Privacy Policy
Your child's data is sacred to us. Here's exactly what we collect, why we collect it, and how we protect it — in plain language.
Draft update for review: July 16, 2026 · Version 1.1Overview & Our Commitments
Our promise to Canadian families: SmartStudy exists to help children learn — not to profit from their data. We limit collection to information needed for stated purposes, prohibit sale and behavioural advertising with learner data, and assess service providers and processing locations before enabling child-data flows.
This Privacy Policy describes how 7110961 Canada Inc., operating as SmartStudy™ ("SmartStudy," "we," "us," "our"), collects, uses, stores, and discloses personal information when you use our platform, including the Maple AI study coach, the parent dashboard, and all associated services (the "Service").
This policy applies to:
- Parents and guardians who create and manage accounts
- Children who use SmartStudy through a parent-managed account
- Visitors to our website at smartstudy.ca
We take our obligations under applicable Canadian privacy and electronic-messaging laws seriously. This policy explains how we collect, use, protect, and respond to requests about personal information.
Who Controls Your Data
The data controller responsible for your personal information is:
- Legal entity: 7110961 Canada Inc.
- Operating name: SmartStudy™
- Registered office: 200 Colborne St West, Whitby, Ontario, L1N 1X2
- Country: Canada
- Privacy contact: privacy@smartstudy.ca
Our designated Privacy Officer is responsible for overseeing compliance with PIPEDA and responding to privacy-related inquiries and complaints.
What We Collect
We collect three categories of information:
| Category | Specific Data | Who It Relates To | Required? |
|---|---|---|---|
| Account Information | Name, email address, password (hashed), province/territory, subscription status | Parent / Guardian | Required |
| Child Profile | First name or nickname, grade level, province, preferred learning style settings, accessibility needs (optional) | Child | Required |
| Learning & Usage Data | Session logs, questions asked, answers given, time spent, XP earned, weekly progress, badges, skill assessments, Maple conversation transcripts | Child | Required |
| Voice Data | Audio input processed in real-time for speech recognition (not stored after processing unless transcript retention is enabled) | Child | Optional |
| Payment Information | Billing name, last four digits of card, billing address. Full card numbers are processed by our payment processor and never stored by SmartStudy. | Parent / Guardian | Required for paid plans |
| Technical Data | IP address (anonymized), browser type, device type, session timestamps, error logs | All users | Automatic |
| Communications | Support emails, feedback submissions, waitlist sign-ups | Parent / Guardian | When provided |
What We Do Not Collect
- Children's last names, home addresses, or phone numbers
- Photos or video from device cameras
- Geolocation beyond province/territory selection
- Social media profiles or third-party account data
- Sensitive health or medical information (accessibility preferences are optional and self-reported)
- Device contacts, call logs, or files outside the app
Children's Information
This section is the most important part of our policy. If you read nothing else, read this.
SmartStudy is a service for children, and we treat data about children with the highest level of care. We follow the principle of data minimization — we collect the least amount of information necessary for Maple to do her job.
Parental Consent & Control
- A parent or guardian must create and maintain the account. Children cannot self-register.
- By creating a child profile, you provide verifiable parental consent for us to collect and use your child's information as described in this policy.
- Parents may view, edit, or delete all child profile information at any time from the parent dashboard.
- Parents may request a complete export of their child's data within 30 days of the request.
- Parents may request permanent deletion of their child's account and all associated data.
What Children's Data Is Used For
Information collected about your child is used exclusively to:
- Personalize Maple's teaching style, pacing, and content to your child's learning profile
- Track curriculum progress and generate your weekly parent report card
- Operate the gamification system (XP, weekly progress, badges)
- Enable spaced-repetition scheduling of review topics
- Support accessibility features and UDL accommodations
- Ensure child safety through content moderation and parental review tools
Children's Data Is Never Used For
- Advertising, behavioral profiling, or marketing to children
- Sale or sharing with third parties for commercial purposes
- AI model training without explicit additional parental consent
- Any purpose other than those listed above
How We Use Data
We use personal information only under the following lawful bases, as required by PIPEDA:
| Purpose | Lawful Basis | Data Used |
|---|---|---|
| Delivering and personalizing the Service | Contractual necessity | Account, child profile, learning data |
| Parent dashboard & reporting | Contractual necessity | Learning data, session logs |
| Processing payments | Contractual necessity | Billing information |
| Sending weekly report card emails | Consent for email updates | Email, learning data summary |
| Responding to support requests | Legitimate interest | Email, account data |
| Safety monitoring & content moderation | Legitimate interest | Conversation transcripts |
| Platform security & fraud prevention | Legitimate interest | Technical data, IP addresses |
| Service improvement (de-identified) | Legitimate interest | Aggregated, anonymized usage statistics |
| Legal compliance | Legal obligation | As required by law |
AI & Maple Data
Maple's intelligence is powered by AI models. Understanding how your child's interactions are handled is important to us.
Conversation Processing
- Conversations with Maple are processed in real-time on Canadian-hosted servers to generate responses.
- Session transcripts are stored and are reviewable by parents in the parent dashboard for up to 90 days, after which they are archived in anonymized form.
- Parents may flag any Maple response for human review at any time from the parent dashboard.
AI Model Training
- We do not use your child's identifiable conversations to train AI models without your explicit, separate consent.
- We may use de-identified, aggregated patterns (such as which types of hints help children most) to improve curriculum content and Maple's pedagogical approach.
- Any future opt-in for more detailed AI improvement participation will be presented separately and clearly.
Voice Processing
When voice input is used, audio is streamed to our Canadian servers for speech-to-text conversion. The raw audio is not stored; only the text transcript is retained subject to the transcript retention policy above. Parents can disable voice features entirely from account settings.
Data Location & Service Providers
Our current architecture uses Canadian regions for core application databases and AI services where supported. A Canadian region does not by itself prove that every support, authentication, delivery, backup, or subprocessor activity occurs only in Canada.
Before enabling real-child-data processing, our launch gate requires a documented vendor and location inventory, contractual review, transfer assessment where applicable, and verification of configured regions. Our intended safeguards include:
- Canadian-region configuration for core databases and supported AI processing
- Documented locations and access paths for authentication, email, support, delivery, backups, and subprocessors
- Contractual and technical safeguards for any access or processing outside Canada
Our public marketing pages may be delivered through global content-delivery infrastructure. Account and form submissions use service providers described in our current processing and vendor records. Provider personnel or infrastructure outside Canada may be involved where documented and permitted, with safeguards appropriate to the processing. Contact our Privacy Officer for current location information relevant to your use.
We will update this policy and notify affected users when a material provider or processing-location change alters the applicable privacy risk or user choice.
SmartStudy is not currently offered in Quebec, and Quebec residents must not create an account or submit a waitlist or service form until Quebec availability is announced. Before activating Quebec, SmartStudy will complete a separate, counsel-reviewed Law 25 readiness and market-activation assessment.
Retention & Deletion
| Data Type | Retention Period | Deletion Method |
|---|---|---|
| Account & profile information | Duration of subscription + 30 days grace period | Permanent deletion upon account closure request |
| Learning session data | Active for the life of the account; anonymized after 2 years of account inactivity | Deletable at any time via parent dashboard |
| Maple conversation transcripts | 90 days (reviewable), then anonymized | Parent may delete individual sessions |
| Marketing site chat logs | 90 days, then purged automatically | Automatic purge |
| Anonymous public homework decodes | 7 days (claimable window), then purged if unclaimed. Photos deleted after 30 days regardless. | Automatic purge |
| Voice audio | Not stored — processed in real-time only | N/A |
| Payment records | 7 years (tax & legal requirement) | Cannot be deleted early due to legal obligations |
| Support communications | 2 years from resolution | Deletable upon written request |
| Technical / error logs | 90 days, anonymized thereafter | Automatic |
Upon account deletion, we will permanently delete all personal data within 30 days, except data we are legally required to retain (such as payment records). We will confirm deletion in writing upon request.
Security
We implement security measures appropriate to the sensitivity of the data we hold — particularly given that it includes children's information. Our safeguards include:
- Encryption in transit: All data transmitted between your device and our servers uses TLS 1.3 encryption.
- Encryption at rest: Databases and backups are encrypted using AES-256.
- Password security: Passwords are hashed using industry-standard bcrypt. We never store plain-text passwords.
- Access controls: Access to production data is restricted to authorized personnel on a need-to-know basis, with multi-factor authentication required.
- Regular audits: We conduct periodic security reviews and vulnerability assessments.
- Breach response: In the event of a data breach creating a real risk of significant harm, we will notify affected users and report to the Office of the Privacy Commissioner of Canada (OPC) as soon as feasible, as required by applicable law. If you have questions about a specific incident, contact hello@smartstudy.ca.
No system is perfectly secure. If you discover a security vulnerability, please report it responsibly to hello@smartstudy.ca.
Your Rights
Under PIPEDA and applicable provincial law, you have the following rights regarding your personal information and your child's information:
Right to Access
Request a copy of all personal data we hold about you or your child.
Right to Correct
Update or correct inaccurate information through your account settings.
Right to Delete
Request deletion of your account and all associated personal data.
Right to Portability
Export your child's learning data in a structured, machine-readable format.
Right to Withdraw Consent
Withdraw consent for non-essential processing such as service improvement.
Right to Complain
File a complaint with the Office of the Privacy Commissioner of Canada.
To exercise any of these rights, contact our Privacy Officer at privacy@smartstudy.ca. We will respond within 30 days. We may need to verify your identity before processing certain requests.
Office of the Privacy Commissioner
If you are unsatisfied with our response, you may file a complaint with the OPC at www.priv.gc.ca or by calling 1-800-282-1376. Residents of Quebec, Alberta, and British Columbia may also contact their provincial privacy commissioners.
CASL & Communications
SmartStudy treats waitlist welcome and update emails as commercial electronic messages and applies the following controls:
- The waitlist form uses an unchecked, optional express-consent choice and records the notice version, source, and server time.
- No waitlist welcome or marketing email is sent when that choice is not selected.
- Commercial messages identify 7110961 Canada Inc. DBA SmartStudy.ca, provide contact information, and include a no-cost unsubscribe link.
- An unsubscribe request is applied immediately to the commercial-message suppression list without requiring sign-in.
- Necessary security, authentication, service-request, and account-administration messages are classified separately from commercial messages.
You may withdraw commercial-message consent using the unsubscribe link in a commercial email or by contacting privacy@smartstudy.ca.
Policy Changes
We may update this Privacy Policy from time to time as the Service evolves or legal requirements change. When we make material changes — particularly changes that affect how we collect or use children's data — we will:
- Notify you by email at least 14 days before the changes take effect
- Post a prominent notice on the Service and website
- For changes affecting children's data specifically, require renewed parental consent where required by law
The "Effective Date" at the top of this policy indicates when it was last updated. We encourage you to review this policy periodically.
Contact & Complaints
For any privacy-related questions, requests, or concerns, please contact our Privacy Officer:
- Email: privacy@smartstudy.ca
- General enquiries: hello@smartstudy.ca
- Company: 7110961 Canada Inc., operating as SmartStudy™
- Registered office: 200 Colborne St West, Whitby, Ontario, L1N 1X2
- Country: Canada
We commit to acknowledging your inquiry within 5 business days and providing a substantive response within 30 days. If a privacy matter requires more time to investigate, we will inform you of the extended timeline and reason.
Privacy questions? Ask us anything.
We built SmartStudy as parents. We take your family's privacy as seriously as our own. No bureaucratic run-around — just honest answers.
Email our Privacy Officer