Privacy Policy

Phygital Learn, LLC

Effective Date: September 2026

1. Introduction

Phygital Learn, LLC ("Phygital Learn," "Company," "we," "our," or "us") develops and provides digital applications, educational technology, research platforms, and Software-as-a-Service (SaaS) solutions.

We are committed to protecting the privacy, security, and confidentiality of individuals who interact with our website, applications, and services. This commitment extends to students, educators, researchers, research participants, institutional partners, and other users.

This Privacy Policy explains how we collect, use, process, store, share, retain, and protect personal information, educational information, and research-related data.

Our Services may support educational instruction, academic research, surveys, assessments, health and wellness studies, and other authorized activities.

This policy applies to our company website, cloud-hosted applications, and related services unless a specific application, research study, or institutional agreement provides additional privacy terms.

2. Our Role in Data Processing

Phygital Learn may act as a data controller or a data processor/service provider, depending on the circumstances.

As a Data Controller: We determine the purposes and methods of processing information collected directly for our business operations, including website inquiries, customer relationships, and account administration.

As a Data Processor or Service Provider: We process information on behalf of educational institutions, researchers, and other organizations that determine the purposes of data collection and use.

When acting on behalf of an institution or research organization, we process information according to applicable agreements, documented instructions, and legal requirements.

3. Information We Collect

The information collected varies depending on the application, its functionality, and the purpose for which it is used.

3.1 Personal and Account Information

We may collect:

Names and email addresses
Usernames and account identifiers
Educational or organizational affiliation
Contact and communication information
Information voluntarily provided through forms, interviews, or other data collection methods

3.2 Educational Information

Our applications may collect or process:

Course and program participation
Academic progress and assessment results
Learning activities and engagement information
Educational survey responses
Student feedback and academic preferences
Other information provided by educational institutions

3.3 Research Information

Applications supporting research may collect:

Research survey and questionnaire responses
Demographic and participant information
Research identifiers and study-related records
Behavioral observations and assessments
Participant-generated content
Interview responses or other research submissions
Information associated with research participation

3.4 Health, Wellness, and Sensitive Information

Certain applications may collect sensitive information when appropriate to their intended purpose, including:

Self-reported physical or mental wellness information
Mood, stress, and emotional well-being assessments
Health-related surveys and questionnaires
Behavioral and lifestyle information
Third-party health devices
Apple Health information (if utilizing a Phygital Learn iOS application)
Other sensitive information expressly identified in the applicable study or application notice

Collection and processing of sensitive information are subject to applicable legal requirements, institutional authorization, and research consent procedures.

3.5 Technical Information

We may collect technical information necessary to operate, maintain, and secure our Services, including:

IP addresses and device identifiers
Browser and operating system information
Application activity and usage logs
Authentication and security events
Error reports and performance diagnostics

4. How We Use Information

Phygital Learn processes information for the following purposes, as applicable:

Providing and maintaining our digital applications and SaaS platforms.
Supporting authorized educational and academic activities.
Facilitating research data collection, management, and analysis.
Managing user accounts and access permissions.
Delivering technical support and customer service.
Maintaining application performance and security.
Preventing unauthorized access, misuse, and fraudulent activity.
Fulfilling contractual, institutional, and legal obligations.
Improving our Services using information we are authorized to use for that purpose.

Research data, student education records, and sensitive information will not be used for unrelated marketing, advertising, or independent commercial research without the required authorization.

5. Research Data Protection

Phygital Learn recognizes the importance of protecting research participants and maintaining the confidentiality and integrity of research information.

5.1 Research Authorization and Consent

Research information is collected and processed according to the applicable research protocol, institutional requirements, and consent procedures.

Where required, participants or their legally authorized representatives will receive information describing the purpose of the research, categories of information collected, intended uses, potential disclosures, and relevant privacy rights.

Research projects subject to Institutional Review Board (IRB) oversight must comply with their applicable approved protocols.

5.2 Confidentiality and Participant Identifiers

Research information may be associated with participant identifiers, pseudonyms, or coded records.

Where appropriate, identifying information may be separated from research responses to reduce unnecessary exposure.

De-identified and pseudonymized information will be handled according to applicable legal, institutional, and contractual requirements.

5.3 Authorized Research Access

Access to research information is restricted to authorized parties according to their responsibilities and approved purposes.

Authorized parties may include:

Designated researchers and principal investigators
Authorized educational institutions and research organizations
Approved research administrators
Phygital Learn personnel requiring access for legitimate technical, operational, or security purposes
Contracted service providers supporting authorized processing

Technical access does not independently authorize personnel to review, analyze, or disclose research content for unrelated purposes.

5.4 Research Data Ownership

Research data ownership, stewardship, and permitted uses are determined by the applicable research agreements, institutional policies, and legal requirements.

Phygital Learn does not claim ownership of identifiable research participant information merely because it is collected, processed, or stored through our applications.

6. Cloud Hosting and Data Security

Our applications use cloud-based infrastructure to support data storage, application hosting, and related services.

We seek to maintain administrative, technical, and organizational safeguards appropriate to the sensitivity of the information processed.

Security controls may include, where implemented:

Encryption during transmission and storage
Authentication and authorization mechanisms
Role-based access controls
Restricted administrative privileges
Security monitoring and logging
Application and infrastructure maintenance
Data backup and recovery procedures
Vulnerability and incident management

Security measures are selected based on application requirements, hosting configurations, contractual obligations, and identified risks.

Although we take data security seriously, no system or method of electronic transmission can be guaranteed to be completely secure.

7. Educational Data and Student Privacy

Phygital Learn provides software that may be used by schools, colleges, universities, and other educational organizations.

Where we process student education records subject to the Family Educational Rights and Privacy Act (FERPA), we will handle such records according to applicable FERPA requirements and institutional agreements.

Student information provided through institutional relationships will be processed only for authorized educational, operational, or research purposes.

We do not independently authorize the use of institutional student records for behavioral advertising or unrelated commercial activities.

8. Children's Privacy

Certain Phygital Learn applications may be used by children and students under the age of 18.

We recognize that children require additional privacy protections.

Where the Children's Online Privacy Protection Act (COPPA) applies, including when collecting personal information online from children under 13, we will comply with applicable notice, consent, parental rights, security, and retention requirements.

Where legally permitted, an educational institution may provide authorization for certain educational uses of student information within the scope allowed by law.

School authorization does not automatically permit unrelated commercial uses or research processing.

Where parental permission, student assent, or additional research consent is required, the responsible parties must establish the applicable procedures before collecting the information.

Parents and guardians may contact us regarding privacy inquiries. Requests involving institution-controlled records may be referred to the appropriate institution.

9. Health and Wellness Information

Our research and educational applications may support the collection of health and wellness information.

We recognize the sensitive nature of this information and limit its processing to authorized purposes.

Where HIPAA applies to Phygital Learn's role, we will comply with applicable requirements, including required business associate agreements and safeguards.

Health and wellness information that is not subject to HIPAA may still be protected by other privacy, consumer protection, education, and research laws.

Our applications do not automatically establish a healthcare provider-patient relationship merely by collecting health or wellness information.

10. Information Sharing

Phygital Learn does not sell identifiable research participant information or student education records.

We may share information with:

Authorized Institutions and Researchers: Organizations and individuals permitted to access information for educational, research, or administrative purposes.

Cloud and Technology Providers: Service providers supporting infrastructure, application functionality, security, authentication, and data storage.

Professional Service Providers: Authorized legal, accounting, security, or other professional advisers where access is necessary and appropriate.

Government and Legal Authorities: Where disclosure is required by applicable law or valid legal process.

Business Successors: In connection with an authorized merger, acquisition, or restructuring, subject to applicable privacy and contractual obligations.

We require appropriate confidentiality, security, and data protection arrangements where applicable.

11. Data Retention and Deletion

Information is retained according to the purpose for which it was collected and applicable legal, institutional, contractual, and research requirements.

Research retention periods may be established by the sponsoring institution, approved research protocol, or applicable agreement.

When information is no longer required, it will be deleted, de-identified, or otherwise disposed of using appropriate procedures, subject to applicable retention obligations.

Backup systems, legal holds, and research recordkeeping requirements may affect the timing of deletion.

We do not retain children's personal information indefinitely and apply applicable legal requirements governing its retention and deletion.

12. Privacy Rights and Requests

Depending on applicable law and the nature of the information, individuals may have rights to:

Request access to their personal information.
Request correction of inaccurate information.
Request deletion of eligible personal information.
Withdraw consent where permitted.
Request information regarding processing or disclosures.
Exercise other applicable privacy rights, including appeal rights where required.

Requests involving data controlled by an educational institution or research organization may need to be submitted to that organization.

Research participants should also consult their study-specific consent materials for information regarding withdrawal and research data handling.

We will review privacy requests and respond according to applicable legal and contractual requirements.

13. Cookies and Website Analytics

Our website and applications may use cookies or similar technologies for essential functions, user authentication, security, and application performance.

Where additional analytics or tracking technologies are implemented, we will provide disclosures and consent or opt-out mechanisms as required by law.

Users may adjust cookie preferences through available browser or application settings.

Disabling essential cookies may affect certain application features.

14. Artificial Intelligence and Automated Processing

Certain Phygital Learn applications may incorporate artificial intelligence, automated analysis, or data-driven functionality.

Where these technologies are used, their processing purposes, relevant data practices, and applicable user choices will be described through appropriate application-specific notices.

We do not authorize identifiable research information or protected student records to be used to train third-party general-purpose AI models without the necessary legal basis, institutional authorization, and applicable consent.

Any automated processing involving sensitive information must be evaluated against relevant legal, contractual, and research requirements.

15. Third-Party Integrations

Our applications may integrate with third-party technologies, including cloud platforms, educational systems, authentication services, and research tools.

Information shared with these providers is subject to applicable service agreements, data protection arrangements, and legal requirements.

Third-party websites and services operating independently of Phygital Learn may maintain separate privacy policies.

16. International Processing

Our cloud infrastructure or authorized service providers may process information in different geographic locations.

Where cross-border processing occurs, we will apply safeguards required by applicable laws and institutional agreements.

Specific data residency commitments will be established where required by contract or law.

17. Data Security Incidents

We maintain procedures intended to identify, assess, respond to, and mitigate security incidents affecting our Services.

If a security incident involves personal, educational, or research information, we will evaluate applicable notification obligations and notify affected parties or authorities where legally or contractually required.

We will take appropriate steps to address identified risks and reduce the likelihood of similar incidents.

18. Updates to This Policy

We may revise this Privacy Policy to reflect changes in our applications, services, operational practices, or applicable legal requirements.

Updates will be published on our website with a revised effective or last-updated date.

Where required, we will provide additional notice or obtain appropriate authorization before making material changes to data processing practices.

19. Contact Us

For questions about this Privacy Policy, our data protection practices, or requests involving personal information, please contact:

Phygital Learn, LLC

Email: success@phygitallearn.com

Website: www.phygitallearn.com

We are committed to responsible data stewardship and protecting the privacy of the individuals, educational institutions, and research organizations that use our Services.