Advancify Privacy Policy
Effective Date: May 15, 2025
This Privacy Policy outlines how we collect, use, and share information through our Services and on the Advancify website at www.advancify.co (the "Site"). By using our Services and/or the Site and submitting your information, you agree to the terms of this Privacy Policy. This policy should be read in conjunction with, and is incorporated into, the Advancify website’s Terms and Conditions of Use (https://www.advancify.co/terms).
This Privacy Policy is governed by the laws of the state specified in the Terms of Service applicable to your Services. Any capitalized but undefined terms used in this Privacy Policy have the meanings assigned to them in the Terms of Service relevant to the Advancify Services you are using.
Summary
Advancify processes two types of personal data in relation to its Services: (1) your account and contact data, for which we are responsible (as the Data Controller under the EU's General Data Protection Regulation (GDPR), the UK GDPR, or as a business under the California Consumer Privacy Act (CCPA)); and (2) your User Data, collected from your monitored devices associated with your User Accounts ("Monitored Devices"), for which you are responsible (as Data Controller under GDPR), while Advancify acts as a data processor under GDPR, UK GDPR, or a service provider under the CCPA.
• Account and Contact Data: This data is used to manage our relationship with you, including account activation, support, invoicing, and service optimization. Details are provided in Section A of this policy.
• User and Monitored Devices Data: This information is processed on your behalf to provide parental control and monitoring services via the parental control panel. This is further detailed in Section B.
You are solely responsible for configuring and using the parental control panel and for processing personal data associated with your account. This includes the collection, storage, and analysis of personal data from users' Monitored Devices. Advancify implements the configurations and instructions you provide, making you solely responsible for how the control panel is set up and used.
Compliance with the Children’s Online Privacy Protection Act (COPPA)
COPPA and its regulations require us to inform parents and legal guardians ("parents") about our practices for collecting, using, and disclosing personal information from children under the age of 13 ("children"). It also requires us to obtain verifiable parental consent for certain types of data collection, use, and disclosure involving children’s personal information.
For more information, please refer to the Federal Trade Commission’s COPPA page. COPPA is designed to safeguard children's privacy. For a child under age 13 in the United States to use the Advancify Services, parental or teacher approval of the registration is required. Advancify Services are intended for use in household environments by parents and are not intended to be used directly by children. We do not knowingly collect personal information directly from children under the age of 13.
You warrant that (a) you have informed any users aged 14 years or older that their Monitored Devices include monitoring software and have obtained their authorization for such activity, or (b) your jurisdiction provides an exemption or an alternative minimum age for such consent, in which case that applicable age will apply. Both Advancify and you agree to fully comply with this Privacy Policy.
A. Data Processed by Advancify as Data Controller
This section applies to personal data that Advancify collects and processes as a Data Controller. It does not apply to User Data collected from Monitored Devices, which is processed on your behalf, as described in Section B.
Data Controller
The Data Controller for your personal data is Neuronext Inc., located at 1207 Delaware Ave #301, Wilmington, DE 19806, USA. For any inquiries or to exercise your data protection rights, you may contact our Data Protection Officer at: privacy@advancify.co.
Advancify collects and processes the following personal data:
• Registration Data: When you register for the Services, we collect your full name and email address. This data is necessary to create and manage your account.
• Computer Information: When you access our platform, we may collect technical information such as the referring URL, destination URL, IP address, browser type, and language settings. This data is used to understand usage patterns, enhance security, and improve our Services. This information is not shared with third parties without your explicit consent.
• Personal Account Data:
• Profile name
• Email address
• Password (encrypted)
• Child’s birthdate
• Child’s gender
• Child’s eyeglasses usage
Some of this data is provided directly by you during registration or through your account settings. We may also collect location-based data such as country or region through your device settings.
Purpose of Processing:
We use the personal data collected to:
• Create and manage your Advancify account
• Communicate with you regarding account activity and updates
• Deliver and support the Services you have requested
• Analyze performance and improve product functionality
• Send system notifications, support messages, and (with your consent) marketing communications
• Enforce our Terms of Service and comply with applicable laws
• Authenticate actions within the app using email-based verification codes
Legal Basis for Processing:
• Performance of a Contract: Processing your data is necessary for the performance of our contractual obligations to you.
• Legitimate Interest: We process data to enhance our Services and ensure optimal user experience, provided this does not override your fundamental rights.
• Legal Obligation: In certain circumstances, we may process data to comply with legal or regulatory obligations.
• Consent: We rely on your consent to send marketing communications and collect optional information. You may withdraw consent at any time by contacting us at privacy@advancify.co.
Service Optimization:
We may process aggregated, anonymized data for statistical and product improvement purposes. Such data does not identify individual users and may be shared with trusted third-party partners for analytics or service enhancement.
Disclosure:
We maintain strict confidentiality of your personal data. However, we may disclose data when necessary to:
• Comply with legal obligations
• Provide Services in accordance with our Terms of Service
• Respond to investigations or legal claims
• Support corporate transactions (e.g., mergers, acquisitions)
• Engage trusted service providers who act on our instructions and under confidentiality agreements.
2. Data Processed from Monitored Devices
This section explains how Advancify processes data from Monitored Devices on your behalf, in our role as a Data Processor or service provider.
User Activity Data
When Advancify Kids or Advancify Kids Desktop is installed on a Monitored Device, we collect specific device activity data to enable parental control features. This includes:
• Application categories (e.g., Games, Social Media)
• Application names (e.g., Telegram, YouTube)
• Categories of websites visited (e.g., Gaming, News, Education)
• Device screen status (on/off)
• Learning-related activity categories (e.g., Math, Science)
We do NOT collect:
• Personal messages
• Passwords
• Payment data
• Browsing history content
• Sensitive personal communications
Technical Data
We collect non-sensitive technical information, including:
• URL metadata
• Online identifiers (e.g., cookie IDs, IP addresses)
• Device information:
• Device ID
• App or program ID
• Network connection details (Wi-Fi, LTE, etc.)
• Service provider
• Device performance metrics
• Browser type and language
• Operating system version
• App version number
Biometric Eye-Tracking Metrics (Advancify Kids Desktop only)
We do not store or transmit raw video or eye-tracking imagery. All biometric processing is performed locally. Only high-level behavioral metrics derived from this data are sent to our secure servers. These include:
• Estimated levels of digital eye strain
• Focus during learning activities
• Indicators of distraction or fatigue
• Threshold eye strain levels (as categorized by our algorithm, e.g., A/B/C)
General Location Data
We collect general location information (e.g., country, region, or state), inferred from device settings such as language or IP address.
Purpose of Processing:
This data is processed solely to:
• Support parental awareness of children's digital behavior
• Monitor educational engagement and wellness indicators
• Enhance child safety and healthy digital habits
• Enable parental insights and application performance monitoring
Data Sharing and Security:
We do not sell, rent, or trade monitored data. It is shared only:
• When legally required
• To protect the security of our systems
• With your explicit parental consent
All third-party processors are contractually bound to confidentiality and must meet our security standards. We implement encryption, access control, and audit protocols to protect data during transmission and storage.
When the Advancify software is installed on iOS Monitored Devices, we may receive data routed through our servers due to the nature of Mobile Device Management (MDM) and system configuration. As a result, Advancify may receive metadata relating to:
• Application names and usage time
• Operating system version
This configuration also means we may receive notifications from third parties (e.g., ISPs or content owners) regarding user behavior. If we receive such notifications, and they suggest violations of law or terms of use, we may:
• Notify you of the activity
• Block access to certain apps or services
• Disclose relevant data to appropriate legal authorities or affected parties
• Suspend or terminate accounts as required
We do not monitor or store the content of internet communications. We process only metadata necessary to support core functionality and system integrity for parental monitoring. All data collected through iOS MDM is routed securely and is not shared with third parties except as explicitly required by law or with your consent.
4. Data Retention
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including:
• To provide and support the Advancify Services
• To comply with legal, regulatory, accounting, or reporting requirements
To determine appropriate retention periods, we consider:
• The volume, nature, and sensitivity of the personal data
• The potential risk of harm from unauthorized use or disclosure
• The purposes for which we process the data and whether those purposes can be achieved through other means
• Applicable legal requirements
Generally, personal data will be retained in an active state during the term of your subscription. After account deactivation or termination, data may be retained in an archived, restricted-access format for up to five (5) years solely for legal, regulatory, or administrative purposes.
Where data is no longer necessary for these purposes, it will be securely deleted, anonymized, or otherwise rendered inaccessible in accordance with our data disposal policies.
We may also retain anonymized data, which cannot be linked back to any individual, for research and statistical purposes indefinitely.
5. Anonymized Data for Statistical Purposes
We may anonymize personal and usage data to create statistical, aggregated insights that help us understand how our Services are used and how to improve them. Once anonymized, this data can no longer be linked back to any individual and is no longer considered personal data under applicable laws.
Purposes for anonymized data processing include:
• Improving our Services and user experience
• Developing new features and functionalities
• Conducting market and product research
• Supporting academic research and reports
• Producing sector or segment insights
Anonymized data of legal age users may be retained indefinitely and shared with:
• Academic institutions
• Research partners
• Commercial partners conducting statistical or behavioral analysis
We ensure that all anonymization techniques comply with the applicable data protection laws and that the data cannot be re-identified using any method reasonably likely to be used by us or by any third party.
6. International Transfers of Data
We may use third-party service providers located outside your country of residence to support the delivery of our Services. This means your (as a legal age user only) personal data may be transferred to, stored in, or processed in jurisdictions that may not provide the same level of data protection as your home country.
Where we transfer personal data outside the European Economic Area (EEA), the United Kingdom, Australia, or other jurisdictions with similar protections, we ensure appropriate safeguards are in place, such as:
• The use of Standard Contractual Clauses (SCCs) approved by the European Commission or equivalent legal mechanisms under applicable law
• Binding corporate rules, where applicable
• Additional technical and organizational measures to ensure a level of protection essentially equivalent to that required by the relevant regulations
Our current key sub-processors include:
• Hetzner Online GmbH (cloud hosting provider). Privacy Policy: https://www.hetzner.com/legal/privacy-policy/
• Zendesk Inc. (customer support platform). Privacy Policy: https://www.zendesk.com/company/customers-partners/privacy-policy/
All third-party service providers are contractually required to process data only in accordance with our instructions and to implement appropriate technical and organizational safeguards.
For a full list of sub-processors and data transfer safeguards, or to obtain a copy of applicable data transfer agreements, please contact us at privacy@advancify.co.
7. Data Security
We are committed to protecting the personal data of our users and implement appropriate technical and organizational measures to safeguard data from unauthorized access, alteration, disclosure, or destruction. Our security practices are designed to ensure a level of security appropriate to the risk presented by the nature of the personal data and the processing we carry out.
Security measures include:
• Encryption of data during transmission and, where appropriate, at rest
• Role-based access controls and user authentication protocols
• Secure data storage environments with monitoring and logging
• Regular security assessments, audits, and software updates
Despite our best efforts, no system can be guaranteed to be 100% secure. In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and the appropriate data protection authorities without undue delay, as required by applicable law.
We encourage all users to take steps to protect their own data, including maintaining strong passwords, logging out of shared devices, and keeping software up to date. If you believe your data may have been compromised, please contact us immediately at privacy@advancify.co.
8. Data Subject's Rights
Data Subject's Rights
Depending on your location and applicable law, you may have certain rights concerning your personal data. These rights include:
Right of Access: You have the right to request access to your personal data held by us and obtain a copy of it.
Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data.
Right to Erasure: You may request that we delete your personal data where there is no lawful reason to retain it. This right is subject to applicable legal exceptions.
Right to Object: You have the right to object to our processing of your personal data where the legal basis is our legitimate interest or where your data is used for direct marketing.
Right to Restrict Processing: You may request that we suspend the processing of your personal data, for example, if you contest its accuracy or object to our use of it.
Right to Data Portability: Where applicable, you may request to receive your personal data in a structured, commonly used, and machine-readable format or ask us to transfer it to another data controller.
Right to Withdraw Consent: If we process your personal data based on consent, you may withdraw your consent at any time. This will not affect the lawfulness of processing carried out before the withdrawal.
Parental Rights for Children’s Data: If we process data of a child under the age of digital consent applicable in your jurisdiction, only the verified parent or legal guardian may exercise the above rights on behalf of the child. This includes rights to access, rectify, delete, or restrict processing of the child’s data. We will take reasonable steps to verify the requester’s authority to act on behalf of the child before fulfilling such requests.
To exercise any of your rights, please contact us at privacy@advancify.co. We may need to verify your identity before fulfilling your request to ensure the security of your data.
We aim to respond to all legitimate requests within one month. In cases where the request is complex or numerous, we may extend this period and notify you accordingly. You will not be charged a fee for making a request unless it is clearly unfounded, repetitive, or excessive, in which case we may charge a reasonable fee or refuse to act on the request.
If you are unsatisfied with our response, you have the right to lodge a complaint with a data protection authority in your country or jurisdiction.
9. Exercising Your Rights to Know or Delete
If you are a resident of a jurisdiction that provides the right to know or delete your personal information, you may submit a request by:
• Emailing us at privacy@advancify.co
Only you, or someone legally authorized to act on your behalf, may submit a request. If you are submitting a request on behalf of your child, you must verify your identity and authority.
Your request must:
• Provide sufficient information to verify your identity or authority to act, such as:
• Contact details associated with the account
• User profile name
• Name of one or more Monitored Devices
• Relevant technical information (e.g., device ID, operating system)
• Any other identifying details we may reasonably require
• Clearly describe your request so we can evaluate and respond to it properly
You are not required to create an account to submit a request. However, if you submit your request through a password-protected account, it will be deemed verified.
We will only use personal information provided in a request to verify identity or authority to make the request. If we cannot verify your identity or the information provided does not relate to you, we may deny the request.
You may submit up to two (2) requests to know within a 12-month period. Requests to delete will be evaluated based on applicable legal grounds and may be denied if an exemption applies (e.g., for security, legal, or contractual reasons).
10. Response Timing and Format
We aim to respond to all verifiable data access or deletion requests within thirty (30) days of receipt. If we need more time, we will inform you of the reason and expected timeline in writing. Under applicable law, we may extend our response time by an additional thirty (30) days if reasonably necessary.
Our response will include the information requested or an explanation of why we cannot comply with your request, where applicable. For data portability requests, we will provide your data in a readily usable format that allows you to transmit the information from one entity to another without hindrance.
We do not charge a fee to process or respond to your request unless it is clearly unfounded, repetitive, or excessive. If we determine that a fee is warranted, we will inform you of the reason for the fee and provide a cost estimate before completing your request.
If you are not satisfied with our response, you have the right to contact your local data protection authority or regulator to lodge a complaint.
11. Commercial Communications
As a user of Advancify Services, you may receive electronic communications including newsletters, product updates, promotional offers, and service alerts, where permitted by law. These communications are sent in accordance with applicable marketing and electronic communication laws, including but not limited to the CAN-SPAM Act, the Privacy and Electronic Communications Regulations (UK), and the ePrivacy Directive (EU).
You may opt out of receiving commercial communications at any time by:
• Clicking the “unsubscribe” link in any email
• Updating your preferences in your account settings (if available)
• Contacting us directly at privacy@advancify.co
Please note that even if you opt out of marketing communications, you may still receive important administrative messages about your account or Services.
We do not send marketing communications to children and require verifiable parental consent before collecting contact details for any individual under the age of digital consent in their jurisdiction.
General
We may update this Privacy Policy from time to time to reflect changes in legal requirements, our data processing practices, or the functionality of our Services. Any changes will be posted on this page, with the effective date updated accordingly. In the case of material changes, we will notify you through the Site, application, or via email prior to the changes taking effect.
We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.
Unless otherwise required by applicable local law, this Privacy Policy is governed by the laws of the State of Delaware, USA, without regard to its conflict of law principles.
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:
Email: privacy@advancify.co
Address: Neuronext Inc., 1207 Delaware Ave #301, Wilmington, DE 19806, USA
B. Data Processed by Advancify as a Processor or Service Provider
When acting on behalf of our users, Advancify functions as a data processor (under the EU and UK GDPR) or a service provider (under the CCPA). In these roles, we process personal data from Monitored Devices exclusively under the documented instructions of the data controller (you, the parent or legal guardian) and not for our own purposes.
1 Scope of Processing Advancify processes data only to:
2 Nature of Data Processed As a processor or service provider, Advancify may process the following categories of data:
We DO NOT:
3 Instructions and Control The parent or legal guardian is the sole data controller for their child’s Monitored Devices. You configure which data is collected, how it is displayed, and whether specific features are enabled or disabled. Advancify follows your instructions as provided through the application interface or support channel.
4 Advancify may subcontract certain obligations and/or grant access to User Data to third-party service providers when necessary for the effective delivery of its Services. By using the Services, you expressly authorize Advancify to engage the following third-party providers.
- Hetzner Online GmbH – Provides cloud hosting infrastructure. For more information, please refer to Hetzner’s Privacy Policy
- Zendesk Inc. – Provides customer support services. For more information, please refer to Zendesk’s Privacy Policy.
Advancify ensures that each subcontractor is contractually bound to process User Data in compliance with applicable data protection laws and strictly in accordance with Advancify’s instructions.
5 Data Retention and Deletion As a processor, Advancify retains Monitored Device data only for as long as necessary to provide services to the data controller. When an account is deleted, all associated Monitored Device data is deleted in accordance with our data retention policy. Parents may also request data deletion by contacting privacy@advancify.co.
6 Security Measures We implement robust security safeguards, including:
- Encryption of data in transit and at rest
- Role-based access restrictions
- Regular audits and penetration testing
- Incident response protocols
7 Assistance and Compliance Advancify assists data controllers in fulfilling their legal obligations related to:
We do not make independent decisions about how personal data is used and process all data solely on your behalf and for your authorized purposes.
If you have any questions or need additional support in our role as your data processor or service provider, please contact us at privacy@advancify.co.