StudyPlugHub is operated by Derick Osafo Aboagye (ABN 98 844 353 839), registered in Australia under the Business Names Registration Act 2011. This Privacy Policy applies to all services at www.studyplughub.com and our associated subdomains, including teachers.studyplughub.com. StudyPlugHub serves two distinct audiences: • Students — across all 54 African countries, using our learning tools (Frema AI Tutor, Berur Chat, Writing Coach, Exam Master, Study Companion, LectureSnap) and our community feature (StudyCircle). • Teachers — using our classroom tools (Lesson Planner, Exam Generator, Assignment Creator, Resource Summariser, Report Card Writer, Wellbeing Hub) and the Armani teaching assistant. This policy applies to both, with specific provisions for each where relevant. For privacy enquiries, contact us at legal@studyplughub.com.

Account Information: your name, email, country and education level (for students) or teaching level and years of experience (for teachers) when you register. Usage Data: how you interact with our tools — which tools you use, how often, and general usage patterns. This helps us improve the platform. Community Content: posts, comments and replies you create in StudyCircle, our community feature. Device and Technical Information: basic information such as browser type, device type, and IP address. We use this for security, to enforce fair-use limits, and to ensure the platform works correctly. Cookies and Local Storage: we use browser local storage to remember your preferences (such as dark mode and selected curriculum), to track usage limits for our free tier, and — for teachers — to store all of your tool work product (lesson plans, report cards, library entries, drafts) on your own device. We do not use advertising or cross-site tracking cookies. We do NOT collect: payment card details, government identification, biometric data, or any sensitive personal information beyond what is listed above.

We use your information to: provide and improve StudyPlugHub and its features; personalise your learning or teaching experience by country and education level; moderate community content to keep the platform safe; send important account and platform updates; respond to enquiries and support requests; detect and prevent abuse, fraud, and security threats; and comply with our legal obligations. We do NOT: sell to advertisers, track you across other websites, profile you for behavioural advertising, or make automated decisions affecting your legal rights without human review.

StudyPlugHub's AI features are powered by Google Gemini 2.5 Flash. When you use any AI feature, the content you submit is sent to Google's Gemini API to generate a response. Our AI surfaces fall into three categories, and each is handled differently: CHAT TOOLS (with conversation memory) • Frema AI Tutor (students) • Berur Chat (students) • Armani Assistant (teachers — the floating chat available on every teacher tool page) For chat tools, recent conversation history (typically the last 5 exchanges) is sent with each request to give the AI context for follow-up questions. Conversation history exists only in your browser session — it is not persisted on our servers. Closing the tab, navigating to another page, or signing out clears the conversation entirely. SINGLE-RESPONSE STUDENT TOOLS • Writing Coach • Exam Master • Study Companion • LectureSnap Your input is sent to Gemini, a response is returned, and we retain anonymous usage logs (which tool, when, how often) but do not persistently store the full content of your requests. TEACHER CLASSROOM TOOLS • Lesson Planner • Exam Generator • Assignment Creator • Resource Summariser • Report Card Writer • Wellbeing Hub For teacher tools, your input is sent to Gemini and a response is returned. Both your input and the generated output are saved only to your browser's local storage — they are not copied to our servers. Your teacher library, drafts, and previously generated content live entirely on your own device. If you clear your browser data or use a different device, that work will not be available. ACROSS ALL AI SURFACES • Your conversations and content are NOT used to train Google's AI models or any StudyPlugHub model. • We operate under Google's paid Gemini API terms, which exclude paid usage from Google's model training data. • Google's processing of your data is additionally governed by Google's Cloud Privacy Notice at https://cloud.google.com/terms/cloud-privacy-notice. • We have configured Gemini's safety settings to minimise the risk of harmful output, particularly given that many of our users are minors. WELLBEING HUB — EXTRA CARE The Wellbeing Hub processes sensitive emotional content (challenges teachers are facing, mood ratings, personal stress). Because of this sensitivity: • Your reflections are stored only in your own browser. They are never copied to our servers. • The only outbound transmission is the Gemini API call needed to generate the support response. • We do not log, analyse, or retain the content of your wellbeing sessions. • We do not use wellbeing content for any purpose other than generating your response in that moment.

When teachers use StudyPlugHub's classroom tools, they may enter information about their students — names, scores, behaviour observations, and areas for improvement (in Report Card Writer); class lists (via bulk paste); or general references to students in lesson planning. This requires a clear legal explanation. THE CONTROLLER / PROCESSOR RELATIONSHIP • The teacher (or their school) is the data controller. The teacher decides what student information to enter, why, and how it will be used in their classroom practice. • StudyPlugHub is the data processor. We process that information on the teacher's behalf, only for the narrow purpose of generating the requested output (e.g. report card comments). WHAT THIS MEANS IN PRACTICE • Student data is never persisted on our servers. Names, scores and observations entered into Report Card Writer or any other teacher tool live only in the teacher's browser local storage. They are sent to the Gemini API for the brief moment needed to generate output, and the result is returned to the teacher's browser. • We do not retain, mine, or analyse student data. It is not visible to us, not part of our analytics, and is not used to train any model. • If a teacher uploads a file (textbook chapter, article, lesson source), the file is processed in the browser and only the extracted text is sent to Gemini. The original file never leaves the device. • Teachers are responsible for compliance with their school's privacy policy and applicable law. If you are a teacher entering student data, you should confirm you have the appropriate authority — school policy, employer instruction, parental consent where required — to do so. FOR PARENTS AND GUARDIANS If you have concerns about a teacher's use of StudyPlugHub for your child's data, please first contact the school or teacher directly — they are the data controller for that information. If your concern relates to our handling of data on the teacher's behalf, contact us at legal@studyplughub.com and we will investigate. FOR SCHOOLS Schools wishing to use StudyPlugHub at an institutional level, with a formal data processing agreement, can contact us at hello@studyplughub.com to discuss enterprise terms.

StudyPlugHub is built on the principle "Learn It. Don't Fake It." Our AI tools are designed to guide thinking, not to do the work for the user. This applies to both students and teachers. FOR STUDENTS • AI can make mistakes. Our tools occasionally generate information that is incorrect, outdated, or incomplete. Always verify important facts with your teachers, textbooks, or other trusted sources before relying on them in exams or submitted work. • Our tools deliberately teach rather than just answer. Frema will explain concepts until you understand them. Exam Master shows you your mistakes and how to learn from them. Writing Coach guides your thinking rather than writing your essay for you. • Academic integrity is your responsibility. Submitting AI-generated content as your own original work may violate your school's academic integrity policy. Many institutions consider undisclosed AI use a form of academic misconduct. When in doubt, ask your teacher about your school's policy and always cite AI assistance where required. • We reserve the right to decline requests that appear designed to circumvent academic integrity — for example, requests phrased as "write my essay for me" rather than "help me think about my essay." FOR TEACHERS • AI-generated lesson plans, exam questions, assignments, and report card comments are starting points, not finished work. Always review and adapt the output before using it in your classroom or sharing it with students or parents. • You are responsible for the accuracy and appropriateness of any content you choose to use. We make no warranty that AI output is suitable for any particular educational context. • When generating report card comments, we strongly encourage you to read every comment carefully before issuing it. Comments about students carry weight and should reflect your own professional judgment — the AI is there to help you draft, not to replace your knowledge of the student. Our goal is for StudyPlugHub to make students better learners and teachers more effective — not to replace either.

We are deliberate about what we store on our servers and what we keep only on your device. WHAT WE STORE ON OUR SERVERS • Account data (Firebase Authentication, Firestore): your name, email, country, and level. Encrypted at rest and in transit. • Email delivery logs (Firestore, with 90-day automatic deletion via Firestore TTL): records of system emails sent to you (welcome emails, important account notices) and their delivery status. Used to support you and to retry failed sends. • StudyCircle community posts: posts and replies you create in our community feature, retained until you delete them or your account. • Anonymised usage analytics: aggregate data on which tools are used and how often, in a form that cannot be tied back to individual users. WHAT WE DO NOT STORE ON OUR SERVERS • Your AI conversation content (Frema, Berur, Armani) — exists only in your browser session, sent to Google's Gemini API to generate a response, then not persisted by us. • Teacher tool work product (lesson plans, exam papers, assignments, summaries, report card comments, library entries, draft sessions) — lives only in your browser's local storage. Clearing browser data deletes all of this. It is not synced to our servers and is not accessible to us. • Student data entered by teachers — see Section 5. • Wellbeing Hub reflections — see Section 4. • Uploaded files (PDFs, DOCX, TXT) — processed in your browser; only the extracted text is transmitted to Gemini, and only for the moment of the API call. The file itself never leaves your device. SECURITY MEASURES • Encrypted data transmission (HTTPS/TLS) for all traffic. • Secure authentication via Firebase Authentication. • Firestore security rules restricting users to their own documents only. • Rate limiting and abuse controls to protect against misuse. • Error monitoring (Sentry) — receives error metadata and stack traces only, never the content of your conversations, your work, or your community posts. We have also configured a strict cost cap on our Google Cloud account to prevent runaway processing. • Regular security reviews and dependency updates. In the event of a data breach posing a real risk to your rights or freedoms, we will notify affected users within 72 hours of becoming aware, in line with leading data protection frameworks. No online system is 100% secure. We work hard to protect your information, but we cannot guarantee absolute security.

We share your information only with trusted service providers who help us operate StudyPlugHub, and with legal authorities when required by law. Service Providers (each operating under data processing terms): • Google (Firebase, Firestore, Gemini API) — account storage, data persistence, AI processing. • Vercel — web hosting and global content delivery. • Zoho Mail (Australia region) — email communication from support@ and legal@ addresses. • Sentry — error monitoring and diagnostics. Sentry receives limited technical data such as error messages and browser type. It does not receive the content of your AI conversations, teacher tool work product, or community posts. Legal Authorities — we may disclose information if required by a valid court order, subpoena, or other legal process, and only to the minimum extent required. We do NOT sell, rent, or trade your personal information to any third party for marketing, advertising, or commercial purposes.

StudyPlugHub is operated from Australia and serves users across all 54 African countries. Because our service providers operate globally, your personal information may be processed in multiple jurisdictions: • Google (Firebase, Gemini): may process data in the United States, Europe, or Asia-Pacific regions. • Vercel: serves content from global edge locations including North America, Europe, and Asia. • Zoho Mail: processes email in the Australia region. • Sentry: processes error data in the United States. These transfers are necessary to operate the platform. We rely on our providers' standard contractual protections — such as Google's and Vercel's Data Processing Addenda — to ensure your data remains protected wherever it is processed. By using StudyPlugHub, you consent to your data being transferred to and processed in these locations. If you have specific concerns about data residency, email legal@studyplughub.com.

You have the right to: • Access — request a copy of the personal data we hold about you. • Correction — ask us to correct inaccurate or incomplete information. • Deletion — request deletion of your account and associated data, which we will action within 30 days. • Portability — receive your data in a machine-readable format. • Objection — object to certain types of processing. • Withdrawal of consent — where we rely on your consent, you can withdraw it at any time. A note on local storage: because much of your work on StudyPlugHub (chat history, teacher tool drafts, library) is stored only on your own device, you control that data directly. To delete it, clear your browser's local storage for studyplughub.com — this does not affect your account, only your locally-stored work. To exercise any of these rights against data we hold on our servers, email legal@studyplughub.com with the subject line "Data Rights Request". We respond within 30 days. We may ask for information to verify your identity before releasing or deleting data.

StudyPlugHub is an education platform, and we recognise that the privacy of minors requires particular care. Our approach differs depending on how a minor's data reaches the platform. 11A — STUDENTS AS DIRECT USERS Many of our student users are minors. We take extra care: • We do not knowingly collect data from children under 13 without parental or guardian consent. • Users aged 13-17 may use StudyPlugHub with parental permission. The age of digital consent varies by country — for example, 13 in Kenya, 16 in South Africa under POPIA. Where local law requires verifiable parental consent, please contact us before signing up. • We do not show advertisements, use behavioural profiling, or sell minors' data. • We collect only the minimum data needed to provide the service. • Parents or guardians can email legal@studyplughub.com to request access to, correction of, or deletion of their child's data. We will action such requests promptly. • If you are a young person using StudyPlugHub and feel uncomfortable with anything on the platform, please speak to a trusted adult and contact us — we will help. 11B — STUDENT DATA ENTERED BY TEACHERS Teachers using StudyPlugHub may enter information about minors in their care. As described in Section 5: • The teacher is the data controller for that information; we are the data processor. • Student data entered into teacher tools is not stored on our servers — it lives only in the teacher's browser. • Teachers are responsible for ensuring they have the appropriate authority (school policy, parental consent where required) to enter student data. • Parents or guardians with concerns about a teacher's use of student data should contact the school first; we will assist as needed. 11C — TEACHERS Teachers using StudyPlugHub are adults. Standard adult privacy rights apply, with the additional consideration that teachers may carry obligations under their school's policies and applicable law when using our tools in their professional capacity.

We respect applicable African data protection laws and work to comply with the frameworks of the countries we serve, including: • Ghana — Data Protection Act 2012 • Nigeria — Nigeria Data Protection Act 2023 (which replaced the earlier NDPR 2019) • Kenya — Data Protection Act 2019 • South Africa — POPIA 2020 (Protection of Personal Information Act) • Egypt — Personal Data Protection Law 2020 • Sierra Leone — Cybersecurity and Crimes Act 2021 • Other relevant national legislation across the 54 countries we serve. If you believe we have not complied with your country's data protection law, contact us first at legal@studyplughub.com so we can investigate. You may also contact your country's data protection authority directly.

We retain your data only as long as necessary to provide the service: • Account data (Firestore): retained while your account is active. Deleted within 30 days of an account deletion request. • Chat history (Frema, Berur, Armani): not persisted on our servers — exists only in your browser session and is cleared when you close the page. • Teacher tool work product: not persisted on our servers — exists only in your browser's local storage. You control retention by managing your local storage. • Wellbeing Hub reflections: not persisted on our servers — same as above. • Community posts (StudyCircle): retained until you delete them or delete your account. • Email delivery logs: retained for 90 days, then automatically deleted by Firestore TTL policy. • Technical and security logs: retained up to 30 days, then deleted or anonymised. • Backups of server-stored data: backup copies may persist for up to 90 days after primary deletion before being overwritten. • Anonymised aggregate usage data: may be retained indefinitely for platform improvement and analytics, as it no longer identifies you. If a legal obligation requires us to retain data longer (for example, fraud investigation or tax records), we will only retain the minimum necessary and only for the minimum time required.

As StudyPlugHub evolves, we may update this Privacy Policy. When we do: • We will update the "Last updated" date at the top of this page. • For significant changes, we will notify registered users by email and display a prominent notice on the site for at least 30 days. • Your continued use of StudyPlugHub after changes take effect means you accept the revised policy. If you disagree with any changes, you are free to delete your account at any time — your data will be removed in accordance with our retention policy above.

For privacy enquiries: legal@studyplughub.com For general enquiries: hello@studyplughub.com For school enquiries (institutional data processing agreements): hello@studyplughub.com We aim to respond to all privacy requests within 30 days. If you are based in Australia and are unsatisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC): • Website: www.oaic.gov.au • Phone: 1300 363 992 If you are based in another country, you may contact your local data protection authority — such as the Data Protection Commission (Ghana), the Nigeria Data Protection Commission, the Office of the Data Protection Commissioner (Kenya), the Information Regulator (South Africa), or the equivalent authority in your country. We take every privacy concern seriously and aim to resolve issues directly before regulator involvement becomes necessary.