PRIVACY POLICY

Effective Date: [INSERT EFFECTIVE DATE]

Last Updated: July 20, 2026

This Privacy Policy explains how Precision Learning Labs, LLC ("Precision Learning Labs," "Ivaro," "we," "us," or "our") collects, uses, discloses, and protects information in connection with the Ivaro website (ivaro.ai) and the Ivaro platform, including Lesson Studio, Deliverable Studio, Grading Studio, Project Studio, and related features (collectively, the "Service").

This Policy applies to teachers, educators, and other authorized users who create an Ivaro account ("you," "Educator Users"). It also explains how we handle information about students that Educator Users may enter into the Service. This Policy does not apply to information collected by schools or districts through their own systems, or by third-party sites we do not control.

Please read this Policy carefully. If you do not agree with it, do not use the Service.

1. INFORMATION WE COLLECT

a. Account Information. When you register for Ivaro, we collect your name, email address, password, role/title, grade level(s) taught, subject area(s), and, optionally, your school or district name.

b. Payment Information. If you subscribe to a paid plan, our third-party payment processor collects your billing information (such as card number, billing address) directly. We do not store full payment card numbers on our own servers; we receive limited transaction data (e.g., plan tier, payment status, last four digits of a card) from our processor.

c. Content You Submit ("User Content"). As part of using the Service, you may enter or upload:

• Lesson plans, assignments, rubrics, and instructional materials you create;
• Class rosters and student information, which may include student first and/or last names, grade levels, student responses to assignments or assessments, performance and mastery data, and behavioral or contextual notes you choose to enter ("Student Data"); and
• Any other content you choose to submit to the Service.

You are solely responsible for the accuracy of, and your legal authority to submit, any Student Data you enter into the Service. See Section 6 ("Educator Responsibilities Regarding Student Data") below.

d. Usage and Device Data. We automatically collect certain technical information when you use the Service, including IP address, browser type, device identifiers, pages viewed, and timestamps, through server logs and similar technologies.

e. Cookies and Similar Technologies. We use cookies and similar technologies to operate the Service (e.g., to keep you logged in), remember your preferences, and understand how the Service is used. [We currently do not use third-party advertising or cross-site tracking cookies. If this changes, we will update this Policy and provide any consents required by law.] You can control cookies through your browser settings, though disabling cookies may affect Service functionality.

f. Communications. If you contact us (e.g., support requests, waitlist sign-up, feedback), we collect the information you provide, such as your name, email, and the content of your message.

2. HOW WE USE INFORMATION

We use the information described above to:

• Provide, operate, and maintain the Service, including generating lesson plans, deliverables, grading feedback, and other AI-assisted outputs based on the content and Student Data you submit;
• Create and manage your account and process payments/subscriptions;
• Sync your content across Ivaro's studios (e.g., Lesson Studio, Grading Studio) so you do not need to re-enter information;
• Respond to support requests and communicate with you about the Service, including updates, security notices, and administrative messages;
• Monitor, analyze, and improve the Service, troubleshoot issues, and develop new features;
• Maintain the security and integrity of the Service, prevent fraud, and enforce our Terms and Conditions; and
• Comply with legal obligations.

We do not sell Student Data or Educator personal information. We do not use Student Data for targeted advertising.

3. HOW AI FEATURES PROCESS YOUR CONTENT

Certain Ivaro features (e.g., AI-assisted lesson generation, grading feedback, and the planned Instructional Partner / Intervention Studio features) use third-party artificial intelligence model providers ("AI Sub-processors") to process the content and Student Data you submit, in order to generate outputs such as lesson plans, feedback, and recommendations.

• We contract with AI Sub-processors under terms that restrict their use of submitted content to providing the requested processing, and prohibit use of your content to train their general-purpose models, where such controls are available from the provider.
• AI-generated outputs may contain errors or inaccuracies. You are responsible for reviewing any AI-generated content before relying on it or sharing it with students, parents, or colleagues. See also Section 9 of our Terms and Conditions.
• A current list of material AI Sub-processors is available at [INSERT SUB-PROCESSOR LIST URL OR "upon request by emailing legal@precisionlearninglabs.com"].

4. HOW WE SHARE INFORMATION

We do not sell your personal information or Student Data. We may share information with:

• Service Providers. Vendors who perform services on our behalf, such as cloud hosting, payment processing, customer support tools, analytics, and the AI Sub-processors described in Section 3. These providers are bound by contractual obligations to protect your information and use it only for the purposes we specify.
• Your School or District (Future Feature). If your school or district adopts Ivaro under an institutional agreement, we may make Student Data associated with your account available to authorized school/district administrators, consistent with the applicable Data Privacy Agreement described in Section 7.
• Legal and Safety Reasons. If required by law, subpoena, or legal process, or if we believe in good faith that disclosure is necessary to protect the rights, property, or safety of Ivaro, our users, students, or the public.
• Business Transfers. In connection with a merger, acquisition, financing, or sale of assets, in which case we will require the receiving party to honor the commitments in this Policy (or notify you of any material change).
• With Your Consent. For any other purpose disclosed to you at the time of collection or with your consent.

5. COPPA AND CHILDREN'S PRIVACY

The Service is designed for use by adult educators, not directly by children. We do not knowingly collect personal information directly from children under 13 through account registration, and children are not permitted to create Ivaro accounts.

Student Data entered into the Service by Educator Users is provided by the teacher, acting on behalf of their classroom, and not collected directly from children by Ivaro. Educator Users are responsible for ensuring that entry of any Student Data relating to children under 13 complies with the Children's Online Privacy Protection Act ("COPPA") and any applicable school or district policy, including obtaining any required notice or consent. If we learn that a child has directly submitted personal information to us in a manner inconsistent with this Policy, we will take steps to delete such information.

6. EDUCATOR RESPONSIBILITIES REGARDING STUDENT DATA

Because Educator Users control what Student Data is entered into the Service, you agree that:

• You have the necessary authorization from your school, district, and/or applicable policy to enter Student Data into a third-party tool such as Ivaro;
• You will only submit the minimum Student Data reasonably necessary for the instructional purpose (e.g., avoid entering sensitive information such as health, disciplinary, or immigration-status details unless clearly necessary and permitted);
• You are responsible for compliance with FERPA, applicable state student data privacy laws, and your school/district's data governance policies when using the Service; and
• You will promptly notify us if you believe Student Data has been entered, used, or disclosed in error.

7. FERPA AND STATE STUDENT DATA PRIVACY LAWS (SCHOOL/DISTRICT USE)

As Ivaro expands to institutional (school and district) customers, we intend to support compliance with the Family Educational Rights and Privacy Act ("FERPA") and applicable state student data privacy laws (such as Illinois SOPPA, California SOPIPA/AB 1584, New York Education Law §2-d, and similar laws). For institutional customers, we will:

• Enter into a written Data Privacy Agreement ("DPA") with the school or district specifying the categories of Student Data collected, permitted uses, retention and deletion timelines, subcontractor/sub-processor disclosures, and breach notification procedures;
• Act, where applicable, as a "school official" with a legitimate educational interest under FERPA's school official exception, using Student Data only for the purposes authorized by the school or district, under the district's direct control, and without redisclosure to unauthorized third parties;
• Not use Student Data to build a personal profile of a student for non-educational purposes, nor sell or use Student Data for targeted advertising; and
• Provide breach notification to the affected school or district within the timeframe required by the applicable DPA or law (generally within 30 days of confirming a breach affecting Student Data), so that the district can notify affected parents/guardians as required.

Until a DPA is in place with your school or district, Educator Users use the Service on an individual basis as described in Section 6.

8. DATA RETENTION AND DELETION

We retain personal information and Student Data for as long as your account is active, and for a reasonable period afterward to comply with legal obligations, resolve disputes, and enforce our agreements. You may request deletion of your account and associated Student Data at any time by emailing legal@precisionlearninglabs.com; we will delete or de-identify such data within [INSERT NUMBER] days, except where retention is required by law or an active DPA with your school/district specifies a different timeline.

9. DATA SECURITY

We use administrative, technical, and physical safeguards designed to protect personal information and Student Data from unauthorized access, use, or disclosure, including encryption in transit, access controls, and vendor security review. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. YOUR RIGHTS AND CHOICES

Depending on your state of residence, you may have rights to access, correct, delete, or receive a copy of your personal information, and to opt out of certain processing. California residents may have rights under the California Consumer Privacy Act ("CCPA"), including the right to know, delete, and correct personal information, and the right to non-discrimination for exercising these rights. We do not sell or share personal information as those terms are defined under the CCPA.

To exercise any privacy rights, email legal@precisionlearninglabs.com. We may need to verify your identity before completing a request.

11. INTERNATIONAL USERS

The Service is currently intended for use by educators located in the United States. If you access the Service from outside the United States, your information will be transferred to and processed in the United States.

12. CHANGES TO THIS POLICY

We may update this Policy from time to time. If we make material changes, we will notify you by email or through the Service prior to the change becoming effective. Continued use of the Service after the effective date constitutes acceptance of the updated Policy.

13. CONTACT US

Questions about this Privacy Policy or our data practices can be directed to:

Precision Learning Labs, LLC

Email: legal@precisionlearninglabs.com

[INSERT MAILING ADDRESS]

[ATTORNEY REVIEW NOTE — remove before publishing: This draft assumes (1) Ivaro does not yet have institutional/district customers or executed DPAs, (2) no targeted advertising or data sales occur, (3) AI processing uses third-party model providers under contract. Confirm actual practices match these assumptions, insert the effective date, mailing address, data-deletion timeline, and sub-processor list location, and have a licensed attorney confirm FERPA/COPPA/state law treatment before this goes live — especially before any district/school contracts are signed.]