1. INTRODUCTION

Akamori ("we," "us," or "our") is committed to protecting the privacy and security of our users' personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you use our AI-powered learning platform and tutoring services.

This policy applies to all users of the Akamori platform, including students, parents/guardians, tutors, and administrators, and covers our website, mobile applications, and all related services.

2. INFORMATION WE COLLECT

2.1 Personal Information

We collect personal information that you provide directly to us, including:

Student Information:

• Name, email address, phone number, date of birth
• Academic records, grades, and educational history
• Learning preferences and accessibility needs
• Course enrollment and participation data
• Assessment results and academic progress
• Communication records with tutors and support staff

Parent/Guardian Information:

• Name, email address, phone number
• Billing and payment information
• Emergency contact details
• Communication preferences

Tutor Information:

• Professional credentials and qualifications
• Background check results (where legally required)
• Teaching experience and specializations
• Performance evaluations and feedback

2.2 Automatically Collected Information

We automatically collect certain information about your device and usage:

• IP address, browser type, and operating system
• Device identifiers and mobile advertising IDs
• Platform usage patterns and session duration
• Learning analytics and engagement metrics
• Technical logs and error reports

2.3 Educational Records and Learning Data

Through our XalyLearn™ AI technology and platform features:

• Academic performance and assessment data
• Learning pathway progression
• Time spent on activities and assignments
• AI-generated learning recommendations
• Video session recordings (with consent)
• Chat logs and communication records

2.4 Third-Party Integration Data

Information collected through integrated services:

TutorTMS Integration:

• Scheduling and appointment data
• Tutor-student matching information
• Session management records

Google Services Integration:

• Google Meet session data
• Google Classroom integration data
• Calendar and scheduling information

3. HOW WE USE YOUR INFORMATION

3.1 Primary Educational Purposes

• Providing personalized tutoring and educational services
• Developing and improving AI-powered learning recommendations
• Matching students with appropriate tutors and courses
• Tracking academic progress and generating reports
• Facilitating communication between students, tutors, and parents
• Issuing certificates and credentials upon course completion

3.2 Platform Operations

• Account creation and management
• Payment processing and billing
• Technical support and customer service
• Platform security and fraud prevention
• Legal compliance and safety monitoring

3.3 Communication and Marketing

• Sending service-related notifications and updates
• Providing educational content and resources
• Marketing communications (with appropriate consent)
• Research and analytics for service improvement

3.4 AI and Machine Learning

Our XalyLearn™ technology uses personal information to:

• Create personalized learning experiences
• Predict learning outcomes and recommend interventions
• Analyze learning patterns and optimize content delivery
• Generate adaptive assessments and feedback

4. INFORMATION SHARING AND DISCLOSURE

4.1 Educational Context Sharing

We may share information within the educational context:

• Between assigned tutors and students for educational purposes
• With parents/guardians regarding their child's progress
• With educational institutions when required for credit transfer
• With authorized administrators for platform management

4.2 Third-Party Service Providers

We share information with trusted service providers who assist our operations:

• TutorTMS for tutor management and scheduling
• Google services for video conferencing and collaboration
• Payment processors for transaction handling
• Cloud hosting providers for data storage
• Analytics providers for service improvement

4.3 Legal and Safety Requirements

We may disclose information when required by law or to protect safety:

• Legal process, court orders, or government requests
• Protection of rights, property, or safety of users
• Investigation of suspected fraud or illegal activity
• Emergency situations requiring immediate action

4.4 Business Transactions

In the event of a merger, acquisition, or sale of assets, user information may be transferred as part of that transaction, subject to appropriate privacy protections.

5. INTERNATIONAL DATA TRANSFERS

Akamori operates globally and may transfer personal information across borders. We ensure appropriate safeguards for international transfers:

• Adequacy Decisions: Transfers to countries with adequate privacy protections
• Standard Contractual Clauses: EU-approved transfer mechanisms
• Binding Corporate Rules: Internal data protection standards
• Consent: Explicit consent for specific transfers when required

6. DATA RETENTION

We retain personal information only as long as necessary for legitimate purposes:

• Student Educational Records: Retained for the duration of enrollment plus applicable legal retention periods (typically 3-7 years post-graduation)
• Communication Records: Retained for 2 years after last interaction
• Technical Data: Retained for 1 year unless required for ongoing security purposes
• Billing Information: Retained per applicable financial record-keeping requirements

Users may request deletion of their information subject to legal and contractual obligations.

7. SECURITY MEASURES

We implement comprehensive security measures to protect personal information:

7.1 Technical Safeguards

• Encryption of data in transit and at rest
• Multi-factor authentication for account access
• Regular security audits and vulnerability assessments
• Secure coding practices and regular updates

7.2 Administrative Safeguards

• Privacy and security training for all staff
• Access controls and role-based permissions
• Incident response and breach notification procedures
• Regular policy reviews and updates

7.3 Physical Safeguards

• Secure data centers with restricted access
• Environmental controls and monitoring
• Backup and disaster recovery procedures

8. YOUR PRIVACY RIGHTS

Depending on your location, you may have specific rights regarding your personal information:

8.1 Universal Rights

• Access: Request copies of your personal information
• Correction: Request correction of inaccurate information
• Deletion: Request deletion of your information (subject to limitations)
• Data Portability: Request transfer of your information

8.2 Regional Specific Rights

European Union (GDPR):

• Right to object to processing
• Right to restrict processing
• Right to withdraw consent
• Right to lodge complaints with supervisory authorities

California (CCPA/CPRA):

• Right to know about personal information sold or shared
• Right to opt-out of sale/sharing of personal information
• Right to non-discrimination for exercising privacy rights

Canada (PIPEDA):

• Right to challenge compliance
• Right to file complaints with Privacy Commissioner

9. CHILDREN'S PRIVACY

9.1 Age Requirements

Akamori primarily serves students in grades 9-12 (typically ages 14-18). We comply with applicable children's privacy laws:

• Under 13: Services not intended for children under 13
• Ages 13-17: Parental consent required in jurisdictions where mandated
• 18+: Full account privileges with direct consent

9.2 Parental Rights and Controls

Parents/guardians of minor students have rights to:

• Review their child's personal information
• Request correction or deletion of information
• Control communication preferences
• Receive notifications about data practices

9.3 Educational Context Considerations

In educational settings, we may collect and use student information without parental consent when permitted by applicable educational privacy laws (such as FERPA's school official exception).

10. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar technologies to enhance user experience:

10.1 Types of Cookies

• Essential Cookies: Required for platform functionality
• Performance Cookies: Analytics and performance monitoring
• Functional Cookies: User preferences and customization
• Marketing Cookies: Advertising and promotional content

10.2 Cookie Management

Users can control cookie preferences through:

• Browser settings and controls
• Platform cookie preference center
• Opt-out tools for marketing cookies

11. JURISDICTION-SPECIFIC PROVISIONS

11.1 Canada

• Compliance with PIPEDA and provincial privacy legislation
• French language services available in Quebec
• Indigenous language support as culturally appropriate

11.2 United States

• FERPA compliance for educational records
• COPPA compliance for users under 13
• State-specific privacy law compliance (CCPA, Virginia CDPA, etc.)

11.3 United Kingdom

• UK GDPR compliance post-Brexit
• ICO registration and compliance monitoring
• Data Protection Act 2018 adherence

11.4 European Union

• GDPR compliance across all member states
• Digital Services Act compliance where applicable
• Privacy by design and default implementation

11.5 United Arab Emirates

• UAE Data Protection Law compliance
• Cross-border transfer restrictions observance
• Local data residency requirements where mandated

11.6 Saudi Arabia

• Personal Data Protection Law (PDPL) compliance
• National Data Governance Office coordination
• Cultural and religious considerations in data handling

11.7 India

• Personal Data Protection Bill compliance preparation
• Information Technology Act compliance
• Local data processing requirements observance