TRUEPHONICS PRIVACY POLICY
Last Updated: September 1st, 2026
Introduction
The Boys and Girls Club of Kingston & Area Inc., operating as TruePhonics (“TruePhonics,” “we,” “us,” or “our”), is proud to offer a web-based structured literacy platform designed to help educators, schools, and school boards manage classrooms, assess progress, and systematically develop foundational reading skills toward fluency, known as the “TruePhonics Platform”.
This Privacy Policy explains what information we collect and describes how we collect, use, store, disclose, and protect the personal information of our customers through our TruePhonics Platform and related websites, mobile applications, web portals, educational content, and services (collectively, the “Services”).
This Privacy Policy also explains how you can ask us questions and make suggestions about our privacy practices and review and update such information.
1. DEFINITIONS
For the purposes of this Privacy Policy, the following definitions apply:
a) “Authorized User” means individuals, including students, educators, administrators, parents and legal guardians, that the Institution allows to access and use the Services as permitted in an Institution Contract;
b) “Controller” has the meaning attributed to it in the applicable GDPR Laws.
c) “Customer” or “you” means Direct Customers and Institutions that are subscribed to access and use the Services.
d) “Data Subject” means the person to which the Personal Information relates.
e) “Direct Customer” means an individual that subscribes to the Services for personal or household use.
f) “Direct Subscription” means a subscription to the Services purchased by a Direct Customer, including through the Apple App Store or Google Play or similar service.
g) “EU GDPR” means the General Data Protection Regulation ((EU) 2016/679).
h) “FIPPA” means the Freedom of Information and Protection of Privacy Act, R.S.O. 1990, c. F.31
i) “GDPR Laws” means:
a. To the extent the UK GDPR applies, the law of the United Kingdom or of a part of the United Kingdom which relates to the protection of Personal Information.
b. To the extent the EU GDPR applies, the law of the European Union or any member state of the European Union to which the Customer or TruePhonics is subject, which relates to the protection of Personal Information.
j) “Institution” means a publicly funded school, school board or other third-party organization that subscribes to or enters into an agreement with TruePhonics for access to or use of the TruePhonics Platform.
k) “Institution Contract” means a purchase order, invoice, quote, or service agreement produced by TruePhonics for an Institution relating to the Services.
l) “Institution Data” means Personal Information provided by an Institution or its Authorized Users.
m) “MFIPPA” means the Municipal Freedom of Information and Protection of Privacy Act, R.S.O. 1990, c. M.56
n) “Personal Information” means information about an identifiable individual, or information that is otherwise defined as “personal information,” “personal data” or an equivalent term under applicable Privacy Laws.
o) “PIPEDA” means the Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5)
p) “Privacy Laws” means all applicable laws relating to the collection, use, disclosure, processing, protection, retention or other handling of Personal Information, including, as applicable, PIPEDA, MFIPPA, FIPPA and the GDPR Laws.
q) “Processor” has the meaning attributed to it in the applicable GDPR Laws.
r) “Public Website” means www.truephonics.ca and any associated informational, marketing, or promotional webpages.
s) “Student Management Dashboards” means the cloud-hosted portal where educators administer classes, manage literacy modules, and track analytics, accessible through portal.truephonics.ca and any associated webpages.
t) “Services” has the meaning given in the Introduction.
u) “UK GDPR” has the meaning given to it in section 3(10) (as supplemented by section 205(4)) of the Data Protection Act, 2018 (UK).
Any terms not described herein have the meanings given in our TERMS OF SERVICE AND LICENSE AGREEMENT available on our Public Website.
2. CONSENT TO COLLECTION, USE, DISCLOSURE
By accessing our Public Website, or by using the Services, you are providing your consent for us and our approved third-party agents to collect, use and disclose your Personal Information in accordance with this Privacy Policy and applicable laws.
No compensation is offered for sharing your information.
You may withdraw your consent at any time, subject to applicable laws. You may also withhold your consent to providing personal information, and you may consent to provide some but not all of any requested personal information. You do not have to provide us a reason for withholding consent.
If you are a parent or guardian of a minor learner who’s Personal Information is being collected, used, or disclosed in accordance with the terms of this Privacy Policy, you consent to the same.
All Institutions subscribing for the Services shall be responsible for obtaining consent of any Authorized Users to the terms herein and shall make these terms available to such Authorized Users.
3. THE DATA WE COLLECT
A. Learner Personal Information
TruePhonics may receive the following, some of which may be considered Personal Information in respect of learners using our Services:
• learners' first and last name (or alias);
• student ID;
• gender;
• date of birth;
• school and classroom;
• teacher name;
• learning progress (completed lessons and activities);
• assessment results;
• time spent on learning activities; and
• achievement information (such as stars earned).
B. Institution Personal Information
When an Institution subscribes to the Services, we may collect the following information related to the educators, administrators and other authorized representatives of the Institution, some of which may be considered Personal Information:
• first and last name;
• job title;
• School Board affiliation;
• school name;
• professional email address;
• institutional phone number;
• reports and performance data; and
• financial billing data.
C. Cookies
As you navigate through and interact with the Services, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns for session persistence, system performance, and application security, some of which may be considered Personal Information including:
• Details of your visits to our Website, including traffic data and other communication data and the resources that you access and use on the Website; and
• Information about your computer and internet connection, including your IP address, operating system, and browser type.
D. Subscription Information
When individuals subscribe to the TruePhonics Platform directly through the Apple App Store or Google Play, we process limited subscription information necessary to manage access to the platform and provide customer support.
This information may include:
• subscription status (e.g., Trial, Active, Expired, or Cancelled);
• purchase platform (Apple App Store or Google Play);
• subscription start and expiry dates;
• first and last name; and
• transaction or purchase identifiers provided by the applicable app store.
4. USE OF PERSONAL INFORMATION
A. Uses of your Personal Information
To the extent of applicable Privacy Laws, you agree and hereby consent that we may use your Personal Information:
• To provide the Services, including your use of the TruePhonics Platform and/or presenting our Public Website and its contents to you. This includes:
• creating a learner’s account;
• saving learning progress between sessions;
• providing lessons at the appropriate level;
• allowing teachers to monitor progress; and
• generating reports that help teachers support student learning
• to investigate and prevent errors, defects, performance and security issues;
• to generally enhance your experience with the TruePhonics Platform;
• to contact you about changes or similar notices related to the TruePhonics Platform or other services that we feel may be of interest to you;
• for the purposes of assisting in the investigation of a contravention of a federal, provincial, or foreign law or to protect or defend a legal interest, if we have reasonable grounds to believe the information could be useful for such purposes;
• in the course of any merger, acquisition, financing, or sale of all or a portion of the Services, provided that any purchasers or transferees are contractually obligated to keep Personal Information confidential, use it only for the purposes for which we disclose it to them, and to process the Personal Information with the same standards set out in this policy;
• for the purposes of research and program evaluation, provided that any use of learner Personal Information will be anonymized in any such research;
• for other such purposes as may be required by applicable law; or
• for any other purpose with your consent.
B. No commercial monetization
TruePhonics processes Personal Information exclusively for the prescribed uses above, and for greater certainty:
• We never sell, rent, lease, or monetize student data.
• We never build marketing profiles, track cross-site behaviours, or target commercial advertising to child or youth users.
• We never reuse or repurpose student performance data for independent product research and development unless the data is stripped of all administrative links and fully and permanently anonymized in accordance with global best practices.
C. Use of Financial Information
Financial billing data provided by Institutions is transmitted securely and handled strictly through an industry-standard, PCI-compliant payment gateway.
All such financial and billing data provided to such third-party payment processor shall be subject to its applicable privacy practices.
For Direct Customers, TruePhonics does not collect, receive, or store payment card numbers, banking information, or other financial payment credentials. All payment processing is handled directly and securely by Apple or Google through their respective app store payment systems.
5. DISCLOSURE OF PERSONAL INFORMATION
We may disclose Personal Information that we collect, or you provide as described in this Privacy Policy:
• to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Public Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy;
• to fulfill the purpose for which you provide it;
• for any other purpose disclosed by us when you provide the information; or
• with your consent.
6. RELATIONSHIP & ROLES
The way in which your Personal Information is processed, and the corresponding level of control that we maintain, depends on whether you access the TruePhonics Platform as a Direct Customer or as an Institution:
A. Institution processing
The Institution shall retain custody and control over all Institution Data and shall be responsible for determining the purposes and means for which Institution Data is collected, used and disclosed in accordance with privacy laws applicable to the Institution.
In this arrangement, TruePhonics will only process the personal information to the extent, and in such a manner, as is necessary to deliver curriculum programming services in accordance with the Institution's instructions.
Where GDPR Laws apply, the Institution shall be deemed to be the Controller of Institution Data and TruePhonics shall be deemed to be the Processor.
B. Direct Customer and Public Website processing
For Direct Customers that have purchased a Direct Subscription, TruePhonics shall be responsible for determining how Personal Information associated with those Direct Customer accounts and use of the TruePhonics Platform is collected, used, disclosed and stored.
In these circumstances, TruePhonics shall be responsible for such Personal Information in accordance with this Privacy Policy.
All Direct Customer account information is managed separately from Institution customer information and such accounts are maintained in separate databases with independent access controls to support data segregation and security.
TruePhonics is responsible for determining how Personal Information is collected, used, disclosed and stored when adult educators browse our Public Website, download marketing brochures, or request pricing sheets.
Such collection, use, disclosure and storage shall be in accordance with this Privacy Policy.
7. PRIVACY & CORRECTION RIGHTS
Individuals may request access to, correction of, or deletion of their Personal Information where permitted by applicable Privacy Laws.
• For Institutions: Requests relating to Personal Information provided to or by Institutions should be directed to the applicable Institution that is responsible for the student's account, as that organization determines the purposes for which the information is collected and used.
• For Direct Customers: If you want to review, verify, correct, or withdraw consent to the use of your Personal Information (or Personal Information related to your child that is under the age of 13), you may send us an email at truephonics@bgcsoutheast.ca with a corresponding request to access, correct, or delete any Personal Information that you have provided. Parents or guardians managing their own TruePhonics Platform subscription may contact TruePhonics directly.
If you are unsure whether we have a record containing any of your Personal Information (or Personal Information related your child under the age of 13) and would like to confirm whether or not we do, or if you would like to withdraw your consent to the use of such Personal Information as described in this Privacy Policy or if you have any comments or suggestions, please send an e-mail to truephonics@bgcsoutheast.ca.
We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We may charge you a fee to access your Personal Information; however, we will notify you of any fee in advance.
8. SECURITY SAFEGUARDS & DATA LOCALIZATION
TruePhonics maintains a comprehensive information security program designed to safeguard student data against loss, unauthorized access, or disclosure:
• Encryption & Data Localization: Data is protected using enterprise-grade encryption protocols (AES-256) at rest, and all transit connections utilize secure HTTPS TLS encryption pipelines. All third-party cloud infrastructure vendors and operational sub-processors utilized by TruePhonics are vetted against Canadian privacy benchmarks and are contractually obligated to maintain the confidentiality of Personal Information. TruePhonics requires its core technical suppliers to formally warrant that their processing facilities comply with relevant provincial and federal data protection statutes.
• Canadian Data Localization Option: TruePhonics offers dedicated data residency routing, allowing Canadian clients to mandate that all student records and operational databases are physically hosted and backed up within Canadian cloud data centers. Canadian customer data is stored exclusively within the Canadian database hosted in Amazon Web Services (AWS) Canada (Montréal). Direct Customer subscription data and Institutional customer data are maintained in separate databases with logical separation and independent access controls.
• Breach Notification: In the event of a confirmed or reasonably suspected breach of our security safeguards impacting your Personal Information that poses a real risk of significant harm to you, we are committed to notifying the Office of the Privacy Commissioner of Canada (OPC) and affected individuals in accordance with requirements under applicable Privacy Laws.
You are also responsible for helping ensure the security of your Personal Information.
For example:
• Registered educators and School Board administrators are responsible for maintaining the confidentiality of their platform credentials. In accordance with educational data protection best practices, accounts must be monitored to ensure student users do not gain unauthorized access to administrative or educator-facing dashboards. Creating accounts using false identities or unauthorized aliases is strictly prohibited.
• Registered educators and administrators are advised that while TruePhonics provides enterprise-grade data protection, the endpoint connection remains an active vector. Authorized platform users must employ a secure, authenticated internet connection when interacting with student profiles and explicitly avoid accessing student literacy reports or phonics screening tools over unencrypted public Wi-Fi networks (e.g., airport, library, or café networks) where unauthorized data sniffing risks are structurally heightened.
9. DISPOSITION & RETENTION
Personal Information shall be retained for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Archival Copy Retention Policy: When an educator account or student information profile is flagged for modification or erasure at the direction of the contracting School Board, TruePhonics immediately soft-deletes the records from active interfaces.
To ensure continuous application availability and infrastructure backup integrity, a secure, unrevised archival copy may be temporarily held within encrypted database backups for the minimum duration required to maintain operational backup synchronization, settle system errors, or fulfill underlying legal framework timelines.
Once these isolated backup rotation windows expire, the information is completely and irreversibly scrubbed or unidentifiably aggregated.
10. INDEPENDENT RECOURSE & REGULATORY OVERSIGHT
In the event you believe your Personal Information has been handled improperly, you have the right to submit a complaint to our organization at the address indicated below and to the applicable privacy regulator, which in Canada would be the Office of the Privacy Commissioner of Canada (OPC).
11. CHILDREN AND MINORS
Our Public Website is not intended for any user under the age of majority.
The TruePhonics Platform, however, may be made available to students, including children under the age of 13, through an Institution or Direct Customer that subscribes to the TruePhonics Platform.
In those circumstances, Personal Information about students may be provided to TruePhonics by the Institution or its Authorized Users or collected through a student’s use of the TruePhonics Platform.
We do not knowingly collect Personal Information directly from children under the age of 13 outside of circumstances where the Institution controls all Personal Information and is responsible for any inputs, or where TruePhonics has received the consent of a parent or guardian.
If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at the address indicated below.
12. CHANGES TO THIS PRIVACY POLICY
We may from time to time change our Privacy Policy in our sole discretion. Changes will be effective when a new version is made available through our Public Website. If you continue to use the TruePhonics Platform after the changes have been posted, you are accepting these changes. It is your responsibility to read, understand and agree to the terms of this Privacy Policy and any changes made. If you do not agree to this Privacy Policy or any changes, it is your responsibility to cancel your subscription to cease use of our Public Website and the Services.
CONTACT TRUEPHONICS PRIVACY OFFICE
For any clarifying structural questions regarding our data architecture or to request compliance documentation for school board evaluations, please contact us: truephonics@bgcsoutheast.ca
