AI Teacher Coaching Solution
(Privacy Policy)

Introduction

Welcome to AI Teacher Coaching Solution (“Application”, “we”, “our”, or “us”). We are committed to protecting your privacy and ensuring the security of your personal data (personal data means information that might identify you personally, for example your name or email address). This Privacy Policy outlines how we collect, use, disclose, and protect, your data in compliance with the Digital Personal Data Protection Act, 2023 (DPDP Act, 2023). The application’s main functionality is described below:

1. Literacy Coach Pro: This is a mobile application and intended for Literacy Facilitator (LF) also called coach.
   1. What features this application module has: The features of this application for the coaches are as below, They can:
      1. View the assigned Schools
      2. View the Teacher’s name, the name of the assigned schools, their previous sessions feedback, action items, no of sessions received this year, no. of sessions received this month, current priority area, pending action plans and no. of teacher app sessions this month.
      3. Create/edit the session schedule with the teachers assigned to them.
      4. View training materials, user can access previously downloaded in device files training resources and materials offline
      5. Change their own phone number and email address.
      6. View privacy policy, terms and conditions, FAQs and about us.
      7. Change Language- English and Hindi
      8. Send requests to the admin to add/edit teachers for their assigned schools.
      9. Query with the copilot on training materials and the previous session feedback.

Questions or concerns? Reading this Privacy policy will help you understand your privacy rights and choices. If you do not agree with this policy and practices, please do not use this application. If you still have any questions or concerns, please contact us at the address given in the contact information section.

Table of Contents

1. What information do we collect?
2. How do we process your information?
3. What is the Legal Basis for collecting and processing your information?
4. What are data storage and security measures?
5. Do we use any AI Model for processing your information?
6. Is there any data sharing and third-party involvement?
7. What are your privacy rights?
8. How long do we keep your information?
9. What about children’s privacy while classroom video recording?
10. What is the policy if any data breach detected?
11. Do we use Cookies or third-party tracker?
12. How can you contact us about this policy?

By using our application, you consent to the practices described in this Privacy Policy.

1. What Information do we Collect?

• Personal Information: The personal information we collect may include the name, gender, email address, phone number, country, state, district, block, and recordings of classroom sessions which may include voices of teachers, and only collect it where needed.

2. How do we process your Information?

Your personal data mentioned above will be used for authentication, account management and personalized service and content (for example to Analyze classroom recordings to provide coaching feedback, generate AI-based feedback and recommendations) and administrative and organizational purposes like coaches getting in contact with teachers.

3. What is the Legal Basis for collecting and processing information?

Our processing of your personal data is based on:

• Consent: Explicit consent for video recording for, AI feedback, and other data processing activities.

4. What are the Data Storage and Security Measures in place?

• Storage: Data stored on Cloud in India data center.
• Security: We implement appropriate technical and organizational measures to ensure effective adherence to Indian data privacy laws and take reasonable security safeguards to prevent a breach. These include end-to-end encryption (encryption in transit & rest), DPDP-aligned privacy compliance, role-based access for data segregation.
• AI Processing: Our AI model (GPT-4o Mini) adheres to stringent security standards when processing data. You can also refer to OpenAI's enterprise-level privacy policy at this link (https://openai.com/enterprise-privacy/). Other AI models used for video analysis are hosted in cloud data center, located in India.

5. Do we use AI Model for Data processing and Analysis?

• Feedback & copilot: We are using AI LLM (GPT-4o Mini) for feedback based on classroom observation form, and query with the copilot related to training material.
• Video Analysis: We are using small AI models for Audio Extraction, Object Detection, and Gesture Recognition, and these models will be open source and hosted on our India located cloud server with adhering the India data privacy laws. Videos never leave the cloud infrastructure. No external API or third-party SaaS involved in video processing.
• Personal information Anonymization: Before any data sharing with GPT or any AI model, personally identifiable information (PII) such as names, gender, emails, phone numbers, and school codes are anonymized. Feedback and questions sent to the GPT-based co-pilot do not include PII information.
• This app uses AI to generate responses, which may not always be accurate. AI chat functionality requires an active internet connection.

6. Is there any Data Sharing & Third-Party Involvement?

We do not sell or rent your data. Information may be shared with:

• Service Providers: Such as Azure Cloud and AI service providers hosted in India only. For the services hosted outside of India, we do not pass any PII data for processing. For technical support purposes, the cloud server will be accessible to our technology partner until an agreement is signed with us. After that, they will hand over and destroy all data related to this project.
• Legal Authorities: When required by law or regulator or for safety concerns.
• Evaluation Partners: For evaluation of data to see the progress and outcome overtime, our evaluation partner will have access to data during the pilot period (July-2025 to Jan-2026).

7. What are your Privacy Rights?

Under the DPDP Act, 2023, you have the right to:

• Right to withdraw your consent.
• Right to complain if you are concerned about your privacy. Contact legal@roomtoread.org
• Right to Access Information: You have the right to know:
  • What personal data is being collected about you.
  • For what purpose and how it is being used.
  • With whom your data has been shared.
• Right to Correction and Erasure: You can request:
  • Correction of inaccurate or misleading personal data.
  • Completion of incomplete personal data.
  • Erasure of personal data that is no longer necessary or was collected unlawfully.

8. How long do we keep your information?

• Personal and Login Data: Retained for up to <3> years following user inactivity.
• Video Recordings: Stored by project sponsor for data validation and analysis purposes until they are no longer needed but never more than <3> years.
• AI Query Logs: Processed transiently for service delivery and not stored permanently.

9. What about children’s privacy while classroom video recording?

Coaches must ensure that classroom recordings comply with the consent form from the teacher, school and students’ guardians regarding student privacy.

10. What is the policy if any data breach detected?

In the event of a data breach:

• Users will be notified within the timeframes mandated by law.
• We will report incidents to the appropriate authorities as mandated by law.
• Immediate security measures will be implemented to mitigate further risks.

11. Do we use Cookies or third-party trackers?

• Usage: Our web-based Admin module may use cookies for session management.
• Policy: No third-party advertising trackers are implemented.

12. How can you contact us about this policy?

For any questions or concerns regarding this policy, please contact Room to Read at legal@roomtoread.org.