Privacy Policy

This Privacy Policy describes how Airow ("Airow", "we", "us") collects, uses, discloses, and safeguards personal information when you use Edugo and its tools, including ClassNote AI (the "Service"). It is designed to comply with applicable Canadian privacy laws — including the Personal Information Protection and Electronic Documents Act (PIPEDA) and Quebec's Act respecting the protection of personal information in the private sector (Law 25) — and, where applicable, the EU General Data Protection Regulation (GDPR) and the UK GDPR.

1. Data Controller

Airow is the controller of personal information processed through the Service. You can reach us using the details in Section 13.

2. Information We Collect

• Account information: email address, display name, and authentication identifiers.
• Roster data: a student's first name and last initial only — no full names, contact details, or other identifying information.
• Notes and comments: classroom observations, draft report-card comments, and any text you choose to enter.
• Technical and usage data: IP address, device and browser information, log data, and basic analytics required to operate, secure, and improve the Service.
• Cookies and similar technologies: see Section 9.

3. Purposes and Legal Bases

We process personal information to (a) provide and operate the Service, including authentication and storage of your roster, notes, and comments; (b) generate AI-assisted drafts at your request; (c) maintain the security and integrity of the Service; (d) comply with legal obligations; and (e) communicate service-related notices. Where the GDPR applies, our legal bases are performance of a contract with you (Art. 6(1)(b)), our legitimate interests in operating and securing the Service (Art. 6(1)(f)), compliance with legal obligations (Art. 6(1)(c)), and, where required, your consent (Art. 6(1)(a)).

4. AI Processing

When you generate a comment, the relevant notes you select are transmitted to our AI inference provider for processing solely to produce your requested output. We instruct providers not to use your content to train their models and rely on contractual commitments to that effect. Outputs may contain inaccuracies; you remain responsible for reviewing them before use.

5. Data Sharing and Sub-processors

We do not sell personal information and do not engage in cross-context behavioural advertising. We share information only with vetted sub-processors that provide services on our behalf — including hosting, database, authentication, and AI inference providers — under written agreements that require appropriate confidentiality and security safeguards. We may also disclose information where required by law, legal process, or to protect rights, safety, and security.

6. International Transfers

The Service may be operated from, and your information may be processed in, countries other than your own, including Canada, the United States, and the European Union. Where personal data is transferred out of the European Economic Area, the United Kingdom, or Quebec, we rely on appropriate transfer mechanisms — such as the European Commission's Standard Contractual Clauses or equivalent — and conduct transfer-impact assessments where required.

7. Data Retention

We retain personal information for as long as your account is active and for a reasonable period thereafter to comply with legal obligations, resolve disputes, and enforce our agreements. When you delete content or your account, we remove the data from production systems promptly and from routine backups within thirty (30) days, subject to longer retention only where required by law.

8. Security

We implement administrative, technical, and physical safeguards appropriate to the sensitivity of the information, including encryption in transit, row-level access controls, principle-of-least-privilege access management, and audit logging. No method of transmission or storage is perfectly secure, and we cannot guarantee absolute security.

9. Cookies and Similar Technologies

We use cookies and local storage that are strictly necessary to operate the Service (for example, to keep you signed in and to remember your cookie preference). Where permitted, we may use limited analytics cookies only with your consent. You can change or withdraw your consent at any time by clearing site data in your browser. Where ePrivacy or equivalent rules apply, non-essential cookies are not set without your prior consent.

10. Your Rights

Subject to applicable law, you may have the right to (a) access your personal information; (b) correct inaccurate or incomplete information; (c) delete your information; (d) object to or restrict certain processing; (e) data portability; (f) withdraw consent where processing is based on consent; and (g) lodge a complaint with a supervisory authority — in Canada, the Office of the Privacy Commissioner of Canada or the Commission d'accès à l'information du Québec; in the EU/UK, your local data-protection authority. You can exercise most rights directly within the app; for others, contact us using the details in Section 13. We will respond within the timeframe required by applicable law.

11. Automated Decision-Making

The Service uses AI to generate drafts that you review before any use. We do not use the Service to make automated decisions that produce legal or similarly significant effects on individuals without meaningful human involvement.

12. Children's Privacy

The Service is intended for use by adult educators. It is not directed to children, and we do not knowingly collect personal information directly from children. The limited roster data you enter (first name and last initial) is processed on your authority as the educator responsible for that classroom and must comply with applicable school-policy and parental-notification requirements.

13. Contact and Data Requests

For privacy questions, requests, or complaints, contact Airow at airow.ca. If we cannot resolve your concern, you may contact the supervisory authority in your jurisdiction.

14. Changes to This Policy

We may update this Policy from time to time. Material changes will be communicated through the Service or by email. The "Last updated" date at the top of this Policy indicates when it was most recently revised.