Privacy Policy

This Privacy Policy explains how [Company Name] (“we,” “us,” “NutriLearn”) handles information in connection with the NutriLearn nutrition-education web application (the “Service”). NutriLearn is sold to schools and school districts (each, a “School”) for use by their teachers and students in a classroom setting. It is not a consumer product and is not offered for signup by members of the public on behalf of a child.

NutriLearn is built to collect the minimum information needed to operate a classroom tool, and no more. Specifically:

Teachers

• Email address (used to log in and for account recovery)
• Display name (as entered at signup)
• Optional school association, set by the School's administrator
• If a School later enables single sign-on (SSO) through a provider such as Google Workspace for Education, Clever, or ClassLink, an SSO provider identifier — this is not active in the current version of the Service.

Students

• A username chosen or assigned within their class (not an email address, and not required to be a real name)
• A display name, which a teacher can set to anything — schools are advised not to enter a student's legal name
• Which class and school the student belongs to
• Gameplay data: challenge scores, selections made during game sessions, lesson/quiz completion, in-game achievements, and an in-game currency balance used for cosmetic character customization
• A student-chosen character appearance (hair, color, accessories, etc.), stored as configuration data — not a photo or biometric data

Students do not provide an email address, phone number, date of birth, home address, or any government identifier anywhere in the product, and the product has no field that accepts one. Student accounts are created only by a teacher, from the class roster screen — a student never fills out their own signup form.

A technical note on student login: because our authentication system (Supabase Auth) requires every account to have an email address internally, each student account is assigned an auto-generated, non-personal placeholder address (in the form username.classcode@student.nutrilearn.app) at creation. This address is never shown to the student, never used to contact anyone, and is not a real, deliverable email address — it exists purely as an internal account identifier and does not constitute collection of an email address from the student.

What we do not collect

• No student email address, legal name requirement, date of birth, or home address
• No free-text fields a student can type into — in-game chat is limited to a fixed list of teacher- and platform-approved phrases; there is no field anywhere in the Service where a student can enter arbitrary text
• No location data, device fingerprinting, or advertising identifiers
• No third-party analytics, advertising, or tracking scripts of any kind. We have reviewed the Service's source code and confirmed no Google Analytics, Mixpanel, ad network, or comparable tracking script is loaded on any page, for either teachers or students.

We use the information above only to operate, maintain, and improve the Service for its intended educational purpose, including to:

• Authenticate teachers and students and keep their accounts and classes separate and secure
• Run gameplay: score challenges, track progress through lesson modules, and award in-game achievements and currency
• Give teachers progress reports for their own students, in their own classes
• Diagnose and fix technical problems with the Service

We do not use student information to build advertising profiles, and we do not use it for any purpose unrelated to providing the educational Service to the School that purchased it.

We do not sell information, and we do not share it with data brokers, advertisers, or ad networks. Information is shared only in the following limited circumstances:

• Within a School:a teacher can see the students and data for the classes they own; students cannot see other students' account details. Our database enforces this separation at the data-access layer (row-level security), not only in application code.
• Service providers who host the Service on our behalf — currently Supabase (database, authentication, and real-time infrastructure) and [Hosting Provider — e.g. Vercel] (application hosting). These providers process data only as necessary to run the Service and are bound by their own data-processing terms; they are not permitted to use School or student data for their own purposes.
• Legal requirements: if required to do so by law, a valid legal process, or to protect the safety of a student or the integrity of the Service.
• Business transfers: if [Company Name] is involved in a merger, acquisition, or asset sale, School and account data may be transferred as part of that transaction, subject to the same commitments described in this policy.

We never make cross-school comparisons, joins, or exports of student data — every student's data stays scoped to their own school and class.

NutriLearn is designed for use by students of all K-12 ages, including children under 13, and we take the Children's Online Privacy Protection Act (COPPA) seriously.

NutriLearn is not sold or offered directly to children or their parents. It is sold to Schools, which review and agree to this Privacy Policy and our Terms of Service, create student accounts themselves (through a teacher, from the class roster tool), and control what information — if any — is entered for each student (for example, whether a display name is a nickname or something closer to a real name).

Because of this, NutriLearn relies on the “school official” exception recognized under the Family Educational Rights and Privacy Act (FERPA) and by the U.S. Federal Trade Commission's COPPA guidance for education technology providers. Under this framework, a School may consent on behalf of parents to a vendor's collection of student personal information, provided that:

• the vendor performs a service the School would otherwise perform itself (here, delivering nutrition-education curriculum and tracking student progress on it),
• the School maintains control over the information collected, and
• the information is used only for the authorized educational purpose — not for any commercial purpose independent of the School's direction, such as advertising.

Under this exception, the School — not the individual parent — is treated as consenting to student data collection on behalf of its students' parents, in the same way it does for other classroom software and services. We do not independently seek verifiable parental consent for each student, and Schools that deploy NutriLearn represent that they have the authority to provide this consent on their students' behalf and, where required by their own policies or applicable state law, have notified parents accordingly.

Consistent with this, and as described above, NutriLearn does not collect a student's real email address, does not require a real name, does not use tracking cookies or fingerprinting to follow students across other sites or apps, and loads no third-party advertising or analytics scripts anywhere a student is logged in.

A parent or guardian with questions about their child's data, or who wants to review or request deletion of it, should contact their child's School first, since the School controls the account. A School itself, or a parent whose School is unresponsive, can also reach us directly — see “Contact us” below.

We retain account and gameplay data for as long as a School's class remains active, so teachers can track ongoing student progress. When a teacher archives a class, that class's student data is not immediately deleted — this gives a School a window to export or reference records — but it is not kept indefinitely.

Our policy is to permanently delete a class's student data no later than 90 days after that class is archived. A server-side job (purge-archived-class-data) permanently deletes each archived class's student accounts and every record tied to them — session history, food selections, achievements, coin transactions, and shop purchases — once 90 days have passed, and this has been directly tested against a real archived class to confirm it works correctly and leaves other classes untouched. [As of this writing, the job itself is built and verified, but is not yet running on an automatic daily schedule — confirm this has been scheduled (see the deployment's own setup notes) before relying on this paragraph as a description of current automatic behavior.]

A School can also request deletion of a class or of specific student records earlier than this schedule at any time — see “Contact us” below.

We take reasonable, industry-standard measures to protect information in the Service, including:

• All traffic to and from the Service is encrypted in transit (HTTPS/TLS).
• Database access is governed by row-level security (RLS) policies enforced by our database provider, Supabase — meaning access rules are checked at the data layer itself, not only in application code. Teachers can only read or modify students and classes they own; students can only read or modify their own records.
• Student game scores are computed and verified on our servers, not accepted as-is from a student's device, to prevent tampering.
• There is no free-text field anywhere a student can type into, which removes an entire category of risk (e.g. a student pasting personal information somewhere it shouldn't be, or inappropriate content).
• Access to administrative/service-level database credentials is restricted to server-side code and is never exposed to the browser.

No online service can guarantee perfect security, and we do not claim NutriLearn is immune to all possible security incidents. If we become aware of a data breach affecting School or student data, we will notify affected Schools promptly and in accordance with applicable law.

Because NutriLearn is a B2B2C product, the School is the primary point of control for student data: Schools decide what (if any) identifying information to enter for a student display name, who has teacher access, when to archive a class, and how to communicate this policy to parents consistent with their own obligations. See our Terms of Service for more detail on this relationship.

• Teachers can update their display name and reset student passwords directly from the product.
• A School can request a copy of, or deletion of, its teachers' or students' data at any time by contacting us.
• Depending on applicable law (for example, state student-data-privacy laws or, for non-U.S. users, frameworks such as GDPR), a School or, in the appropriate case, a parent may have additional rights to access, correct, or delete personal information. We will honor valid requests consistent with our contractual obligations to Schools.

We may update this Privacy Policy as the Service changes. If we make material changes, we will update the effective date above and, where appropriate, notify Schools directly.

Questions about this policy, or requests to access or delete data, can be sent to [Contact Email — e.g. privacy@[yourdomain].com].

[Company Name] — [Company Address — placeholder, fill in before publishing]