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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:

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

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.