1.  Privacy at a glance

o   Bonocle is built for education, not advertising

o   We collect only the minimum data needed to support thelearning environment

o   Student data is controlled by schools and educators

o   We do not sell personal information

o   We do not use personal information for targeted advertising

o   Parents, schools, and educators can request access,correction, or deletion of data.

2.  Introduction

Bonocle is a Canadiantechnology company focused on accessibility, braille literacy, and digitalinclusion for blind and low-vision students. Bonocle began as a student projectand grew into a mission-driven organization after observing the real-world barriersfaced by blind and low-vision learners, including limited access to moderntools and reduced opportunities for consistent practice.

In response, we created Bonocle,a cross-platform learning system designed specifically for blind and low-visionstudents and the educators who support them. Bonocle works across smartphones,tablets, and braille displays, and includes:

BoQuest – Gamified Braille App

·     Engaging games andtactile challenges that help students of all ages practice braille literacy anddigital accessibility skills in a fun, motivating way.

·     Work with brailledisplays or smart booklets that create endless practice opportunities.

BoDesk – Teacher Dashboard

·     Tools that allowteachers to manage lessons, assign practice remotely, track progress, andgenerate reports automatically.

·     AI-supported insightsthat help personalize instruction and reduce administrative workload.

We take privacyseriously—especially when it comes to students. This Privacy Policy explainshow we collect, use, disclose, store, and protect information when Bonocleapplications or websites are used by students, educators, schools, or parents.

This policy is designed toalign with applicable privacy and education laws in Canada and the UnitedStates, including:

1. Canada:     Personal Information Protection and Electronic Documents Act (PIPEDA);     provincial public-sector privacy legislation such as Ontario’s Municipal     Freedom of Information and Protection of Privacy Act (MFIPPA) and     other applicable Freedom of Information and Protection of Privacy Acts     (FIPPA).
2. United     States: Family Educational Rights and Privacy     Act (FERPA); Children’s Online Privacy Protection Act (COPPA); and     applicable state student privacy laws (such as Student Online Personal     Information Protection Acts).

3.  Our Role in Schools

WhenBonocle is used by a school or school board, we act as a service provider tothe educational authority. We process information only on the school’s behalfand in accordance with its instructions.

Schools retain ownership andcontrol of student data at all times. Bonocle does not use student informationfor commercial purposes, advertising, or any activities unrelated to education.

4.  Information We Collect

We collect only the minimuminformation necessary to provide safe and effective educational services.

a.     Information from Educators or Schools

·     Name and professionalcontact information (such as a school email address)

·     School or districtinformation required for account administration

·     Communicationpreferences and support requests

b.     Information from Students

Bonocle products are designedto minimize student data collection. Student information may include:

·     A teacher-assignedusername or anonymous identifier which cannot reasonably be used by Bonocle toidentify an individual student.

·     Learning progress,performance data, and in-app activity

·     Limited technical data(such as device type, operating system, IP address, and crash reports)

Bonocle does not require orknowingly collect unnecessary personal information such as student name, homeaddresses, personal phone numbers, personal email addresses, orgovernment-issued identifiers.

5.  How We Use Information

Informationis used only to:

·     Deliver, operate, and improve Bonocle’s educationalservices

·     Support instruction, assessment, and progress tracking

·     Respond to school, educator, or parent inquiries

·     Maintain platform security and integrity

·     Comply with legal and contractual obligations

Bonocledoes not use student information for marketing, targeted advertising, or profiling.

6.  Consent and Lawful Basis

Bonocle’s service and dataprocesses are built to respect user choice, limit data retention, and ensuretransparency around how data is used to support our core learning mission.

Canada

Under Canadian privacy laws,Bonocle relies on authorization and consent provided by schools, school boards,or parents/guardians, as appropriate, or on other lawful authority granted toeducational institutions.

United States

FERPA: Bonocleprocesses education records under the direct control of the school or schooldistrict.

COPPA: WhenBonocle is used in a school setting, the school may provide consent on behalfof parents for educational purposes. Bonocle does not independently collectpersonal information from children for commercial use.

Consent may be withdrawn bythe school or parent/guardian, subject to applicable educational and legalrequirements.

7.  Disclosure of Information

Bonocle does not sell or rentinformation.

Information may be shared onlywith:

·     Authorized serviceproviders (such as secure cloud hosting, analytics, or support services) whoare contractually required to protect information and use it only for Bonocle’sservices

·     Schools or educatorswho administer student accounts

·     Legal or regulatoryauthorities, where disclosure is required by law

All information sharing isconducted in accordance with applicable Canadian and U.S. privacy legislationand uses appropriate security measures, including encryption.

8.  Data Storage, Residency, and Cross-Border Transfers

Bonocle makes reasonableefforts to store and process student personal information in the same countryas the school or educational authority, supporting compliance with localprivacy requirements and high standards of data protection.

When cross-border data storageor processing is necessary, Bonocle ensures that:

·     Appropriate contractualand technical safeguards are in place

·     Data is encrypted bothin transit and at rest

·     Access is limited toauthorized personnel based on role and necessity

9.  Security Safeguards

Bonocle uses administrative,technical, and physical safeguards appropriate to the sensitivity of theinformation we handle, including:

·     Encrypted datatransmission (HTTPS)

·     Encryption of storeddata where appropriate

·     Access controls andauthentication measures

·     Ongoing systemmonitoring and regular security reviews

·     Staff training onprivacy and data protection practices

10. Retention and Deletion

Personal information isretained only for as long as needed to support educational purposes or to meetlegal obligations.

At the request of a school oran authorized parent/guardian, Bonocle will delete or anonymize studentinformation within a legally compliant timeframe, including from active systemsand, where feasible, from backups.

11. Access, Correction, andStudent/Teacher Rights

In accordance with applicablelaws, schools, parents/guardians, teachers, and eligible learners may:

·     Request access to theiruser information

·     Request corrections toinaccurate or incomplete information

·     Request deletion, wherepermitted by law

Requests may be submitted bycontacting Bonocle's Privacy Officer at the contact information below. We aimto respond within 30 days, unless a different timeframe is required by law.

12. Cookies and OnlineTechnologies

Bonocle may use cookies orsimilar technologies to:

·     Maintain secure usersessions

·     Improve platformfunctionality and performance

·     Analyze anonymizedusage patterns to improve our services

Bonocle does not use cookiesfor targeted advertising or marketing to children.

13. Updates to This Policy andPrivacy Officer Contact

This Privacy Policy isreviewed annually and updated as needed to reflect changes in legalrequirements or business practices. Material changes will be communicated toschools or registered users.