Privacy Policy

Effective Date: 01-Jan-2026

BY USING THE ROTUTIA WEBSITE AND ROTUTIA CO-EDUCATOR SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THE ROTUTIA CO-EDUCATOR PRIVACY POLICY.

Agreement to Terms
Welcome to Rotutia Technology Pte. Ltd. ("rotutiA," "we," "our," "us"). We are a Singapore-based company (UEN No. 202529031Z) with the vision of "Redefining Education through Artificial Intelligence" and the mission of "Unlocking Educator Productivity and Learner Success".
This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Website (www.rotutia.com) and adaptive learning Platform, the rotutiA Co-Educator (the "Service"). This Service is intended for use by educators and learners.
Information We Collect
We collect minimal personal data to provide and improve our Service.
Personal Data:
- For All Users (Educators & Learners): We collect your name and email address during account registration.
- For Educators: Prior to publishing a course, you must provide a short biography, your academic level, your subject specialisation, your qualifications, your areas of expertise and your teaching philosophy. This information is displayed on the Platform to help learners understand your background and choose courses, but is not processed by our AI.
Course and Interaction Data:
- Educator-Provided Content: This includes the course name, code, description, goals, objectives, and any materials (e.g. PDF, PPT, etc.) you upload.
- Learner-Provided Content: This includes data generated from Learner interactions with the AI Co-Educator, including:
  - Chat conversation content (messages, transcript, questions, and prompts).
  - Progress metrics and engagement data.
  - Learning performance indicators, completion status, and learning gap analysis.
  - Interaction metadata (timestamps, frequency, duration).
  - Analytics derived from all of the above.
How We Use Your Information
We use the information we collect for the following purposes:
- To create, manage, and secure your user account.
- To enable the core functionality of the Service, which includes using AI to formulate learning objectives and insights based on pedagogical frameworks.
- To facilitate interactions between learners and the AI Co-Educator.
- To provide advanced analytics to educators and learners on learning gaps and paths.
- To process subscription payments through our third-party processor, Stripe.
- To improve and train our proprietary AI models, using course information and interaction data (in anonymized form where possible).
Legal Basis for Processing (For International Users)
Governing Law: This Privacy Policy and our data processing practices are governed by the laws of the Republic of Singapore, specifically the Personal Data Protection Act 2012 (PDPA).
Legal Basis: As a Singapore company, we primarily comply with the Singapore Personal Data Protection Act (PDPA). For users outside Singapore, our legal basis for processing your data is the performance of our Service contract with you. By using the Service, you consent to your data being processed in Singapore and other locations as outlined in Section 8 (International Data Transfers).
How We Share Your Information
We uphold a strict principle of minimising data sharing.
- With Your Educator: If you are a learner:
  - Always Shared: Your progress metrics, engagement analytics, learning performance data, time spent, completion status, and learning gap analysis are always shared with the Educator of your course.
  - Chat History Sharing:
    - During Beta Period: Your chat conversation content (messages and transcript) with the AI Co-Educator is NOT shared with the Educator. This is a temporary measure while we develop privacy control features.
    - After Privacy Settings Launch: Once privacy settings become available (you will be notified via email), your chat conversation content will be shared with your Educator by default. You may opt out of sharing through your account privacy settings at any time after this feature launches.
    - Note: Your progress metrics, engagement analytics, learning performance data, and learning gap analysis are always shared with your Educator regardless of your chat history sharing preferences.
- With Third-Party Service Providers: We engage the following providers essential to our operation:
  - Cloud Hosting: Our Platform is hosted on the Microsoft Azure cloud Platform. All data is stored and processed within their global network of data centres.
  - Large Language Model (LLM) Providers: To power the AI Co-Educator, our Platform interacts with various third-party Large Language Model APIs. The specific LLM used for a course is determined by the Educator's selection or Platform's configuration. When you interact with a course's AI Co-Educator, your prompts and the relevant course materials are transmitted to the API of the configured LLM provider to generate responses. This constitutes a transfer of data to that third party.
  - Email Communications: We use Microsoft Exchange Online (part of Microsoft 365) to send transactional emails, notifications, and account-related communications. Your email address and name are transmitted to Microsoft for email delivery purposes.
  - Stripe: Our payment processor. We do not store your payment card details.
We do not sell, rent, or trade your personal data with any other third parties for marketing or other purposes.
Data Retention
We retain your data only for as long as necessary to fulfil the purposes outlined in this policy.
1. Standard Data Retention
  - Account Data: Retained for the duration your account is active and for a reasonable period thereafter to fulfil legal and business obligations.
  - Course Materials (Educators): Removed from public access when a course is terminated or removed. Production system data is deleted according to our standard deletion cycles.
  - Interaction Data (Learners): Your chat history and interaction data with the AI Co-Educator remains in our backup systems after your subscription ends. You will no longer have access to view this data through the Platform.
  - AI Training Data: Course information and interaction data (in anonymized form where possible) may be retained indefinitely for the purpose of training and improving our proprietary AI models, even after:
    - A subscription ends.
    - A course is deleted.
    - An account becomes inactive.
2. Data Retention for Violations and Legal Purposes
  Notwithstanding Section 6.1 (Standard Data Retention), if your account or course is terminated due to:
  - Content Policy violations.
  - Terms of Service violations.
  - Illegal activity.
  - Fraud, abuse, or serious misconduct.
  We may retain the following data as evidence:
  - Course Materials and content.
  - Account information and registration data.
  - Interaction data and chat history.
  - Communications related to the violation.
  - Any other data relevant to the violation or investigation.
  This data:
  - Will be securely stored and not publicly accessible.
  - May be used for legal proceedings, regulatory compliance, or reporting to authorities.
  - May be shared with law enforcement or regulatory bodies as required by law.
  - Will be retained for as long as necessary to fulfil legal, regulatory, or evidentiary purposes.
  - Will be deleted once no longer needed for these purposes.
3. Data Deletion Requests
  Upon a verified request for data deletion, we will permanently remove all associated personal data, including account details, course information, and interaction data, from our production and backup systems within thirty (30) days.
  Exception to Deletion: We may retain data despite a deletion request if:
  - Required by applicable law or legal obligation.
  - Needed as evidence for ongoing or anticipated legal proceedings or investigations.
  - Related to violations of our Terms of Service, Content Policy, or illegal activity as described in Section 6.2 (Data Retention for Violations and Legal Purposes).
  - Necessary for regulatory compliance or cooperation with law enforcement.
  - Required to protect our legal rights or defend against claims.
  If we retain data under these exceptions:
  - We will inform you that we cannot fully comply with your deletion request (unless prohibited by law from doing so).
  - Retained data will be limited to what is strictly necessary.
  - Data will be securely stored with restricted access.
  - Data will be deleted once the retention purpose is fulfilled.
Your Data Rights and Choices
You have the right to:
- Access: You can access your personal data (name, email) directly through your account settings, or request a copy of personal data we hold about you by contacting us at support@rotutia.com.
- Correction: You can update your personal data directly through your account settings. If you believe any personal data we hold is inaccurate or incomplete, you may request correction by contacting us at support@rotutia.com.
- Withdrawal of Consent: Where we rely on your consent to process personal data, you may withdraw your consent at any time by adjusting your privacy settings or contacting us at support@rotutia.com. Withdrawal of consent does not affect the lawfulness of processing conducted prior to withdrawal.
- Data Deletion: You can request the permanent deletion of all your personal data associated with our Service by contacting us at support@rotutia.com. We will respond to and fulfil all legitimate requests within thirty (30) days.
International Data Transfers
rotutiA is headquartered in Singapore. Your personal data is processed and stored on our behalf by our service providers, primarily within the Microsoft Azure cloud Platform, which operates a global network of data centres.
By using our Service, you acknowledge that your data may be transferred to and processed in any country where we or our service providers (including Microsoft Azure and LLM providers) operate. These countries may have data protection laws that differ from those in your country of residence.
Data Security
We implement robust security measures, including encryption and secure network architectures, to protect your data within our systems. However, no electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.
Changes to this Policy
We may update this policy from time to time. We will notify you of any changes by posting the new policy on this page and updating the "Effective Date" date. Your continued use of the Service after any change constitutes your acceptance of the new policy.
Contact Us
If you have any questions, concerns, or feedback regarding this Privacy Policy, please contact us at support@rotutia.com.