LEARNCARD PRIVACY POLICY

Last Updated: February 4, 2026

1. Overview and Design Principles

Learning Economy Foundation (“Learning Economy,” “we,” “our”) develops and operates LearnCard, a digital wallet and credentialing platform designed to minimize data collection, prioritize user and guardian control, and prevent monetization of learner data.

LearnCard is not a zero-data system. Limited metadata is processed to operate the service securely. However, credential contents and cryptographic private keys are designed to remain under user or guardian control and are not accessible to Learning Economy in decrypted form.

2. Organizational Identity

Legal Entity: Learning Economy Foundation, LLC
Product: LearnCard
Website: https://www.learncard.app
Contact: privacy@learningeconomy.io

Learning Economy does not sell personal data, operate advertising networks, or act as a data broker.

3. System Architecture and Data Custody

User-Controlled Data

• Private cryptographic keys are generated and stored on user devices
• Credential contents are encrypted end-to-end prior to transmission
• Learning Economy does not possess decryption keys for encrypted credentials

Centrally Stored Metadata

Learning Economy stores limited platform metadata necessary to operate LearnCard, including:

• Profile information (e.g., display name, contact method, country, date of birth if provided)
• Consent and authorization records
• Credential identifiers and metadata (not decrypted contents)
• Guardian-managed account relationships

This metadata is encrypted at rest and transmitted using industry-standard security protocols.

4. Personal Data We Process

Depending on configuration and consent, LearnCard may process:

• Display name or alias
• Email address or phone number (if used for authentication)
• Date of birth and country (for age-based consent enforcement)
• Decentralized Identifiers (DIDs)
• User-provided profile content
• Consent and sharing records

LearnCard does not store:

• User private cryptographic keys
• Decrypted credential contents
• Government-issued identification numbers

5. Analytics, Logs, and Operational Telemetry

LearnCard uses limited operational telemetry solely for security, reliability, and service improvement.

Telemetry may be processed by third-party service providers (e.g., Firebase, Sentry, cloud infrastructure providers) and may include technical identifiers such as IP address, device information, session metadata, or internal identifiers.

LearnCard does not use analytics for advertising, behavioral targeting, or marketing.

K–12 and Minor Protections

• Analytics and telemetry are disabled by default for users under 13
• Analytics for minors aged 13–17 require explicit consent
• Districts and schools may require analytics to be fully disabled
• Minimal security logging may still occur to protect system integrity

Operational telemetry is limited to what is reasonably necessary to operate and secure the service.

6. Data Sharing and Consent

Data sharing occurs only through explicit user, guardian, or district-authorized consent flows.

Users or guardians select which credentials or categories to share. Sharing may be time-limited and revocable where technically feasible.

Learning Economy may observe that a sharing event occurred but cannot access the contents of encrypted credentials.

7. Children, Minors, and Educational Use

LearnCard supports educational use by minors subject to appropriate safeguards.

• Under 13: Access requires verified guardian or school authorization
• Ages 13–17: Parental consent is required where mandated by law

Guardians and schools may manage, review, revoke consent for, or delete student data.

8. Artificial Intelligence Features

LearnCard offers optional AI-assisted features accessed exclusively through LearnCard-controlled systems. Learners do not interact directly with third-party AI platforms.

When enabled:

• User-provided inputs and contextual learning data may be processed by external AI providers
• Learning Economy does not permit AI providers to train models on learner data
• AI providers may retain inputs and outputs in accordance with their own policies

K–12 AI Restrictions

• External AI features are disabled by default for users under 13
• AI features may be restricted or disabled by districts or schools
• All AI usage requires explicit consent from the user or guardian

9. Data Retention and Deletion

Users and guardians may delete accounts at any time.

Deletion removes, to the extent technically feasible:

• Profile data
• Credential metadata
• Consent records

Residual data may persist in:

• Encrypted system backups
• Operational logs and analytics retained by third-party providers
• Credentials previously shared with third parties

10. Security Measures

LearnCard employs:

• Encryption in transit
• Encryption at rest
• End-to-end encryption for credential contents
• Role-based access controls

11. Privacy Rights

Depending on jurisdiction, users and guardians may have rights to access, correct, delete, or export personal data. Requests may be submitted to privacy@learningeconomy.io.

APPENDIX A — K–12 Privacy Commitment

When LearnCard is used pursuant to a school or district agreement:

• No advertising is displayed
• Student data is not sold or monetized
• Analytics and AI features are restricted by default
• Schools and guardians retain authority over access and consent

APPENDIX B — FERPA & COPPA Alignment Statement

FERPA

When contracted by a school or district, Learning Economy functions as a service provider acting under district direction and does not independently control education records.

COPPA

Parental consent is required for children under 13. Data collection is minimized, and analytics and external AI features are disabled by default.

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