Privacy at Leráni

1. Who is responsible for your information?

Leráni is responsible for personal information under its control.

Privacy Officer: Erann Zlotnik

Privacy email: erann.zlotnik@gmail.com

Business mailing address: 7 Broadway Avenue, Toronto, ON M4P 3C5, Canada

Questions, concerns or privacy requests may be directed to our Privacy Officer.

2. Who uses Leráni?

Leráni is designed primarily for secondary-school language learners.

Students may create their own Leráni account, but Leráni requires approval from the parent or guardian identified during registration before the student's learning activities can begin.

Teachers do not currently receive access to a student's Leráni account. If authorized, they may receive limited learning reports by email.

Parents and guardians do not currently receive access to the student's Leráni account. If parental consent has been provided, they may receive limited progress reports by email.

3. Information we collect

Leráni collects only information reasonably required to provide the service.

4. Information we intentionally do not collect

Leráni is not designed to collect:

• Ontario Education Numbers (OEN);
• health information;
• disability information;
• Individual Education Plans or special-education records;
• race or ethnicity;
• religion;
• sex or gender;
• sexual orientation;
• government identification numbers;
• precise geolocation;
• photographs;
• audio or video recordings;
• biometric information; or
• financial information.

Students and schools should not submit this type of information to Leráni unless Leráni expressly introduces a feature requiring it and provides appropriate notice.

5. Why we use personal information

We use personal information to:

• create and maintain student accounts;
• verify and document required consent;
• provide language-learning practice;
• personalize the level and focus of practice;
• analyze student responses;
• provide feedback;
• track practice history and learning progress;
• identify appropriate next practice;
• generate authorized parent and teacher reports;
• secure and administer Leráni;
• respond to privacy, correction and deletion requests; and
• meet applicable legal and accountability obligations.

We do not use student information to determine school grades, rank students against one another, or make admissions or placement decisions.

6. How Leráni uses artificial intelligence

Artificial intelligence is an important part of Leráni.

Leráni currently uses AI to help:

• analyze diagnostic responses;
• generate and validate practice activities;
• analyze practice responses;
• provide feedback and retry guidance; and
• produce short practice-session summaries.

Student diagnostic writing and practice responses may therefore be processed by AI services made available through Leráni's technology providers.

Leráni's current AI prompts do not intentionally include the student's first name, last name, email address or school name.

Depending on the function, AI processing may include information such as:

• the student's written response;
• a diagnostic writing sample;
• grade;
• the language skill being practised;
• previous attempts;
• mastery information; and
• recurring language-error patterns.

AI outputs can influence the practice that Leráni presents and the learning feedback the student receives.

AI is not used by Leráni to predict a student's grade, rank students, determine admission, discipline a student or make similarly significant school decisions.

Leráni uses third-party AI services through its technology platform. Those providers may process information outside Canada. Further details about provider location, retention and subprocessors will be maintained as information becomes available from our service providers.

7. Children and young people

We recognize that information about children and young people deserves heightened protection.

Before a student may use Leráni's diagnostic or practice features, the parent or guardian identified during registration must approve the student's use of Leráni.

While consent is pending, Leráni may retain the limited account information required to create the account and request consent, but learning activities are blocked.

If parental consent is declined, the student cannot access Leráni's learning features.

Parents or guardians may ask to withdraw consent. Where the required consent is withdrawn, Leráni will stop allowing further learning activity and will review the appropriate treatment of existing information in accordance with applicable legal and retention requirements.

Leráni is currently intended for secondary-school learners. Users should not provide false information about their identity, school, grade, parent or teacher.

8. Teacher reporting

Teacher reporting is a separate, consent-controlled feature.

A teacher invitation is sent only after parental consent has been approved. A teacher report may be generated or sent only where that teacher has separately approved receiving Leráni reports for the student.

A teacher does not obtain general access to the student's Leráni account through this process.

9. How we share information

We do not sell or rent student personal information.

We do not use student personal information for targeted advertising.

We may disclose information to service providers that help us operate Leráni, including providers involved in:

• application hosting and databases;
• authentication;
• artificial-intelligence processing;
• email delivery; and
• storage or delivery of application assets.

Current providers include Base44 as Leráni's application technology platform, email-delivery infrastructure used for consent and reports, Google where a user chooses Google sign-in, and AI providers accessed through Base44's AI integration.

These service providers receive only the information required for their role, subject to the capabilities and contractual arrangements of those services.

10. Processing outside Canada

Some Leráni service providers may store or process information outside Canada, including in the United States or other jurisdictions.

For example, email-delivery and AI services may involve cross-border processing.

When information is processed in another jurisdiction, it may be subject to the laws of that jurisdiction and may be accessible to courts, law-enforcement or governmental authorities in accordance with applicable law.

Leráni does not currently represent that all student information is stored exclusively in Canada.

11. School use

A school or school board that chooses to use Leráni may have its own legal and privacy obligations regarding student information and educational technology.

Leráni is designed to provide schools with information about:

• the personal information collected;
• why it is collected;
• how AI is used;
• service providers involved;
• parent and teacher reporting;
• retention and deletion; and
• privacy contacts.

Leráni does not currently integrate with student information systems, school rosters, the Ontario Student Record, OEN, Google Classroom or learning-management systems.

School use may also be governed by an agreement between Leráni and the school or school board.

For Ontario school boards, specific legal requirements may apply when student digital personal information is disclosed to third-party software applications.

12. Security

Leráni uses safeguards intended to protect information against unauthorized access, use or disclosure.

Current safeguards include:

• authenticated user accounts;
• role-based authorization;
• server-side ownership checks;
• record-level access controls;
• HTTPS connections;
• server-side secret management;
• hashed consent tokens;
• single-use consent links;
• consent-link expiry; and
• restricted administrative functions.

No internet-based service can guarantee absolute security.

If Leráni becomes aware of a privacy or security incident, it will assess the incident and take steps required under applicable law.

13. Retention

Leráni retains personal information only for as long as it is reasonably needed for the purposes described in this policy, to provide the service, or to meet legal, security and accountability requirements.

At present, Leráni's application records do not use an automatic time-based deletion process.

We are establishing formal retention and deletion schedules before commercial school deployment.

Where an account-deletion request is approved, Leráni will remove the student's application-level profile and learning records, subject to information that must reasonably be retained for legal, security or accountability purposes and subject to the deletion lifecycle of our technology providers and backups.

14. Access and correction

Students may view and edit certain profile information through their Leráni account.

Individuals may also request:

• access to their personal information;
• correction of inaccurate information;
• withdrawal of consent where applicable; and
• deletion of their Leráni account and associated information.

Some information may not be deleted immediately where retention is reasonably required by law, security, fraud prevention or accountability requirements.

We will explain any material limitation when responding to a request.

15. Account deletion

A request to delete a Leráni account may be submitted through the student's Account privacy controls.

A deletion request does not mean that the account has already been deleted. Leráni reviews the request and completes the necessary deletion steps.

Certain platform-managed authentication information may require separate administrative deletion through our technology provider.

16. Consent withdrawal

A student or parent/guardian may request withdrawal of consent.

Where parental consent is required for the student's use of Leráni, withdrawal will mean that the student's learning activity can no longer continue.

Withdrawal of consent does not necessarily require immediate deletion of all previously collected information where limited retention remains necessary for legal or accountability purposes.

17. Cookies and analytics

The Leráni application does not currently use advertising cookies or advertising trackers.

Leráni does not currently use application-level behavioural analytics to profile students for advertising.

Our technology providers may use essential browser storage, session technologies or technical logs required to provide their services.

18. Advertising and sale of data

Leráni does not:

• sell student personal information;
• rent student personal information;
• use student personal information for targeted advertising;
• operate a data brokerage business;
• display behavioural advertising to students; or
• compare students for marketing purposes.

19. Changes to this Privacy Policy

We may update this Privacy Policy as Leráni develops, applicable law changes or service providers change.

Where a change materially affects how student information is collected, used or disclosed, Leráni will provide appropriate notice and obtain additional consent where required.

The "Last updated" date at the top identifies the current version.

20. Questions, complaints and privacy requests

Questions or concerns about Leráni's privacy practices may be directed to the Leráni Privacy Officer.

Individuals may challenge Leráni's compliance with applicable privacy obligations and may also have the right to contact the Office of the Privacy Commissioner of Canada or another applicable privacy regulator.