Privacy Policy

Oct 6, 2026

1. Introduction and Scope

This Privacy Policy explains how PEPfluent ("we," "us," or "our") collects, uses, discloses, and protects information in connection with the PEPfluent platform (the "Service"), used by families, schools, and students in Jamaica to prepare for the Primary Exit Profile (PEP) examinations.

This Policy applies to parents and guardians, the children they register, teachers, principals, school administrators, and sponsors. It should be read together with our Terms of Service. If you do not agree with this Policy, please do not use the Service.

2. Information We Collect

From a parent or guardian: name, email address, phone number, and password (stored in encrypted form, never in plain text).

About a child, provided by a parent, guardian, or school: first and last name, date of birth, gender, grade level, school, and class. A child's username and password are separate from the guardian's own login.

Generated by using the Service: diagnostic and practice answers, time spent, topic and subject mastery levels, session history, and progress over time. We also collect device and usage information such as browser type, IP address, and pages visited, for security and reliability purposes.

From a school: school name, parish, contact details, and the names and roles of staff the school's principal or administrator chooses to add.

From a sponsor: name, email address, and payment information, collected only at the time of a sponsorship payment and processed by our payment provider; PEPfluent does not store full card numbers.

We do not knowingly collect more information about a child than is reasonably necessary to provide the Service, and we do not collect sensitive categories of information (such as health, religion, or government identification numbers) about a child.

3. Children's Information and Parental Consent

PEPfluent is designed for use by children under the guidance of a parent, guardian, or school, and a child cannot create their own account independently. We collect information about a child only:

• Directly from a parent or legal guardian, who provides verifiable consent by creating or linking the child's account; or
• From a school, acting on behalf of, and with the consent of, the child's parent or guardian, when the school enrolls the child through PEPfluent.

A parent or guardian may, at any time: review the information we hold about their child; correct inaccurate information; request that we stop collecting further information about their child; and request deletion of their child's account and associated data, subject to Section 9. Requests can be made by contacting us at the email address in Section 13.

We do not use a child's information for targeted advertising, and we do not sell a child's information to third parties. A child's practice answers, mistakes, and detailed activity are never shown to anyone outside the child's own family and the staff of their own school who are authorized to view them; a sponsor never sees this detail, as explained in Section 6.

4. How We Use Information

We use the information we collect to:

• Operate the Service, including creating accounts, delivering diagnostic and practice content, and tracking progress;
• Generate reports for a parent, guardian, teacher, principal, or school administrator about a student's own progress;
• Communicate with you, including account notices, password resets, and (where you have agreed to receive them) updates about the Service;
• Maintain the security, integrity, and proper functioning of the Service, including detecting and preventing fraud or abuse;
• Process payments, where applicable, through our payment provider; and
• Understand usage patterns at an aggregate level, to improve the Service and the quality of its content.

We do not use a child's personal information to build an advertising profile, and we do not use it for any purpose unrelated to providing and improving the Service.

5. How We Share Information

We do not sell personal information. We share information only in the following circumstances:

• Within a family: a primary guardian and any co-guardian they add can see their own children's information. If a guardian's account is deactivated, that guardian loses access to the child's information, but other active guardians and the child's school are unaffected.
• With a child's school: teachers and administrators at a student's own school can see that student's name, grade, class, and progress information, for the purpose of supporting their learning. They cannot see billing or payment information.
• With service providers: we use third-party providers for hosting and database services, payment processing, and email delivery, each of whom is contractually required to protect your information and use it only to provide services to us.
• With sponsors: only as described in Section 6, and only to the extent a guardian has consented.
• For legal reasons: if required to comply with a legal obligation, protect the safety of a child or others, or protect PEPfluent's rights, in each case limited to what is reasonably necessary.
• In a business transfer: if PEPfluent is involved in a merger, acquisition, or sale of assets, information may be transferred as part of that transaction, subject to this Policy or a policy offering at least equivalent protection.

6. Sponsorships and What Sponsors Can See

A sponsor is a person who pays for a student's or a school's access without ever receiving a PEPfluent login. What a sponsor can see is controlled entirely by the consent choice made by the student's guardian (or, for a school-wide link, by the school) when the sponsorship link is created:

• Progress shared: the sponsor sees the child's first name, grade, school, and a high-level summary of tier-level progress by subject (for example, "Proficient" in Mathematics). No individual answers, mistakes, question text, or percentage scores are shown.
• Progress not shared: the sponsor sees only that access has been funded, with no child's name and no progress information of any kind.
• School-level sponsorship: the sponsor sees only aggregate, anonymized figures, such as how many students are enrolled and how many seats remain to be funded. No individual child is ever identified.

A sponsor's own name, email, and payment details are visible to PEPfluent for processing the payment and are not shared with the sponsored student's family unless the sponsor chooses to identify themselves directly.

7. Schools, Teachers and Principals

When a child is enrolled through a school, that school's principal and administrators can manage the school's own staff and see school-level enrollment and progress information. A teacher can see information only for students in their own class or their school's unassigned pool, for the purpose of supporting those students.

School staff cannot see another school's data, and cannot see a family's billing or payment information. If a staff member's account is deactivated, or their school's account is deactivated, they immediately lose access to all student information; this does not affect the students' or families' own access to their accounts.

8. Data Storage, Security and International Transfer

Information is stored using reputable third-party cloud database and hosting providers. Access to personal information is restricted by role: a database-level security policy, independent of the application itself, ensures that a parent can see only their own children, a teacher only their own students, and so on, and this restriction cannot be bypassed by application code alone. Administrative access to raw data is limited to authorized PEPfluent personnel and is logged.

Passwords are stored using industry-standard encryption and are never visible to PEPfluent staff in readable form. We maintain records of significant administrative actions (such as an account being deactivated) for accountability, without storing the underlying personal details of what changed.

As PEPfluent's infrastructure providers operate internationally, information about users in Jamaica may be processed and stored on servers located outside Jamaica, including in the United States. Where this occurs, we take reasonable steps to ensure the information continues to be protected in a manner consistent with this Policy.

No method of storage or transmission is completely secure, and we cannot guarantee absolute security. If we become aware of a security incident affecting your personal information, we will notify you as required by applicable law.

9. Data Retention

We retain account and progress information for as long as the account remains active, and for a reasonable period afterward in case the account is reactivated or as needed to comply with legal, accounting, or safeguarding obligations. A deactivated account's data is retained but is not accessible for ordinary use.

If a parent or guardian requests deletion of their child's account, we will delete or anonymize the child's personal information within a reasonable time, except where we are required or permitted to retain certain records (for example, payment records, or records needed to investigate a safeguarding concern). Aggregated or anonymized information that no longer identifies a specific child may be retained to improve the Service.

10. Your Rights and Choices

Depending on your role and location, you may have the right to: access the personal information we hold about you or your child; correct inaccurate information; request deletion of information, subject to Section 9; object to or restrict certain processing; and receive a copy of your information in a portable format.

You can exercise most of these rights directly within the Service (for example, editing a profile or a child's details), or by contacting us at the email address in Section 13. We will respond to a verified request within a reasonable time and in accordance with applicable law. If you are not satisfied with our response, you may have the right to lodge a complaint with a relevant data protection authority.

11. Cookies and Similar Technologies

We use a limited number of essential cookies and similar technologies, primarily to keep you signed in and to remember your session. We do not use cookies for cross-site advertising or tracking, and we do not knowingly serve targeted advertisements to children. If this changes in the future, we will update this Policy and provide any notice or consent mechanism required by law.

12. Changes to This Policy

We may update this Privacy Policy from time to time, including to reflect new features, legal requirements, or the introduction of paid plans. If we make a material change, particularly one affecting how we handle a child's information, we will provide reasonable advance notice, such as an email to the address on your account or a notice within the Service, before the change takes effect.

13. Contact Us

If you have questions about this Privacy Policy, or wish to exercise any of the rights described above, please contact us at:

PEPfluent Attn: Rahel Wallace 876 Aeropost Way, KIN 22853 Miami, Florida 33206, United States hello@pepfluent.com