---

Tuva Labs Inc. (“we” or “Tuva”) is dedicated to protecting your privacy.

Tuva WILL NOT sell, trade, or assign any unaggregated, personally-identifiable personal information that it collects to third parties outside of Tuva. If Tuva shares any such information with a third party, it will be in accordance with the terms of this privacy policy and for the limited purposes that we discuss below.

If you have any questions, concerns or comments regarding this privacy policy, you may contact us at the email and address posted at the end of this policy statement. We are committed to addressing your privacy or security questions or concerns.

1. Information Collected by Tuva

In order for a student to participate in Tuva’s K-12 Instructional Program at tuvalabs.com, and/or other Tuva products (the “Tuva Programs”), a parent or a legal guardian of that student or an authorized school official must first register on Tuva.

If you do not register at our website, you and your student(s) will not be able to use the Tuva Programs. This registration process will require you to provide your name, email address, your institution, and your role. Once you have registered, you may then sign up your student(s) for the Tuva Programs by providing each student’s first and last name.

We call this information “Registration Information.” We will also require a process to verify your consent to the registration of your student and to the collection of your student’s Registration Information.

When you and your student(s) participate in the Tuva Programs, Tuva will automatically collect information about usage, session data, and other information relating to choices and preferences, including that of your student or students. We call this information “Participation History.”

2. How Tuva will use the information collected from you

Email Address: Your email address may be used to send a confirmation email at registration, as well as information and updates to the Programs. In some cases we will also email your student’s personal reports to you, with further information about the progress your student is making on the Programs. We may use the email address as an additional means of communicating with you about the Tuva Programs, including notifying you of updates to the Web Site or its related policies.

Student’s Name: Your student’s name will be used to customize your student’s participation in the Programs, as well as to personalize the reports and updates about your student’s progress in the Programs.

Secondary Uses: Registration Information & Participating History may be used by us for customer support, marketing, development, and other operations and business purposes, including improvements to the Tuva Programs.

Tuva WILL NOT sell, trade, or assign any unaggregated personal information that it collects to third parties outside of Tuva.

3. Information Tuva collects directly from your student

Tuva collects information directly from your student, over the internet, in the form of the interactions that your student makes when participating in the Tuva Programs.

We refer to the data resulting from such participation, which includes but is not limited to data on when your student starts and stops an activity, lesson, or task, the responses your student makes to questions asked, the timing of your student’s responses, the datasets that your student uploads, and the graphs and charts that your student creates as “Performance Data.”

We will use Performance Data for educational purposes only, including to (1) measure your student’s performance in each lesson of the Tuva Programs, (2) analyze your student’s Performance Data, and provide you with periodic progress reports about your student’s performance in the Tuva Programs, (3) conduct educational research on teaching, learning, and assessment, and (4) improve the Tuva Programs.

If we ever need to collect information that is not Performance Data directly from your student, Tuva will seek your authorization prior to collecting such additional information from your student. In addition, we may aggregate your student’s Performance Data with the Performance Data of other students participating in the Programs for marketing and other business related purposes. Aggregate information will be ANONYMOUS and will not identify your student.

4. Opting-out of providing the information we request

Because the Tuva Programs are individualized and customized for each student, all the information we request from you and your student is required for you and your student to participate in the Programs, with the exception of certain information to be used for our marketing purposes to you only.

At any time, you may revoke your consent to allowing your student to participate in the Tuva Programs or refuse to allow Tuva to further use or collect your student’s personal information.

Any ANONYMOUS performance data will be retained, but we will no longer use any identifiable information regarding you or your student that you have provided. However, if you do any of the foregoing, you and your student will not be able to participate in the Programs.

5. Reviewing and changing your information

You may review and modify your Registration Information at any time by accessing our website using your password.

6. Consent

We will require you to review and submit consent as a parent, legal guardian, or an authorized school official as part of the registration process, which will require you to consent to our collection and use of information directly from your student over the Internet as described above.

7. Password Protection

You will be asked to select a password to access the Tuva Programs through our website, and this password will be used to allow your student to use the Tuva Programs. Your password should be kept confidential. Your password will also allow you to review and change the information we collect about you and your student or students.

8. Protecting your information

No data transmissions over the internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. Tuva has multiple security measures in place to protect the loss, misuse or alteration of information under our control.

Please note that the Tuva Programs is hosted in the United States. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your personal data to the United States, which does not have the same data protection laws as the EU or other regions and by providing your personal data you consent to the use of your personal data for the uses identified above in accordance with this Privacy Policy; and the transfer of your personal data to the United States as indicated above.

9. Your information and third parties

Except as provided in this Privacy Policy, Tuva WILL NOT disclose the information that it obtains from you to third parties without your express written permission, or where we believe, in good faith, that the law requires us to disclose the information.

Tuva WILL NOT sell, trade, or assign any unaggregated personal information that it collects to third parties outside of Tuva. We, however, may aggregate the information that we collect from users of our website to create demographic and performance profiles regarding the progress of students who use the Tuva Programs.

Tuva may share aggregated information with educational research organizations or potential investors. This aggregated information will be compiled and reported in the form of ANONYMOUS group statistics only.

In addition, in order to offer and improve the Programs, Tuva may share Registration Information about the parents, legal guardians, and school officials that register to participate in the Programs, along with such registrants’ Participation History, to contractual business partners of Tuva that are directly involved in the sale, distribution, operation, maintenance, and support of the Programs on behalf of Tuva.

Notwithstanding anything to the contrary, as Tuva continues to develop its business, it might sell some or all of its assets. In such transactions, customer information is generally one of the transferred business assets. An acquiring company would be required to protect all information that Tuva collects from users of our website and Programs in accordance with the terms of this Privacy Policy.

10. Unsolicited third-party promotional emails

Tuva will not send you unsolicited third-party promotional emails.

11. Use of cookies

As a standard practice, Tuva uses “cookies”. A cookie is a small amount of data sent to your browser from our web server and stored on your computer, then sent back to the server by your browser each time you access our website.

Cookies enable us to track usage of our website. In addition, cookies are required for the operation of the Programs. Please note that if you refuse the Tuva cookie (by turning cookies off in your browser or by clicking “don’t accept” if you have set your browser to warn you before accepting cookies), our Programs will not work.

Cookies cannot be used to gather personal information from your computer.

12. Children’s Online Privacy Protection Act

Congress has enacted a law called the Children’s Online Privacy Protection Act of 1998 (COPPA) which is designed to protect children’s privacy during use of the Internet. Tuva has implemented practices consistent with the guidelines provided by the Federal Trade Commission to date.

Tuva will never knowingly request personally identifiable information or private content from anyone under the age of 13 without parental consent. If you subscribe to our Programs, provided you are 18 years of age or older, you will be asked, at the time of registration, whether you consent to allowing users under the age of 13 to use your subscription and to be subject to this Privacy Policy.

If we receive this consent, we may receive personal information from children under the age of 13 listed on your subscription account in order to provide our Programs and services to them. Tuva DOES NOT SHARE CHILDREN’S PERSONALLY IDENTIFIABLE INFORMATION WITH THIRD PARTIES.

You may, at any time, revoke your consent to allow your student to use the Programs under your subscription, refuse to allow Tuva to further use or collect your student’s personal information, or direct Tuva to delete all identifiable information regarding your student that you have provided. To do so, please contact our Privacy Officer at the contact information below. However, if you do any of the foregoing, your student will not be able to use the Programs.

If you would like more information about COPPA, please go tohttp://www.ftc.gov/ogc/coppa1.htm.

13. The Children’s Internet Protection Act

The Children’s Internet Protection Act (CIPA) is a federal law enacted by Congress in December 2000 to address concerns about access to offensive content over the Internet on school and library computers. CIPA imposes certain types of requirements on any school or library that receives funding support for Internet access or internal connections from the “E-rate” program — a program that makes certain technology more affordable for eligible schools and libraries. Our Programs do not provide links to external resources or chat rooms, and do not contain any offensive or inappropriate matter. As a result, any school or library that uses Tuva Programs will be fully compliant with CIPA. If you would like more information about CIPA, please go to http://www.fcc.gov/cgb/consumerfacts/cipa.html.

14. The Family Educational Rights and Privacy Act

The Family Educational Rights and Privacy Act (FERPA) is a Federal law that protects the privacy of student education records. The law applies to all schools that receive funds under an applicable program of the U.S. Department of Education.

FERPA gives parents certain rights with respect to their children’s education records. These rights transfer to the student when he or she reaches the age of 18 or attends a school beyond the high school level.

Tuva is fully compliant with FERPA. Specifically:

• Any sensitive online information is transmitted over secure channels.
• All student data are stored in ways that are not publicly accessible.
• Security audits are regularly performed to ensure data integrity.

Tuva does not share student information with any third parties. If a school requests that student data should be sent to a third party, with parental consent, Tuva would send the data to the school and never directly to the third party.

If you would like more information about FERPA, please go to http://www.ed.gov/policy/gen/guid/fpco/ferpa/index.html.

15. Amendments

Tuva may amend this Privacy Policy from time to time. We will notify you by email regarding any material changes to our privacy and security practices. Please review all revisions to the Privacy Policy. Your continued use of our website(s) and the Programs after the date Tuva has emailed such notices will be deemed to be your agreement to the changed terms.

16. Contact Us

If you have any questions about your privacy or security measures at Tuva, please contact our Privacy Officer:

Tuva Labs Inc.

222 Broadway, 19th Floor

New York, NY - 10033

(646) 481-2150

Or email us at hello@tuvalabs.com

Last Updated: June 1, 2023