models (Google Gemini via Vertex AI) according to their terms and privacy policies.
Legal Requirements: If required by law, subpoena, or other legal process, or to protect our rights or the safety of others.
Aggregated/De-identified Data: We may share non-personally identifiable data for research or statistical purposes.
Business Transfers: In case of a merger, acquisition, or sale of assets, user information may be transferred.

5. Data Security

We rely on the security measures provided by Google Cloud and Firebase (e.g., encryption at rest and in transit, access controls) and implement reasonable administrative and technical safeguards. However, no online service is 100% secure.

6. Data Retention

We retain personal information as long as the user account is active or as needed to provide the service, comply with legal obligations, resolve disputes, and enforce agreements. We delete data upon verified parental request or account deletion according to our policies.

7. Your Choices and Rights (Including Older Minors)

Users (and parents for children under 13) can typically access and update basic profile information via their linked Google account or Fenton profile settings (if applicable). Depending on your jurisdiction (e.g., California, GDPR), you may have additional rights like access, correction, deletion, or objection to certain processing. Please contact us to exercise these rights.

8. Changes to This Policy

We may update this Privacy Policy. We will notify users of significant changes, potentially requiring renewed consent if changes materially affect the handling of children's data.

9. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact:

[Your Company Name/Operator Name]

[Your Contact Email Address, e.g., privacy@fenton.example.com]

[Your Physical Address, if applicable]

[Your Phone Number, if applicable]

The Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g; 34 CFR Part 99) is a Federal law that protects the privacy of student education records. The law applies to all schools that receive funds under an applicable program of the U.S. Department of Education.

Fenton and FERPA

When Fenton is used by a school, district, or teacher (collectively "School") as part of their educational program, certain data collected by Fenton may be considered part of the student's "education record" under FERPA. Fenton is committed to acting as a "school official" with a "legitimate educational interest" under FERPA when providing services to Schools, subject to the terms of our agreement with the School.

Data Considered Education Records

When used under the direction of a School, the following data collected by Fenton may constitute education records:

Student identifiers (name, email, user ID) linked to usage.
Student performance data (skill progress, scores, confidence levels).
Records of work completed (questions answered, interactions).
Feedback provided by the system or administrators related to educational performance.

Data Access, Use, and Disclosure

Fenton uses student data solely to provide and improve the educational services contracted by the School.
We do not use education records for targeted advertising or create profiles for non-educational purposes.
Access to personally identifiable information (PII) from education records is restricted to authorized personnel of Fenton and the contracting School who require access to perform their duties.
We will not disclose PII from education records to third parties without consent, except as permitted by FERPA (e.g., to service providers acting as school officials, for audits, or as required by law). Our agreements with service providers (like Google Cloud) include data protection terms.

Parental Rights under FERPA

FERPA affords parents and eligible students (students over 18 or attending postsecondary institutions) certain rights with respect to their education records. These include:

The right to inspect and review the student's education records maintained by the school.
The right to request that a school correct records which they believe to be inaccurate or misleading.
The right to consent to disclosures of personally identifiable information contained in the student's education records, except to the extent that FERPA authorizes disclosure without consent.

Parents wishing to exercise these rights should contact their child's School directly. Fenton will assist Schools in meeting their FERPA obligations regarding data maintained within our service.

Data Security and Deletion

We implement reasonable security measures to protect education records. Data is retained only as long as necessary to provide the service to the School or as directed by the School, consistent with FERPA and applicable agreements. Data is securely deleted upon request by the School or at the end of the contract term.

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