Last Updated: June 1, 2026
Effective Date: June 10, 2026

1. Introduction

EMPENHANCE EdTech Solutions Inc. ("EMPENHANCE," "we," "our," or "us") is committed to protecting the privacy and security of the personal information of learners, tutors, visitors, and users of our platform.

This Privacy Policy explains how we collect, use, disclose, store, retain, and protect personal information through our website, learning platform, applications, and related services (collectively, the "Platform").

By accessing or using the Platform, you acknowledge that your personal information will be processed in accordance with this Privacy Policy.

2. Scope

This Privacy Policy applies to:

Learners;
Tutors and tutor applicants;
Visitors to the Platform;
Individuals communicating with EMPENHANCE; and
Any person whose personal information is processed in connection with our services.

3. Information We Collect

3.1 Information You Provide

We may collect information including:

Full name;
Email address;
Telephone number;
Account credentials;
Billing and payment information;
Educational background;
Professional qualifications;
Identity verification documents;
Tutor application information;
Communications with EMPENHANCE;
Feedback and support inquiries.

3.2 Learner Data

Learner Data may include:

Contact information;
Account information;
Messages and communications;
Course enrolment details;
Learning progress;
Assessment responses;
Completion status;
Certificate information;
Payment-related status;
Learner activity records.

3.3 Automatically Collected Information

We may automatically collect:

Device information;
Browser type;
IP address;
Login information;
Usage logs;
Session activity;
Technical diagnostics;
Platform interaction records.

4. How We Use Personal Information

We use personal information to:

Create and administer accounts;
Deliver educational services;
Facilitate courses and live sessions;
Verify tutor qualifications;
Process payments;
Provide customer support;
Issue certificates;
Monitor course quality;
Maintain Platform integrity;
Prevent fraud and abuse;
Investigate complaints;
Ensure legal compliance;
Improve Platform functionality;
Enforce our agreements and policies.

5. Legal Basis for Processing (GDPR)

Where GDPR applies, we process personal information based on one or more of the following legal grounds:

Performance of a contract;
Compliance with legal obligations;
Legitimate business interests;
Protection of vital interests;
User consent where required by law.

Users may withdraw consent at any time where processing is based on consent.

6. Tutor Access to Learner Data

Tutors may access Learner Data solely to deliver approved services through the Platform.

Tutors are prohibited from:

Collecting additional personal information from learners without authorization;
Storing Learner Data outside the Platform;
Copying or exporting Learner Data;
Disclosing Learner Data to third parties;
Using Learner Data for marketing purposes;
Contacting learners outside approved Platform channels;
Processing Learner Data for unauthorized purposes.

Violations may result in suspension or termination.

7. Communications and Monitoring

Communications occurring through the Platform may be monitored, reviewed, filtered, recorded, or assessed using automated systems for purposes including:

Learner safety;
Fraud prevention;
Policy enforcement;
Quality assurance;
Platform security;
Investigation of misconduct;
Compliance with legal obligations.

8. Sharing of Personal Information

We may disclose personal information to:

Service providers supporting Platform operations;
Payment processors;
Hosting providers;
Analytics providers;
Accessibility service providers;
Technical support vendors;
Legal and regulatory authorities;
Law enforcement agencies where required by law;
Professional advisers;
Courts and dispute resolution bodies.

We do not sell personal information.

9. International Transfers

EMPENHANCE operates internationally. Personal information may be transferred to and processed in jurisdictions outside an individual's country of residence, including Canada.

Where required, we implement appropriate safeguards to protect transferred information, including contractual protections and security measures consistent with applicable law.

10. Data Retention

We retain personal information only for as long as necessary to:

Deliver our services;
Complete courses;
Maintain learner records;
Verify certificates;
Resolve disputes;
Conduct investigations;
Meet legal obligations;
Protect Platform integrity.

Certain records may be retained for audit, compliance, legal defence, and evidentiary purposes.

11. Security Measures

EMPENHANCE maintains reasonable administrative, technical, and organizational safeguards designed to protect personal information against:

Unauthorized access;
Loss;
Misuse;
Disclosure;
Alteration;
Destruction.

No method of transmission or storage can be guaranteed to be completely secure.

12. Privacy Incidents and Reporting

Users and tutors should promptly report any suspected:

Unauthorized access;
Security breaches;
Privacy incidents;
Harassment;
Fraud;
Misuse of personal information;
Platform misconduct.

EMPENHANCE may investigate reported incidents and cooperate with appropriate authorities where necessary.

13. Individual Rights

13.1 Canadian Privacy Rights (PIPEDA)

Individuals may request:

Access to their personal information;
Correction of inaccurate information;
Information regarding our privacy practices.

Requests may be subject to legal limitations and verification requirements.

13.2 European Privacy Rights (GDPR)

Where GDPR applies, individuals may have rights to:

Access personal data;
Rectify inaccurate data;
Erase personal data;
Restrict processing;
Object to processing;
Data portability;
Withdraw consent;
Lodge complaints with supervisory authorities.

14. Children's Privacy

EMPENHANCE does not knowingly collect personal information from children in violation of applicable laws.

Where consent from a parent or legal guardian is required, users must obtain such authorization before using the Platform.

15. Confidentiality Obligations

Individuals with access to non-public information obtained through the Platform must maintain its confidentiality and use such information only for authorized purposes.

Confidential information includes:

Learner Data;
Platform operations;
Technical information;
Business information;
Review processes;
Non-public communications.

16. Changes to this Privacy Policy

We may update this Privacy Policy periodically to reflect changes in legal requirements, operational practices, or Platform functionality.

Material changes will be communicated through reasonable means, including email notifications, Platform notices, or updates posted on the Platform.

Continued use of the Platform following the effective date of an updated Privacy Policy constitutes acceptance of the revised policy.

17. Contact Us

If you have questions, concerns, requests, or complaints regarding this Privacy Policy or our handling of personal information, please contact:

EMPENHANCE EdTech Solutions Inc.
Privacy Officer
Ontario, Canada
Email: info@empenhance.com

If you are not satisfied with our response, you may contact the appropriate privacy regulator in your jurisdiction.

By using the Platform, you acknowledge that you have read and understood this Privacy Policy.