PRIVACY POLICY

Effective Date: October 31, 2026

Last Updated: October 31, 2026

This Privacy Policy explains how Precision Learning Labs, LLC ("Precision Learning Labs," "Ivaro," "we," "us," or "our") collects, uses, discloses, and protects information in connection with the Ivaro website (ivaro.ai) and our Watchlist and related email communications (together, the "Website").

Scope. This Policy covers only the Website. It does not cover the Ivaro Teacher Suite, private testing, or any accounts, sign-in, uploaded content, or student information in them; those activities are subject to their own terms and privacy disclosures. Ivaro has not launched publicly, and we do not currently offer public teacher accounts or paid subscriptions through the Website.

This Policy does not apply to information collected by schools or districts through their own systems, or by third-party sites we do not control.

1. INFORMATION WE COLLECT

a. Watchlist and Communications. If you join our Watchlist or contact us (e.g., support requests or feedback), we collect the information you provide, such as your first name, email address, and the content of your message. Watchlist names and email addresses are stored with our email service provider (see Section 3).

b. Usage and Device Data. We automatically collect certain technical information when you visit the Website, including IP address, browser type, device identifiers, pages viewed, and timestamps, through server logs and similar technologies. We also use Google Analytics on our website; see Section 1(d).

c. Cookies and Similar Technologies. We use cookies and similar technologies to operate the Website, remember your preferences, and understand how the Website is used. We do not use cookies for third-party advertising, remarketing, or tracking you across other companies' websites. Our analytics cookies are described in Section 1(d). If this changes, we will update this Policy and provide any consents required by law. You can control cookies through your browser settings, though disabling cookies may affect Website functionality.

d. Website Analytics (Google Analytics). We use Google Analytics 4 on ivaro.ai to understand how educators find and use our website. Google Analytics uses cookies and similar technologies to collect information such as the pages you view (including individual Ivaro Studio pages), the links and buttons you click on our site, how long you spend on pages, the website, search, or social post that referred you, your approximate location (derived from your IP address), and your device type and browser. When someone joins our Watchlist, we record only that a sign-up happened; we do not send your name, email address, or anything you type into a form to Google Analytics. We use this information in aggregate to improve our website and understand which content helps teachers. We do not use Google Analytics for advertising, remarketing, or ad personalization: we have turned off Google Signals and ads personalization for our property, and we have turned off Google's optional data-sharing settings (sharing with Google's other products and services, and contributing to Google's modeling and business insights). Google processes this data on our behalf under its data processing terms. We allow Google's technical support staff to access our analytics data only when we ask them for help.

Website fonts. The fonts used on our website (Inter, Plus Jakarta Sans, and Fraunces) are hosted by us and delivered from ivaro.ai, so your browser does not contact Google or any other font service to display our pages. Our pages, scripts, and consent notice are all served from ivaro.ai (hosted by Vercel), and Google Analytics is loaded only once analytics is turned on as described below.

Your choices. If you visit from the European Economic Area, the United Kingdom, Switzerland, Brazil, or Quebec, Canada, or if we cannot determine your location, we turn on Google Analytics only if you accept analytics cookies in our cookie notice. In other locations, Google Analytics is on by default. Everywhere, you can decline or withdraw your choice at any time by selecting "Cookie Preferences" in the footer of any page. We treat a Global Privacy Control signal from your browser as a choice to decline analytics, even if you accepted analytics on an earlier visit. Our website does not respond to the separate "Do Not Track" setting in browsers, because there is no common standard for how websites should treat it; Global Privacy Control, which we do honor, is a different signal. You can also adjust your browser settings or install Google's opt-out browser add-on at https://tools.google.com/dlpage/gaoptout. Declining does not limit your use of the website or your ability to join the Watchlist. We use one cookie of our own, "ivaro_consent," to remember your choice for about six months. The choice applies on both ivaro.ai and www.ivaro.ai.

How long analytics data is kept. We have configured Google Analytics to keep detailed event-level data for 2 months. User-level data (data connected to cookie and device identifiers) is kept for 14 months, and that period restarts each time the same visitor returns, so it is deleted after 14 months without new activity. Aggregated reports that do not identify individual visitors may be kept longer. Google Analytics cookies are stored on your device for up to two years unless you decline, withdraw your choice, or delete them. To learn how Google uses data from sites that use its services, see https://policies.google.com/technologies/partner-sites.

2. HOW WE USE INFORMATION

We use the information described above to:

• Operate and maintain the Website;
• Send Watchlist updates and other communications you asked to receive, and respond to your messages;
• Understand how the Website is used, troubleshoot issues, and improve it;
• Maintain the security and integrity of the Website and prevent fraud; and
• Comply with legal obligations.

We do not sell your personal information.

3. HOW WE SHARE INFORMATION

We do not sell your personal information. We may share information with:

• Service Providers. Vendors who perform services on our behalf: website hosting (Vercel), email list management (Brevo), and website analytics (Google Analytics). We use each of these providers under its own terms of service. Our agreements with Brevo and Google include data-processing terms.
• Legal and Safety Reasons. If required by law, subpoena, or legal process, or if we believe in good faith that disclosure is necessary to protect the rights, property, or safety of Ivaro, our users, or the public.
• Business Transfers. In connection with a merger, acquisition, financing, or sale of assets, in which case we will require the receiving party to honor the commitments in this Policy (or notify you of any material change).
• With Your Consent. For any other purpose disclosed to you at the time of collection or with your consent.

4. YOUR RIGHTS AND CHOICES

Depending on your state of residence, you may have rights to access, correct, delete, or receive a copy of your personal information, and to opt out of certain processing. California residents may have rights under the California Consumer Privacy Act ("CCPA"), including the right to know, delete, and correct personal information, and the right to non-discrimination for exercising these rights. We do not sell or share personal information as those terms are defined under the CCPA. You can limit website analytics as described in Section 1(d), and you can unsubscribe from Watchlist emails at any time using the link in any email we send.

To exercise any privacy rights, email legal@precisionlearninglabs.com. We may need to verify your identity before completing a request.

5. DATA RETENTION AND DELETION

We keep Watchlist and communication information until you unsubscribe or ask us to delete it. Website analytics data is kept for the periods described in Section 1(d). You may request deletion of your Watchlist or communication information at any time by emailing legal@precisionlearninglabs.com; we will delete it within 45 days, except where retention is required by law.

6. DATA SECURITY

We use reasonable safeguards designed to protect personal information from unauthorized access, use, or disclosure, including encrypted (HTTPS) connections to the Website. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

7. CHILDREN

The Website is intended for adult educators, not for children. We do not knowingly collect personal information from children under 13 through the Website. If we learn that we have done so, we will take steps to delete it.

8. INTERNATIONAL VISITORS

Ivaro is built for and offered to K–8 educators in the United States, and we do not currently offer our services in other countries. Our public website can be viewed from anywhere. If you access our website from outside the United States, your information will be transferred to and processed in the United States. If you visit our website from the European Economic Area, the United Kingdom, Switzerland, Brazil, or Quebec, Canada, we ask for your consent before setting analytics cookies.

9. CHANGES TO THIS POLICY

We may update this Policy from time to time, and we will update it before we launch new products that collect additional information. If we make material changes, we will notify you by email (for example, if you are a Watchlist subscriber) or on the Website prior to the change becoming effective.

10. CONTACT US

Questions about this Privacy Policy or our data practices can be directed to:

Precision Learning Labs, LLC
Email: legal@precisionlearninglabs.com
16029 N 173rd Ave, Surprise, AZ 85388