Privacy Policy – Nova Mymentor AI EdTech Platform

Our Privacy Policy – Your Data, Our Responsibility

This Privacy Policy ("Policy") document is an electronic record in terms of the Information Technology Act, 2000 and rules made thereunder. This electronic record is generated by a computer system and does not require any physical or digital signatures.

This document is published in accordance with the provisions of the Information Technology Act, 2000 and rules made thereunder that requires publishing the rules and regulations, privacy policy and terms of service for access or usage of this website.

We, Rubix IT Solution Private Limited, are a company incorporated under the laws of the Republic of India with its office located at 1st Floor, Srinivasa Nilayam, Bachupally, Hyderabad – 500090, India ("Company" / "we" / "our" / "us"), committed to protecting the privacy of our users ("you" / "your" / "yourself") who are using our website www.novamymentor.com ("Website") and accessing our services provided on the Website ("Services").

It is our mission to help educators deliver meaningful learning experiences and provide students with access to quality AI-powered learning tools through our flagship AI tutor "Nova Mymentor" and comprehensive educational platform. Creating a safe and secure environment where users freely share content and ideas is central to the success of our endeavors.

In case your grievance was not handled in compliance with applicable laws by the Company, you have the right to file appropriate complaints with the Data Protection Board of India under the provisions of the Digital Personal Data Protection Act, 2023.

1. Introduction

This Privacy Policy governs the use of data collected by us to provide Services through our Website, including our AI tutor "Nova Mymentor" and related educational technologies.
The aim of this Privacy Policy is to ensure that you understand what information we collect about you, the reasons for collection and use, and the entities we may share it with.
We ensure compliance with all applicable laws, including the Digital Personal Data Protection Act, 2023, FERPA, COPPA, and other relevant educational data privacy regulations.
You can contact us anytime with queries about this Privacy Policy at support@novamymentor.com.

2. Definitions

Child / Children: a person who has not completed the age of 18 years.
Educational Records: records directly related to a student and maintained by Rubix IT Solution Pvt Ltd or a party acting for Nova Mymentor.
Nova Mymentor: our flagship AI tutoring system that provides personalized learning experiences, interactive lessons, and intelligent educational support.
Large Language Models (LLMs): advanced AI models designed to process and analyze natural language data for educational purposes.
Messages: messages sent to users from Nova Mymentor via SMS, WhatsApp, email, or other mediums.
Personal Identifiable Information (PII): names, email addresses, phone numbers, gender, address, location, school, ID numbers, etc.
Users: students, teachers, parents, and educational institutions using the Service.

3. Scope of the Policy

By accessing or using the Website or otherwise giving us your information, you undertake that you have the capacity to enter into a legally binding contract through this Policy.
This Policy describes the types of information the Company collects, why and how we use the information, with whom we share it, and the choices you can make.
We may rely on schools to provide requisite consent on behalf of parents for students under 18 for educational purposes, in compliance with FERPA requirements.
This Policy may be amended from time to time. Any changes will become effective upon posting with appropriate notice to affected users.

4. Applicability to Children and Educational Settings

Children's Privacy Protection

When a Child creates an account, we collect their information in compliance with COPPA and other applicable laws by seeking verifiable parental consent.
Account creation is done through a one-time-password (OTP) sent to the parent's verified phone number or email address.
When our Website is used by a school in an educational setting, we rely on the school to provide requisite consent through contractual arrangements on behalf of the parent for students under 18.
Failure to obtain proper consent renders the child ineligible.

FERPA Compliance

For educational institutions, we act as a school official with legitimate educational interests in student data.
We maintain the confidentiality of student educational records and do not redisclose personally identifiable information without proper authorization.
Parents and eligible students have rights under FERPA to inspect and review educational records.

5. Types of Information Collected

Personal Information

First and last names
Age, gender and grade level (for educational purposes)
Student identification numbers (when applicable)
Email addresses
Mobile phone numbers
School or institution affiliation

Educational Data

Assessment results and scores
Learning progress and performance analytics
Subject preferences and learning patterns
Interaction data with Nova Mymentor AI Tutor
Course completion status
Time spent on educational activities
Learning path recommendations

Technical Information

Device information (browser type, operating system)
IP addresses and location data (general geographic area only)
Website usage patterns and navigation data
Log files and error reports
Performance and analytics data

AI Interaction Data

Conversations and interactions with Nova Mymentor AI Tutor
Questions asked and responses provided
Learning preferences and feedback
Personalization settings and recommendations
Error patterns and learning difficulties identified

6. Why Do We Collect This Information?

We use the data collected for the following educational purposes:

Core Educational Services

Provide personalized learning experiences through Nova Mymentor AI tutor
Track student progress and learning outcomes
Generate adaptive learning paths and recommendations
Facilitate communication between teachers, students, and parents
Create assessments and provide feedback

Platform Improvement

Improve Nova Mymentor AI tutor's accuracy and effectiveness
Develop new educational features and content
Analyze usage patterns to enhance user experience
Ensure platform security and prevent misuse
Conduct educational research (with anonymized data)

Communication and Support

Send important notifications about account activity
Provide customer support and technical assistance
Share educational updates and platform improvements
Communicate with parents or teachers about student progress (where applicable)

7. What We Do Not Do With Your Data

Prohibited Uses

We do not sell Personal Information or Educational Data to third parties
We do not use student data for targeted advertising or commercial marketing
We do not allow advertising networks to collect data from our platform
We do not share data with data brokers or for non-educational purposes
We do not use student PII to train AI models for commercial purposes outside of educational improvements

FERPA Compliance Commitments

We do not redisclose student educational records without proper authorization
We do not use educational data for purposes other than those specified in our agreements with educational institutions
We do not retain student data longer than necessary for educational purposes

8. Data Security and Protection

Security Measures

Industry-standard encryption for data in transit and at rest
Secure cloud storage or data centers in India
Multi-factor authentication for administrative access
Regular security audits and vulnerability assessments
Employee training on data privacy and security protocols

AI Data Protection

Nova Mymentor AI tutor interactions are securely stored
Access to AI systems is restricted to authorized personnel only
Principle of least privilege applied to all data access
Regular monitoring for unauthorized access or data breaches

Incident Response

In the event of a security breach, we will notify affected users within the timeframe required by applicable law
We maintain detailed incident response procedures and recovery protocols
Users will be provided with information about steps taken to address any security incidents

9. Data Sharing and Third Parties

Permitted Sharing

With educational institutions for legitimate educational purposes
With parents or legal guardians regarding their child's educational progress
With service providers who assist in platform operations (under strict data protection agreements)
When required by law or legal process
To protect the safety and security of our users

Third-Party Service Providers

All vendors are required to sign data protection agreements
Vendors must comply with FERPA, COPPA, and other applicable privacy laws
We conduct regular audits of third-party data handling practices
Vendors are prohibited from using data for non-educational purposes

International Data Transfers

Student data is primarily stored in India
Any international data transfers comply with applicable cross-border data protection requirements
We maintain appropriate safeguards for any data transferred outside India

10. Data Retention and Deletion

Retention Periods

Personal Information: Retained only as long as necessary for educational purposes or as required by law
Educational Data: Retained in accordance with institutional policies and legal requirements
AI Interaction Data: Anonymized after a reasonable period for platform improvement
Account Data: Deleted upon account closure, subject to legal retention requirements

User Rights

Users may request access to their personal information
Parents may request access to their child's educational records
Users may request correction of inaccurate information
Users may request deletion of their data (subject to legal and educational requirements)
Educational institutions may request export of their data

11. Compliance with Educational Regulations

FERPA Compliance

We maintain the confidentiality of student educational records.
Parents and eligible students have the right to inspect and review educational records.
We obtain proper consent before sharing educational information.
Access to educational records is limited to authorized personnel with legitimate educational interests.

COPPA Compliance

We obtain verifiable parental consent before collecting information from children under 13.
Parents are provided with clear notice of our information practices.
Parents have the ability to review and delete their child's information.
Participation in our services is not conditioned on disclosure of more information than necessary.

State and Federal Requirements

We comply with all applicable state student data privacy laws in India.
We maintain compliance with federal and national regulations regarding educational technology.
Our practices are regularly reviewed and updated to ensure continued compliance.

12. Applicability to Indian Users Only

Our Services are available exclusively to users located in India. We do not target or provide our Services to individuals residing outside India.
All personal data processing is governed by Indian laws and regulations, including the Information Technology Act, 2000, the Digital Personal Data Protection Act, 2023, and associated rules.
Users located outside India are not eligible to create accounts or access our Services. Any access attempts from outside India may result in automatic account suspension.
For questions regarding our data practices under Indian law, users may contact our Grievance Officer at support@novamymentor.com.

13. Cookie Policy

We use cookies to enhance user experience and platform functionality.
Essential cookies are necessary for the operation of the platform.
Analytics cookies help us analyze usage patterns and improve our services.
Users can manage their cookie preferences through browser settings.
Blocking certain cookies may affect or limit the functionality of the platform.

14. AI Transparency and Fairness

Nova Mymentor uses advanced AI technology to provide personalized educational experiences.
Measures are implemented to address potential bias in AI recommendations.
AI-generated content is clearly identified for user awareness.
Users are encouraged to independently verify important information.
We continuously monitor and improve AI fairness and accuracy.
Regular audits are conducted to detect bias and discrimination.
Transparency is provided regarding how AI recommendations are generated.
Users can provide feedback on AI interactions.
Human oversight is maintained over AI educational content.

15. Parental Rights and Controls

Parents and guardians have the right to review their child's personal information and educational records.
Ability to request correction or deletion of their child's data.
Right to control their child's participation in our services.
Access to information about how their child's data is used.
Ability to withdraw consent for their child's participation at any time.
Clear notice is provided to parents regarding our data practices.
Parents receive updates about significant changes to privacy practices.
Accessible channels are maintained for parent inquiries and concerns.

16. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices or applicable laws.
Material changes will be communicated via email, SMS, or prominent notice on the website.
Continued use of our services after notification constitutes acceptance of the changes.
Previous versions of the Privacy Policy are available upon request.

17. Camera and Microphone Access – Emotional and Voice-Based Features

Nova Mymentor uses device camera and microphone to enable unique emotional and voice-based learning interactions with the AI Tutor.
By using these features, you consent to enabling camera and microphone access for:
- Real-time facial expression analysis to understand emotions, engagement, and frustration during learning
- Voice data recording to analyze intonation, sentiment, and transaction quality for voice-based communication and support
Data collected is processed using secure, privacy-preserving algorithms and encrypted storage/transmission.
No raw audio or video is stored permanently unless explicitly permitted by the user for specific learning review features.
Biometric, emotional, and voice data is not shared with third parties except as required by law or with explicit consent.
Parents or legal guardians must expressly consent to enable these features for minors; opt-out options are available.
Users may withdraw consent and disable camera/microphone features at any time, understanding some learning features may become unavailable.
All usage of camera/microphone data complies with applicable biometric data privacy laws in India and internationally.
This section supplements our general commitments to privacy and security for all personally identifiable information and educational data.

18. Contact Information and Grievance Redressal

Primary Contact

Email: support@novamymentor.com
Phone: +91-xxxxxxxxx
Address: 1st Floor, Srinivasa Nilayam, Bachupally, Hyderabad, Telangana - 500090, India

Grievance Officer

Name: Ms. Radhika
Email: support@novamymentor.com
Phone: +91-xxxxxxxxx
Address: 1st Floor, Srinivasa Nilayam, Bachupally, Hyderabad, Telangana - 500090, India

Regulatory Complaints

In case your grievance was not handled in compliance with applicable laws by the Company, you have the right to file appropriate complaints with:

Data Protection Board of India (under Digital Personal Data Protection Act, 2023)
Department of Education (for FERPA-related concerns)
Federal Trade Commission (for COPPA-related concerns)

Effective Date: September 8, 2025