Privacy Policy

1.1 Controller. Explanova LLC, a Virginia limited liability company, is the data controller for information collected through the Service. For mailing correspondence, see Section 13 (Contact Information).

1.2 Covered Services. This Policy applies to:

• The Explanova website at https://explanova.ai
• The Explanova parent dashboard at https://explanova.ai
• Related features including homework help, avatar video lessons, practice sessions, and account management
• Communications sent from @explanova.ai or explanovasupport@gmail.com

1.3 Not Covered. This Policy does not apply to third-party websites or services linked from the Service, which have their own privacy policies.

2.1 Parents Hold Accounts. All Explanova accounts are held by parents, legal guardians, or school-authorized adults aged 18 or older. Children do not register for or directly authenticate to the Service.

2.2 Child Profiles Are Sub-Profiles. A parent may create one or more child profiles under their account to personalize educational content. Child profiles are not independent accounts. They do not have login credentials. They are created, modified, and deleted solely at the discretion of the parent.

2.3 Verifiable Parental Consent. We obtain verifiable parental consent in two steps, an affirmation and an emailed acknowledgement:

• At account creation, the parent affirms that they are the parent or legal guardian of any child for whom they create a profile, and accepts this Privacy Policy and the Terms of Service. On the Explanova web dashboard, this affirmation is asked for on every route that creates a family, including an account created by signing in with Google or Apple for the first time. In our iOS and Android apps it is asked for on the sign-up form, and we are extending it to the one remaining route, a first-time sign-in with Google or Apple, in an app update. Where an account was created without being asked, we record that no affirmation was given rather than recording one that was not.
• Explanova then emails the parent, at the email address on the account, a one-click acknowledgement link.
• The parent clicks that link. We record the click, the time of it, the method, and the version of this Policy in force, and that record is the account's record of verifiable parental consent. Until it is clicked, no child profile can be created and no information about a child is collected, used, or disclosed. The one exception, which applies when we could not deliver that email because of a failure on our side, is described below.

After the parent clicks the link, we send them a second, confirmatory email recording that consent was given and explaining how to revoke it. That email follows the acknowledgement rather than gating it: the parent is not asked to do anything with it, and it is not a condition of creating a child profile.

Taken together, these steps are the "email plus" method of obtaining verifiable parental consent, which the FTC's COPPA Rule permits at 16 C.F.R. § 312.5(b)(2). Consent is obtained under the Children's Online Privacy Protection Act (COPPA), 15 U.S.C. § 6501 et seq., and the FTC's COPPA Rule, 16 C.F.R. Part 312, as amended effective April 22, 2026.

This process applies to accounts created on or after September 4, 2026. Accounts created before that date were created under the process described in the previous version of this Policy, which did not include the emailed acknowledgement step. We are not asking those parents to complete that step now, and it is not applied to their existing accounts.

If the acknowledgement link is not used, no child profile can be created, and we send one reminder to the same address. We do not close an account for missing that reminder. An account that never completes this step is eventually removed under the retention schedule in Section 8, and never before that reminder has actually been sent. The account holder can request a fresh acknowledgement link at any time from Crew Settings. Each link is single use and expires 24 hours after it is sent.

If we cannot deliver the acknowledgement email, we record the delivery failure and the reason for it. A failure on our side, such as an outage at the service we use to send mail, is recorded separately from a rejection of the address on the account, because the two are not the same thing and only one of them is ours to fix. When the failure is ours, we do not block the account for it: child profile creation stays available for a limited period while we retry. A rejection of the address on the account is not a failure on our side, and in that case the acknowledgement link still has to be used. If the address on the account is permanently rejected, or there is no address on the account at all, we stop offering to send the link again, we say so in the account, and we give a support address to write to from an inbox that does work. A person reads that mailbox and replies; there is no automatic way to complete this step once the address on the account cannot be reached. Keeping a working email address on the account is what makes this step possible.

4.1 Educational Service Delivery. To generate explanations, practice problems, and avatar lessons tailored to the child's grade band and question.

4.2 Account and Billing. To authenticate parents, process subscriptions via Stripe, and send transactional emails.

4.3 Service Improvement. To improve curriculum quality, fix bugs, and measure engagement using de-identified or aggregated metrics.

4.4 Security and Compliance. To detect fraud, unauthorized access, abuse, and legal violations; and to comply with applicable law.

4.5 Communication with Parents. To send service announcements, product updates, and support responses.

6.2 Legal Obligations. We may disclose information when required by law. We will notify parents unless legally prohibited.

6.3 Business Transfers. If Explanova is acquired or merged, personal information may transfer to the successor entity. We will notify users in advance.

6.4 Aggregated or De-Identified Data. We may share aggregated, de-identified data that cannot reasonably be used to identify an individual.

6.5 Optional YouTube Recommender (Beta). When you opt into the optional YouTube Recommender feature (currently in beta and default-off until you explicitly enable it for your session), Explanova may submit a server-side request to the YouTube Data API v3 search.list endpoint to discover educational video candidates matching the topic of the homework problem you just solved. The only data we send to YouTube is: (a) the parsed problem topic, (b) the learner's grade band, and (c) an optional method/strategy label. We do NOT send your name, email, IP address, Firebase Auth identifier, family ID, child ID, payment information, or any other personally identifiable information to YouTube. YouTube candidates are filtered through SafeSearch=strict and a separate server-side moderation pass before any title or thumbnail is shown to you. The video plays inside Explanova using YouTube’s own embedded IFrame player, and you can also open it directly on youtube.com. In our mobile apps that same YouTube player is loaded through a small Explanova-hosted page (explanova.ai/yt-embed.html) whose only purpose is to give the player a valid web origin; it performs no tracking of its own. Explanova does not download, transcode, rehost, modify, or play YouTube content in a custom player. Candidate metadata (titles, channel names, thumbnail URLs) is cached in our database for up to 24 hours and is then deleted automatically by a database time-to-live policy; we do not build a per-user YouTube viewing history. YouTube's handling of any data we submit is governed by the YouTube API Services Terms of Service and the Google Privacy Policy.

7.1 Technical Safeguards. We implement industry-standard safeguards:

• All data in transit is protected by TLS 1.2 or higher
• Authentication uses OAuth 2.0 with Sign in with Apple and Google Sign-In
• Firestore security rules restrict data access to the owning parent account
• Homework photos and live voice audio are processed transiently to generate the explanation and are not persisted to storage; only the text of problems and explanations is retained, per the schedule in Section 8
• Secrets and API keys are managed via Google Secret Manager
• Firebase App Check is initialized on the client as a defense-in-depth signal
• Audit logs are maintained for sensitive operations

7.2 Organizational Safeguards. Access to personal information is limited to personnel with a legitimate business need, under confidentiality obligations.

7.3 Breach Notification. In the event of a security breach, we will notify affected parents and applicable authorities within the timeframes required by law (including 72 hours where required by GDPR Article 33).

9.2 California Residents (CCPA / CPRA). Additional rights under California privacy law including the right to know, delete, opt out of sale/sharing (we do not sell or share), and non-discrimination.

9.3 Virginia Residents (VCDPA). Rights under the Virginia Consumer Data Protection Act including access, correction, deletion, portability, and opt-out of targeted advertising (we do not engage in targeted advertising).

9.4 Other U.S. State Privacy Laws. Residents of Colorado, Connecticut, Utah, Texas, Oregon, and other states have substantively similar rights.

9.5 EEA / UK / Switzerland. Legal basis: contractual necessity, consent, or legitimate interests. You have the right to lodge a complaint with your data protection authority.

11.2 No Third-Party Advertising Trackers. We do not use Facebook Pixel, Google Ads conversion tracking, TikTok Pixel, or similar advertising trackers. We do not allow third parties to track users across the Service.