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DRAFT. Pending legal review. This policy is a working draft and not yet legally reviewed. Bracketed [items] need to be completed before publication.

Privacy Policy

VindicaOS, a Seneca product, operated by [legal entity name] ("VindicaOS," "we," "us"). Last updated [date].

VindicaOS is a platform that SAT-prep academies and schools ("academies") use to run their programs. This policy explains what we collect, how we use it, and the choices you have. It covers our website and the VindicaOS application.

1. Two kinds of data, two roles

We handle two categories of information, and our role differs for each:

2. What we collect

3. How we use it

4. We do not sell your data

We do not sell personal information, and we do not share it with third parties for their own marketing. We share data only with the sub-processors below, who act under contract on our behalf.

5. Sub-processors

We use a small set of vetted providers to run the service. Each is bound by data-protection terms.

ProviderPurpose
SupabaseDatabase, authentication, and file storage
NetlifyWeb hosting, serverless functions, and content delivery
Google (Gemini API)AI-generated explanations and report drafting
ResendTransactional email (e.g. reports and notifications)
StripeSubscription billing

6. Security

We encrypt data in transit and at rest, isolate each academy's data at the database level so it is not accessible to other customers, and restrict access by role: students see only their own records, and staff only their own academy's. See our data & security overview for more.

7. Retention & deletion

We keep data for as long as the academy's account is active, and then delete or return it as described in the Data Processing Agreement, except where law requires retention. Academies can export or delete their data at any time from within the platform.

8. Your choices & rights

Depending on where you are, you may have rights to access, correct, or delete personal information. For student data, requests should go to the academy that controls it; we will assist the academy in responding. For account data, contact us at [privacy@vindicaseneca.com].

9. Children's data

VindicaOS is sold to academies and schools, not directly to students or children. Where an academy enrolls students under 13, the academy is responsible for obtaining any parental consent required (for example under COPPA), and we process that data solely on the academy's behalf. We do not use children's data for advertising, and we do not allow third-party advertising trackers on student-facing pages.

10. International transfers

We may process data in the regions where our providers operate. Where data crosses borders, we use an appropriate safeguard consistent with applicable law. [Specify residency commitments per region, e.g. Korea PIPA for international schools.]

11. Cookies

We use only the cookies needed to sign you in, remember your preferences, and keep the service secure. We do not use advertising cookies.

12. Changes & contact

We will post any material change here and update the date above. Questions? Contact kevinchoi@vindicaseneca.com.

VindicaOS · a Seneca product · privacy policy draft v0.1, pending legal review.