Version 3.0 • Effective: June 16, 2026
Document Reference: FBA-POLICY-V3-GLOBAL-2026
Future Builders Academy • fbalearning.com
Operated by Fortify Solutions Inc., Alberta, Canada
1. About This Policy and Who It Applies To
This document is the complete Privacy Policy, AI Disclosure, Terms of Use, and Child Safety Policy for the Future Builders Academy Learning OS portal. It applies to all users worldwide, regardless of country of access.
Future Builders Academy is operated by Fortify Solutions Inc., a company registered in Alberta, Canada. This policy has been written to comply with the privacy and child safety laws of Canada, the United States, the European Union, the United Kingdom, Gulf Cooperation Council member states, and Australia. Where the laws of different jurisdictions conflict, we apply the stricter standard.
By agreeing at the end of this document, the parent or legal guardian confirms they have read, understood, and accepted all terms on behalf of themselves and the child who will use this portal.
2. Jurisdiction-Specific Rights
Depending on where you are located, different privacy laws apply to you. The following table summarises the key frameworks and your rights under each.
Canada (Federal — PIPEDA)
Canada's Personal Information Protection and Electronic Documents Act (PIPEDA, S.C. 2000, c. 5) applies to all users in Canada. You have the right to access your data, correct inaccuracies, and withdraw consent at any time. We are required to identify the purpose of data collection before or at the time of collection, obtain meaningful consent, and protect personal information with appropriate security safeguards.
Canada (Alberta — PIPA)
Alberta's Personal Information Protection Act (PIPA, SA 2003, c P-6.5) applies to users in Alberta. Alberta PIPA largely mirrors PIPEDA with some provincial variations. Our Privacy Officer is accountable for compliance and can be reached at privacy@fbalearning.com.
United States — COPPA
The Children's Online Privacy Protection Act (COPPA, 15 U.S.C. §§ 1301–1308) applies to users in the United States where the student is under 13 years of age. We do not knowingly collect personal information from children under 13 without verifiable parental consent. This consent form constitutes verifiable parental consent under COPPA. Parents of children under 13 have the right to review the personal information we have collected about their child, direct us to delete it, and refuse to permit further collection. To exercise these rights contact: privacy@fbalearning.com
United States — CCPA (California)
California residents have additional rights under the California Consumer Privacy Act (CCPA, Cal. Civ. Code § 1798.100 et seq.). These include the right to know what personal information is collected, the right to delete personal information, the right to opt out of the sale of personal information (we do not sell personal information), and the right to non-discrimination for exercising these rights. California residents may submit requests to: privacy@fbalearning.com
United States — FERPA
If this portal is used in connection with a school or educational institution in the United States, the Family Educational Rights and Privacy Act (FERPA, 20 U.S.C. § 1232g) may apply. We act as a School Official under FERPA when operating under a formal agreement with a US educational institution. Student education records are protected and will not be disclosed without consent except as permitted by FERPA.
European Union — GDPR
The General Data Protection Regulation (GDPR, Regulation EU 2016/679) applies to users in the European Union and European Economic Area. Our legal bases for processing personal data under GDPR are as follows: we process student name and grade level on the basis of consent (Article 6(1)(a)); we process learning activity data on the basis of legitimate interests in providing the educational service (Article 6(1)(f)); we process search history on the basis of legitimate interests in child safety monitoring (Article 6(1)(f)). For children under 16, we process data on the basis of parental consent under Article 8 GDPR.
EU users have the following rights under GDPR: right of access (Article 15), right to rectification (Article 16), right to erasure / right to be forgotten (Article 17), right to restriction of processing (Article 18), right to data portability (Article 20), right to object (Article 21), and rights related to automated decision-making (Article 22). To exercise any of these rights contact: privacy@fbalearning.com. You also have the right to lodge a complaint with your national supervisory authority.
Canada has been granted adequacy status by the European Commission under Article 45 GDPR, meaning data transfers from the EU to Canada are permitted without additional safeguards. All data processed by this portal remains locally on your device and is not transferred to our servers.
United Kingdom — UK GDPR and Age Appropriate Design Code
The UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 apply to users in the United Kingdom. UK users have the same rights as EU GDPR users listed above. In addition, the UK Age Appropriate Design Code (Children's Code) applies to this service. We have designed this portal with child safety as the default: privacy settings are set to high by default, data minimisation is practised, the best interests of the child are a primary consideration, and no profiling of children is conducted.
Gulf Cooperation Council Countries
Users in the United Arab Emirates are subject to UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL). Users in the Kingdom of Saudi Arabia are subject to the Personal Data Protection Law (PDPL, Royal Decree M/19). Users in Qatar are subject to Law No. 13 of 2016. In all GCC jurisdictions, we obtain prior consent before processing personal data, process only what is necessary, and provide mechanisms to access, correct, and delete data. All requests should be directed to: privacy@fbalearning.com
Australia
Users in Australia are subject to the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). We comply with all 13 APPs including APP 1 (open and transparent management of personal information), APP 3 (collection of solicited personal information), APP 6 (use and disclosure of personal information), APP 11 (security of personal information), and APP 12 (access to personal information). Australian users may contact our Privacy Officer at privacy@fbalearning.com to access or correct their information or to make a complaint. If unsatisfied, you may complain to the Office of the Australian Information Commissioner (OAIC).
3. Privacy Policy
3.1 Information We Collect and Our Legal Basis
We collect the following categories of personal information:
- Student name (first and last) — collected on the basis of parental consent, used solely for personalisation within the portal. Not transmitted to any server.
- Grade level and subject focus — collected on the basis of parental consent, used to adjust AI content to the appropriate curriculum level. Only the grade level (not the name) is transmitted to the AI service when generating lessons.
- Learning activity data — collected on the basis of legitimate interests in providing the educational service, includes lessons completed, quiz scores, and practice results. Stored locally on your device only.
- In-portal search history — collected on the basis of legitimate interests in child safety, includes every search query entered with timestamp. Visible to the parent in the Parent Dashboard in real time. Stored locally on your device only.
3.2 Information We Do Not Collect
We do not collect phone numbers, home or mailing address, photographs or biometric data, payment or financial information, government-issued identification, device identifiers for tracking purposes, IP addresses for profiling, location data, or social media account information. We do not conduct behavioural profiling or automated decision-making about children.
Parent email address is collected via the consent form on the basis of parental consent (GDPR Article 6(1)(a); PIPEDA s.7). It is used solely for account authentication and password recovery. It is never sold, shared with third parties, or used for marketing without separate consent.
3.3 Where Data is Stored
Learning progress, XP, and session data is stored locally in your browser. Your account information (email address and authentication credentials) is stored securely on servers in Canada via Supabase. No personal data is stored outside Canada.
We recommend using the Export Backup feature in Student Settings regularly to preserve your child's progress and as your own personal data record.
3.4 Data Transmitted to Third-Party AI Service
When a lesson is generated, two pieces of non-identifying information are transmitted to Anthropic Inc. (our AI service provider): the topic the student searched for, and the student's grade level. The student's name, any other personal information, and search history are never transmitted. Anthropic processes this data under its own Privacy Policy available at anthropic.com/privacy. Anthropic is a US-incorporated company. Data transmitted to Anthropic is subject to US data protection laws and Anthropic's data processing practices.
3.5 Third-Party Services
The following third-party services are used by this portal: Anthropic (Claude AI, USA) for lesson generation; Netlify (USA) for portal hosting, which does not receive student data; and Google LLC for font delivery via Google Fonts, subject to Google's Privacy Policy at policies.google.com/privacy.
3.6 Data Retention
Local learning data persists on your device until you clear your browser data. Account data on our servers is retained while your account is active. You may request deletion at any time by contacting privacy@fbalearning.com. Upon account deletion, all server-side personal data is permanently removed within 30 days. Note: locally stored data mulete it through the Student Settings Reset function, clear your browser data, or the 24-hour session expiry causes automatic data clearing. There is no server-side retention because we do not receive the data.
3.7 International Data Transfers
This portal is operated from Canada. Canada has been granted adequacy status by the European Commission, meaning transfers of personal data from the EU to Canada are lawful without additional safeguards. Data transmitted to Anthropic (lesson topic and grade only) involves a transfer to the USA. Anthropic maintains Standard Contractual Clauses and other appropriate safeguards for international transfers.
3.8 Your Rights — All Jurisdictions
Regardless of your location, you have the right to access all data stored about your child (via Parent Dashboard and Student Settings); to correct your child's profile at any time (via Student Settings); to export a complete copy of all data (via Data Backup in Student Settings); to delete all data permanently (via Reset in Student Settings, which constitutes the Right to Erasure under GDPR Article 17); and to withdraw consent at any time by discontinuing use of the portal.
For all privacy requests, complaints, or inquiries: privacy@fbalearning.com. We commit to responding within 30 days.
4. AI Disclosure
Global AI Transparency Notice. All lessons, explanations, quiz questions, and other educational content in this portal are generated by artificial intelligence. This is consistent with AI transparency requirements under the EU AI Act (Regulation EU 2024/1689), the proposed Canadian Artificial Intelligence and Data Act (AIDA), and emerging AI disclosure standards globally. AI-generated content has not been individually reviewed by a human teacher. Errors can and do occur.
4.1 AI System Used
This portal uses Claude, an AI system developed by Anthropic Inc., a company incorporated in the United States. The AI system processes the topic and grade level of each lesson request and generates educational content in response. The AI system does not have access to any personal information about the student.
4.2 Known Limitations of AI
AI may produce mathematical errors, particularly in complex multi-step calculations. AI may state inaccurate facts with apparent confidence. AI responses are probabilistic and may vary for identical inputs. AI cannot replace qualified human teachers or professional educational assessment. AI is not capable of diagnosing learning disabilities, attention disorders, or other educational or psychological conditions. AI content should be treated as a starting point for learning, not as a definitive or authoritative source.
4.3 Human Oversight
We have implemented the following human oversight mechanisms: a two-step mathematical verification system that independently calculates answers before evaluating student responses; a parent dashboard that provides full visibility of all AI interactions; and a content safety filter that prevents the AI from responding to inappropriate queries. We commit to ongoing monitoring of AI output quality and safety.
4.4 AI and Children — Special Considerations
We recognise that children may be more susceptible to treating AI-generated content as authoritative. We encourage parents to discuss AI limitations with their children and to reinforce that AI is a tool that requires critical thinking and human verification. This portal is designed as a supplement to, not a replacement for, qualified human instruction.
5. Terms of Use
5.1 Acceptable Use
This portal may be used only for legitimate educational purposes aligned with the Grade 5 to 12 school curriculum; by the registered student only; without attempting to bypass, manipulate, or misuse the content safety system; and in compliance with the student's school acceptable use policy where applicable.
5.2 Limitation of Liability
To the maximum extent permitted by applicable law, Future Builders Academy and Fortify Solutions Inc. disclaim all liability for errors or inaccuracies in AI-generated content; academic outcomes or results; technical interruptions or data loss; and decisions made based on AI-generated content. This portal is provided for supplementary educational use only and does not constitute professional educational, psychological, medical, or therapeutic advice of any kind.
Nothing in this clause limits liability for death or personal injury caused by negligence, fraudulent misrepresentation, or any other liability that cannot be excluded by law in your jurisdiction.
5.3 Intellectual Property
The Future Builders Academy Learning OS is the proprietary intellectual property of Future Builders Academy, operated by Fortify Solutions Inc., Alberta, Canada. Protected under the Canadian Copyright Act (R.S.C., 1985, c. C-42). Trademark application pending at the Canadian Intellectual Property Office (CIPO), Class 41, Education and Training Services. Unauthorised copying, reproduction, distribution, reverse engineering, or creation of derivative works is strictly prohibited and may result in civil and criminal liability.
5.4 Governing Law and Dispute Resolution
This agreement is governed by the laws of the Province of Alberta, Canada, and the applicable federal laws of Canada, without regard to conflict of law principles. Users in the European Union retain the right to bring proceedings before the courts of their EU member state in addition to Canadian courts. Users in Australia retain the right to bring proceedings before Australian courts. Nothing in this clause removes or limits any statutory rights available to consumers under the mandatory laws of their country of residence.
5.5 Changes to This Policy
We may update this policy from time to time. Material changes will result in a new version number. Where required by applicable law (including GDPR), we will obtain renewed consent before processing continues under the updated terms.
6. Child Safety Policy
6.1 Age Range and Parental Consent
This portal is designed for students in Grades 5 to 12, approximately aged 9 to 18 (Grade 4 to Grade 12). We require verifiable parental or guardian consent before any student uses this portal. The consent given through this form constitutes parental consent under COPPA (USA), GDPR Article 8 (EU), UK GDPR (UK), and the equivalent provisions of Canadian, GCC, and Australian privacy law.
6.2 Design for Children — UK Age Appropriate Design Code Compliance
We have designed this portal in accordance with the UK Age Appropriate Design Code (Children's Code). Specifically: privacy settings are set to high by default and cannot be lowered by the child; data collection is minimised to what is strictly necessary; no behavioural advertising is conducted; no profiling of children is performed; no nudge techniques are used to encourage children to share more data; geolocation is not collected; no parental monitoring tools are hidden from parents; and the best interests of the child are the primary design consideration.
6.3 What This Portal Does Not Contain
By design this portal contains no advertising of any kind; no links to external websites or social media; no peer-to-peer or live communication features; no public profiles or social sharing; no in-app purchases; no location tracking; no content generated by or communication with strangers; and no dark patterns designed to manipulate children's choices.
6.4 Content Safety System
Every search query is evaluated through a two-layer AI-powered content safety system before any lesson is generated. The first layer applies an instant keyword filter for clearly harmful content without making any external API call. The second layer uses AI intent classification to evaluate the educational appropriateness of the query in the context of the student's grade level. Queries classified as inappropriate are blocked, never reach the lesson AI, and are logged immediately in the Parent Dashboard with the exact search term, date, and time.
After three blocked search attempts in a single session, the portal is paused and requires a four-digit parent PIN to unlock. This is consistent with child safety best practices and the UK Children's Code requirement for age-appropriate access controls.
6.5 Reporting Safety Concerns
If you believe your child has encountered inappropriate content, or if you have concerns about their safety or privacy, contact us immediately. We commit to responding within 24 hours for safety matters and 48 hours for privacy matters.
Child Safety: safety@fbalearning.com
Privacy Officer: privacy@fbalearning.com
7. Local Storage Disclosure
This portal uses browser localStorage to store student data on your device. localStorage is a web browser technology that stores data locally, similar in function to cookies but without expiry by default. This data does not leave your device. We use localStorage in place of server-side storage specifically to protect your child's privacy by keeping data under your direct control at all times. You may clear localStorage data at any time by using the Reset function in Student Settings or by clearing your browser's site data.
8. Contact Information
Privacy Officer and Data Controller: Future Builders Academy (operated by Fortify Solutions Inc.), Alberta, Canada
General Support: support@fbalearning.com (existing users — login, billing, portal help)
General Enquiries: info@fbalearning.com (new families, general questions)
Privacy Officer: privacy@fbalearning.com (GDPR, COPPA, PIPEDA requests)
Child Safety: safety@fbalearning.com (safety incidents — 24hr response)
Schools & Educators: schools@fbalearning.com
Response time: 30 days for privacy requests, 24 hours for safety concerns.
EU Representative: For the purposes of GDPR Article 27, enquiries from EU data subjects may be directed to privacy@fbalearning.com pending appointment of a formal EU representative as user volume in the EU warrants.
UK Representative: For the purposes of UK GDPR Article 27, enquiries from UK data subjects may be directed to privacy@fbalearning.com.
9. Consent Record
By ticking the confirmation box below and clicking the agreement button, the parent or legal guardian confirms they are the parent or legal guardian of the child who will use this portal, and that they have read and agree to this complete policy document on behalf of themselves and their child. This consent is recorded digitally with an ISO timestamp and is valid for one year from the date of agreement.