Data Sharing Policy

This Data Sharing Policy explains how Astute Verse collects, uses, shares, discloses, and protects Customer Data and Personal Data in connection with the Astute Verity AI service ("Service").

Astute Verse shares information only where necessary to deliver the Service, support authorized educational activities, maintain the security and integrity of the Service, comply with applicable legal obligations, or as otherwise authorized by the Customer.

1.1 Scope

This Policy applies to Customer Data and Personal Data processed by Astute Verse in connection with the Service and describes the circumstances under which such information may be shared with Customers, Authorized Users, service providers, educational institutions, government authorities, and other permitted recipients.

1.2 Relationship with Other Policies

This Policy should be read together with the Terms of Service, Privacy Policy, Data Processing Agreement (where applicable), and any applicable commercial agreement. In the event of any conflict, the applicable written commercial agreement shall prevail to the extent of the inconsistency.

Astute Verse shares only the information that is necessary to operate the Service, fulfill the Customer's instructions, provide authorized educational services, comply with applicable legal obligations, or as otherwise described in this Policy.

2.1 Account and Authentication Information

Astute Verse may share information required to authenticate and manage access to the Service, including:

• Institution-managed authentication information;

• User account identifiers;

• User roles (such as Student, Teacher, Parent/Guardian, School Administrator, or District Administrator); and

• Access and authorization information necessary to provide the Service.

2.2 Educational Information

Astute Verse may share educational information necessary to deliver the Service, including:

• School, district, class, grade, and curriculum information;

• Learning progress and performance data;

• Assessment results;

• Instructional reports; and

• Other educational records authorized by the Customer.

2.3 Learning Interactions

Astute Verse may share learning interactions submitted through the Service, including:

• AI tutoring interactions;

• Student responses and learning activities;

• Session progress and instructional interactions; and

• Other information generated through a user's use of the Service.

2.4 Operational Information

Astute Verse may share operational information necessary to support, secure, and improve the Service, including:

• Security and audit logs;

• Service monitoring information;

• Diagnostic and troubleshooting information;

• Fraud, abuse, and misuse detection information; and

• System performance and reliability information.

2.5 Data Minimization

Astute Verse follows the principle of data minimization and shares only the information reasonably necessary to provide the Service, support authorized educational activities, maintain the security and integrity of the Service, comply with applicable legal obligations, or fulfill the Customer's documented instructions.

Astute Verse shares Customer Data only with authorized recipients and only to the extent necessary to provide the Service, support authorized educational activities, comply with applicable legal obligations, or as otherwise authorized by the Customer.

3.1 Educational Institutions

Astute Verse may share Customer Data with the Customer, including participating schools, school districts, educational institutions, and other authorized educational organizations, to:

• Administer the Service;

• Support instructional activities;

• Monitor student progress and performance;

• Review assessments and instructional reports; and

• Fulfill other educational purposes authorized by the Customer.

3.2 Teachers and School Administrators

Astute Verse may share information with authorized teachers, school administrators, and district administrators to:

• Deliver classroom instruction;

• Monitor student participation and learning progress;

• Review assessments, reports, and learning insights; and

• Support educational interventions and instructional decision-making.

3.3 Parents and Guardians

Where authorized by the Customer or permitted under applicable law, Astute Verse may share student learning information with parents or legal guardians to provide visibility into student learning progress, assessments, and other educational information made available by the Institution.

3.4 Service Providers

Astute Verse may share limited Customer Data with trusted third-party service providers that support the operation of the Service, including cloud hosting, infrastructure, storage, monitoring, security, identity management, communications, and other operational services.

Astute Verse currently utilizes providers such as Microsoft Azure for cloud hosting and infrastructure. The specific service providers used by Astute Verse may change from time to time based on business, technical, security, operational, legal, or regulatory requirements.

These providers process Customer Data only on Astute Verse's behalf and only for the purposes authorized by Astute Verse and the Customer.

3.5 Artificial Intelligence Service Providers

Certain AI Features within the Service utilize trusted third-party AI service providers to deliver tutoring, instructional assistance, content generation, and other AI-powered functionality.

Astute Verse currently utilizes providers such as OpenAI Business Services to support certain AI Features available through the Service. The AI service providers used by Astute Verse may change from time to time based on business, technical, security, operational, legal, or regulatory requirements.

Astute Verse shares only the minimum Customer Data reasonably necessary to provide the requested AI functionality. Third-party AI service providers process Customer Data solely to perform the requested services on behalf of Astute Verse and do not obtain any ownership, intellectual property, or independent rights in Customer Data.

3.6 Data Minimization

Astute Verse follows the principle of data minimization and shares only the minimum Customer Data reasonably necessary for each authorized recipient to perform its permitted educational, operational, security, or legal function.

Astute Verse engages trusted third-party service providers only where necessary to operate, secure, maintain, and support the Service. Such providers process Customer Data solely on behalf of Astute Verse and only for the purposes authorized by Astute Verse and the Customer.

4.1 Cloud Hosting and Infrastructure Providers

Astute Verse currently utilizes providers such as Microsoft Azure to deliver cloud hosting, infrastructure, storage, encryption, backup, monitoring, disaster recovery, and security services required for the operation of the Service.

These providers process Customer Data only as necessary to provide the contracted services and do not acquire ownership of Customer Data.

The cloud infrastructure providers used by Astute Verse may change from time to time based on business, technical, security, operational, legal, or regulatory requirements.

4.2 Artificial Intelligence Service Providers

Astute Verse currently utilizes providers such as OpenAI Business Services to deliver certain AI Features, including AI-assisted tutoring, instructional assistance, content generation, and other functionality available through the Service.

Customer Data shared with AI service providers is processed solely to provide the requested functionality on behalf of Astute Verse and in accordance with applicable contractual commitments, this Policy, the Privacy Policy, and applicable law.

Consistent with current business service commitments, Customer Data processed through OpenAI Business Services is not used to train or improve OpenAI's foundation models by default.

The AI service providers used by Astute Verse may change from time to time based on business, technical, security, operational, legal, or regulatory requirements.

4.3 Service Provider Restrictions

Astute Verse requires its third-party service providers to process Customer Data only for the purposes of delivering the contracted services.

Unless otherwise authorized by the Customer or required by applicable law, third-party service providers must not:

• Use Customer Data for advertising or marketing purposes;

• Sell or commercially exploit Customer Data;

• Create independent customer profiles unrelated to the Service;

• Use Customer Data for purposes outside the services they provide to Astute Verse; or

• Acquire ownership of Customer Data.

Astute Verse is committed to protecting Customer Data and Personal Data. Except as expressly described in this Policy, authorized by the Customer, or required by applicable law, Astute Verse does not disclose Customer Data for purposes unrelated to providing the Service.

5.1 Prohibited Data Sharing Practices

Astute Verse does not:

• Sell Customer Data, Personal Data, or Educational Records.

• Rent, lease, or license Customer Data to third parties for their independent use.

• Share Customer Data for advertising or marketing purposes.

• Use Customer Data for behavioral advertising or cross-context behavioral advertising.

• Build commercial marketing profiles using Customer Data or Personal Data.

• Use Customer Data to train publicly available or generally available artificial intelligence models.

• Share Educational Records except as authorized by the Customer or required by applicable law.

5.2 No Commercial Exploitation

Astute Verse does not commercially exploit Customer Data or Personal Data for purposes unrelated to providing, maintaining, securing, supporting, or improving the Service.

5.3 Customer Control

Astute Verse shares Customer Data only:

• At the direction of the Customer;

• As necessary to provide the Service;

• As described in this Policy;

• As required by applicable law; or

• As otherwise authorized by the Customer.

Astute Verse may disclose Customer Data where required to comply with applicable law, protect the security and integrity of the Service, or safeguard the rights, safety, or property of Astute Verse, the Customer, Authorized Users, or others.

6.1 Compliance with Legal Obligations

Astute Verse may disclose Customer Data where required to:

• Comply with applicable laws, regulations, or governmental requirements;

• Respond to a valid subpoena, court order, warrant, or other legal process;

• Cooperate with law enforcement or regulatory authorities where required by applicable law; or

• Enforce Astute Verse's legal rights or contractual obligations.

6.2 Protection of Rights, Safety, and Security

Astute Verse may disclose Customer Data where reasonably necessary to:

• Protect the rights, safety, or property of Astute Verse, the Customer, Authorized Users, or other individuals;

• Investigate suspected fraud, abuse, misuse, or other unlawful activity;

• Detect, prevent, or respond to security incidents or cyber threats; or

• Protect the security, integrity, availability, or reliability of the Service.

6.3 Customer Notification

Where legally permitted and reasonably practicable, Astute Verse will notify the applicable Customer before disclosing Customer Data in response to a legal request.

If prior notice is prohibited by law or would interfere with a legal investigation, Astute Verse will provide notice as soon as legally permitted.

Astute Verse uses and shares Customer Data solely to provide the Service, support authorized educational activities, fulfill the Customer's documented instructions, comply with applicable legal obligations, or as otherwise described in this Policy.

7.1 Instructional Support

Customer Data may be used to:

• Deliver personalized learning experiences;

• Provide AI-assisted tutoring and instructional guidance;

• Support adaptive learning pathways; and

• Deliver educational content and learning activities through the Service.

7.2 Learning Progress and Assessment

Customer Data may be used to:

• Measure student progress and learning outcomes;

• Evaluate assessments and learning activities;

• Generate instructional reports and learning insights; and

• Support educators in monitoring student performance and identifying opportunities for instructional support.

7.3 Educational Administration

Customer Data may be used to:

• Support school-authorized educational programs and activities;

• Enable classroom, school, and district reporting;

• Facilitate implementation and administration of the Service; and

• Support institutional oversight of educational programs.

7.4 Service Operations

Customer Data may be used to:

• Maintain the security, integrity, and availability of the Service;

• Monitor system performance and reliability;

• Detect, prevent, and investigate fraud, abuse, misuse, and security incidents; and

• Support troubleshooting, maintenance, and continuous improvement of the Service.

Astute Verse implements and maintains appropriate administrative, technical, organizational, and physical safeguards designed to protect Customer Data against unauthorized access, disclosure, alteration, loss, misuse, or destruction, taking into account the nature of the information processed and the risks associated with such processing.

8.1 Security Safeguards

Astute Verse maintains security measures designed to protect Customer Data, including:

• Encryption of Customer Data during transmission;

• Encryption of Customer Data at rest, where appropriate;

• Role-based and least-privilege access controls;

• Secure cloud infrastructure, hosting, storage, and backup services.

• Security monitoring, logging, and auditing;

• Vulnerability management and security patching; and

• Security controls designed to detect, prevent, and respond to unauthorized access or security incidents.

8.2 Access Controls

Access to Customer Data is limited to authorized personnel, contractors, and approved service providers who require such access to perform their authorized responsibilities and who are bound by appropriate confidentiality, security, and contractual obligations.

8.3 Secure Data Handling

Astute Verse is committed to protecting Customer Data throughout its lifecycle. As part of this commitment:

• Production Customer Data is not stored on employee devices.

• Production Customer Data is not maintained in local development environments.

• Access to production environments is restricted to authorized personnel with a legitimate business need.

• Customer Data is processed in accordance with this Policy, the Privacy Policy, applicable commercial agreements, and applicable law.

8.4 Continuous Security Improvement

Astute Verse continually reviews and enhances its security practices to address evolving threats, technological developments, industry standards, and applicable legal and regulatory requirements.

Astute Verse is committed to supporting the Customer's compliance with applicable student privacy and data protection laws. The Service is designed to support educational institutions in meeting their legal obligations while protecting Customer Data and Educational Records.

9.1 Compliance with Applicable Laws

Astute Verse designs and operates the Service to support compliance with applicable United States student privacy laws and regulations, including, but not limited to, the following :

• The Family Educational Rights and Privacy Act (FERPA);

• The Children's Online Privacy Protection Act (COPPA); and

• Other applicable federal, state, and local student privacy and data protection laws.

Nothing in this Policy relieves the Customer of its own legal obligations under applicable law.

9.2 Educational Purpose Limitation

Customer Data and Educational Records are processed and shared solely for authorized educational, administrative, operational, security, and legal purposes in accordance with this Policy, the Privacy Policy, the Terms of Service, applicable commercial agreements, and applicable law.

Astute Verse does not process or disclose Customer Data for unrelated commercial activities.

9.3 Student Privacy Commitment

Astute Verse is committed to protecting the privacy of students, educators, parents or guardians, and educational institutions by implementing appropriate safeguards and limiting the collection, use, and sharing of Customer Data to what is reasonably necessary to provide the Service.

Astute Verse may update this Data Sharing Policy from time to time to reflect changes in applicable law, regulatory requirements, industry standards, the functionality of the Service, security practices, or relationships with third-party service providers.

10.1 Policy Revisions

Astute Verse reserves the right to modify this Data Sharing Policy at any time. Updates may be made to:

• Reflect changes in applicable laws or regulations;

• Address changes to the Service or its functionality;

• Reflect changes to security practices or operational processes;

• Reflect changes to third-party service providers; or

• Improve the clarity or accuracy of this Policy.

10.2 Publication of Updates

The most current version of this Data Sharing Policy will be made available through the Service or on Astute Verse's website. The "Last Updated" date at the beginning or end of this Policy will indicate when the most recent revisions became effective.

10.3 Material Changes

Where required by applicable law or contractual obligations, Astute Verse will provide reasonable notice of material changes to this Policy before such changes become effective.

Continued use of the Service following the effective date of an updated Policy constitutes acceptance of the revised Policy, except where applicable law or a written agreement with the Customer requires a different process.

If you have any questions about this Data Sharing Policy, Astute Verse's data sharing practices, or the handling of Customer Data, please contact us using the information below.

11.1 Privacy Inquiries

Questions regarding this Data Sharing Policy, privacy practices, or requests relating to Customer Data may be directed to Astute Verse's Privacy Team.

Privacy Team

Email: : support@astuteverse.com

Website: https://astuteverity.astuteverse.com/

Address: ASTUTE VERSE PRIVATE LIMITED

25A/61A, 5th Phase, Maharani Avenue, Vadavalli,

Coimbatore – 641041, Tamil Nadu, India

Contact Number: +91 4223552883

11.2 Customer Support

For general product support or operational questions regarding the Service, Customers may contact Astute Verse through the support channels available on the Astute Verse website.

11.3 Policy Availability

The most current version of this Data Sharing Policy will be available through the Service or on the Astute Verse website. Customers are encouraged to review this Policy periodically to remain informed about Astute Verse's data sharing practices.

By accessing or using the Service, Customers acknowledge that they have reviewed this Data Sharing Policy and understand how Astute Verse collects, uses, protects, and shares Customer Data in accordance with this Policy, the Privacy Policy, the Terms of Service, applicable commercial agreements, and applicable law.