Firefly Education Network Privacy Policy (With COPPA, FERPA, and GDPR Compliance)

Effective Date: 7.16.25

1. Overview

Firefly Education Network values your privacy. This policy describes how we collect, use, and protect your information. Our practices comply with the Children’s Online Privacy Protection Act (COPPA), Family Educational Rights and Privacy Act (FERPA), and the General Data Protection Regulation (GDPR) where applicable.

2. What We Collect

We collect information in the following categories:

a. Personal Information

• Parent/guardian name, email, and payment data
• Student name, age, and academic records

b. Technical Data

• IP address, browser/device type, usage logs, cookies

c. Educational Activity

• Courses accessed, assessments taken, reward metrics

3. How We Use It

We use your data to:

• Operate and maintain the Firefly platform
• Deliver educational services
• Manage token-based rewards
• Monitor platform performance
• Comply with legal and educational standards

4. COPPA Compliance (For Children Under 13)

We do not knowingly collect data from children under 13 without verifiable parental consent. Parents have full access to their child’s records and may request deletion at any time.

5. FERPA Compliance (For U.S. Schools)

If Firefly is used by an educational institution governed by FERPA, we act as a “School Official” with legitimate educational interest, maintaining compliance and enabling parental access to records.

6. GDPR Rights (EU Users)

If you are located in the EU, you have the right to:

• Access your personal data
• Correct inaccuracies
• Withdraw consent
• Request deletion
• File a complaint with a supervisory authority

Submit GDPR-related requests to privacy@fireflyedu.org.

7. Data Storage & Blockchain

Educational records, completion logs, and reward transactions may be stored on decentralized blockchain infrastructure (e.g., IPFS). While this ensures transparency and immutability, it may limit our ability to fully delete certain records.

8. Sharing Information

We do not sell or rent your personal data. We only share data:

• With service providers under binding confidentiality
• With instructors or moderators for educational purposes
• As required by law or court order

9. Security

Firefly implements encryption, access controls, and decentralized storage to protect your data. However, no platform can guarantee absolute security.

10. Data Retention

We retain your data as long as your account is active and as necessary to fulfill educational and legal obligations.

11. Updates to This Policy

We may update this Privacy Policy. Changes will be posted on our website. Your continued use of the platform after an update constitutes acceptance.

12. Contact

For privacy concerns or data access requests, please contact: privacy@fireflyedu.org Firefly Blockchain LLC, 32 N Gould St, Sheridan, WY 82801