Preliminary version, not in force
This text is a draft under legal review. It doesn't apply yet and will be replaced by the approved version before launch.
DRAFT — NOT FINAL. NOT LEGAL ADVICE. DO NOT PUBLISH. This is a structural starting point for counsel to review and complete, grounded in what the product actually does as of 2026-10-23. Every bracketed
[TODO]is a fact only Hafid or counsel can supply. SeeREADME.mdin this folder for what each factual claim below is based on in the real code.
Privacy Policy (draft)
Last updated: [TODO — date of actual publication, not this draft]
Who we are
TutoLys is operated by [TODO — exact legal entity name, e.g. “BylTek Labs Inc.” — and its jurisdiction of incorporation]. You can reach us about privacy matters at info@tutolys.ca ([TODO — postal address]). [TODO — once Quebec Law 25 applies, name the designated person responsible for the protection of personal information (“responsable de la protection des renseignements personnels”) — this is a legal requirement, not optional, and none has been named yet].
What TutoLys is, and who it’s for
TutoLys is a learning platform for children in Quebec’s elementary curriculum (JK through grade 6). An adult — a parent/guardian, or a school on behalf of its students — creates and manages the account. A kid accesses the app on a device paired to that account by a one-time code; a kid never creates their own account, sets their own password, or provides information directly to us.
Information we collect
From the adult (guardian, tutor, or school administrator)
- Email address and password (stored as a cryptographic hash, never in plain text).
- Display name and preferred language, if provided.
- Organization information (household, solo-tutoring practice, or school) and your role within it.
- Subscription and billing status. We do not store your card number or other payment details — these are handled directly by our payment processor, Stripe; we retain only a Stripe-issued customer reference and subscription identifier.
About the kid, provided by the guardian
- A nickname — never the child’s full legal name.
- Grade level.
- Birth year only — never a full date of birth.
- A key identifying a bundled, pre-set avatar — never an uploaded photo or any image of the child.
- A record that you consented to this collection: the date/time, and which guardian account gave it.
Generated by the kid’s use of the app
- Which exercises were attempted, whether the answer was correct, how long it took, and whether a hint was used. This is used to compute progress indicators (mastery of a skill, play streaks) shown to the guardian or an authorized tutor — never shared outside the organization that created the kid’s profile.
- Device and session identifiers needed to keep this data correctly attributed and secure, not for tracking across other services.
Why we collect it
- To operate the core product: present age/grade-appropriate exercises, track progress against Quebec’s official curriculum (PFEQ), and show a guardian or tutor what a child has learned.
- To operate the account: authentication, billing, and support.
- To meet our own legal and security obligations (e.g., responding to a data-subject request, detecting abuse).
We do not use a child’s data for advertising, and do not sell personal information to any third party. [TODO — counsel to confirm this statement matches final business practice before publishing, especially if any analytics/advertising vendor is added later.]
Who we share it with
- Stripe (payment processing) — for guardians/schools on a paid plan. Stripe receives payment details directly; we never see or store them.
- SendGrid (transactional email) — to deliver account emails (invitations, password resets). SendGrid does not receive a child’s information, only the guardian’s email address and message content.
- A school’s own staff, if the account is a school organization — scoped to the students actually assigned to that staff member, not the whole school.
- [TODO — hosting/infrastructure provider, once Track C’s hosting decision is made. This affects where data is physically stored and which jurisdiction’s rules on cross-border transfer apply — must be filled in before publication, not left as a placeholder.]
We do not share a child’s information with any other party, and do not permit any processor to use it for their own purposes.
How long we keep it
- Raw gameplay event data is compressed after 30 days and permanently deleted after 24 months from when it was recorded.
- Account and profile data (guardian account, kid profile, progress summaries, reports) is kept for as long as the account is active, or until you request deletion (see “Your rights,” below).
- If you close your account, kid profiles are archived (hidden, not visible to anyone, but not yet erased) unless you specifically request erasure.
Your rights
As the guardian who manages a kid’s profile, you can:
- Access and export everything we hold about your kid — their profile, progress, and any reports generated — as a single downloadable file, from within the product (an organization administrator feature today; a self-serve guardian-facing surface in the website is not built yet — see Track F).
- Request erasure (“right to be forgotten”). This permanently deletes your kid’s raw gameplay history and anonymizes their profile (we keep enough of a record — with the personal details removed — to avoid corrupting a tutor’s or school’s own historical reports that reference it, rather than silently breaking them).
- Correct inaccurate information, by editing the profile directly.
- Withdraw consent at any time, which we treat as an erasure request.
To exercise these rights today, contact [TODO — support email/process — no self-serve guardian-facing flow exists yet outside an organization administrator].
Security
Passwords are never stored in plain text. Communication between our services uses short-lived, narrowly-scoped credentials rather than a long-lived shared secret, so that a credential used for one purpose (e.g., reading progress) cannot be reused for another (e.g., deleting data). [TODO — counsel/Hafid to add any further security commitments, and confirm against the hosting decision once made.]
Children’s privacy
This service is directed, in part, at children under 13, and is designed around that from the ground up: a child never creates their own account or provides information directly to us — only a verified adult does, and we require an explicit, logged consent action before any child profile is created. [TODO — counsel to confirm specific COPPA verifiable-parental- consent-method requirements are met by the current flow, and to address Quebec Law 25’s specific provisions for minors’ data, which differ in some respects from COPPA.]
Changes to this policy
[TODO — standard “we’ll notify you of material changes” clause, to be drafted by counsel alongside the final version.]
Contact us
[TODO — final contact details.]