Privacy Policy

Overview

PhonoLogic Learning Systems Inc. ("PhonoLogic," "we," "our," or "us") builds an AI-powered phonics education platform for children in Kindergarten through Grade 2. This Privacy Policy explains what information we collect, why we collect it, how we use and protect it, and what rights you have.

An important thing to understand about how PhonoLogic works: only adults create accounts. Parents, teachers, and tutors sign up and then create "learner profiles" for the children they work with. Children use PhonoLogic through their parent's, teacher's, or tutor's account. We never ask children to create their own accounts or provide personal information directly to us.

This policy applies to our website at phonologic.ca, all subdomains, and the PhonoLogic web application (collectively, the "Service").

Company: PhonoLogic Learning Systems Inc., PO Box 98124, Toronto RPO Queen Carlaw, ON M4M 3L9, Canada

Privacy Contact: privacy@phonologic.ca

What We Collect

Information from account holders (adults only)

When you create a PhonoLogic account, we collect:

• Email address -- used for login, password resets, and account communications
• Name -- used to personalize your experience
• Password -- stored only as a cryptographic hash; we never store or see your actual password
• Account type -- whether you are a parent, teacher, or tutor (this determines which features you see)
• Payment information -- processed entirely by Stripe; we never store credit card numbers, CVVs, or bank account details on our servers

Information in learner profiles (children)

When an account holder creates a learner profile for a child, the only information stored is:

• First name -- so the child can identify their profile (no last name is collected)
• Reading level -- set by the adult and updated through assessments
• Phonics scope settings -- which phonics patterns the child is working on
• Story history -- AI-generated stories created for this profile
• Word encounter data -- which words the child has practiced and how they performed
• Assessment results -- scores and progress from reading assessments

We do not collect date of birth, last name, home address, school name, photographs, or any other identifying information for learner profiles.

Information collected automatically

• Usage analytics -- pages visited, features used, session duration (collected via Google Analytics 4)
• Error reports -- technical error data to help us fix bugs (collected via Sentry)
• IP address -- logged temporarily for security and rate-limiting purposes; not stored long-term or linked to learner profiles
• Device and browser information -- browser type, operating system, screen size (for analytics and compatibility)

Cookies and Local Storage

PhonoLogic uses cookies and browser local storage to keep you signed in and to remember your preferences. Here is exactly what we set:

Authentication cookies

Cookie	Purpose	Duration	Accessible to JavaScript?
auth_token	Keeps you signed in	12 hours	No (HttpOnly)
refresh_token	Silently renews your session so you don't have to log in every 12 hours	30 days	No (HttpOnly)
auth_indicator	Tells the app whether you are currently signed in (contains no sensitive data)	12 hours	Yes

Local storage

We use browser local storage (not cookies) to remember your display preferences, such as dark mode and color-blind mode settings. This data stays on your device and is never sent to our servers.

Analytics cookies

Google Analytics 4 sets its own cookies to help us understand how people use PhonoLogic in aggregate (e.g., which pages are most visited, where users drop off). You can opt out of analytics cookies through our cookie consent banner or by using a browser extension like Google Analytics Opt-out.

Disabling cookies

You can block or delete cookies through your browser settings. If you block authentication cookies, you will need to sign in each time you visit. The core reading and phonics tools will still work, but session persistence will not.

How We Use Your Information

We use the information we collect for the following purposes:

• Providing the Service -- generating phonics stories, tracking reading progress, running assessments, and personalizing content to each learner's level
• Account management -- authenticating your identity, processing payments, and sending transactional emails (verification, password resets, subscription receipts)
• Improving PhonoLogic -- analyzing anonymized usage patterns to identify bugs, improve features, and make the product more effective
• Customer support -- responding to your questions via live chat or email
• Security -- detecting and preventing fraud, abuse, and unauthorized access
• Legal compliance -- meeting our obligations under PIPEDA, COPPA, and other applicable privacy laws

We do not use your information to serve advertising. We do not sell your information to anyone. We do not use children's reading data to build marketing profiles.

AI-Generated Content and Data Processing

PhonoLogic uses artificial intelligence (Google Gemini) to generate decodable phonics stories tailored to each learner's reading level and phonics scope. Here is how that works:

• When a story is requested, we send the learner's reading level and phonics scope settings (not their name or any identifying information) to Google Gemini to generate an appropriate story.
• Generated stories are stored in our database and associated with the learner profile so the child can re-read them.
• We apply content safety filters to every generated story before it reaches the child. Stories that fail our safety checks are blocked and never displayed.
• Google Gemini does not retain prompts or outputs for model training when used through our API integration.

Anonymized analytics

We send anonymized usage data to BigQuery (Google Cloud) for aggregate analysis. Profile IDs are hashed before export -- no names, email addresses, or other personally identifiable information are included in analytics data.

Third-Party Services

We use the following third-party services to operate PhonoLogic. Each service receives only the minimum data necessary to perform its function:

Service	Purpose	Data shared
Google Gemini AI	Generates decodable phonics stories	Reading level, phonics scope settings (no names or PII)
Google Cloud Firestore	Primary database	All account and learner profile data (encrypted at rest)
Google BigQuery	Anonymized usage analytics	Hashed profile IDs, usage events (no PII)
Upstash Redis	Caching and rate limiting	Temporary session data, rate limit counters
Stripe	Payment processing	Email, subscription status (Stripe handles all card data directly)
Brevo	Email delivery	Email address, account type, subscription status (for transactional emails and, if you opt in, product tips and onboarding guidance)
Google Analytics 4	Website analytics	Page views, anonymized usage data, IP address (anonymized by GA4)
Vercel	Hosting and deployment	All web traffic passes through Vercel's infrastructure
Better Stack	Uptime monitoring	Server availability status only (no user data)
Sentry	Error tracking	Error details, browser info, anonymized user context
Crisp	Live chat support	Name and email of the adult using chat (chat is not shown to child profiles)

We do not share data with advertisers, data brokers, or social media platforms for targeting purposes. We do not sell personal information to any third party.

Children's Data and COPPA Compliance

Protecting children's privacy is central to how PhonoLogic is designed. Here is our approach:

How our architecture protects children

• Children never create accounts. Only adults (parents, teachers, tutors) can register for PhonoLogic. There is no sign-up flow for children.
• Minimal data collection. A learner profile contains only a first name, reading level, and learning data. We do not collect last names, dates of birth, addresses, photos, or any other identifying information from children.
• No direct contact with children. Live chat support (Crisp) is only available to signed-in adult account holders, not to child profiles. We do not send emails or push notifications to children.
• No advertising or tracking of children. We do not serve ads to any user, and we do not use children's reading data for marketing or profiling purposes.
• No social features for children. Children cannot post content, communicate with other users, or share information publicly.

Parental consent

Because only adults create accounts and manage learner profiles, the adult account holder provides consent for the collection and use of children's learning data by creating a learner profile and using the Service. Parents can review, modify, or delete their child's learner profile and all associated data at any time from their account settings.

Teacher and school use

When teachers use PhonoLogic in a classroom setting, the teacher acts as the account holder and creates learner profiles for their students. Under COPPA, schools and teachers can consent on behalf of parents for the collection of student data when it is used solely for educational purposes. We limit our use of student data to providing and improving the educational Service.

Deletion of children's data

Account holders can delete any learner profile at any time. When a learner profile is deleted, all associated data -- stories, assessment results, word encounter data, and progress records -- is permanently removed from our active systems. If you believe a child has provided personal information to us directly (outside of an adult-managed profile), please contact us at privacy@phonologic.ca and we will promptly investigate and delete any such data.

FERPA Compliance (School Records)

When PhonoLogic is used by schools or school districts, student learner profile data may constitute "education records" under the Family Educational Rights and Privacy Act (FERPA). In these cases:

• We act as a "school official" with a legitimate educational interest, providing a service the school would otherwise perform itself.
• We use student data only for the educational purposes specified by the school.
• We do not disclose student data to other third parties except as described in this policy and as permitted by FERPA.
• We do not use student data for advertising, marketing, or building non-educational profiles.
• Schools and parents retain all FERPA rights, including the right to inspect, amend, and request deletion of student records.

Data Retention

We keep your data only as long as it is needed to provide the Service or as required by law:

• Active accounts: Account and learner profile data is retained for as long as your account is active.
• Deleted learner profiles: Data is permanently removed from active systems promptly after deletion. Encrypted backups that may contain residual data are overwritten on a rolling cycle.
• Closed accounts: When you close your account, we delete all personal data and associated learner profiles within 60 days.
• Payment records: Stripe retains transaction records as required by financial regulations. We retain only subscription status and plan type.
• Anonymized analytics: Aggregated, de-identified usage data may be retained indefinitely because it cannot be linked back to any individual.
• Legal holds: If we are required to preserve data for a legal proceeding, we will retain the minimum data necessary for the duration of the hold.

Data Security

We take the security of your data seriously and implement multiple layers of protection:

• Encryption in transit: All data is transmitted over HTTPS/TLS. We enforce secure connections across the entire Service.
• Encryption at rest: Data stored in Google Cloud Firestore is encrypted at rest using Google's default encryption.
• Password security: Passwords are cryptographically hashed; we never store plaintext passwords.
• Authentication tokens: Access tokens are stored in HttpOnly cookies that cannot be read by JavaScript, reducing the risk of cross-site scripting attacks.
• Rate limiting: All public-facing API endpoints are rate-limited to prevent abuse.
• Input validation: All user input is sanitized to prevent injection attacks.
• Content Security Policy: We enforce a strict Content Security Policy that blocks unauthorized scripts from running on our pages.
• Access controls: Learner profile data is accessible only to the account holder who created the profile (and to linked accounts they have explicitly authorized).

No system is perfectly secure. If you discover a security vulnerability, please report it to privacy@phonologic.ca.

Data Breach Notification

In the event of a data breach that poses a real risk of significant harm:

• We will notify the Office of the Privacy Commissioner of Canada as required by PIPEDA's breach notification provisions.
• We will notify affected account holders as soon as feasible, describing what happened, what data was involved, and what steps we are taking.
• If the breach involves children's data, we will also notify the U.S. Federal Trade Commission as required by COPPA.
• Where required by GDPR, we will notify the relevant EU supervisory authority within 72 hours of becoming aware of the breach.

International Data Transfers

PhonoLogic is a Canadian company. Our primary infrastructure is hosted on Vercel and Google Cloud, which may process data in the United States and other countries. When your data is transferred outside of Canada or the European Economic Area, it is protected by:

• Contractual safeguards: Our third-party service providers are bound by data processing agreements that require them to protect your data to standards at least equivalent to PIPEDA and GDPR.
• Google Cloud: Google maintains compliance with SOC 2, ISO 27001, and offers Standard Contractual Clauses for EU data transfers.
• Vercel: Vercel's infrastructure operates primarily in the United States and is covered by their data processing addendum.

Your Rights

All users

Regardless of where you live, you can:

• Access your data: View all information we hold about you and your learner profiles in your account settings.
• Correct your data: Update your name, email, or any learner profile information at any time.
• Delete your data: Delete individual learner profiles or close your entire account.
• Export your data: Request a copy of your data in a portable format by emailing privacy@phonologic.ca.

Canadian residents (PIPEDA)

Under Canada's Personal Information Protection and Electronic Documents Act, you have the right to:

• Know what personal information we hold about you and how it is used
• Challenge the accuracy and completeness of your information
• Withdraw consent for the collection, use, or disclosure of your information (subject to legal or contractual restrictions)
• File a complaint with the Office of the Privacy Commissioner of Canada if you believe your rights have been violated

We will respond to access and correction requests within 30 days.

European residents (GDPR)

If you are in the European Economic Area or the United Kingdom, you have additional rights under the General Data Protection Regulation:

• Legal basis: We process your data based on contractual necessity (to provide the Service you signed up for), legitimate interest (to improve and secure the Service), and consent (for analytics cookies).
• Right to restrict processing: You can ask us to limit how we use your data in certain circumstances.
• Right to object: You can object to processing based on legitimate interest.
• Right to data portability: You can request your data in a machine-readable format.
• Right to lodge a complaint: You can file a complaint with your local data protection authority.

California residents (CCPA/CalOPPA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act and CalOPPA:

• Right to know: You can request the categories and specific pieces of personal information we have collected about you.
• Right to delete: You can request deletion of your personal information.
• Right to non-discrimination: We will not treat you differently for exercising your privacy rights.
• No sale of personal information: We do not sell personal information to third parties. We do not share personal information for cross-context behavioral advertising.
• Do Not Track: We honor Do Not Track browser signals by limiting analytics collection.

To exercise any of these rights, contact us at privacy@phonologic.ca. We will respond within 30 days (45 days if an extension is needed, with notice).

Email Communications (CASL Compliance)

Under Canada's Anti-Spam Legislation (CASL), we only send you emails that you have consented to receive or that are directly related to your use of the Service. Specifically:

• Transactional emails (account verification, password resets, subscription receipts) -- sent automatically as part of the Service; no separate consent required.
• Product updates and tips -- sent only if you have opted in; every such email contains a clear unsubscribe link.

We send transactional emails through Brevo. If you opt in to marketing emails during onboarding, we also send onboarding tips, reading activity reminders, and subscription-related notifications through Brevo. We sync your account type, onboarding status, last activity date, and subscription status to Brevo to personalize these communications. We do not send unsolicited commercial email.

Links to Other Websites

PhonoLogic may contain links to third-party websites. Once you leave our Service, you are subject to that site's privacy policy. We are not responsible for the privacy practices of other websites.

Business Transfers

If PhonoLogic Learning Systems Inc. is involved in a merger, acquisition, or sale of assets, your personal information may be transferred as part of that transaction. In such a case, we will notify you before your data is transferred and becomes subject to a different privacy policy. The acquiring entity will be required to honor the commitments made in this Privacy Policy, particularly regarding children's data.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. When we make changes:

• We will update the "Updated" date at the top of this page.
• For significant changes, we will notify account holders by email before the changes take effect.
• For material changes affecting children's data, we will seek renewed consent from account holders as required by COPPA.

Your continued use of the Service after changes are posted constitutes acceptance of the updated policy.

Governing Law

This Privacy Policy is governed by the laws of the Province of Ontario and the federal laws of Canada applicable therein. Any disputes related to this policy will be subject to the jurisdiction of the courts of Ontario, Canada.

If you are located in a jurisdiction with privacy laws that provide additional protections (such as GDPR, CCPA, or Quebec's Law 25), those protections apply to you in addition to the rights described here.

Contact Us

If you have questions about this Privacy Policy, want to exercise your data rights, or have a concern about how we handle personal information, please contact us:

• Email: privacy@phonologic.ca
• Mail: PhonoLogic Learning Systems Inc., PO Box 98124, Toronto RPO Queen Carlaw, ON M4M 3L9, Canada
• Privacy hub: phonologic.ca/privacy

We aim to respond to all privacy inquiries within 30 days.

If you are not satisfied with our response, you may file a complaint with the Office of the Privacy Commissioner of Canada or your local data protection authority.