Vives Tutor Privacy Policy

1. Who we are and what this policy covers

Vives Tutor is a service of Smores Vacations LLC, a Florida multi-member limited liability company, doing business as Vives Tutor. Contact: adolfo@vivestutor.com. In this policy, “Vives Tutor,” “we,” “us,” and “our” refer to Smores Vacations LLC doing business as Vives Tutor.

This Privacy Policy explains how we collect, use, disclose, and protect personal information when you or your child use:

• The Vives Tutor marketing website at vivestutor.com
• The Vives Tutor web application at app.vivestutor.com (the parent dashboard, the student app, and the AI tutor Vee)
• Any related support or communication we provide to you by email

Vives Tutor is directed to children under 13 and is subject to the Children’s Online Privacy Protection Act (COPPA). We also apply the same protections to students ages 13–17 who use the service under a parent account.

This policy does not cover:

• Services or websites operated by third parties that you reach from within Vives Tutor
• The device, browser, or operating system your child uses. Features provided by your device’s manufacturer or operating system, for example the keyboard’s built-in voice-to-text dictation, system-level accessibility features, or cloud backup of browser data, are governed by the manufacturer’s or OS provider’s own privacy policy, not ours. We describe below which features inside Vives Tutor are ours versus which are provided by your device.

2. How we verify parental consent

Before any child can use Vives Tutor, a parent or legal guardian must create the account and provide verifiable parental consent.

During our private and early public beta, we use the “email-plus” consent method permitted by COPPA for services where children’s personal information is not disclosed to third parties beyond those we describe in Section 6. After the parent signs in with a magic link emailed to their verified email address, the app presents a plain-English direct notice of our data practices. The parent must check a box affirming they have read the notice and click an “I Agree and Consent” button before their child can sign in. We store the parent’s consent record, including the version of the notice they consented to, the date and time, the IP address of the consenting device, and the full text of the notice they saw, in our database.

For paid subscriptions, we use a stronger form of verifiable parental consent by verifying the parent’s identity through a credit or debit card transaction processed by our payment provider (Stripe). The card transaction confirms the consenting person has access to a payment instrument that is not generally available to minors.

If we cannot verify that a parent has given consent, the child cannot sign in to the service. If you believe your child has created an account without your consent, email adolfo@vivestutor.com and we will delete the account promptly.

You may withdraw your consent at any time by emailing adolfo@vivestutor.com or by using the “Delete my account” feature in the parent dashboard. Withdrawing consent ends your child’s access to the service and causes us to delete the child’s personal information as described in Section 9.

3. Information we collect

We collect only what we need to run the service. We break it down by who it comes from.

3.1 Information you give us as a parent

When you create a parent account, we collect:

• Your email address, used for sign-in (magic link) and to communicate with you about your account.
• Billing information, if you subscribe to a paid plan. Billing is handled by Stripe. We do not store your full credit or debit card number on our servers; we store only a token that lets us charge the card through Stripe, along with the last four digits and card type for your reference.
• Any information you choose to send us, such as when you email support or respond to a survey.

3.2 Information you give us about your child

When you set up a student profile for your child, we ask you to provide:

• Your child’s first name or preferred name, used by Vee to personalize lessons.
• Your child’s grade level or approximate age, used to calibrate lesson difficulty.
• A username and password you create for your child to sign in.
• Optional notes you write about your child (we call these “Vee’s Notes”), such as interests or learning accommodations you want Vee to keep in mind.
• Optional topic controls and worldview lens settings you configure, which tell Vee what subjects to cover or avoid and what educational perspective to take.

You can edit or delete any of this information at any time from the parent dashboard.

3.3 Information we collect from your child as they use the service

As your child uses Vives Tutor, we collect:

• The text of conversations between your child and Vee, including anything your child types or dictates as input and Vee’s replies.
• Quiz questions, answers, and scores when your child takes a quiz.
• Illustrations and sketches Vee generates as part of lessons, and the scene descriptions used to generate them.
• Images or photos your child uploads to show Vee. Examples: a page from a workbook, a drawing they made, a worksheet they need help with. We strip metadata from these images in your child’s browser before they leave the device (see Section 7.1).
• “Vee’s Notes” entries Vee saves automatically based on conversation, when you have turned this feature on. For example, if your child mentions they love dinosaurs, Vee may save a note to remember that. Memory features are off by default; you decide whether to enable them in settings (see Section 7.3). When enabled, you can review and delete any saved note in the parent dashboard, and you can turn the feature back off at any time.

3.4 Information collected automatically

When your child or you use the service, we and our infrastructure providers automatically collect limited technical information necessary to operate the service and keep it secure:

• Device and browser information: browser type and version, operating system, approximate screen size.
• Network information: IP address of the device used to sign in, used for session security and to record in your parental consent record.
• Service logs: which pages were loaded, which features were used, error logs, timestamps. We retain these for up to 12 months for security and troubleshooting.

We do not use cookies, pixels, or tracking technologies to build advertising profiles. The service uses only the minimum storage necessary to keep your child signed in and to remember their session.

3.5 Information we do not collect

We do not collect:

• Your child’s last name, home address, phone number, or date of birth. (We ask only for a first name and grade level.)
• Your child’s precise geolocation.
• Your child’s school name, classroom, or teacher information.
• Biometric identifiers of any kind. The speech-to-text feature converts your child’s spoken words to text on the device itself (see Section 7.2); no voice audio is ever sent to or stored on our servers.
• Your child’s contacts, calendar, photo library (other than the specific images they choose to upload), or any other data from your device.
• Any information about people other than you and your child.

4. How we use the information we collect

We use the information we collect to:

• Provide the tutoring service. Deliver Vee’s responses, generate illustrations, grade quizzes, and personalize lessons based on your child’s name, grade level, interests, and the topic controls and worldview lens you configure.
• Let you monitor your child’s learning. Show you full transcripts of every conversation your child has had with Vee, quiz scores, and illustrations.
• Keep the service safe. Filter prompts that ask for inappropriate content, block attempts to make Vee say things outside the bounds you set, and detect abuse or security problems.
• Communicate with you. Send you account-related emails (sign-in links, subscription notices, account changes). We will not send you marketing emails without your separate consent.
• Improve our prompts and safety rules. We review aggregated patterns, for example, categories of questions Vee handles poorly, using conversation transcripts as reference material. Any internal review is done by Adolfo (the operator) on a case-by-case basis and never shared outside the service. We do not use transcripts, uploads, or any other child data to train artificial intelligence models, ours or anyone else’s.

We do not use information we collect to:

• Show advertising to your child or to you.
• Build marketing profiles.
• Train or fine-tune any AI model.
• Sell, rent, trade, or license to third parties.
• Contact your child directly for any reason.

5. Legal bases (for parents outside the United States)

Vives Tutor is operated from and directed primarily to users in the United States. If you or your child use the service from outside the United States, the information we collect will be transferred to and processed in the United States. Most of our infrastructure (Firebase hosting, Firestore database, authentication, and Google Cloud Text-to-Speech) runs inside Google Cloud data centers. AI text generation is processed inside either Google Cloud or Amazon Web Services data centers, both in the United States, depending on which Zero Data Retention backend our text routing provider selects on a given request (see Section 6.1). By using the service, you consent to this transfer.

Where applicable law requires, our legal basis for processing your child’s personal information is your consent as the parent or legal guardian, which you provide through the process in Section 2.

6. Who we share information with

We do not sell personal information. We do not share personal information with advertisers or data brokers. We share personal information only with the limited set of service providers necessary to run the service, and only for the purposes described below. Each provider is bound by contract to handle the data only for those purposes and to protect it to standards at least as strong as our own.

6.1 Service providers we currently use

• Google Cloud Platform (Google LLC), which includes Firebase (our hosting, authentication, database, and email delivery layer) and Google Cloud Text-to-Speech (for Vee’s read-aloud voice). Conversations, uploaded images, quiz data, and Vee’s text and audio replies are stored inside Google Cloud. Google Cloud may also process your child’s text and image data when it serves as a backend for our text routing provider (OpenRouter, below). Google Cloud is contractually prohibited from using your child’s data to train its own models or for any purpose other than operating the service for us.
• OpenRouter (OpenRouter, Inc.). Our text AI routing provider. OpenRouter delivers an Anthropic Claude model to power Vee, served from a Zero Data Retention (ZDR) backend operated by AWS or Google Cloud inside data centers in the United States. Our account is configured so that every request must use a ZDR endpoint and must reach one of these approved backends; no other models or hosts are reachable. OpenRouter also automatically redacts common sensitive patterns, such as email addresses, phone numbers, and similar identifiers, from outgoing requests before they reach the backend. None of these providers retains prompts or completions, and none may use child data to train AI models.
• Anthropic (Anthropic, PBC). Developer of the Claude AI model that powers Vee. Anthropic does not directly receive your child’s data; Claude is operated for us by the cloud backends described above, under those backends’ Zero Data Retention controls.
• Amazon Web Services (Amazon Web Services, Inc.). One of the cloud backends that may run Claude on our behalf when OpenRouter routes a request to AWS. When AWS handles a request, your child’s text and image inputs and Vee’s text replies are processed on AWS infrastructure in the U.S. AWS does not retain prompts or completions and is contractually prohibited from using them to train models.
• Brave Search (Brave Software, Inc.). When your child asks Vee a factual question where Vee is uncertain, Vee can search the web for a current, correct answer. We use Brave Search as the web search provider (selected by Anthropic as part of Claude’s web search tool). The search query is a short factual question Vee formulates, for example, “Was Dracorex a herbivore?”, and contains no personal information about your child.
• OpenAI (OpenAI, L.L.C.). Generates illustrations when your child or Vee asks for a picture as part of a lesson. Before any illustration request is sent to OpenAI, we automatically strip personal information from the scene description so that OpenAI receives only a short, anonymized description such as “a friendly dragon flying over a stone castle at sunset.” Our OpenAI access is configured so that it can only be used for image generation; text and conversation requests cannot be sent under our account. OpenAI retains scene descriptions for up to 30 days for abuse monitoring and is contractually prohibited from using them to train models.
• Stripe (Stripe, Inc.). Processes parent subscription payments. Stripe receives your billing information and collects information about your parent account for fraud prevention and regulatory compliance. Stripe does not receive information about your child.

We provide contact information, DPAs, and subprocessor certifications for each of these providers on request. Email adolfo@vivestutor.com.

6.2 Changes to our subprocessors

The list above is the full set of providers that may handle your child’s data today. We may need to change this list over time, for example, to switch text routing providers if our current vendor changes its terms, to add a new image generation provider, or to route around an outage at our primary text provider. To make sure parents are never surprised, our service is built around a forcing function:

• The list of providers in our parent-facing direct notice is the source of truth. Our admin tools cannot switch a category of provider (text AI, image AI) without simultaneously updating that notice in the same database write. The two cannot drift apart.
• Whenever the notice version changes, every active parent is required to review the updated notice and renew consent the next time they sign in. Until they do, the parent dashboard is blocked and any associated student account is paused.
• If you do not consent to the updated subprocessor list, you can delete the account instead and your child’s information will be removed per Section 9.

This means you will never learn about a new subprocessor by reading a press release or an updated policy alone; the in-app notice is updated and your renewed consent is collected before any child data flows to a new provider.

6.3 Legal disclosures

We may disclose personal information if required by law, legal process, or a valid government request, such as a subpoena or court order. We will notify you before disclosing your information unless we are legally prohibited from doing so.

6.4 Business transfers

If Vives Tutor is ever sold, merged, or transferred to another operator, we will provide advance notice to you and you will have the opportunity to delete your account before any transfer. Any successor operator will be bound by the commitments in this policy, or will be required to obtain fresh consent from you under their own policy before continuing to process your child’s data.

7. How specific features work

We want to be transparent about how the less obvious features of the service collect and use information.

7.1 Image uploads

Your child can upload a photo or picture to show Vee, for example, a math problem, a worksheet, a drawing. Before the image leaves your child’s device, our app automatically strips all metadata from the image, including GPS location, device identifier, timestamp, and any embedded thumbnail. Only the pixel data of the image itself is sent to our servers and on to the active text AI provider, where it is processed under the Zero Data Retention terms described in Section 6.1.

The image is processed by Vee to answer your child’s question. It is stored in the conversation transcript so you can see it in the parent dashboard. It is deleted when you delete the conversation or the account, subject to the retention schedule in Section 9.

7.2 Voice features

Vives Tutor has two voice features, and neither involves sending your child’s voice audio to our servers.

• Speech-to-text (your child talks to Vee). When your child uses the “hold to talk” microphone button, their spoken words are converted to text on the device itself, using a speech recognition model that runs inside the browser. The audio recording never leaves your child’s device; only the resulting text transcript is sent to our servers, where it is treated the same as any text your child typed. On some older devices, the browser’s built-in speech recognition is used as a fallback; in that case the audio is handled by the device’s operating system under the OS provider’s own privacy policy, and we still receive only the resulting text.
• Text-to-speech (Vee reads replies aloud). When the “read aloud” feature is on, Vee’s text reply is sent to Google Cloud Text-to-Speech, which returns synthesized audio of the reply that is played in your child’s browser and then discarded. The text being read is Vee’s reply to your child (which may contain your child’s first name and the conversational context you or your child have shared) and is processed under Google Cloud’s data protection terms.

A separate “voice conversation” mode existed in earlier versions of the app and is currently disabled. If we reintroduce it in the future, we will update this policy and obtain renewed parental consent before it can be used.

7.3 Vee’s Notes (memory)

Vee can remember things across conversations, for example, that your child is learning multiplication or that their favorite animal is a pangolin, so lessons feel continuous. Memory features are turned off by default. If you want Vee to remember anything across sessions, you turn memory on in settings. There are two kinds of memory entries, each controlled separately:

• Parent-written notes are anything you type into the “Vee’s Notes” field in the student settings page. These are only used when you have memory turned on. You add, edit, or delete them at any time.
• Auto-saved notes are short entries Vee saves automatically based on what your child mentions in conversation. Auto-saving is a separate setting that you turn on in addition to memory itself; both must be on for Vee to save notes automatically. When auto-saving is on, notes are added to Vee’s memory right away so future lessons can build on them. You can review every saved note in the parent dashboard at any time and delete any of them, and you can turn auto-saving back off at any time.

If you have enabled memory features, we recommend periodically reviewing Vee’s Notes for your child to make sure Vee’s memory reflects what you want her to remember.

7.4 Worldview lens

You can choose the educational perspective Vee takes when responding to your child, for example, standard, Christian, general faith, or secular, at a strength of your choosing. This setting only affects how Vee frames her responses; it does not change what we collect about your child.

7.5 Topic controls

You can block specific subjects or allow only specific subjects for your child. These controls are enforced inside Vives Tutor. A safety floor built into Vee prevents her from producing content that is graphically violent, sexual, or harmful regardless of your settings.

7.6 Parent-assigned quizzes and assignments

You can create quizzes and assignments for your child from the parent dashboard. The assignment text, quiz questions, any answer keys, and your child’s responses and scores are stored in the same way as regular conversation data.

7.7 Pushback and web search

If your child tells Vee she is wrong about a factual matter, Vee is programmed to check herself by doing a quick web search before answering. The search query is a short factual question Vee formulates and contains no personal information about your child. To prevent abuse, we limit how often this check can happen in a single conversation.

8. Your rights as a parent

Under COPPA, and as a matter of how Vives Tutor is designed, you have the following rights. All of them are exercisable from the parent dashboard, or by emailing adolfo@vivestutor.com. We respond to email requests within seven business days.

• Right to review any personal information we have collected from your child. The parent dashboard gives you direct access to every conversation transcript, quiz, illustration, uploaded image, and memory note associated with your child’s profile. If you prefer an export in a portable format, email us.
• Right to delete your child’s personal information. You can delete individual conversations, individual memory notes, or the entire student profile at any time. You can also delete your parent account, which deletes all associated student profiles and data.
• Right to refuse further collection. You can stop using the service at any time and close your account, which halts further data collection and initiates deletion. You can also turn off individual features, auto-memory, voice, illustrations, or specific topics, while keeping the account active.
• Right to withdraw consent at any time, with the same effect as deletion.
• Right to know which third parties have received information about your child. See Section 6. The list is also reflected in the in-app direct notice you consented to, and a full archive of every version of the notice you have seen is available in your account.

We will not condition your child’s participation in the service on your providing more information than is reasonably necessary to use the service.

9. How long we keep information

We keep personal information only as long as we need it for the purposes described in this policy. Our specific retention rules:

Some retention periods may be extended if required to comply with a legal obligation, resolve a dispute, or enforce our agreements.

When we delete data, we delete it from our active systems immediately. Copies may persist in routine encrypted backups for a short additional period before being overwritten in the normal backup rotation, typically within 30 days.

10. How we protect information

We take reasonable steps to protect personal information from unauthorized access, disclosure, alteration, and destruction. These steps include:

• All traffic between your device and our servers is encrypted in transit using HTTPS.
• All data at rest in our databases and file storage is encrypted using the default encryption provided by Google Cloud.
• Access to production data is limited to authorized Vives Tutor personnel and is authenticated with two-factor authentication. No employee, contractor, or third party outside the service providers listed in Section 6 has access to production data.
• Passwords are stored only as salted hashes, never in plain text.
• We maintain a written internal information security program covering access control, encryption, logging, incident response, and annual review.
• We conduct periodic risk assessments of the service and our vendors.

No security system is perfect. If we discover a security incident that affects personal information belonging to you or your child, we will notify you by email without unreasonable delay and in any event within the timeframes required by applicable law.

11. Children’s own online behavior

The only online interaction available in Vives Tutor is between your child and Vee. There are no chat rooms, message boards, social features, public profiles, comment sections, or ways for your child to contact other users of the service. Your child cannot post publicly, cannot be contacted by other users, and cannot share information with anyone other than Vee and, through you, our service providers.

12. Changes to this policy

We may update this Privacy Policy from time to time. When we do:

• For changes that are typographical, clarifying, or do not materially affect how we collect or use personal information, we update the “Last updated” date at the top of this document.
• For any material change, for example, adding a new service provider, adding a new category of collected information, or changing how we use existing information, we will:
  1. Update this document with a new version number and effective date.
  2. Update the in-app direct notice with the same changes.
  3. Present the updated notice to every active parent the next time they sign in, and require renewed affirmative consent before continuing service.
  4. Pause any student account whose parent has not yet renewed consent.

You can review the full history of every version of the direct notice you have consented to inside the parent dashboard.

13. How to contact us

For any question about this policy, any request to review or delete your child’s information, any request to withdraw consent, or any complaint:

• Email: adolfo@vivestutor.com
• Operator: Vives Tutor (Smores Vacations LLC DBA Vives Tutor)
• Response time: We respond to privacy-related emails within seven business days and aim for faster.

You may also contact the U.S. Federal Trade Commission about COPPA concerns at ftc.gov/coppa or by phone at 1-877-FTC-HELP.

14. Summary table: what is collected, from whom, why, for how long