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Edvenure Ltd.
PRIVACY NOTICE
Last Updated: August 17, 2025

Introduction
At Edventure Ltd. ("Edventure," "us," "we," or "our"), we recognize and respect the importance of maintaining the privacy of our users. This Privacy Notice describes the types of information we collect from you when you use our platform, website ("Site"), and/or services ("Services"), which include our digital diagnostic tool designed to assess students' learning tendencies (SmartMap©) and provide personalized learning recommendations (Edwin AI©). This Privacy Notice explains how we process, transfer, store, and disclose the data collected, as well as your rights regarding the control of certain uses of the collected data.
By using our Services, you acknowledge that you have read and understand this Privacy Notice and agree to the collection, use, and disclosure of your Personal Data as described herein.

Children’s Privacy
Our Services are designed to be used by children aged 6 to 18 in educational settings, and teaching personnel. Therefore, we are committed to complying with common privacy principles to protect children's data, and to accommodate to special circumstances of data collection and processing regarding children, requiring parental consent or authorizations whereby appropriate, meeting common standards of GDPR (EU 679/2016 General Data Protection Regulation) and COPPA (U.S. Children’s Online Privacy Protection Act).
We collect Personal Data from children under age 13 [LE1] only with the consent of their parents or guardians, typically through consent obtained by the educational institutions using our Services. We do not require a child to disclose more information than is reasonably necessary to participate in an activity.
Parents have the right to review, modify, and request deletion of their child's Personal Data, and  may contact us directly using the contact information provided at the end of this Privacy Notice to exercise these rights.
We do not use children's Personal Data for marketing purposes or share it with third parties for commercial purposes unrelated to the provision of our educational Services. We do not condition a child's participation in an activity or the child's disclosing more Personal Data than is reasonably necessary to participate in such activity.

Personal Data We Collect
The types of information that indirectly or directly identify you (“Personal Data”) we collect about you depends on how you interact with us. The following are the categories and specific types of personal data that we may collect:
Category[PK2] 
Type of Data Collected
How Data is Collected
User Information
When you register for our Services, we collect Personal Data provided by you, which may include:

  • Full name

  • Email address

  • Phone number

  • School or educational institution

  • Age or grade level

  • Gender

  • Payment information (when applicable)

  • Directly from you when you register, create an account, complete forms, respond to questionnaires, or otherwise provide information

  • For children under 13, we obtain verifiable parental consent prior to any collection, use, or disclosure of Personal Data.

Student Information
For students using our Services, we collect:

  • Learning assessment results

  • Responses to questionnaires

  • Academic performance metrics

  • Learning preferences and tendencies

  • Skills assessments (reading, writing, mathematics, etc.)

  • Voice recordings

  • Lesson history

  • Directly from students

  • From educational institutions that provide us with information about students or classes

  • From parents/guardians

Automatically Collected Information
When you use our Site, we automatically collect certain data, including:

  • IP address

  • Device information and identifiers

  • Browser type and version

  • Operating system

  • Automatically through cookies and similar technologies when you use our Site

Educational Institution Data
When educational institutions use our Services, we may collect:

  • School name and location

  • Teacher and administrator information

  • Class and grade information

  • Aggregated student performance data

  • From educational institutions

  • For children under 13, we obtain verifiable parental consent prior to any collection, use, or disclosure of personal information.

Generally, the provision of Personal Data is voluntary. However, we may not be able to fulfill the requested purpose of collection if you do not provide us with your personal data, such as to provide our Services or for our normal business administration.  However, unless otherwise specified, not providing your personal data will not result in legal or other consequences to you.
For the purposes of the GDPR, with respect to the Edwin AI© we are considered as the Controller (as such term is defined under the GDPR), and with respect to the SmartMap© we are considered as Data Processor, or a "service provider" for purposes of CCPA. Student Personal Data will be processed in accordance with a data protection agreement which will be executed with educational institutions.

How We Use Personal Data
We use your Personal Data for the following purposes[PK3] :

  • Providing our service - to provide our educational assessment services by providing personalized reports and educational experiences; creating custom lesson plans for teachers, educational content and personalized learning recommendations; monitoring participation and track trends.

  • Improvement of products and services – we also use your Personal Data on an anonymized and aggregated basis to maintain and improve the functionality of our Services, enhance user experience and develop new features and capabilities.

  • Support and communication - to respond to your inquiries or requests, provide important notices and updates about our Services, send administrative communications, and with your consent, send marketing communications and educational resources.

  • Educational research - to conduct educational research aimed at improving teaching methods and learning outcomes, develop and validate educational mapping questionnaires and analyze learning patterns and trends (on an anonymized and aggregated basis).

  • Administrative and legal purposes - to maintain business records, comply with legal obligations, enforce our terms and conditions, protect our legal rights and interests, prevent fraud and ensure cybersecurity.
     

Legal Basis for Processing
We rely on the following legal grounds for the collection, processing, and use of your Personal Data, in accordance with the laws and regulations applicable in the relevant country:

  • Consent: In countries where explicit consent is required, we process Personal Data when you have provided your explicit consent for specific processing activities, including marketing communications or research participation. For children, we obtain verifiable consent from parents or guardians in accordance with local legal requirements.

  • Legitimate Interests: In countries whereby permitted by law, processing is necessary for our legitimate interests, such as improving our Services, ensuring security, developing new features, and conducting educational research, provided these interests are not overridden by your data protection rights. For children under 13, we do not rely on legitimate interests as a basis for processing personal information.

  • Performance of a Contract: Processing is necessary to provide our Services to you in accordance with our terms and conditions. For children under 13, this applies only to the extent that the processing is necessary to provide the service requested by the child, and we do not collect, use, or disclose more personal information than is reasonably necessary for that purpose.

  • Legal Obligations: Processing is necessary for compliance with legal obligations to which we are subject.
     

Disclosure of Personal Data
We may share your Personal Data with the following categories of recipients:

  • Service Providers and Subcontractors - we may disclose your Personal Data to service providers and subcontractors who assist us in the operation of our Services, including: cloud hosting providers (such as Azure), customer support services, payment processors, analytics providers, and educational content providers. We require all such service providers to maintain the confidentiality, security, and integrity of personal information they access or process on our behalf. 

  • Educational Institutions - when our Services are used in educational settings, we may share assessment results and recommendations with teachers (for their specific students), school administrators (typically in aggregated form) and educational support professionals. For children under 13, such disclosures are made only with verifiable parental consent.

  • AI Service Providers - we use OpenAI's services for processing text and generating educational responses. Any data transferred to OpenAI is subject to their privacy policies and security measures. For more information, please see the Paragraph "Use of Artificial Intelligence (AI)" below.

  • Legal Requirements - we may disclose your personal data to legal, governmental, or judicial authorities, as instructed or required by those authorities or applicable laws, or to other parties in relation to legal process, such as in response to a subpoena. We may also disclose such personal data if we believe disclosure is necessary to prevent physical, financial, or other harm, injury, or loss.

  • Law Enforcement - we may disclose your personal data to law enforcement agencies where we believe it is necessary to prevent or investigate illegal activity.

  • Corporate Transactions - we may disclose your personal data in connection with a proposed or actual corporate merger, acquisition, consolidation, sale of assets, bankruptcy, insolvency or other corporate changes.

  • Additional Disclosures - from time to time, we may disclose your information to our attorneys, banks, auditors, securities brokers, and other professional service providers and advisors in connection with the purposes described above.

  • Other Disclosures with your Consent - we may disclose your personal data with your consent to other unaffiliated third parties who are not described elsewhere in this Privacy Notice
     

International Transfers
Your Personal Data may be transferred to, and processed in, countries other than the country in which you reside. These countries may have data protection laws that are different from the laws of your country.
Specifically, our servers are located in Israel and the United States, and we may also use service providers located in various countries. When we transfer your Personal Data to other countries, we take steps to ensure that appropriate safeguards are in place to protect your Personal Data as required by applicable data protection laws. For children under 13, we ensure that any such transfer complies with applicable requirements for data privacy and security.
By using our Services, you consent to the transfer of your Personal Data to countries outside your country of residence, including to Israel and the United States, in accordance with applicable data protection laws.

Your Rights
Depending on where you are located, you may have certain rights regarding your Personal Data. The rights available to you depend on our reason for processing your Personal Data and the requirements of applicable law. Specifically, you may have the following rights:

  • Right to Access: You may have the right to obtain confirmation as to whether we process your Personal Data and to receive a copy of the Personal Data we hold about you.

  • Right to Correction: You may have the right to request that we correct inaccurate incomplete, or unclear Personal Data concerning you.

  • Right to Deletion: In certain circumstances, you may have the right to request the deletion of your Personal Data.

  • Right to Restrict Processing: In certain circumstances, you may have the right to restrict our processing of your Personal Data.

  • Right to Data Portability: You may have the right to request that we transfer the personal data we have collected about you to another organization, or directly to you, in a structured, commonly used, and machine-readable format, under certain conditions.

  • Right to Object: You may have the right to object to our processing of your personal data under certain conditions, and we can be required to no longer process your personal data. If you have a right to object and you exercise this right, your personal data will no longer be processed by us for such purposes. Such a right to object may not exist if the processing of your personal data is necessary to take steps prior to entering a contract or to fulfil a contract already concluded.

  • Right to Withdraw Consent: Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.

To exercise these rights, please contact us at [support@edventureil.com]. We will respond to your request in accordance with applicable data protection laws.
Parents' Rights Regarding Children's Data: Under the US Children’s Online Privacy Protection Act (COPPA), parents or guardians have the right to review the Personal Data we have collected about their children, have such information deleted, and refuse further collection or use of their children's Personal Data. To exercise these rights, parents should contact us as detailed in the Contact Information section. We will respond to all verifiable parental requests within a reasonable time.

Data Retention
We retain your Personal Data for as long as necessary to fulfill the purposes for which we collected it, including for the purpose of satisfying any legal, accounting, or reporting requirements.
For educational assessment data, we typically retain this information for the duration of a student's enrollment in the educational institution using our Services, plus a reasonable period thereafter to allow for educational planning and continuity.
When determining the appropriate retention period for Personal Data, we consider:

  • The amount, nature, and sensitivity of the Personal Data

  • The potential risk of harm from unauthorized use or disclosure

  • The purposes for which we process the Personal Data

  • Whether we can achieve those purposes through other means

  • Applicable legal requirements
     

Security
We implement appropriate technical and organizational measures to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.
The security measures we may use include:

  • Encryption of data in transit and at rest

  • Access controls and authentication mechanisms

  • Regular security assessments

  • Staff training on data protection

  • Physical security measures for our facilities

However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Use of Artificial Intelligence (AI)
As described above, we use artificial intelligence (AI) technologies as part of our services. The use of AI may involve the processing of Personal Data, and we are committed to ensuring that such processing is carried out in accordance with applicable laws. We take appropriate measures to protect your privacy, including transparency regarding the use of AI, implementing suitable technical and organizational safeguards, and ensuring that any processing of Personal Data by AI is lawful, fair, and limited to what is necessary for the purposes described in this Privacy Notice.
We do not use AI for automated decision-making that produces legal effects or similarly significant effects concerning you, without human intervention, and unless such processing is permitted by applicable laws and appropriate safeguards are in place. If you have any questions about our use of AI, you are welcome to contact us by email provided below.

Cookies and Similar Technologies
Cookies are small text files that are placed on your device when you visit a website. They allow the website to recognize your device and remember information about your visit.
We use the following types of cookies:

  • Necessary Cookies: These cookies are essential for the operation of our Site and enable you to navigate and use its features.

  • Functionality Cookies: These cookies allow us to remember choices you make and provide enhanced, personalized features.

  • Performance/Analytics Cookies: These cookies collect information about how you use our Site, helping us to improve its functionality and performance.

  • Marketing Cookies: With your consent, these cookies may be used to deliver advertisements relevant to your interests.

Most web browsers allow you to control cookies through their settings. You can typically delete existing cookies, block certain types of cookies, or set your browser to notify you when cookies are being placed on your device. For children under 13, parents or guardians may manage cookie settings on behalf of their children.
For more information about how to manage cookies, please visit your browser's help section or settings.

Third Party Links
Our Sites may contain links to websites, content, or services owned or operated by third parties. Please note, we have no control over the privacy practices of websites or services that we do not own.  We encourage you to review the privacy policies of any third-party website or application for details about what information is collected and how it is used and/or disclosed. We assume no liability for how third parties may collect and/or use your Personal Data.

Changes to this Privacy Notice
We may update this Privacy Notice from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we update our Privacy Notice, we will revise the "Last Updated" date at the top of this page.
For significant changes that materially affect your rights or how we use your Personal Data, we will provide a more prominent notice, such as sending you an email notification.
We encourage you to review our Privacy Notice periodically to stay informed about our data practices.

Contact Information
If you have any questions, concerns, or requests regarding this Privacy Notice or our data practices, please contact us at:
Email: support@edventureil.com
If you are a parent or guardian and have questions about your child's data, please contact us at the above address.
 
 
 [LE1]Note to Company: Please let us know if is expected processing of children between the age of 13 to 16, and if so, need to consider if a parental consent will also be required. Specifically, in the EU this may be an issue, while in the U.S., COPPA relates only to age 13 and below.
 [PK2]Note to Company: Please ensure that all collected PII is covered correctly in the Table
 [PK3]Note to the Company: Please make sure the we have covered all data usage purposes

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