Privacy Policy

Effective Date: August 1, 2025

1. Introduction

This Privacy Policy explains how InfiVista, Inc. (“we,” “us,” or “our”) collects, uses, discloses, and protects your personal information when you access or use CritiCoach (the “App”). By using the App, you agree to the collection and use of information in accordance with this Privacy Policy.

2. Information We Collect

We collect the following categories of information:

Account Information: First Name, Last Name, Email Address, and Password.
User-Generated Content: Messages, responses, or other data submitted through interactions with the AI tutor.
Performance Data: User scores, progress, feedback, or summaries generated by the App.
Usage Data: App activity, log data, session length, features accessed, and diagnostic logs.
AI Interaction Data: Inputs and outputs related to use of the AI services for training, quality assurance, or service improvement.

3. How We Use Your Information

Your information may be used for the following purposes:

To provide, operate, and maintain the App and AI features.
To personalize your learning experience and track progress.
To improve AI accuracy, content relevance, and feature functionality.
To analyze usage patterns and conduct internal research and development.
To detect, prevent, and respond to technical issues or security breaches.
To comply with legal obligations or enforce our Terms of Service.

4. Legal Basis for Processing (If Applicable)

If you are located in the European Economic Area (EEA) or other jurisdictions requiring a legal basis for processing, we process your data based on:

Your consent (Article 6(1)(a) GDPR).
Performance of a contract (Article 6(1)(b)).
Legitimate interests, such as product improvement and fraud prevention (Article 6(1)(f)).
Compliance with legal obligations (Article 6(1)(c)).

5. Data Sharing and Disclosure

We do not sell your personal data. However, we may share your information with:

Educational Institutions: If your account is managed through a school or district license, limited data may be shared with authorized school personnel.
Legal Authorities: When required by law, court order, or government request, or to protect our rights, safety, or property.

6. Children's Privacy

We do not knowingly collect personal information from children under the age of 13 unless such collection is in compliance with the U.S. Children’s Online Privacy Protection Act (COPPA) and conducted through verifiable parental or school-based consent. If we become aware that we have collected data from a child without appropriate consent, we will delete such data promptly.

7. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law. When data is no longer needed, it is securely deleted or anonymized.

8. Data Security

We implement appropriate technical, organizational, and administrative security measures to protect your information from unauthorized access, alteration, disclosure, or destruction. However, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

9. International Data Transfers

Your information may be transferred to and maintained on servers located outside of your jurisdiction, including in the United States. By using the App, you consent to such transfers. Where required by law, we use appropriate safeguards such as Standard Contractual Clauses to protect your data.

10. Updates to This Privacy Policy

We may update this Privacy Policy periodically. Material changes will be communicated via in-app notification or email. Continued use of the App after such changes constitutes your acknowledgment of the updated policy.