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Privacy Policy

Last updated December 17th, 2025

1. Introduction

This Privacy Policy describes how Enya Labs Inc. ("we," "our," or "us") collects, uses, and discloses information about users of the Enya Learning platform and associated services (the "Service"). This policy applies to all personal information collected through our Service, regardless of how it is collected or stored.

By using the Service, you consent to the data practices described in this Privacy Policy. If you do not agree with the data practices described, you should not use our Service.

2. Personal data we collect

We may collect the following types of personal information:

  • Contact information (such as name, email address, phone number)
  • Demographic information (such as age, gender, school)
  • Account credentials (such as username, password)
  • Educational information (such as grade level, learning progress, assessment results)
  • Parent/guardian information for users under 18
  • Payment information (if applicable)

Usage Data Collected

We automatically collect certain information when you visit, use, or navigate our Service. This information may include:

  • Device information (such as device type, operating system)
  • IP address
  • Browser type and version
  • Pages visited and features used
  • Time spent on pages
  • Clickstream data
  • Date and time of access
  • Referring website address

Cookies and Tracking Technologies

We may use cookies, web beacons, tracking pixels, and other tracking technologies to help customize the Service and improve your experience. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Compliance for Minors

For students under 18, all tracking and analytics activities are strictly limited to those necessary for the educational functionality of the Service and are conducted in full compliance with the relevant School District agreements and applicable provincial privacy rules, including the Freedom of Information and Protection of Privacy Act (FIPPA) in British Columbia. We do not use persistent third-party tracking for behavioral advertising on student accounts

3. How we use personal data

We collect and use your personal information for the following purposes:

Personalized Learning Experience

  • To create and maintain your account
  • To provide personalized learning content and recommendations
  • To track and assess learning progress
  • To adapt content difficulty based on performance

Service Improvement

  • To analyze usage patterns and trends
  • To diagnose technical problems
  • To improve user experience
  • To develop new features and functionality

Research and Development

  • To conduct educational research
  • To improve our AI algorithms and models
  • To develop new educational methodologies
  • To publish anonymized research findings

Communication with Users

  • To respond to inquiries and support requests
  • To send administrative information
  • To provide updates about the Service

Marketing Limitation for Student Data

Enya will not use any student data, including personal information or usage data, for marketing, advertising, or commercial purposes, except as required for the core educational functionality of the platform or with explicit, separate consent from the parent, guardian, or School District.

4. How we share personal data

We may share personal information with third-party service providers to help us operate our business and the Service or administer activities on our behalf. These may include:

  • Cloud hosting providers
  • Analytics services (limited as per Section 2 of this Privacy Policy)
  • Payment processors
  • Customer support tools

We share personal information with these providers only to the extent necessary for them to perform their services, and they are contractually obligated to use your personal information only for the purposes of providing these services to us and to comply with Canadian privacy standards.

Data Residence and Storage

Our primary data servers are located in Canada.

Commitment to Canadian Data Residency for Student Data: All student data collected and processed by Enya will be stored and remain within Canada. Enya explicitly commits that student data will not be transferred, processed, or stored outside of Canada unless the relevant School District or client provides explicit, written consent for cross-border processing, in which case Enya will ensure all necessary legal and contractual safeguards are in place.

5. Retention

We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies.

When personal information is no longer required, we will delete it using secure methods. Upon request, we will delete or anonymize your personal information so that it can no longer be associated with you, subject to certain exceptions where retention is required or permitted by law.

6. Security and Breach Notification

We implement appropriate technical and organizational security measures to protect your personal information from accidental loss, unauthorized access, disclosure, alteration, and destruction

These measures include:

  • Encryption of sensitive data
  • Regular security assessments
  • Access controls and authentication
  • Staff training on data protection
  • Incident response procedures

However, please note that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

Contractual Security Commitment

Enya warrants that it maintains a comprehensive information security program designed to protect the confidentiality, integrity, and availability of the personal information we process. The specific security controls and audit rights are further detailed in the separate Security Addendum to the School District Agreement.

Breach Notification Commitment

In the event of a confirmed or suspected security breach involving personal information, Enya will notify the affected School District or client without undue delay and in no case later than the timeframes required by applicable Canadian privacy legislation (e.g., PIPA, FIPPA). Enya will provide all necessary information and cooperate fully with the School District or client in investigating and mitigating the breach

7. Your rights and choices

Under British Columbia's Personal Information Protection Act (PIPA), you have the right to:

Right to Access Personal Information

You have the right to request access to the personal information we hold about you and to receive an explanation of how that information is used.

Right to Correction of Inaccurate Information

You have the right to request that we correct any inaccurate or incomplete personal information we hold about you.

Right to Withdraw Consent

Where we rely on your consent to process your personal information, you have the right to withdraw that consent at any time.

Right to Deletion

In certain circumstances, you have the right to request the deletion of your personal information, subject to our legal obligations and legitimate business interests.

8. Jurisdiction-Specific Disclosures

This Privacy Policy is designed to comply with the requirements of Canadian federal and provincial privacy legislation, including the Personal Information Protection Act (PIPA) of British Columbia and the Freedom of Information and Protection of Privacy Act (FIPPA). Our primary jurisdiction for data processing is Canada.

9. Privacy policy changes

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

10. Contacting us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact our Privacy Officer at:

Mail: Roman Nurpeissov, Partnerships and Legal Affairs Advisor