Privacy Policy
1. Who we are
Simon Eyes is a product of 3R Innovation Inc. ("3R Innovation," "we," "us"). This policy explains what personal data we collect through the Simon Eyes product and this website, why we collect it, and the choices available to schools, teachers, students, and parents/guardians.
2. What we collect
Depending on how an institution configures Simon Eyes, we may process:
- Account and roster information provided by the school (student name or ID, class/course, teacher/proctor accounts).
- Behavioral signals captured during an assessment session — for example gaze direction, head/body pose, keystroke and touch patterns, stylus data, and screen activity.
- Audio-based signals limited to detecting the presence of nearby speech, where enabled by the institution.
- Device and technical information needed to run the product (device type, OS, browser).
- Contact details submitted through this website's demo request or partnership forms (name, email, organization, message).
Simon Eyes is designed around data minimization and on-device processing where possible: raw sensor data is processed to produce assessment-relevant signals, rather than being retained as raw video or audio recordings by default.
3. How we use it
- To provide the proctoring and assessment-assistant features an institution has licensed.
- To generate the evidence summaries and reports shown to teachers/proctors.
- To maintain the security, integrity, and availability of the product (see our ISO/IEC 27001-aligned information security practices).
- To respond to inquiries submitted through this website.
We do not sell personal data. We do not use student data to serve advertising.
4. Children's privacy
Many Simon Eyes users are minors. Where applicable law requires it (including COPPA in the United States and Korea's Personal Information Protection Act for children under 14), we rely on the school or a parent/guardian to provide the necessary consent before a child's data is processed, consistent with the "school official" / "school consent" exceptions recognized under COPPA and equivalent local frameworks. Parents and guardians can contact their child's school, or us directly at the address below, to ask about, access, or request deletion of their child's data.
5. Legal bases and regional frameworks
Where the GDPR, UK GDPR, US state privacy laws (including the CCPA), Korea's PIPA, Singapore's PDPA, or similar frameworks apply, we process personal data on the basis of a contract with the institution, a legitimate interest in providing and securing the service, or consent, as applicable, and we support the institution in honoring data subject rights (access, correction, deletion, and restriction of processing) under those frameworks.
6. Data retention
We retain assessment-related data for as long as the institution's contract requires it, or as needed to resolve an active review or dispute, after which it is deleted or anonymized in line with our data retention schedule (available to institutional customers on request).
7. Security
3R Innovation maintains an information security management system aligned with ISO/IEC 27001, with a dedicated privacy and security team responsible for access control, encryption, and incident response.
8. International transfers
Where personal data is transferred across borders, we use appropriate safeguards (such as standard contractual clauses or equivalent mechanisms) as required by applicable law.
9. Your rights
Depending on your location, you may have the right to access, correct, delete, or restrict the use of your personal data, and to object to certain processing. Requests should generally be directed to your school or institution first, since they control the underlying account; you can also contact us directly and we will coordinate with the institution as needed.
10. Contact us
Questions about this policy or your data can be sent to care@focuspang.com.