Privacy Policy

Effective Date: May 9, 2026

Last Updated: May 9, 2026

CentIQ provides a financial-literacy learning platform used by students, teachers, and individual consumers. This Privacy Policy describes the personal information we collect, how we use it, who we share it with, your rights, and how to contact us. It applies to both our website at www.centiqapp.com and our iOS mobile application.

CentIQ has two operating channels:

• School channel — students access CentIQ through their teacher’s class code, supplied by the school district. The school district is the data controller; CentIQ acts as a school official under the FERPA school-official exception (34 CFR 99.31(a)(1)(i)(B)) and processes student information only on the district’s instructions and pursuant to a signed Data Processing Agreement.
• Consumer channel — individuals create an account directly. Consumer accounts are restricted to users 13 and older. We do not knowingly collect personal information from children under 13 in the consumer channel.

This Privacy Policy applies to both channels. Where a section addresses one channel specifically, it is labeled.

1. Operator Identity and Contact

Operator: CentIQ (operated by Josh Wolters)

Email: privacy@centiqapp.com (general privacy inquiries) — josh@centiqapp.com (technical / security)

Mailing address: [To be provided before publication]

For school-channel inquiries that originate from a district under our DPA, please contact your district’s records officer. Your district will route the inquiry to us.

2. Categories of Personal Information We Collect

2.1 Account information

• Email address
• Display name (typically first name + last initial)
• For teachers: school affiliation, role (teacher / school administrator / super administrator)
• For consumers: date of birth (used to confirm age 13+)

2.2 Learning telemetry

• Lesson completions and timestamps
• Quiz scores
• Points earned (“Cents”)
• Streak count
• Daily activity flag (whether the user was active on a given day)
• For school-channel users: which class(es) the user belongs to

2.3 Live game data

• Player display name (chosen at game join)
• Per-question answers and response times
• Per-game accumulated points
• Persistent leaderboard statistics (games played, total points, wins) when the user has completed at least one live game

2.4 Communications with CentAI (our AI assistant)

• Questions you submit to CentAI
• Lesson context (slide text from the lesson you are reading) when CentAI is invoked from a lesson
• For the in-app general CentAI chat (iOS): your aggregate progress statistics (points, streak, current course/lesson). Your name and email are anonymized to an opaque identifier server-side before transmission to OpenAI and resolved back to your real name in the response — OpenAI never sees the real values.
• For teachers using the dashboard CentAI surface: aggregate statistics and progress data referenced by opaque identifiers (e.g., S001, S002 for students; T1 for the teacher; SCH1 for the school). Real student names and email addresses, the teacher’s name and email, and the school name are never transmitted to OpenAI from this surface — identifiers are resolved back to names client-side after the response returns.

2.5 Technical data

• IP address (logged by our hosting provider Vercel for ~7 days)
• Browser user agent
• Device type (iOS app version, OS version) for the mobile app
• Crash logs (PII-scrubbed before transmission to our error monitoring service)

2.6 Information we DO NOT collect

• Social security number
• Payment information from students (we do not charge students; consumer subscriptions are processed by Apple via in-app purchase, and we receive only a non-PII transaction confirmation)
• Biometric data
• Precise geolocation
• Behavioral advertising profiles
• Social graph

We do not collect information from third parties to enrich our own records.

3. How We Use Personal Information

We use the personal information described above to:

• Provide the CentIQ service (lessons, quizzes, live games, CentAI chat)
• Authenticate users (verify your identity at sign-in)
• Track your learning progress so you and (for school-channel users) your teacher can see what you have completed
• Compute leaderboards (where enabled by the school)
• Generate AI-assisted lesson hints and dashboard summaries (CentAI)
• Send transactional emails (account verification, multi-factor authentication codes for administrators, teacher invitations) — we do not send marketing emails to students
• Detect and prevent abuse (rate limiting, security event monitoring)
• Comply with our legal obligations and respond to lawful requests from authorities

We do not use personal information for behavioral advertising, profile building beyond educational personalization, or sale to third parties.

4. Service Providers and Subprocessors

We share personal information with the following service providers (“subprocessors”) strictly to operate the CentIQ service. Each is bound by a data processing agreement that limits their use of the information to the purposes we authorize.

For school-channel deployments, we will furnish the executed DPA with each subprocessor on request. Public DPAs from each vendor are linked in our internal subprocessor inventory; signed copies are filed in our audit binder and shared under the district’s DPA.

We notify school districts of any new subprocessor or material change to an existing subprocessor at least 30 days in advance.

5. Minimum Necessary Use (COPPA §312.7)

We collect only the personal information reasonably necessary for a child to participate in the activity. Specifically:

• We do not require children to disclose more information than is reasonably necessary as a condition of participating in the service.
• A child’s participation in any activity (a lesson, a quiz, a live game) is conditioned on providing only the personal information described in §2 above.
• We do not encourage or require additional disclosure for prizes, recognition, or other features.

6. CentAI and OpenAI

When you use CentAI (the in-app AI assistant), your question is sent to OpenAI together with a server-built locked system prompt and (for some endpoints) lesson context. Specifically:

• The lesson hint endpoint sends your question + the slide text you are reading. It does not send your name, email, school, or any other identifier.
• The dashboard endpoint (used by teachers, not students) sends the teacher’s question + a summary of the teacher’s own class roster (student first names + emails when class size is 30 or fewer; aggregated counts for larger classes).
• The iOS general chat endpoint sends your question + your own progress summary (your points, streak, active course) so CentAI can give context-aware answers. It does not send your name or email.

OpenAI’s API terms specify that they do not use API data to train their models. They retain API requests and responses for up to 30 days for abuse monitoring. As an architectural safeguard, every CentAI surface anonymizes user identifiers before transmission to OpenAI: real names and email addresses are replaced server-side with opaque identifiers (e.g., the speaking user is U1; on the teacher dashboard surface, students are S001, S002, the teacher is T1, and the school is SCH1) and resolved back to names client-side or server-side after the response returns. The user-facing experience is unchanged — OpenAI never sees the real values. This guarantee is enforced in code and verified by an automated regression test in our CI pipeline. We are evaluating OpenAI’s Zero Data Retention (ZDR) tier as a defense-in-depth third layer.

We do not log CentAI prompts or responses on our own servers (neither the question you submit nor the AI’s reply is written to our database).

7. Data Retention

We retain personal information as long as your account is active. Specifically:

• Account information (email, name, role): retained while your account is active.
• Learning telemetry: retained while your account is active so you can resume your progress.
• Live game data: persistent leaderboard stats are retained while your account is active; per-game responses are retained with the game record.
• Audit logs (administrator actions only — not student activity): retained for two years.
• Master administrator multi-factor authentication codes: 10 minutes. Sessions: 30 minutes.

When an account is deleted (see §8), the corresponding data is removed from our active systems within 30 days. Backup copies (daily Firestore exports retained for 30 days) age out within 60 days of deletion.

8. Your Rights — Access, Correction, Deletion, Portability

School-channel users

(Students whose accounts originated from a class code.) Your district is the controller of your data under the FERPA school-official exception. To exercise rights, contact your district’s records officer; the district will issue the request to us, and we will respond through the district. CentIQ commits to processing district-routed requests within the timeline specified in our DPA.

Consumer-channel users

(Those who signed up directly.) You may exercise the following rights at any time:

• Access — request a copy of your personal information.
• Correction — request that we correct inaccurate information (most fields can be edited in your profile; for others, contact us).
• Deletion — request that we delete your account and all associated data.
• Portability — request your data in a structured, machine-readable format (JSON).

Parents / guardians of users under 13 (consumer channel)

Although we restrict consumer-channel signups to users 13 and older, we recognize that parents may discover that an account was created using their child’s information. Parents may at any time:

• Review the personal information we have collected from their child.
• Refuse to permit further collection or use of the child’s personal information by deleting the child’s account.
• Direct us to delete the child’s personal information.

To exercise any of these rights, send an email from a verified parent email address to privacy@centiqapp.com with:

• Subject line: “COPPA Parent Request”
• The child’s email address or display name on the account
• A statement of which right(s) you wish to exercise

We will respond within 5 business days to acknowledge the request and within 30 calendar days with the data export, correction confirmation, or deletion confirmation. We may request additional information to verify your identity as the parent/guardian before fulfilling the request, in compliance with FTC COPPA guidance on verifiable parental consent for review/deletion requests.

9. Data Security

We protect personal information using industry-standard security practices, including:

• TLS 1.2+ encryption in transit for every connection between users, our backend, and our subprocessors.
• AES-256 encryption at rest for all personal information stored in Firestore (Google-managed) and Cloudflare R2.
• Multi-factor authentication required for every administrator action.
• Role-based access control enforced at the database rule layer.
• Audit logging of every administrative action.
• Quarterly internal access review of who can access production student data.
• Continuous security monitoring with PII-scrubbed event capture.

We follow a defined incident response runbook with notification timelines that meet or exceed state-law floors (NY Education Law 2-d 7-day notification, IL SOPPA 30-day, CA SOPIPA / TN “without unreasonable delay”). Specific notification timelines are codified in each district’s DPA.

No security system is impenetrable. If we discover a breach affecting your personal information, we will notify you and (where applicable) your district within the timelines required by law and our DPA.

10. Children’s Privacy and COPPA

The Children’s Online Privacy Protection Act (COPPA) governs the collection of personal information from children under 13.

School channel: COPPA satisfied via the FTC school-authorization theory

For school-channel users, we operate under the FTC’s school-authorization theory (FTC COPPA FAQ §M.2): the school district authorizes CentIQ to collect personal information from students for educational purposes on behalf of the parent. The district is the entity required by law to obtain verifiable parental consent for collection of student information for educational purposes; under our DPA, the district makes this determination.

Consumer channel: 13+ only

Consumer-channel signups require the user to be 13 or older. We collect a date of birth at consumer signup and reject signups from users under 13. We do not knowingly collect personal information from children under 13 in the consumer channel.

If we learn that a child under 13 has created a consumer-channel account, we delete the account and any associated personal information promptly.

If you are a parent or guardian and believe that we have collected personal information from your child under 13 in the consumer channel, please contact privacy@centiqapp.com (see §8 procedures).

11. International Users

CentIQ is intended for use by users in the United States. Personal information is stored on servers located in the United States. If you access CentIQ from outside the United States, your personal information will be transferred to and processed in the United States. By using CentIQ from outside the United States, you consent to this transfer.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes:

• We will update the “Last Updated” date at the top of this page.
• We will notify users via email (or in-app notice for significant changes that change how we collect or use personal information).
• For school-channel deployments, we will notify the district through the channel specified in the DPA.

You can review the current Privacy Policy at any time at www.centiqapp.com/privacy.

13. Contact

General privacy inquiries: privacy@centiqapp.com

Technical / security: josh@centiqapp.com

Mailing address: [To be provided before publication]

For school-channel inquiries, please route through your district’s records officer per §1.

Last updated: May 9, 2026