Privacy Policy

Tutterra Ltd. ("Tutterra", "we", "us") provides an educational platform designed for language learning, guided conversation, and safe interaction between students. This Privacy Policy explains how we collect, use, and protect personal information—including information relating to children under 18—when using our mobile application ("App") or website (“Platform”).

This Policy complies with:

• Google Play Families Policy Requirements
• GDPR
• Israeli Privacy Protection Law
• COPPA principles (if applicable)

By using the Platform, you consent to this Policy.

1. Information We Collect

We collect only the minimum information required to provide the App’s educational services.

1.1 Information Provided by Users or Parents

• Full name
• Username
• Age or date of birth (to enable age-appropriate features)
• Profile photo (optional / required for safety verification)
• Language preferences and learning level
• Interests and hobbies (optional)
• Parent/guardian name and contact details
• Billing information (processed via secure third-party payment providers; we do not store full credit card numbers)

1.2 Audio/Video/Communication Data

With explicit parental consent:

• Live audio and video during learning sessions
• Session recordings (only when enabled)
• Speech-to-text transcripts
• AI-generated educational feedback
• Messages or communication submitted through the Platform

We do not use audio or video content for advertising or for any purpose unrelated to providing the service.

1.3 Automatically Collected Data

• Device type, operating system, and browser
• IP address (for security and regional matching only)
• Connection quality statistics
• Crash logs and performance analytics
• Authentication and session data

1.4 Cookies and Local Storage

Used only for:

• Login and authentication
• Security
• Internal analytics
• Performance optimization

We do not use cookies for advertising, tracking across apps/sites, or profiling.

1.5 Safety & Moderation

We may collect:

• Reports of abuse or misconduct
• Security alerts
• Automated content flags

These measures are necessary to maintain a safe environment for minors.

2. Purpose of Data Processing

We use information exclusively for:

• Delivering educational and tutoring services
• Matching learners with appropriate partners
• Providing feedback and improving learning outcomes
• Securing and monitoring the Platform
• Preventing misuse, fraud, or harm
• Complying with legal and regulatory requirements
• Improving performance and functionality through internal analytics

We do not:

• Serve personalized ads
• Sell data
• Profile children for behavioral advertising
• Share data with advertisers

This App complies with Google Play Families Policy – No Ads, No Tracking.

3. Third-Party Service Providers

We use select third-party processors to support platform functionality (e.g., cloud hosting, secure video infrastructure, speech-to-text).

All service providers are:

• Bound by strict contractual data protection agreements
• Prohibited from using data for their own purposes
• Required to comply with GDPR and Google Families Policy
• Approved for use in applications designed for children
• Operating in the EEA or under Standard Contractual Clauses (SCCs)

A current list of third-party processors is available upon request.

We never allow third parties to collect data for advertising, tracking, or profiling.

4. Data Sharing and Legal Compliance

We may disclose Personal Data only when legally required or necessary to:

• Respond to lawful requests
• Protect the safety of a child
• Detect or prevent fraud, security threats, or misuse

We always disclose the minimum amount of data required.

5. International Data Transfers

When data is transferred outside the EEA or Israel, such transfers occur only under:

• EU adequacy decisions, or
• Standard Contractual Clauses (SCCs), and
• Additional safeguards for children’s data.

6. Data Retention

We retain Personal Data only as long as necessary for:

• Delivering the educational service
• Safety, security, fraud prevention
• Legal and regulatory compliance

Session recordings and transcripts are deleted or anonymized once no longer educationally required.

Parents may request earlier deletion unless legal obligations require retention.

7. Children’s Privacy

• The App is designed for use by children only with verified parental consent.
• Children cannot access the Platform without parent/guardian authorization.

The App does not contain:

• Targeted advertising
• Personalized advertising
• Behavioral tracking
• Unapproved SDKs

We follow the strictest applicable standard for child data protection.

8. User, Parent, and Guardian Rights

Parents/guardians may at any time:

• Access their child’s data
• Request correction
• Request deletion
• Withdraw consent
• Request export of data (data portability)

Requests can be made via email to:

We may need to verify identity to protect the child’s safety.

9. Security Measures

We apply industry-standard and enhanced child-data security measures:

• Encryption of data in transit and at rest
• Strict authentication and access controls
• Zero-trust internal architecture
• Regular penetration tests and audits
• Secure development lifecycle (SDLC)
• Continuous security monitoring

No method of transmission is 100% secure, but we take all reasonable and legally required steps.

10. Limitation of Liability

To the fullest extent permitted by law:

• The Platform is provided "AS IS"
• Tutterra is not responsible for:
  • Network failures
  • Device malfunctions
  • User misuse or negligence
  • Incorrect information provided by users
  • Interactions between users outside the Platform

Parents are responsible for:

• Authorizing the child’s use
• Supervising the child’s activity
• Ensuring compliance with safety guidelines

This does not limit liability where prohibited by law.

11. Changes to the Policy

We may update this Policy as needed. Material changes will be communicated through the App or website. Continued use after changes constitutes acceptance of the updated Policy.