Privacy Policy

1.1 Personal Information (Data Minimization)

We are committed to the principle of data minimization. When you use our software or services, we collect only the absolute minimum personal information necessary to provide our educational services. This includes:

• A unique student identifier (provided by the school)
• A school-issued email address for account set-up

We DO NOT collect: Social Insurance Numbers (SIN), Social Security Numbers (SSN), credit card information, financial data, or any other highly sensitive personal data. Any additional information (such as name, phone number, or postal address) is entirely optional and not required to use our core services.

1.2 Usage Information

We may collect technical information about how you interact with our software or services, such as device type, the features you use, the apps you visit, and the actions you take within the VR/AI environment. This information is strictly used to help us improve our software and provide a better educational user experience. It is never shared with third parties for commercial purposes.

2.1 Provide and Improve Educational Services

We use your information exclusively to provide and improve our software and services for our educational customers. This includes personalizing the learning experience, responding to inquiries, and enhancing the functionality and performance of our software. We strictly prohibit the use of student data for targeted advertising, behavioral advertising, or building personal profiles of students for non-educational purposes.

2.2 Communication

We may use contact information (for adult users and administrators) to send important updates, notifications, and materials related to our software or services. Users can opt out of receiving promotional communications at any time.

2.3 Analytics and Aggregated Data

We may analyze usage patterns to improve our software and develop new educational features. This information is always aggregated and anonymized to protect user privacy.

3.1 FERPA Compliance (U.S. Education Institutions)

• FN Immersive Innovation complies with the Family Educational Rights and Privacy Act (FERPA) when handling student information provided by schools.
• We act as a "school official" under FERPA with a legitimate educational interest. We use student data solely for authorized educational purposes under the direct control of the school.
• We will not re-disclose Personally Identifiable Information (PII) without direct school authorization. Schools maintain full control over student records and can request access, corrections, and deletion at any time.

3.2 COPPA Compliance (U.S. Children Under 13)

• FN Immersive Innovation complies with the Children's Online Privacy Protection Act (COPPA). Our products are often used by students in Grade 4 and up (ages 9+).
• For users under 13, we rely on the "School Consent" exception under COPPA. We require schools to act as the parent's agent and provide verifiable consent before we collect any personal information from students under 13.
• Data collected under school consent is used exclusively for educational purposes and is never used for commercial purposes, marketing, or sold to third parties.
• Parents have the right to review their child's data and request its deletion by contacting their school administrator.

3.3 PIPEDA & Canadian Provincial Privacy Laws

• FN Immersive Innovation complies with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws (such as PIPA in Alberta/BC, and MFIPPA/FIPPA in Ontario).
• We ensure meaningful consent is obtained, either directly from mature students or via schools/parents for younger children, prior to data collection.

3.4 State Student Privacy Laws (e.g., SOPIPA, AB 1584)

We comply with comprehensive state student privacy laws, such as California's Student Online Personal Information Protection Act (SOPIPA). We do not use student data for targeted advertising, nor do we sell or rent student data under any circumstances.

3.5 PHIPA Compliance (Ontario, Canada - Health Information Protection)

FN Immersive Innovation does not collect Personal Health Information (PHI) and is not subject to PHIPA regulations. Should this change in the future, we will fully comply with Ontario's PHIPA requirements.

We take stringent, reasonable measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction.

• We utilize the Azure Cloud platform, adhering to industry-standard security practices including encryption for data at rest and in transit.
• While we employ robust safeguards, no method of transmission over the internet or electronic storage is 100% secure.
• Employees handling personal data are strictly trained in compliance and security protocols.
• All third-party service providers handling data on our behalf must comply with strict security obligations.

• FN Immersive Innovation does not sell, rent, or trade personal data to third parties under any circumstances.
• We only share data with essential third-party service providers (sub-processors, such as Microsoft Azure for cloud hosting) strictly for the purpose of delivering our educational services.
• All third-party sub-processors are bound by strict contractual agreements to protect student privacy and are prohibited from using the data for any other purpose.

• We retain only the minimum data necessary and store it only for as long as required to provide services, or as mandated by law.
• Customers (schools and organizations) have full control over student and employee data stored on our system.
• Upon the termination or expiration of a school contract, or upon direct request, personal data will be securely erased or anonymized within five (5) business days.
• Deletion requests can be submitted to fnii_info@fnimmersiveinnovation.com.

Users, and parents/guardians of students under 13 (coordinated through the school), have the right to:

• Access, update, correct, or delete their information.
• Withdraw consent for data collection and request restrictions.
• Opt-out of communications.

To exercise these rights, please contact your school administrator or reach out to us at fnii_info@fnimmersiveinnovation.com.

• Our software and services are not intended for independent use by children under 13 without verifiable parental or school consent.
• If we discover that personal information from a child under 13 was collected without appropriate consent, we will promptly delete it.

In the highly unlikely event of a data breach involving personal information, we will:

• Notify affected organizations (schools), users, and relevant regulatory authorities without unreasonable delay, and no later than 30 days (or sooner if required by specific state/provincial laws, such as within 7 days where applicable).
• Provide detailed information on the nature and extent of the breach, the data involved, and the mitigation steps taken.
• Take immediate action to secure the data and prevent further unauthorized access.

We may update this Privacy Policy from time to time to reflect changes in legal requirements or our practices. Any changes will be posted on our website or software, and the revised policy will indicate the effective date. We will notify school administrators of any material changes to this policy.

For any privacy-related inquiries, data access requests, or concerns, please contact us at:

Email: fnii_info@fnimmersiveinnovation.com

Website: www.fnimmersiveinnovation.com