Privacy Policy

1. Who uses Glentavo

A parent or legal guardian ("Parent") creates the account, gives consent, pays, and creates up to three child profiles. A child uses Glentavo only inside the Parent's account, signing in with a scarf color and a PIN. We never ask a child for a real name, birthday, school, email address, phone number, photo or home address.

2. What we collect

From Parents:

• Account: email address and password (stored hashed), or the identifier Google provides if you sign in with Google; your language and time zone.
• Purchases: the Package, the child it is for, order number, amount and receipt. Card details go directly to Stripe; we never receive them.
• Consent records: which version of which document you accepted, when, how, and from which IP address and browser.
• Security records: the IP address of Parent and staff actions, and short-lived rate-limit records.
• Email delivery and opens, so we know whether the weekly report is being read.
• Messages you send to our support address.

About children, through the child profile:

• Profile: nickname, grade, whether the child attends school in the United States, the scarf color and the PIN (stored hashed).
• Learning data: every answer, the time spent on each question, answer events, and the passages the child highlights.
• Essays the child types during a practice test.
• If the Parent chooses to enter them: the test date, the extended-time setting, real test scores and admission results. Only the Parent can see admission results.

To keep a device signed in we use a random device identifier that we issue ourselves and a session. We do not record the IP address of children's actions.

Visits to our public website glentavo.com are counted by Cloudflare Web Analytics, which sets no cookies.

We collect from a child only what is reasonably necessary to provide the study service, and we do not require more than that for a child to take part.

3. How we use information

• To run the service: practice tests and practice sets, the study plan, cycle reports and weekly reports for the Parent, and the child's progress.
• To run the account: sign-in, purchases, receipts, refunds, support, and the emails in Section 7.
• To keep the service safe: preventing abuse, security records and error monitoring.
• To improve the service: aggregated, de-identified statistics (for example, how hard a question is) to calibrate our questions. These statistics cannot identify a child.

We do not use children's personal information for marketing or advertising, and we do not use it to train AI models. In the 2026–27 winter season no AI service receives children's answers or essays.

4. Who else processes the data

We share personal information only with the companies that help us run Glentavo, and only for that purpose. We do not sell personal information and do not share it with advertisers or data brokers.

• Supabase: database and sign-in (US East). Handles all account, profile and learning data.
• Vercel: hosts the app (US East). Data passes through it when you use the app.
• Stripe: payments and receipts. Handles the Parent's payment details and order amounts; it does not receive your child's information.
• Resend: sends our emails. Handles the Parent's email address and the emails we send.
• Sentry: error monitoring. Handles technical error data; it is set up not to receive children's nicknames or essays and not to store IP addresses.
• Google: optional sign-in for Parents. Handles your Google account identifier and email, only if you choose to sign in with Google.
• Cloudflare: our domain and our public website glentavo.com. It does not handle the data in the app.
• Google Workspace: our support mailbox. Handles the messages you send to our support address.

Before a child's personal information would be given to anyone for a purpose other than running the service, we will ask the Parent for a separate consent first. We add a provider to this list before it handles any child's personal information.

5. Cookies

The app uses only the cookies it needs: your session, the device sign-in, the child you looked at last, and your language. Our public website sets no cookies. We do not use advertising or cross-site tracking cookies.

6. How long we keep data (our data retention policy)

For each kind of information, here is how long we keep it and why:

• Parent account information (email address, password hash or Google identifier, language, time zone): kept while the account exists.
• An account that never buys a Package: deleted after 180 days without a sign-in, so a family can come back to its free Start. We email the Parent 30 days before; signing in keeps such an account.
• A paid child's data (profile, learning data, essays, reports): kept so you can still read the reports and your child can return for a later season, then deleted 24 months after the last purchase for that child ends. We email the Parent 30 days before.
• Order records: kept for 7 years for tax and accounting, and separated from the child once the child's data is deleted. Stripe keeps payment records under its own policy.
• Audit records: kept as long as order records, with the child replaced by a placeholder once the child's data is deleted. Consent records: kept while the account exists and deleted with it.
• Rate-limit records that contain an IP address: kept for 30 days, to stop abuse.
• Other rate-limit records, which count attempts by account, child or device and contain no IP address: kept for up to 7 days.
• The device identifier: deleted when you revoke (remove) the device, or with the account; a revoked device can no longer sign in until you set it up again. Audit records that mention the device keep that reference for as long as audit records are kept (above), and counts of wrong PINs entered on the device are kept for 7 days. Sessions stop working when you sign out or they expire.
• Email delivery and open records: kept with the record of that email and deleted with it.
• Visit statistics for glentavo.com: aggregate counts kept by Cloudflare under its own default settings.
• When you delete a child's data or your account, it is deleted after the 7-day undo period. Copies in our backups disappear within 30 days.

7. Emails we send

Account emails (email verification, password reset, consent confirmation, data requests and deletion notices), receipts, the weekly report (with a one-click unsubscribe link), a reminder if your child has not signed in yet, and a reminder when a practice test was interrupted. We do not send marketing emails, and we never email children.

8. Your rights and choices

The account page has three buttons. Each asks you to enter your password again (or confirm with Google), and each is recorded:

• Request my data: we prepare a file with your child's answers, essays, report facts, profile and your consent records, within 30 days.
• Delete this child's data: stops all collection for that child. You can undo it for 7 days; after that the data is deleted for good.
• Delete my account: deletes all child profiles and your account, with the same 7-day undo.

Withdrawing consent works the same way as deleting the child's data. Deleting does not give a refund. You can see everything your child has done in the parent pages, and you can turn off the weekly report from its unsubscribe link. Questions: support@glentavo.com.

9. How we get a parent's consent

When you create an account, you read a short notice and tick three boxes, none ticked in advance: one confirms that you are the child's parent or legal guardian and at least 18, one gives your consent to the notice, and one agrees to our Terms of Service and this Privacy Policy. After you verify your email address, we send a confirmation email that repeats what you consented to and how to withdraw. When you pay for a Package or redeem a code, you confirm again.

Giving a child's personal information to anyone for a new purpose would need a separate, specific consent from you first.

If we make a material change to how we handle children's information, you will see a summary of the changes the next time you sign in, and you will need to consent again before you can use the parent pages. Your child can keep practicing for 14 days in the meantime; after that, practice pauses until you consent again.

10. Security

Data is encrypted in transit and at rest. Passwords and children's PINs are stored hashed. Only a small number of staff can see account data, and our administrators sign in with a second step. If we learn of a breach affecting your data, we will tell you as the law requires.

11. Where data is stored

All data is stored in the United States. If you use Glentavo from outside the United States, including from mainland China, your and your child's information is transferred to and processed in the United States under US law and this policy. We do not market Glentavo in mainland China.

12. Selling and targeted advertising

We do not sell personal information and do not do targeted advertising, so there is nothing to opt out of.

13. Changes to this policy

The version number and effective date appear at the top of this page.

If we make a material change to how we handle children's information, you will see a summary of the changes the next time you sign in, and you will need to consent again before you can use the parent pages. Your child can keep practicing for 14 days in the meantime; after that, practice pauses until you consent again.

14. Contact

Spruce Health Sciences, Inc., which operates Glentavo · support@glentavo.com. You may also contact the US Federal Trade Commission about COPPA.