Privacy Policy

1. Introduction

cortexios is committed to protecting the privacy and security of personal data belonging to students, educators, and schools using our AI tutoring systems. This Privacy Policy explains how we collect, use, protect, and share information in connection with our services for K-12 education in Singapore.

We recognize that educational data requires special care and attention. Our approach to privacy is guided by Singapore's Personal Data Protection Act (PDPA), educational best practices, and our core value that student data belongs to students and their schools.

2. Data Controller

cortexios acts as the data processor for student and educator information collected through our platform. Schools using our services remain the data controllers and retain ownership and control over all student and educator data.

3. Information We Collect

We collect and process the following categories of personal data:

3.1 Student Information

• Name and student identification number provided by the school
• Grade level and class assignment
• Learning activity data (responses to exercises, time spent, progress through curriculum)
• Performance metrics and progress indicators

3.2 Educator Information

• Name and professional email address
• Subject area and grade levels taught
• Usage data related to platform features accessed

3.3 School Administrative Information

• School name, address, and contact details
• Curriculum frameworks and subject scope
• Implementation preferences and settings

3.4 Technical Information

• Device type and operating system
• Browser type and version
• IP address and general location (city/region level only)
• Session duration and page access patterns

4. How We Use Information

We use collected information only for legitimate educational purposes:

• Providing adaptive tutoring and personalized learning support
• Generating progress reports and analytics for teachers and school administrators
• Improving curriculum alignment and content quality
• Ensuring platform security and preventing unauthorized access
• Responding to technical support requests from schools
• Communicating with school administrators about service delivery and updates

5. Legal Basis for Processing

We process personal data under the following legal bases:

• Contractual necessity: Processing required to deliver our AI tutoring services as contracted with schools
• Legitimate interest: Platform improvement and educational research, conducted with appropriate safeguards
• Consent: When schools and parents provide specific consent for particular uses beyond core service delivery
• Legal compliance: When required to comply with Singapore data protection laws and educational regulations

6. Data Sharing and Third Parties

We do not sell student or educator data. We share information only in limited circumstances:

6.1 Service Providers

We engage trusted third-party service providers for hosting, security, and technical infrastructure. These providers are contractually bound to protect data and use it only for specified purposes.

6.2 School Officials

We provide student progress data to authorized teachers and administrators within subscribing schools.

6.3 Legal Requirements

We may disclose information if required by Singapore law, court order, or government regulation.

7. Data Security Measures

We implement comprehensive security measures to protect personal data:

• Encryption of data in transit (TLS/SSL) and at rest
• Regular security audits and vulnerability assessments
• Access controls limiting data access to authorized personnel only
• Secure authentication mechanisms for platform access
• Regular backup procedures to prevent data loss
• Incident response protocols for potential security breaches

8. Data Retention

We retain personal data only as long as necessary for legitimate educational purposes or as required by law:

• Student learning data: Retained during active enrollment and for one academic year after a student leaves the subscribing school, unless the school requests earlier deletion
• Educator accounts: Retained while the educator is active at a subscribing school and for six months after separation
• School administrative data: Retained for the duration of our service agreement plus two years for legal and audit purposes
• Technical logs: Retained for 90 days for security and troubleshooting purposes

9. Your Rights

Under Singapore's Personal Data Protection Act, individuals have the following rights:

• Right to access: Request a copy of personal data we hold
• Right to correction: Request correction of inaccurate data
• Right to withdraw consent: Withdraw consent for processing where consent was the legal basis
• Right to data portability: Receive data in a structured, commonly used format
• Right to object: Object to processing based on legitimate interest grounds

To exercise these rights, schools should contact us at privacy@cortexiieon. We respond to requests within 30 days.

10. Cookies and Analytics

We use cookies and similar technologies to improve user experience and understand platform usage. For detailed information about our cookie practices, please see our Cookie Policy.

We use web analytics to understand how educators and students interact with our platform. This information helps us improve usability and educational effectiveness. Analytics data is aggregated and anonymized where possible.

11. Children's Privacy

Our services are designed for use in K-12 educational settings under school authorization. We do not knowingly collect personal information directly from children without school and parental consent.

Schools using our services are responsible for obtaining appropriate parental consent where required and for ensuring that student use complies with applicable laws and school policies.

12. International Data Transfers

All student and educator data is stored on servers located in Singapore. We do not transfer personal data outside Singapore except where necessary for technical support purposes, and only with appropriate safeguards in place.

13. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify subscribing schools of material changes via email and post the updated policy on our website.

Continued use of our services after policy updates constitutes acceptance of the revised policy.

14. Contact Us

For questions, concerns, or requests related to privacy and data protection:

15. Supervisory Authority

If you believe we have not adequately addressed a privacy concern, you have the right to lodge a complaint with the Personal Data Protection Commission of Singapore (PDPC).