Effective Date: April 2026 Last Updated: April 2026

TLVI PRIVACY POLICY

At Teaching Lab Ventures Inc. (TLVI), we are committed to protecting the privacy of Educators and Students who interact with our platform. This Privacy Policy explains how Coteach - a product being incubated at TLVI - collects, uses, discloses, and safeguards information in connection with the Service.

DEFINITIONS

For the purposes of this Privacy Policy, the following capitalized terms have the meanings set forth below:

• Coteach.ai (or "we," "us," or "our"): Refers to the Coteach.ai platform and the company operating it.
• Service: The Coteach.ai website, platform, tools, and related features provided for educational use.
• School: A school, district, or educational institution that contracts with or authorizes use of Coteach.ai.
• Educator: Teachers, administrators, school staff, or other individuals authorized by a School to use the Service for educational purposes.
• Educator Data: Any information collected from or about Educators, including account information, profile details, usage data, and technical information.
• Student: A K-12 student or any individual under the age of 18 whose data may be processed through the Service.
• Student Data: Any information that relates to an identifiable Student and is provided or uploaded by a User, or generated through the Service in connection with educational activities. This includes, but is not limited to, student names, identifiers, or work samples explicitly input by Educators.
• Personal Information: Information that identifies, relates to, or could reasonably be linked with a particular Educator or Student.
• Child: A Student under the age of 13 (for purposes of COPPA) or as otherwise defined under applicable law.
• De-identified Data: Information that has been processed so that it cannot reasonably be used to identify an individual Educator or Student, and from which re-identification has been prevented through reasonable means.
• Subprocessor: Any third-party service provider engaged by Coteach.ai to process data on its behalf under strict contractual safeguards.

Important Note: Coteach.ai is designed to operate with minimal to no Student Data collection. Educators can use many features without entering or uploading identifiable Student Data. We strongly recommend using the platform in ways that avoid sharing Student Personal Information.

1. EDUCATOR DATA

Information We Collect from Educators

We may collect:

• Account information (name, email address, school affiliation, password).
• Profile details (optional: subject area, grade level, preferences).
• Usage data (interactions with the platform, generated content, session logs).
• Device and technical information (IP address, browser type) for security and service improvement.

We do not require or encourage entry of sensitive personal information beyond what is necessary for account creation and service delivery.

How We Use Educator Data

Educator Data is used solely to:

• Provide, maintain, and improve the Service.
• Authenticate accounts and enable features such as session creation and collaboration tools.
• Offer customer support.
• Send essential service-related communications (e.g., account updates, security notices).

We pledge that we will never:

• Use any Educator Data to train, retrain, or improve artificial intelligence or machine learning models.
• Use Educator Data for marketing, advertising, or promotional purposes.
• Sell, rent, or share Educator Data with third parties for commercial purposes.

We may use De-identified Data derived from Educator Data for internal analytics and platform improvement only.

Data Sharing

We share Educator Data only in limited cases:

• With Subprocessors who help operate the Service, bound by strict confidentiality and data processing agreements that prohibit AI training and marketing use.
• With vetted research partners for non-commercial educational or scientific research purposes, subject to written research agreements that require confidentiality, data security, prohibition of AI training, marketing, commercial use, or re-identification, and require deletion of the data upon completion of the research.
• To comply with legal obligations (e.g., court orders or subpoenas).
• In the event of a merger, acquisition, or sale of assets, with notice to affected users where required.
• With your School upon their verified request, consistent with applicable agreements.

We do not share identifiable Educator Data for any marketing or non-educational purposes.

2. STUDENT DATA

Student Data We May Collect (Limited)

Student Data is only collected if an Educator explicitly inputs it or when a Student completes or uploads assignments, work samples, or other educational materials through features authorized by their Educator or School (e.g., student names in assessment analyses). We do not require Student accounts or direct Student logins for core features. Any Student-related data remains under the control of the Educator and their School.

How We Use Student Data

Student Data is used exclusively for the educational purposes authorized by the Educator or School, such as analyzing assessments or creating instructional materials.

We make the following strict pledges:

• We will never use any Student Data to train, retrain, or improve artificial intelligence or machine learning models (including third-party models). All AI processing is transient where possible, with zero data retention for training purposes.
• We will never use Student Data for marketing, advertising, behavioral profiling, targeted advertising, or any commercial purposes.
• We will never sell, rent, or share Student Data with third parties except as strictly necessary to provide the Service, for approved educational research purposes as described in the Data Sharing section, or as required by law.

De-identified Data

We may create and use De-identified Data for internal analytics and platform improvement only. Such data is stripped of any information that could reasonably identify an individual Educator or Student. We will not attempt to re-identify De-identified Data, nor will we use it for marketing, advertising, or any purpose other than internal service enhancement and analytics. We may also share De-identified Data with vetted research partners under the same strict safeguards described in the Data Sharing section.

Data Sharing and Third Parties

Student Data is shared only:

• With the Educator or authorized School personnel who provided it.
• With vetted Subprocessors bound by contracts that prohibit any use beyond service delivery, including prohibitions on AI training or marketing.
• With approved research partners for non-commercial educational research purposes, only with prior School authorization and preferably using De-identified Data. Such sharing will be governed by written agreements compliant with FERPA, COPPA, and other applicable laws, prohibiting AI training, marketing, commercial use, re-identification, and limiting use to the specific research project.
• To comply with legal requirements (e.g., subpoenas) or protect safety.

We do not engage in cross-context tracking, profiling, or any practices that could harm Students.

SECURITY

We implement industry-standard technical, administrative, and physical safeguards, including encryption of data in transit and at rest, access controls, regular security audits, vulnerability monitoring, and intrusion detection. In the event of a data breach involving Personal Information, we will notify affected Educators, Schools, and relevant authorities without unreasonable delay as required by law.

We maintain a current list of our Subprocessors, including certain research partners, which is available upon request at privacy@coteach.ai. All data is stored in secure facilities located in the United States.

COOKIES AND SIMILAR TECHNOLOGIES

We use essential cookies and similar technologies to operate the Service, authenticate users, and maintain security. We do not use tracking cookies for marketing or advertising purposes. For more details on our cookie practices, please contact privacy@coteach.ai.

DATA RETENTION AND DELETION

We retain Educator Data and Student Data only as long as necessary to provide the Service or fulfill legal obligations. Upon account deletion, termination of your subscription, or termination of a School contract, we will delete or return all applicable data within 60 days (except where retention is required by law) and provide certification of deletion upon request. Educators and Schools control access to and deletion of their data.

COMPLIANCE WITH EDUCATION LAWS

We act as a service provider to Schools and comply with applicable laws, including the Family Educational Rights and Privacy Act (FERPA) — acting as a "school official" when processing Student Data under School agreements — the Children's Online Privacy Protection Act (COPPA), and state student privacy laws (such as SOPIPA). When Schools enter into a Data Privacy Agreement (DPA), we adhere to its terms.

Educators are responsible for ensuring that they have all necessary authorizations or consents from their School (and, where required, from parents or guardians) before inputting any Student Data or allowing Student to upload any Student Data into the Service, and for complying with their School's policies and applicable laws. Because we process Student Data on behalf of Schools, parents or guardians with questions, requests, or concerns regarding their child's Student Data (including rights to access, correction, or deletion) should direct those requests to their child's School. We will forward any such requests we receive to the relevant School for handling.

YOUR RIGHTS

Educators may access, correct, or update their information via account settings or by contacting us.

Schools and Educators may request deletion of Educator Data or Student Data (subject to legal retention requirements).

For School-managed accounts, rights requests should be directed through the School administrator.

CHANGES TO THIS POLICY

We may update this policy periodically. We will notify Educators and Schools of material changes via email or in-app notice and post the updated policy with a new "Last Updated" date.

CONTACT US

If you have any questions about this Privacy Policy, please contact us at: privacy@coteach.ai

By using Coteach.ai, you acknowledge that you have read and understood this policy. This policy works alongside our Terms of Service.