1. Introduction
2. Information We Collect
3. How We Use Information
4. How We Share Information
5. International Data Transfers
6. Children's Privacy and Parent Rights (COPPA)
7. State, Provincial and National Privacy Rights
8. Cookies and Tracking
9. Data Retention
10. Data Security
11. Do Not Track and Global Privacy Control
12. Changes to This Policy
13. Contact Us

01Introduction

Wys-Peer is operated by XIVB Education LLP, a Limited Liability Partnership incorporated under the laws of India, having its registered office at Delhi , India ("Wys-Peer," "we," "us," or "our"). We provide online small-group mathematics tutoring to children residing in the United States and Canada. This Privacy Policy explains what personal information we collect, how we use it, with whom we share it, and the rights and choices you have. It applies to wyspeer.com (the "Website"), our tutoring services, our email and WhatsApp communications, and any other Wys-Peer service that links to this Policy.

Because our Services are designed for children aged UKG (kindergarten) through Grade 8, a significant portion of our users are under the age of 13. We treat the personal information of these children with the heightened care required by the United States Children's Online Privacy Protection Act (COPPA), the Digital Personal Data Protection Act, 2023 of India (the "DPDP Act"), and analogous protections under Canadian and US state law. Section 6 of this Policy is dedicated specifically to the rights of Parents under COPPA.

By using our Services, booking a demo, or enrolling a child, you confirm that you have read and understood this Policy.

02Information We Collect

2.1 Information you provide directly (Parent)

When you book a demo, enroll a Student, communicate with us, or use our Services, we collect:

• Parent name, email address, and mobile phone number
• Country, state/province, and time zone
• Information about your child (see Section 2.2 below)
• Payment information processed exclusively by Razorpay, our authorized payment processor. We do not store full credit card numbers, CVVs, or banking credentials on our servers.
• Communications you send us (email, WhatsApp messages, demo notes, support tickets)
• Marketing source attribution if you tell us how you heard about us

2.2 Information about the Student (your child)

With your verifiable consent (see Section 6), we collect:

• Student first name and last initial (used during class to address the Student)
• Student age, current grade, and applicable Grade Band (UKG–G3, G4–6, or G7–8)
• Areas of mathematical strength and challenge, identified during the diagnostic demo
• Session attendance, completion of in-session activities, and teacher observations on conceptual understanding
• Audio and video of the Student during live Sessions (transmitted via Google Meet; see Section 2.3 on recording)
• Worksheet responses and assessment outcomes submitted during or after Sessions

2.3 Session recordings

Live Sessions are conducted via Google Meet. We may record Sessions for the limited purposes of (a) teacher quality assurance, (b) training new teachers, and (c) sharing a specific Session recording back to a Parent on request. Recordings are stored on access-controlled cloud storage (Google Workspace) for a maximum of ninety (90) days and are then deleted. Parents may opt out of recording for their child at any time by emailing privacy@wyspeer.com.

2.4 Information collected automatically

When you visit our Website, we automatically collect limited technical information necessary for the Website to function and for us to improve it:

• IP address (used for security and to infer broad region, not stored against child records)
• Browser type, operating system, and device type
• Pages visited, time spent, and referring URL
• Cookie identifiers (see Section 8)

We do not use behavioral advertising cookies or third-party advertising trackers on pages directed to children.

2.5 Information we do not collect

To minimize risk, we have explicitly chosen not to collect:

• Government-issued identifiers (Social Security Number, Aadhaar, SIN, passport number, driver's license)
• Precise geolocation (GPS-level location)
• Biometric data (facial recognition, fingerprints, voiceprints)
• School records, transcripts, or report cards (unless you voluntarily share them and ask us to)
• Health or medical information
• Race, religion, sexual orientation, caste, or other sensitive categories

03How We Use Information

We use the information we collect for the following purposes, and only these purposes:

• To schedule and deliver tutoring Sessions (including matching the Student to an appropriate Batch and teacher)
• To prepare diagnostic summaries and progress reports for the Parent
• To communicate with the Parent about scheduling, payments, makeup classes, and Service updates
• To process enrollment payments through Razorpay
• To improve our curriculum and teaching methods (using aggregated, de-identified data wherever possible)
• To train and quality-assure our teachers (using Session recordings)
• To respond to support requests and resolve disputes
• To comply with legal obligations under Indian, US, and Canadian law and to protect our legal rights
• To send the Parent (not the Student) occasional educational content, tips, and announcements — you may unsubscribe at any time

04How We Share Information

We share personal information only in the limited circumstances described in this Section. We do not sell personal information under any definition of "sale" in any United States state, Canadian provincial, or Indian law.

4.1 Service providers

We share information with carefully selected third-party service providers who help us deliver the Services. These providers are contractually bound to use the information only as directed by us and consistent with this Policy. Our current providers include:

Google Workspace (Google LLC) Email, calendar, video classes (Meet), document storage Parent and Student name, email, Session video and audio, calendar invites Razorpay (Razorpay Software Pvt Ltd) Sole authorized payment processor for all enrollment fees Parent name, email, billing address, card data (processed by Razorpay, not stored by us) Emergent CMS Website hosting, Lead CRM, content management Parent and Student name, contact details, enrollment status WhatsApp (Meta Platforms Inc.) Parent communication channel Parent name, mobile number, message content (only on Parent's initiation)

4.2 Teachers

Wys-Peer teachers, including independent contractors operating from India, receive access to limited Student information necessary to deliver instruction: Student first name and last initial, age, grade, current Level, recent Session notes, and identified areas of strength and challenge. Teachers are contractually bound to confidentiality and may not use Student information for any purpose other than instruction.

4.3 Legal compliance

We may disclose personal information if required to do so by law, court order, subpoena, or government request from Indian, US, or Canadian authorities, or if we believe in good faith that disclosure is necessary to protect our rights, the safety of any person, or the integrity of the Services. Where legally permitted, we will notify the Parent before disclosing child information in response to such a request.

4.4 Business transfers

If XIVB Education LLP is involved in a merger, acquisition, asset sale, restructuring, or financing, personal information may be transferred to the successor entity, subject to the protections of this Policy. Parents will be notified of any such transfer and offered a meaningful opportunity to delete their child's information before the transfer takes effect.

4.5 With your consent

In all other cases, we share personal information only with your explicit consent.

05International Data Transfers

By enrolling your child, you provide informed consent to the international transfer of your child's personal information to India for the purpose of receiving the Services. You may withdraw this consent at any time under Section 6.3, in which case Services will terminate and any refund will be processed under our Refund Policy.

06Children's Privacy and Your Rights as a Parent (COPPA)

This Section applies to all Students under the age of 13 and is required by the United States Children's Online Privacy Protection Act (COPPA). It also describes the rights we extend, by Wys-Peer policy, to all Students under the age of 18 regardless of jurisdiction, in alignment with the heightened protections for children under India's Digital Personal Data Protection Act, 2023.

6.1 Verifiable parental consent

Before we collect any personal information from a child under 13, we obtain verifiable consent from the Parent. We use the following consent methods, which are recognized by the FTC as permitted methods under COPPA:

• Monetary transaction method: At enrollment, the Parent provides a valid payment card through Razorpay. The associated bank or card network independently verifies the Parent's identity, and a monetary transaction is processed. This is the "monetary transaction" method of verifiable parental consent under 16 CFR §312.5(b)(2)(iii).
• Email plus method: Where no monetary transaction is involved (for example, for the free demo), we use the "email plus" method: the Parent provides consent by email, and we follow up with a confirmation message to the same email and require a second confirmation step before any Student information is collected.

6.2 Direct notice to Parents

Before collecting child information, we provide Parents with a clear, plain-language notice describing what we collect, how we use it, and the Parent's rights. That notice is reproduced in summary form below; the full notice is sent by email at the time of enrollment.

6.3 Your rights as a Parent

To exercise any of these rights, email privacy@wyspeer.com from the email address on file. We will respond within thirty (30) days. We may need to verify your identity before processing the request; this is to protect your child from unauthorized requests.

6.4 No conditioning

We will not condition any Student's participation in any Wys-Peer activity on the disclosure of more personal information than is reasonably necessary for that activity.

6.5 No behavioral advertising to children

We do not use the personal information of children for behavioral or targeted advertising. We do not allow third parties to collect personal information from children on our Services for their own purposes. This commitment also aligns with the prohibition under India's DPDP Act, 2023 on behavioural tracking of children and targeted advertising directed at children.

6.6 Operator information

For the purposes of COPPA, the operator collecting personal information is:

• XIVB Education LLP
• Ashok Vihar, Delhi, North West Delhi, India
• Privacy contact: privacy@wyspeer.com

07State, Provincial and National Privacy Rights

7.1 California residents

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), including:

• Right to know what personal information we collect, use, disclose, and sell
• Right to delete personal information
• Right to correct inaccurate personal information
• Right to opt out of "sale" or "sharing" of personal information — note: Wys-Peer does not sell or share personal information as those terms are defined under CCPA
• Right to limit use and disclosure of sensitive personal information
• Right to non-discrimination for exercising these rights

California minors under 16 have an additional right of consent for any sale or sharing of their information. We do not sell or share child information, so this right is preserved by default. To exercise CCPA rights, email privacy@wyspeer.com.

7.2 Other US states

Residents of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Tennessee, Indiana, Delaware, and other states with applicable privacy laws have analogous rights. We extend the rights described in this Policy to all US residents regardless of state.

7.3 Canadian residents

If you reside in Canada, you have rights under the federal Personal Information Protection and Electronic Documents Act (PIPEDA), and, where applicable, provincial laws including Quebec's Law 25, Alberta's PIPA, and British Columbia's PIPA. You have the right to access your child's personal information, request correction, withdraw consent, and lodge a complaint with the Office of the Privacy Commissioner of Canada. Email privacy@wyspeer.com to exercise these rights.

7.4 Indian residents (applicable to staff and Indian-resident users)

To the extent the Digital Personal Data Protection Act, 2023 applies, Indian residents (including XIVB Education LLP staff whose data we process, and any Indian-resident user) have the right to access, correct, and erase their personal data, the right to nominate a representative, and the right to grievance redressal. Our designated grievance officer is reachable at privacy@wyspeer.com. If unresolved, complaints may be escalated to the Data Protection Board of India once constituted under the Act.

08Cookies and Tracking Technologies

We use a minimal set of cookies and similar technologies. We do not use behavioral advertising cookies on any page directed at children.

Strictly necessary cookies

These cookies are essential for the Website to function (for example, to remember whether you are signed in to the Parent dashboard). They cannot be disabled.

Analytics cookies

We use privacy-respecting analytics to understand how Parents use our Website. Analytics cookies are not placed on Student-facing pages. You can opt out of analytics cookies via the cookie banner shown on first visit, or by adjusting your browser settings.

No third-party advertising

We do not use Google Ads, Meta Pixel, TikTok Pixel, or any other behavioral advertising technology on our Website.

09Data Retention

We retain personal information only for as long as necessary to provide the Services, comply with legal obligations under Indian, US, and Canadian law, resolve disputes, and enforce our agreements.

Lead information (Parents who book a demo but do not enroll) 24 months from last contact, then deleted Active student records (enrolled Students) Duration of enrollment + 12 months Inactive student records (completed or terminated) 36 months, then deleted or de-identified Session recordings 90 days, then automatically deleted Payment records 8 years (Indian Companies Act and Income Tax Act retention requirements) Support communications 24 months from last interaction

You may request earlier deletion at any time under Section 6.3. Where Indian statutory retention obligations (such as those under the Income Tax Act, 1961 or the Companies Act, 2013) require us to retain certain records, we will retain only the minimum required information for the minimum required period.

10Data Security

We use commercially reasonable physical, technical, and organizational measures to protect personal information, including:

• Encryption of data in transit (TLS 1.2+) and at rest where supported by the platform
• Access controls limiting personal data to staff who need it for their role
• Multi-factor authentication for administrative access to our systems
• Regular review of third-party service providers' security practices
• Background verification for all teaching staff before they receive access to Student information
• Mandatory privacy, COPPA, and DPDP Act training for all staff and teachers

No system is perfectly secure. In the event of a data breach involving personal information, we will notify affected Parents and applicable authorities (including the FTC, relevant state Attorneys General, the Office of the Privacy Commissioner of Canada, and the Data Protection Board of India as applicable) as required by law.

11Do Not Track and Global Privacy Control

Our Website honors the Global Privacy Control (GPC) signal. When we detect a GPC signal from your browser, we treat it as an opt-out of any "sale" or "sharing" under applicable state law. We do not currently respond to legacy "Do Not Track" browser signals, as no industry standard for response has been established.

12Changes to This Privacy Policy

We may update this Policy from time to time. If we make a material change — for example, a change in the categories of information we collect or how we use it — we will notify Parents by email at least thirty (30) days before the change takes effect, and we will obtain renewed verifiable parental consent where required by COPPA. The "Effective Date" at the top of this Policy reflects the most recent update.

13Contact Us

For any privacy question, request, or complaint, contact our Privacy Lead:

If you believe we have not adequately addressed your privacy concern, you have the right to lodge a complaint with the relevant regulator: the United States Federal Trade Commission (ftc.gov), your state Attorney General, the Office of the Privacy Commissioner of Canada (priv.gc.ca), your provincial privacy authority, or the Data Protection Board of India once constituted under the DPDP Act, 2023.

— End of Privacy Policy —