Privacy Policy

1. Who we are

LearnDrive AI Inc. ("LearnDrive AI", "we", "us", "our") is an edtech and learning-AI consulting studio based at 112 Harbord Street, Suite 200, Toronto, ON M5S 1G6, Canada. Business Number: 902374615 RC0001. We provide adaptive learning design, intelligent tutoring, learning analytics and related professional services to client institutions and educators across Canada and North America.

This Privacy Policy explains how we collect, use, disclose, retain and protect personal information when you visit learndriveai.pro, contact us, or engage our services. We comply with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation, including the Freedom of Information and Protection of Privacy Act (FIPPA) where we process data on behalf of Ontario public institutions.

2. Privacy Officer

Our Privacy Officer is responsible for ensuring compliance with this policy and responding to privacy enquiries. You may contact the Privacy Officer at:

Email: [email protected]
Mail: Privacy Officer, LearnDrive AI Inc., 112 Harbord Street, Suite 200, Toronto, ON M5S 1G6, Canada
Phone: +1 (416) 742-6053

3. Scope

This policy applies to personal information collected through our website, contact forms, email correspondence, discovery calls, client engagements and any other channel where LearnDrive AI acts as the organization determining the purposes and means of processing. When we process personal information solely on behalf of a client institution under a data processing agreement, the client's privacy policy and applicable institutional policies also apply. In those cases, we act as a service provider / processor and follow the client's documented instructions.

4. What personal information we collect

4.1 Website visitors

When you visit learndriveai.pro, we may collect: browser type and version, operating system, referring URL, pages viewed, time and date of visit, and general geographic location derived from IP address (city/province level). If you submit our contact form, we collect your name, email address, organization name (if provided), enquiry type and message content. We collect this information only when you voluntarily provide it or when strictly necessary cookies are deployed.

4.2 Client and prospect contacts

When you enquire about or engage our services, we may collect: name, job title, institutional affiliation, business email and phone, billing address, project scope details, procurement references and correspondence records. We may also collect information shared during discovery workshops, including institutional learning objectives and anonymized LMS data summaries provided by you.

4.3 Student, educator and learner data in client projects

During client engagements involving adaptive learning, intelligent tutoring or learning analytics, we may process learner interaction logs, assessment results, tutoring transcripts and educator feedback — but only where the client institution has authorized such processing and provided appropriate notice and consent to affected individuals. We treat student and minor data with heightened care. We do not independently collect learner data outside of authorized client projects.

4.4 Special care for minors

Where our work involves K-12 learners or other minors, we apply enhanced safeguards: minimal data collection, role-based access controls, shortened retention periods where feasible, and prohibition on using minor data for purposes unrelated to the authorized project. We require client institutions to confirm they have authority to share minor data with us and that appropriate parental or institutional consent has been obtained where required by law.

5. Purposes of collection and use

We collect and use personal information for the following purposes:

• Responding to enquiries submitted through our website or email
• Scoping, delivering and invoicing professional services under contract
• Designing, building and operating adaptive learning, tutoring and analytics solutions for client institutions
• Conducting model bias and fairness checks on anonymized or pseudonymized datasets
• Maintaining LMS integrations and human-in-the-loop review workflows
• Complying with legal, regulatory and contractual obligations
• Improving our website through analytics cookies (only with your consent)
• Protecting the security and integrity of our systems

We do not sell personal information. We do not use student or educator data for unrelated marketing. We do not make automated decisions about individual learners that produce legal or similarly significant effects without human review and explicit client authorization.

6. Legal bases and consent

Under PIPEDA, we rely on meaningful consent for the collection, use and disclosure of personal information, except where an exception applies (for example, compliance with a subpoena or protection of vital interests). Website contact form submission requires explicit consent via the PIPEDA checkbox, which is not pre-checked. Cookie analytics and preference storage require consent via our cookie banner. Client project data processing is governed by written agreements specifying purposes, retention and sub-processors.

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawal may limit our ability to respond to your enquiry or continue a service engagement.

7. Disclosure to third parties

We may disclose personal information to:

• Cloud hosting providers located in Canada (website and email infrastructure)
• AI and machine-learning API providers used in client projects (disclosed in project-specific sub-processor lists)
• Accounting, legal and professional advisors bound by confidentiality obligations
• Client institutions, where learner or educator data is processed on their behalf and returned or shared per contract
• Law enforcement or regulatory bodies when required by applicable law

Where personal information is transferred across borders (for example, to a US-based AI API provider), we assess the transfer under PIPEDA's accountability principle, implement contractual safeguards and document the transfer in our data processing agreements. Clients may request sub-processor details during procurement.

8. Retention

Contact form submissions and general correspondence: retained for up to three years from last interaction, unless a longer period is required for an active client relationship or legal obligation. Client project data: retained per the statement of work and data processing agreement — typically deleted or returned to the client within ninety days of project completion unless a retainer or legal hold applies. Website analytics data (if consented): retained in aggregated form for up to twenty-six months. Cookie consent records: stored locally for six months, per our cookie policy.

9. Security

We implement administrative, technical and physical safeguards appropriate to the sensitivity of the information we hold, including: encrypted transport (TLS) for website and email communications, access controls and role-based permissions for project environments, employee confidentiality agreements, secure development practices for LMS integrations, and incident response procedures. No method of transmission or storage is completely secure; we cannot guarantee absolute security but we commit to notifying affected parties and regulators of significant breaches as required by law.

10. Your rights

Under PIPEDA, you have the right to:

• Access personal information we hold about you
• Request correction of inaccurate or incomplete information
• Withdraw consent where processing is consent-based
• Challenge our compliance with PIPEDA

To exercise these rights, contact our Privacy Officer at [email protected]. We will respond within thirty days unless an extension is permitted. If you are a learner whose data is processed on behalf of an institution, please contact that institution first; we will assist them in fulfilling your request.

11. Office of the Privacy Commissioner of Canada

If you believe we have not adequately addressed your privacy concern, you may contact the Office of the Privacy Commissioner of Canada (OPC):

Website: www.priv.gc.ca
Toll-free: 1-800-282-1376

12. Cookies

Our website uses cookies as described in our Cookie Policy. Strictly necessary cookies do not require consent. Analytics and preference cookies are deployed only after you accept them via our cookie banner.

13. Links to other websites

Our website may contain links to third-party sites. We are not responsible for the privacy practices of those sites. We encourage you to read their privacy policies before providing personal information.

16. Data breach notification

In the event of a security incident involving personal information under our control, we will investigate promptly, take steps to contain and remediate the incident, and notify affected individuals and relevant regulators where required by PIPEDA and applicable provincial law. Notification will describe the nature of the incident, the types of information involved, steps we are taking and recommended actions for affected individuals. Client institutions will be informed without undue delay when the incident involves learner or educator data processed on their behalf.

17. Data portability and deletion

Upon request and subject to contractual and legal obligations, we will return or securely delete personal information processed during a client engagement. Deletion procedures follow industry-standard secure erasure practices for cloud-hosted and on-premise environments. Aggregated, anonymized analytics derived from project data may be retained for internal research where individual identification is no longer possible.

18. Changes to this policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top of this page indicates the most recent revision. Material changes will be posted on this page. Continued use of our website after changes constitutes acknowledgment of the updated policy.

19. Change log

• 10 July 2026 — Initial publication