Introduction & Scope
AINOW EduOS is an all-in-one autonomous AI-native education operating system developed and operated by AINOW Pte. Ltd. (“we”, “us”, or “our”). The platform is specifically built for Singapore education institutions, including tuition centres, enrichment academies, language schools, music academies, sports institutions, private education institutions (PEIs), and training providers.
This Privacy Policy applies to all users of the AINOW EduOS platform, including institution administrators, educators, staff members, parents, legal guardians, and students (collectively referred to as “Users” or “Data Subjects”).
By registering an account, accessing, or using AINOW EduOS, you acknowledge that you have read, understood, and agreed to the practices outlined in this Privacy Policy.
Data Controller & Data Processor Roles
Under the Singapore Personal Data Protection Act 2012 (PDPA):
- Data Controller: The subscribing education institution acts as the primary Data Controller for student, parent, and staff data ingested into AINOW EduOS for administrative and educational operations.
- Data Intermediary / Processor: AINOW Pte. Ltd. acts as a Data Intermediary (Data Processor) processing personal data solely on behalf of and according to the instructions of the subscribing institution.
- Direct Data Controller: AINOW Pte. Ltd. acts as the Data Controller for direct user account management data, direct billing details of subscribers, and platform website analytics.
Personal Data Collected
We collect personal data required to fulfill educational administration, automated fee handling, student safety, and AI-assisted workflows:
Student Records
- Full Legal Name & Preferred Name
- NRIC / FIN / Birth Certificate No. (only where legally mandated or permitted by MOE / EduTrust regulations)
- Date of Birth, Gender & Nationality
- Academic level, school attending, and subject enrolment
- Attendance logs, diagnostic test results & progress reports
- Hardcopy homework submission scans for AI OCR auto-grading
Parent & Guardian Contact Info
- Full Name & Relationship to student
- Singapore Mobile Number & Email Address
- Residential or Billing Address
- Emergency Contact Details
- WhatsApp communication records for AI admissions assistant
Teacher & Staff Profiles
- Name, Staff ID, Professional Email
- Qualifications, certification credentials
- Class schedule allocations & payroll rate attributes
- System audit & activity logs
Payment & Billing Data
- PayNow UEN transaction reference IDs
- GIRO bank account details (masked)
- Credit/Debit Card payment tokens (handled by PCI-DSS Level 1 payment gateways)
- Invoicing logs, package credit balances, and receipt history in SGD
Purpose of Data Collection
Personal data collected within AINOW EduOS is processed exclusively for legitimate, defined educational and operational purposes:
1. Platform Operation & Core Workflows
Managing student enrolment pipelines, class scheduling, attendance tracking, portal access authentication, parent communications, and student progress reporting.
2. Billing & Financial Administration
Generating automated tax-compliant SGD invoices, processing PayNow UEN & GIRO payments, calculating Average Daily Active (ADA) proration, and managing package credits.
3. Singapore Regulatory Compliance
Facilitating compliance audits for Ministry of Education (MOE) registration, Committee for Private Education (CPE/SSG) ERF regulations, Fee Protection Schemes (FPS), and EduTrust standards.
4. AI Agent Processing
Powering the 9 integrated AI agents (e.g., Admissions CRM Agent, Timetable Optimizer Agent, AI Hardcopy Homework Inspector OCR). Note: AI models operate within isolated multi-tenant sandboxes and do NOT retain or share student PII across customers.
Legal Basis under Singapore PDPA
We collect and process personal data in accordance with the legal bases recognized under the Singapore PDPA 2012:
Data Sharing & Third Parties
AINOW Pte. Ltd. does NOT sell, rent, or trade personal data to third parties for marketing purposes. Data is disclosed only to vetted service providers operating under strict confidentiality contracts:
| Third Party Category | Provider Name | Purpose | Data Location |
|---|---|---|---|
| Payment Processors | Stripe / PayNow (DBS, OCBC, UOB) | Payment processing & receipt verification | Singapore / Global PCI-DSS |
| Cloud Hosting & Storage | Amazon Web Services (AWS) | Encrypted database & file hosting | Singapore (ap-southeast-1) |
| Messaging Gateway | Twilio / WhatsApp Business API | Parent notifications & admissions chat | Encrypted Transit |
| System Diagnostics | Sentry / DataDog | Error tracking (Anonymized logs) | SOC 2 Compliant Nodes |
Data Retention & Disposal Standard
In compliance with the PDPA Retention Limitation Obligation, we retain personal data only for as long as necessary to fulfill the educational purposes or meet legal/statutory requirements.
Data Subject Rights under Singapore PDPA
As an individual in Singapore, you possess statutory rights regarding your personal data:
Data Security & Technical Safeguards
We implement enterprise-grade security controls to protect personal data from unauthorized access, alteration, disclosure, or destruction:
Children's Data Protections
Recognizing that AINOW EduOS processes student records for minors (including children under 13 years of age), we enforce heightened protective standards:
- Parental Consent Mandate: Educational institutions using AINOW EduOS warrant that they have obtained verifiable parental or guardian consent before uploading minor student records.
- Zero AI Training on Minors' PII: Homework inspection scans and student progress logs processed by our AI agents are strictly ephemeral for execution and are never used to train foundational AI models.
- Restricted Direct Marketing: Minor student profiles cannot receive direct promotional communications or targeted advertisements.
International Data Transfers
All core platform databases and file repositories are hosted in the AWS Singapore (ap-southeast-1) cloud region.
In compliance with the PDPA Transfer Limitation Obligation, if any cross-border data routing occurs for global backup or specialized cloud services, AINOW Pte. Ltd. ensures that the recipient destination provides a standard of protection comparable to Singapore's PDPA through legally binding agreements or binding corporate rules.
Changes to Policy
We may update this Privacy Policy from time to time to reflect changes in regulatory requirements, AI features, or operational practices.
Material changes will be notified at least 30 days in advance via prominent platform dashboard banners and direct notification to institutional administrators. Continued use of AINOW EduOS following the effective date constitutes acceptance of the revised policy.
Contact Information & Data Protection Officer
Data Protection Officer (DPO)
If you have questions, data access requests, correction notices, or privacy complaints under the PDPA, please contact our designated DPO: