Privacy Policy – Scolaro (Canada / Quebec)

Version: November 18, 2025

1. Introduction

At Scolaro (the "Platform"), we place great importance on protecting your privacy and personal information. This policy explains how we collect, use, disclose, and protect your information when you use Scolaro, particularly in a school context in Quebec and elsewhere in Canada.

By using Scolaro, you acknowledge that you have read this privacy policy and agree that it governs our processing of your personal information.

2. Data Controller and Privacy Officer

Data Controller
Scolaro SAS

Privacy Officer (Law 25 – Quebec)
Name: Louka Milani
Title: Chief Information Security and Privacy Officer

For any questions, requests for access, rectification, portability, or deletion of your personal information, or for any privacy-related complaints, please use the contact form available at:

https://scolaro.ca/contact.html

Requests sent via this form will be forwarded to the Privacy Officer.

3. Information We Collect

We only collect information necessary for the purposes described in this policy.

3.1 Registration Information

To create an account:

• First and last name
• Email address
• Password (stored in encrypted form)
• Status (teacher / student)
• Educational establishment (mainly for teachers and institutional accounts)

3.2 Pedagogical and Usage Data

As part of using the Platform:

• Tests, questionnaires, assignments, and evaluations created
• AI-generated questions adjusted by the teacher
• Student responses, exam copies, texts, and projects
• Grades, scores, feedback, and comments
• Time spent on activities and progression in evaluations
• Browsing history within the Platform (pages viewed, main actions)
• Account preferences (language, display options, class settings, etc.)

3.3 Technical Data

For security and technical operation purposes:

• IP address
• Browser type and version
• Operating system and device type
• Technical identifiers (session tokens, Firebase IDs, etc.)
• Error and activity logs
• Cookies and similar technologies (see Section 11)

4. How We Use Your Information

4.1 Service Provision

We use your information to:

• Create, manage, and authenticate your user account
• Enable the creation, distribution, and taking of tests and evaluations
• Generate questions, instructions, and feedback using artificial intelligence (AI)
• Automatically correct certain responses and calculate scores
• Display progress reports, results, and pedagogical analyses
• Provide technical support and respond to your assistance requests

4.2 Service Improvement and Product Development

We may analyze aggregated or pseudonymized data to:

• Understand Platform usage
• Improve our AI algorithms and response quality (e.g., statistically evaluating correction quality without focusing on a specific student)
• Develop new educational features
• Optimize Platform performance, ergonomics, and security

We strive to minimize the use of directly identifiable information (name, email, etc.) for these analytical purposes.

4.3 Communications

We may use your contact information to:

• Send important service-related notices (security, significant modifications, planned interruptions)
• Respond to requests sent via the contact form
• Inform teachers and school officials of significant Platform updates
• Send you, with your consent, information or marketing communications (newsletters, new features)

You can withdraw your consent to marketing communications at any time using the unsubscribe link or by writing to us at https://scolaro.ca/contact.html.

5. Legal Bases for Processing

Depending on the context, we process your personal information on the following bases:

• Performance of a contract: when processing is necessary to provide the Scolaro service (account creation, class management, test taking, corrections, etc.).
• Legitimate interest: to ensure Platform security, prevent abuse, improve service quality, manage technical incidents, and produce reasonable internal statistics.
• Consent: for certain uses, including marketing communications, specific cookies and analytics tools, as well as certain optional personalization features.
• Legal obligations: when applicable laws (Quebec, Canada, or other relevant jurisdictions) require us to retain or disclose certain information (e.g., in case of a legitimate request from a competent authority).

6. Sharing Your Information

We do not sell your personal information.

We may, however, disclose it in the following cases:

6.1 Service Providers

We use service providers for:

• Cloud hosting and databases (e.g., Firebase / Google Cloud)
• Artificial intelligence and content generation services (e.g., OpenAI)
• Analytics and audience measurement tools
• Support and communication tools

These providers process information only on our behalf and according to our instructions, under contractual agreements that provide for confidentiality, security, and personal information protection obligations.

6.2 Sharing with Educational Establishments

In a school context, certain data (grades, results, work, reports) are shared with:

• The teacher or authorized staff members
• Establishment or school board administrators who have adopted the Platform

This sharing is necessary for pedagogical management, evaluation, and student tracking. Establishments maintain their own responsibilities regarding personal information protection.

6.3 Legal Obligations and Rights Protection

We may disclose your information if required by law or if reasonably necessary to:

• Comply with a legal process, court order, or request from a competent authority
• Prevent or detect fraud, abuse, or a security incident
• Protect the rights, property, or security of Scolaro, our users, or the public

7. International and Out-of-Province Transfers

Your information may be hosted or processed in territories located:

• Within Canada
• Outside of Quebec
• Outside of Canada, notably in the United States (e.g., via Google Cloud or OpenAI)

Before making these transfers, we evaluate risks and implement appropriate protection measures, such as:

• Contractual clauses governing personal information protection
• Technical measures (encryption, minimization of sent data)
• Strict access controls

By using the Platform, you understand that your information may be subject to the laws of the territory where it is hosted, subject to the additional protections we implement.

8. Information Retention

We retain your personal information only for the duration necessary for the purposes for which it was collected, unless otherwise required by law.

As an indication:

• Account information: retained as long as the account is active. If the account is inactive, we may deactivate or anonymize it after a certain period, unless law requires longer retention.
• Pedagogical data (tests, results, work): retained for the duration agreed upon with the establishment or teacher, then deleted or anonymized.
• Technical and security logs: retained for a limited duration for security, traceability, and compliance purposes.

When data is no longer necessary, we delete or anonymize it securely.

9. Your Rights Regarding Personal Information

In accordance with laws applicable in Quebec and Canada, you notably have the following rights, subject to certain conditions:

• Right of access: obtain confirmation that we hold information about you and receive a copy.
• Right to rectification: have any inaccurate, incomplete, or equivocal information corrected.
• Right to deletion (right to erasure): request the deletion of certain information, when permitted by law (e.g., when the information is no longer necessary for the intended purposes).
• Right to portability: obtain certain information in a structured and commonly used format, when provided by law.
• Right to withdraw consent: when processing is based on your consent (e.g., marketing, certain cookies), you can withdraw it at any time.
• Rights regarding automated decisions: when we use automated processing (AI) to produce results or recommendations concerning you, you have the right to be informed of this use and to request that a person review the decision, as well as to obtain information on the main factors that led to this decision.

Exercising Your Rights

To exercise any of these rights, or to ask a question about the protection of your personal information, please use the contact form available at:

https://scolaro.ca/contact.html

We may ask you for additional information to verify your identity before responding to your request.

If you are a student using Scolaro in a school context, we may ask you to go through your educational establishment or teacher for certain requests, in accordance with the establishment's rules.

Complaints and Recourse

If you believe your rights are not being respected, you can file a complaint with:

• The Commission d'accès à l'information du Québec (CAI), if you reside in Quebec or if the school is located in Quebec
• The Office of the Privacy Commissioner of Canada, if federal privacy laws apply

10. Use of AI and Automated Decisions

Scolaro uses artificial intelligence to:

• Generate questions, instructions, and evaluation rubrics
• Propose automatic corrections for certain responses
• Produce automated feedback and progress analyses

These features aim to support teachers and students. Final decisions regarding grades, official evaluation, or orientation remain the responsibility of the teacher or establishment.

When results or feedback are produced automatically:

• They are clearly presented as generated by AI in the interface, where relevant.
• Teachers can always review, correct, or ignore these suggestions.
• Students and/or their parents can request a human review of a grade or feedback produced automatically by contacting the teacher or using the contact form.

11. Cookies and Analytics Tools

We use cookies and similar technologies to:

• Maintain your login session and ensure security
• Remember certain preferences
• Measure Platform usage and improve our services

Certain cookies are strictly necessary for the service's operation and cannot be deactivated without affecting Platform functionality.

Other cookies, notably those used for analytics (e.g., Google Analytics), are used only with your consent. You can:

• Give or refuse your consent to these cookies via our banner or preferences management module
• Modify your preferences at any time

You can also configure your browser to block certain cookies, although this may affect the functionality of certain features.

12. Minors and School Context

Scolaro is primarily used in a school context. Teacher accounts are generally created by adults acting within their professional capacity.

For minor students:

• Data may be collected and processed as part of a pedagogical project authorized by the educational establishment or school board.
• For students under 14 in Quebec, the establishment or teacher must ensure they have obtained parental consent or appropriate authorization when required by law.
• Parents or legal guardians can exercise rights regarding their children's personal information by contacting the establishment or writing to us at https://scolaro.ca/contact.html.

We do not knowingly ask a child to provide more information than is reasonably necessary to use the Platform for educational purposes.

13. Information Security

We implement reasonable technical and organizational security measures, adapted to the sensitivity of the information we process, including:

• Encryption of data in transit and, where possible, at rest
• Secure authentication mechanisms
• Role-based access controls (student, teacher, administrator)
• Logging and monitoring of certain activities to detect anomalies
• Regular backups and disaster recovery procedures

Despite these measures, no system is entirely free from incidents. In case of a privacy incident presenting a risk of serious injury, we will comply with notification obligations provided by law (notice to concerned persons and the Commission d'accès à l'information, when required) and maintain an incident registry.

14. Modifications to This Policy

We may update this privacy policy to reflect changes in our practices, services, or legal requirements.

In case of a significant modification, we will inform you via the Platform and/or by email, when possible. The update date will appear at the beginning of the policy.

We invite you to consult this policy regularly.

15. Contact

For any questions, requests, or complaints regarding personal information protection, please use the contact form available at:

https://scolaro.ca/contact.html

Messages will be handled by Louka Milani, Chief Information Security and Privacy Officer, or a designated person under their supervision.

Terms of Use – Scolaro (Canada / Quebec)

Version: November 18, 2025

1. Acceptance of Terms

By accessing and using the Scolaro platform, you agree to be bound by these Terms of Use (the "Terms"). If you do not accept these Terms, you must not use the Platform.

These Terms apply to all users, including:

• Teachers and educational staff members
• Students
• Representatives of educational establishments

2. Service Description

Scolaro is an educational platform that uses artificial intelligence to help teachers to:

• Create tests and evaluations
• Generate questions and evaluation rubrics
• Correct and analyze student responses

Students can:

• Access evaluations assigned to them
• Respond to questions and assignments
• Consult their results and certain automated or teacher-provided feedback

AI is used as an assistance tool. Teachers and establishments remain responsible for official evaluations, final grades, and all pedagogical decisions.

3. User Accounts

3.1 Account Creation

To use Scolaro, you must create an account and provide accurate, complete, and up-to-date information. You are responsible for the confidentiality of your credentials (email and password) and all activities performed under your account.

You agree to:

• Not share your credentials with third parties
• Promptly notify Scolaro of any unauthorized use of your account
• Update your information in case of changes

3.2 Account Types

• Teachers / educational staff: can create classes, tests, and manage student results. The establishment may require proof of your educational status.
• Students: access tests via a class code or an invitation provided by a teacher or establishment.
• Institutional accounts: can be created for schools, school service centers, or other organizations, with administration privileges.

3.3 Responsibility of Teachers and Establishments

Teachers and establishments who create student accounts or enter student data into Scolaro represent and warrant that they:

• Comply with applicable laws regarding personal information protection and school privacy (notably Law 25 in Quebec)
• Have obtained, where required, necessary authorizations or consents from parents, guardians, or students
• Only enter into Scolaro information necessary for the Platform's pedagogical use

4. Acceptable Use

4.1 Authorized Uses

You may use Scolaro to:

• Create, administer, or take evaluations in a legitimate educational context
• Consult pedagogical resources and result analyses
• Collaborate with teachers, students, or colleagues for educational purposes

4.2 Prohibited Uses

You agree not to use Scolaro to:

• Non-educational, illegal purposes or contrary to applicable laws
• Attempt to circumvent security measures or access data you are not authorized to
• Transmit, publish, or store content that is illegal, hateful, defamatory, violent, pornographic, or otherwise inappropriate
• Violate the intellectual property rights of third parties (texts, images, questions, etc.)
• Massively collect or export other users' data without authorization

In case of violation of these rules, we reserve the right to suspend or terminate your account, and take any appropriate measures.

5. Content and Intellectual Property

5.1 Content You Create or Upload

You retain intellectual property rights to the content you create or upload to Scolaro (questions, tests, responses, assignments, pedagogical resources), subject to pre-existing rights of third parties.

By uploading or creating content in Scolaro, you grant us a limited, non-exclusive, and free license to:

• Host, process, and display this content as part of the Platform's normal operation
• Reproduce and adapt it technically when necessary for the service (e.g., for formatting or internal indexing)

This license is strictly limited to service provision and does not authorize us to commercially exploit your content outside of Scolaro without your agreement.

5.2 AI-Generated Content

Questions, correction suggestions, or feedback generated by AI are made available to you for educational use. Depending on your status:

• As a teacher, you can freely modify, accept, or reject them, and integrate them into your evaluations.
• As a student, you understand that certain instructions or feedback may come from an AI system.

We recommend teachers review AI-generated content before using it in a formal evaluation context.

5.3 Scolaro Ownership

The Platform, its interface, its code, its structure, its logos, its predefined texts, and its AI technology are protected by copyright and other intellectual property rights. No ownership right is transferred to you outside the licenses expressly provided in these Terms.

6. Role of AI and Automated Decisions

Scolaro uses AI to assist teachers and students, notably for:

• Generating questions and texts
• Proposing corrections and scores
• Produiving pedagogical analyses and recommendations

Final decisions regarding official grades, summative evaluations, and student orientations:

• Must not rely exclusively on automated processing without appropriate human intervention
• Are the responsibility of the teacher or establishment

To the extent that a decision significantly affecting you is based on automated processing, you have the right to:

• Be informed of the use of AI
• Request that a person review the decision
• Obtain information on the main factors that led to this decision

Practical modalities for this review are exercised mainly via your teacher or establishment, or by contacting us via https://scolaro.ca/contact.html.

7. Personal Data and Privacy

The collection and use of your personal information within Scolaro are governed by our Privacy Policy. By using Scolaro, you declare you have read and accepted this policy.

In case of contradiction between the Terms of Use and the Privacy Policy regarding personal information protection, the Privacy Policy prevails.

8. Third-Party Services (Firebase, OpenAI, Analytics, etc.)

Scolaro relies on certain third-party services, including:

• Firebase / Google Cloud for hosting, authentication, and database
• AI Providers (e.g., OpenAI) for automated generation and correction
• Analytics Tools (e.g., Google Analytics) to measure and improve Platform usage

The use of these services is governed by contractual agreements aimed at protecting personal information. Some of these services may be located outside of Quebec or Canada.

Non-necessary cookies and analytics tools are used only with your consent, as described in the Privacy Policy and/or the cookie banner. You can withdraw this consent at any time.

9. Service Availability

We strive to make Scolaro available 24 hours a day, 7 days a week. However, we do not guarantee that the service will be free from interruptions, errors, or failures.

Temporary unavailability may occur, notably in case of:

• Planned maintenance or Platform evolution
• Technical incident or outage of our providers
• Force majeure or circumstances beyond our control

We will use reasonable efforts to limit the duration and impact of these interruptions.

10. Limitation of Liability

To the extent permitted by applicable laws:

• Scolaro is provided "as is", without express or implied warranty as to its accuracy, reliability, availability, or suitability for a particular purpose.
• We cannot be held liable for indirect, incidental, special, punitive, or consequential damages resulting from the use or inability to use the Platform.
• Our aggregate liability to you, for any claim related to the Platform, is limited to the total amount you directly paid us for service use during the twelve (12) months preceding the event giving rise to the claim, if any.

Nothing in these Terms limits liability that cannot be excluded or limited under applicable laws.

11. Termination

11.1 By You

You can stop using Scolaro at any time. You can also request the deletion of your account and personal information in accordance with the Privacy Policy by contacting us via https://scolaro.ca/contact.html.

11.2 By Us

We reserve the right to suspend or terminate your access to Scolaro, notably in case of:

• Violation of these Terms
• Attempt to circumvent security measures
• Abusive or fraudulent use of the Platform

To the extent possible, we will inform you prior to termination, except in case of serious violation or immediate risk to security or other users.

12. Modifications to Terms of Use

We may modify these Terms to reflect the evolution of our services, practices, or legal requirements.

In case of a significant modification, we will inform you via the Platform and/or by email, when possible. Your continued use of the Platform after the effective date of the new Terms constitutes your acceptance of these modifications.

If you do not accept the modified Terms, you must stop using Scolaro and, if applicable, request your account's deletion.

13. Governing Law and Dispute Resolution

These Terms and any claim or dispute arising from them are governed by and interpreted in accordance with:

• The laws of the province of Quebec
• The federal laws of Canada applicable in that province

Any dispute will be submitted to the exclusive jurisdiction of the courts located in the judicial district of Montreal (Quebec), subject to mandatory rules of jurisdiction.

14. Contact

For any questions regarding these Terms of Use or Platform operation, please contact us via the contact form available at:

https://scolaro.ca/contact.html

Requests can be handled by Louka Milani, Chief Information Security and Privacy Officer, or a designated person under their supervision.

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