SMART Privacy Policy

Effective Date: July 8, 2026

SURUGIWORLD (“we,” “us,” or “our”) respects the privacy of SMART users. This Privacy Policy explains how we collect, use, share, retain, and protect personal information through the SMART website, mobile application, education operation tools, and related services.

SMART may be used globally, including by students, parents, guardians, teachers, campuses, and partner organizations in Korea, Japan, the United States, and other countries.

1. Information We Collect

We may collect the following information as needed to provide the service.

Account and profile information:

•name, nickname, English name, email address (including Apple Hide My Email private relay addresses when Sign in with Apple is used), login identifier;

•role, campus or partner organization, class, enrollment information;

•student-guardian relationship information;

•language setting, country or region, account status.

Education and learning information:

•class enrollment, attendance, homework, submissions, scores, feedback, comments;

•learning progress, goals, schedules, notifications, ClassMeet reports;

•teacher feedback and operational notes.

User-provided materials:

•homework photos, PDFs, images, audio, recordings, files, messages, comments;

•inquiries, reports, support requests, and related attachments.

Technical and security information:

•authentication IDs, Firebase UID, device and browser information, app version;

•IP address, access time, logs, error records, security events;

•cookies, local storage, and similar technologies used for service operation.

Sensitive information:

We do not intentionally request unnecessary sensitive information. Users should not upload health, religion, political opinions, biometric data, government identification numbers, passport numbers, or other sensitive information unless specifically required for the service. Where limited safety, attendance, or absence-related information is provided for education operations, we process it only as necessary.

2. How We Use Information

We use personal information to:

•create accounts, authenticate users, and manage permissions;

•provide classes, homework, materials, attendance, feedback, schedules, and notifications;

•allow parents or guardians to view a child’s learning status;

•support teachers, campuses, and partner organizations in education operations;

•protect student safety, prevent abuse, and maintain security;

•fix errors, improve service quality, and provide support;

•comply with law, respond to disputes, and protect rights;

•send marketing information about events, Private Classes, or services where consent has been obtained.

We do not sell student or children’s personal information. We do not use children’s personal information for behavioral advertising.

3. Children and Student Privacy

SMART is an education service that may be used by children and minor students. Student accounts may be provided through parents, guardians, schools, campuses, teachers, or partner organizations.

Where applicable law requires parental or guardian consent, such consent is required. If an educational institution creates student accounts or enters student information, that institution must have obtained the required guardian consent and authority.

Parents and guardians may request access, correction, deletion, or restriction of a child’s personal information. We may verify the requester’s identity and guardian relationship before acting.

4. Sharing of Information

We may share personal information only in the following cases:

•with teachers, campuses, or partner organizations responsible for the student’s education operation;

•with parents or guardians linked to a student account;

•with service providers that support hosting, authentication, storage, security, notifications, payments, or customer support;

•when required by law, court order, government request, or to protect rights;

•when necessary to investigate or prevent abuse, security threats, or child safety issues.

We do not sell personal information.

5. Service Providers and International Transfers

SMART may use Firebase, Google Cloud, Apple, Google Play, and other technical service providers. Personal information may be processed in the United States, Japan, Korea, or other countries where our service providers operate.

Where international transfer is required, we work to ensure information is processed only as necessary for service delivery, security, storage, authentication, support, and legal compliance.

6. Retention

We retain personal information for as long as needed for service delivery, education records, learning history, support, security, dispute handling, legal compliance, and legitimate business needs.

When information is no longer needed, we delete, de-identify, or restrict access to it. Some attendance, class, payment, dispute, safety, or compliance records may be retained after account deletion where necessary.

7. Account Deletion and Privacy Rights

Users, parents, or guardians may request access, correction, deletion, restriction, withdrawal of consent, or account deletion.

Requests may be sent via:

•**MY PAGE:** MY PAGE → Policy → **Account deletion policy** or MY PAGE → Settings → Account → **Request account deletion**

•**Support:** MY PAGE → Support → **Report a problem** or MY PAGE → Support → **SURUGIWORLD OFFICE** chat

•**Email:** support@surugiworld.com

•Please include the account email, student name, campus or organization, and request details.

We will process requests within a reasonable period after verifying identity. Information required by law or needed for education operations, disputes, or security may not be deleted immediately.

8. Security

We use authentication, role-based access controls, Firebase/Firestore security rules, storage access restrictions, HTTPS, log monitoring, and administrative access controls to protect personal information.

No online service can be guaranteed to be completely secure. Users must protect passwords, devices, and account access.

9. Marketing Communications

Where consent has been obtained, we may send emails, app notifications, or other communications about events, Private Classes, service updates, and learning-related information. Users may withdraw marketing consent at any time. Essential notices related to classes, security, accounts, payments, or service operation may still be sent.

10. Cookies and Similar Technologies

SMART may use cookies, local storage, or similar technologies for login sessions, security, preferences, error analysis, and service operation. Users may limit some technologies through browser or device settings, but some features may not work properly.

11. Regional Rights

Depending on where users live, they may have rights to access, correct, delete, port, restrict, object to processing, withdraw consent, or complain to a supervisory authority. We respond to requests according to applicable law.

12. Changes

We may update this Policy as the service or legal requirements change. Material changes will be notified through the service, email, or another appropriate method.

13. Contact

SURUGIWORLD

Email: support@surugiworld.com