LEARNCARD PRIVACY POLICY

Last Updated: October 27, 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.

This Privacy Policy explains how Learning Economy Foundation processes personal data in connection with LearnCard and related services. The personal data processed, the purposes of processing, and the rights available to individuals depend on how the Services are used and whether LearnCard is provided directly to an individual or under an agreement with a school, district, employer, or other organisation. Where an organisation determines the purposes and means of processing, additional privacy notices and contractual terms may apply.

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2. Organizational Identity

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

Learning Economy processes personal data as described in the Privacy Policy. Depending on the service and deployment, Learning Economy may act as a controller for certain processing activities or as a processor acting on the documented instructions of a school, district, or other organisation. Learning Economy's role and responsibilities are determined by the actual processing activities, applicable law, and relevant contractual arrangements.

3. System Architecture and Data Custody

User-Controlled Data

LearnCard is designed to give individuals and, where applicable, their guardians control over their learning credentials and authorised data sharing.

To protect accounts while allowing recovery, a user’s private key is split into several encrypted parts, with two shares required to reconstruct the key. Learning Economy stores one encrypted share on its servers and uses a separate escrow system to hold a last recovery share. If a learner loses access to all other recovery methods, this system allows the learner to recover their account after a seven day waiting period. These systems are carefully designed to support account recovery without giving Learning Economy independent access to a learner’s private key.

Credentials stored in a user’s personal LearnCard storage are encrypted using  the user’s key, which Learning Economy does not hold in a form that allows it to decrypt those credentials. However, not all credentials are end to end encrypted in every situation. This includes credentials that a user chooses to send unencrypted and credentials sent through the universal inbox to an email address not linked to a LearnCard account. In the latter case, the credential/s are stored temporarily until the recipient claims them. Once the credentials are claimed they are then deleted from Learning Economy’s servers and are encrypted for the recipient. 

Account and network metadata, as well as text submitted to AI assisted features, may also be processed outside end-to-end encrypted storage. 

These protections apply subject to the technical design and configuration of the relevant feature. They do not mean that all personal data processed by LearnCard is inaccessible to Learning Economy.

Centrally Stored Metadata

To operate, secure, and maintain LearnCard, Learning Economy may process and store platform metadata, including:

• Profile information and account identifiers.
• Decentralized Identifiers (DIDs) and other technical identifiers.
• Consent, authorisation, and account relationship records.
• Credential identifiers, issuer information, and other credential metadata.
• Security, audit, and operational records.

Certain metadata may be accessible to authorised personnel or systems where necessary for service operation, support, security, or administration.

Encryption at rest and in transit is used where applicable. The protection applied to particular data depends on its type, storage location, and technical function.

LearnCard's architecture is intended to minimise unnecessary access to learner data while enabling the Services to function securely.

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4. Personal Data We Process

Depending on how LearnCard is used and configured, the user's privacy preferences, and any applicable guardian or school settings, Learning Economy may process the following categories of personal data. Not all categories apply to every user.

Account and Identity

• Display name, profile ID, profile photo, biography, website links and preferred language.
• Email address and phone number, where provided or used for sign-in, contact or account recovery, including verification status.
• Decentralized identifiers (DIDs) and information linking an account to sign-in providers, such as Firebase, Posthog or OpenID Connect (OIDC).
• Date of birth, country or region, and age-related indicators used to apply age-based settings and feature restrictions.
• Profile visibility and connection settings.

Credentials and Sharing

• Credential contents, including credentials temporarily stored in plaintext when a user chooses to send a credential unencrypted or when a credential is sent through the Universal Inbox to a recipient who does not yet have a LearnCard account.
• Credential metadata, such as credential names, achievement types, and issuer and recipient identifiers.
• Credential lifecycle and audit records, including creation, delivery, claiming, expiry and revocation events, together with relevant actors and timestamps.
• Credentials awaiting claim, including the email address or phone number to which they are addressed, where applicable.
• Consent records, consent terms, referral requests and records of information shared with others.

Relationships and Organisations

• Guardian and managed-account information, including managed profile types, relationships between accounts, guardian email addresses and guardian approval status, where applicable.
• Organisation roles and permissions, including administrator, issuer and member permissions relating to organisational credentials.
• Connections and blocked profiles.

Account Security and Recovery

• Encrypted private-key shares and records of available recovery methods, which may include passkeys, backup files, recovery phrases, email-based recovery and escrow recovery.
• Recovery requests and related records, including source IP addresses, request status, release times and recovery-related email delivery records.
• Privacy preferences, including settings for AI-assisted features, analytics and bug reporting.

Device and Usage Data

• Push notifications.
• IP addresses, device type, operating system, app version, locale and platform information.
• Product analytics events, which may be linked to a user's DID.
• Error reports and diagnostic information, including session replay data where enabled and subject to applicable masking or blocking controls.
• Feedback and bug reports submitted by users.

Apps and AI-Assisted Features

• Information about installed or connected apps and app-specific data, such as points, streaks, levels and notifications, where applicable.
• Text and other information submitted to AI-assisted features, which may be processed by our AI service providers.

Information from Other Sources

• Credentials and recipient contact details received from issuers, schools and organisations.
• Information shared with or received from connected apps, subject to the relevant permissions and sharing settings.

Security and Audit Logs

• Error reports and security monitoring logs.
• Account recovery and authority-related audit trails.
• System and access logs.

The personal data processed depends on the features used, account configuration, applicable permissions and any relevant school or district agreement. Some information may be processed temporarily or for specific purposes, such as delivering a credential or recovering an account as stated above in this privacy policy.

Credentials stored in a user's personal LearnCard storage are encrypted using the user's key, and Learning Economy does not hold the keys needed to decrypt those credentials. However, credentials sent unencrypted or through the Universal Inbox before a recipient claims them may not be end-to-end encrypted during transmission or temporary storage. Account and network metadata, security and operational logs, and information submitted to AI-assisted features may also be processed outside end-to-end encrypted storage.

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5. Analytics, Logs, and Operational Telemetry

LearnCard may process technical information to maintain security, investigate errors, support service reliability, and understand the operation of the Services.

Depending on the features enabled, this information may include IP addresses, device and session information, timestamps, error reports, account or technical identifiers, and records of interactions with the platform.

Third-party infrastructure and monitoring providers may process this information on our behalf. These providers may include Firebase, Sentry, Posthog, and other providers identified in the applicable service configuration or privacy information.

The information collected, its purpose, and its retention depend on the relevant service and configuration. We do not use operational telemetry for behavioural advertising or the sale of learner profiles.

Where analytics or similar technologies are optional or require consent under applicable law, they will be subject to the relevant consent and preference mechanisms.

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K–12 and Minor Protections

LearnCard uses a user's age, country or region, account type, and applicable guardian or school settings to determine access to optional analytics and AI-assisted features. These features may be restricted or disabled for younger users, depending on the applicable age threshold and the user's privacy settings.

For users below the applicable product threshold, optional analytics and AI-assisted features are disabled by default through the initial privacy settings. For eligible accounts above that threshold, these features may be enabled by default, subject to the user's account type, available privacy settings, and any applicable guardian or school restrictions.

Feature availability and default settings do not, by themselves, determine whether consent or other authorisation is legally required. LearnCard applies additional restrictions where required by applicable law or by the terms governing a school or district deployment. Where consent or authorisation is required, the appropriate consent or authorisation process must be followed.

Schools and districts may require optional analytics or AI-assisted features to be disabled for their deployments. Users may manage the privacy preferences available to them, subject to applicable account, guardian and school settings.

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Limited security and operational logging may continue when optional analytics are disabled, where reasonably necessary to operate and secure LearnCard, protect system integrity, and investigate or prevent misuse. Such logging is limited to what is reasonably necessary for these purposes.

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

6. Data Sharing and Consent

LearnCard allows users and, where applicable, their guardians or educational institutions to control the sharing of learning credentials and other information through available consent, authorisation and privacy settings. Users may select which credentials or categories of information to share. 

Depending on the feature used, information may also be processed by Learning Economy's service providers, including providers supporting AI-assisted features, account recovery, analytics, security and service operation. Such processing is subject to applicable privacy requirements and the relevant service settings and agreements.

Credentials stored in a user's personal LearnCard storage are encrypted using the user's key, and Learning Economy does not hold the keys needed to decrypt those credentials. However, not all credential transfers are end-to-end encrypted. Credentials that users choose to send unencrypted, and credentials sent through the Universal Inbox to recipients who do not yet have a LearnCard account, may be temporarily processed or stored in a form that is not end-to-end encrypted. Universal Inbox credentials are deleted from Learning Economy's servers after the recipient claims them and are then encrypted for the recipient, subject to the applicable technical and retention arrangements.

Learning Economy may record that a sharing or consent event occurred, together with related metadata such as timestamps, recipient identifiers and the scope of the sharing. These records help operate the service, maintain audit trails and support security and accountability. The contents of encrypted credentials in a user's personal storage remain protected by the user's key, but Learning Economy may process other information associated with credential delivery, sharing and service operation.

Where a school or district governs the use of LearnCard for its deployment, additional authorisation requirements and restrictions may apply under the relevant agreement and applicable law. Consent or authorisation is obtained where required by law; the availability of a sharing or privacy setting does not, by itself, establish that all legal consent requirements have been met.

7. Children, Minors, and Educational Use

LearnCard may be used by children and young people, including through school and district deployments. We recognise the importance of protecting children's personal data and applying safeguards appropriate to their age, location and circumstances. 

Age-Appropriate Processing

The information processed and features available may depend on the user's age, country or region, account type, privacy preferences, and applicable guardian or school settings.

LearnCard applies country-specific age thresholds to determine whether a parent or guardian must create and authorise a child's account. Where the applicable threshold requires parental consent, a parent must sign up and authorise the child's account before the child can use the service.

Optional analytics and AI-assisted features are disabled by default for children. Their availability may also be subject to applicable law, account settings, and guardian or school restrictions.

These product safeguards do not replace any additional consent, authorisation or other requirements imposed by applicable law. School or district involvement does not, by itself, remove the need to comply with applicable privacy and children's data protection requirements.

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Guardian and School Involvement

Depending on the deployment, applicable law and relevant agreements, authorised guardians and schools may be able to manage accounts, permissions, access, and requests concerning student information.

The respective responsibilities of Learning Economy, schools, districts, guardians, and learners depend on the applicable law, service configuration, and contractual arrangements.

Children's Privacy Safeguards

We seek to:

• Minimise the personal data collected from children.
• Restrict access to authorised purposes.
• Apply age-appropriate privacy settings.
• Disable optional analytics and AI-assisted features by default for children.
• Provide appropriate information about how personal data is processed.
• Support applicable rights to access, correct, or delete personal data.

Limited security and operational logging may continue when optional analytics are disabled, where reasonably necessary to operate and secure LearnCard, protect system integrity, and investigate or prevent misuse.

The availability of particular controls and the process for exercising rights may vary according to the relevant school or district agreement and applicable law.

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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

Learning Economy retains personal data only for as long as reasonably necessary for the purposes for which it is processed, subject to applicable legal obligations and contractual requirements.

Retention periods depend on the category of information, the purpose of processing, the applicable deployment, and any legal or security requirements.

Deletion Requests

Subject to applicable law and the relevant contractual arrangements, users or authorised guardians may request deletion of account information through the available account controls or by contacting privacy@learningeconomy.io.

For school and district deployments, deletion requests may need to be handled in coordination with the relevant institution where it determines the purposes and means of processing.

Where deletion is appropriate, we will take steps to delete or anonymise the relevant personal data from active systems within the applicable operational and contractual timeframes.

Exceptions and Residual Data

Some information may remain for a limited period where necessary for:

• Encrypted backups and disaster recovery.
• Security, fraud prevention, and audit requirements.
• Compliance with legal obligations.
• Establishing, exercising, or defending legal claims.
• Processing by third parties that have independently received the information and are entitled or required to retain it.

Where data remains in backups or other residual systems, it will be subject to appropriate safeguards and deleted or overwritten in accordance with applicable retention procedures.

Deleting an account does not necessarily delete credentials or information previously disclosed to third parties. Requests concerning information held by those parties may need to be made directly to them or handled under the relevant contractual arrangements

10. Security Measures

LearnCard employs:

• Encryption in transit and at rest
• Vendor security and access controls
• End-to-end encryption for credential contents
• Role-based access controls and restrictions on privileged access.

Access to personal data is limited to authorised personnel and systems where necessary for legitimate operational, security, support, or administrative purposes.

11. Privacy Rights

Depending on the applicable law and the circumstances of the processing, individuals may have rights to:

• Request access to their personal data.
• Request correction of inaccurate or incomplete information.
• Request deletion of personal data.
• Request restriction of processing.
• Object to certain processing activities.
• Request portability of personal data where applicable.
• Withdraw consent where processing is based on consent..

These rights are subject to applicable legal conditions and exceptions.

How to Exercise Your Rights

Requests may be submitted to privacy@learningeconomy.io. We may need to verify the identity and authority of the person making a request to protect the relevant individual.

Where a school, district, or other organisation determines the purposes and means of processing, we may refer the request to that organisation or coordinate with it to ensure that the request is handled appropriately.

We will respond within the time limits required by applicable law.

Where required, we will provide information about the relevant supervisory authority and the process for lodging a complaint.

12. International Data Transfers

LearnCard may use service providers and infrastructure located in, or processing personal data from, countries other than the country in which the individual resides.

Where personal data is transferred internationally, Learning Economy will apply the transfer mechanisms and safeguards required by applicable data protection law.

Depending on the circumstances, these may include an applicable adequacy decision, approved contractual safeguards, or another lawful transfer mechanism.

Information about relevant transfer destinations, safeguards, and how to obtain further details will be provided where required by applicable law.

13. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in law, technology, the Services, or our data processing practices.

The date at the beginning of this Policy indicates when it was last updated. Where changes are material, we will provide notice through appropriate channels and obtain any additional consent required by applicable law.

The applicable privacy notice and contractual terms will govern the relevant service, subject to mandatory legal requirements.

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APPENDIX A — K–12 Privacy Commitment

When LearnCard is provided under a school or district agreement:

• Student data is not sold or used for behavioural advertising.
• Personal data is processed in accordance with the applicable agreement, documented instructions, and legal requirements.
• Access to student information is restricted to authorised purposes.
• Analytics and AI features are subject to applicable privacy requirements and the relevant deployment configuration.
• Student data is retained and deleted in accordance with applicable contractual obligations and retention procedures.
• Schools, districts, guardians, and learners may exercise the rights and controls available to them under applicable law and the relevant agreement.

The precise responsibilities of Learning Economy and the relevant school or district depend on the applicable agreement, the processing activities, and applicable law.

This commitment supplements, and does not replace, any applicable data processing agreement or other contractual privacy and security requirements.

APPENDIX B — FERPA & COPPA Alignment Statement

FERPA

For school and district deployments subject to the Family Educational Rights and Privacy Act (FERPA), Learning Economy's role and obligations depend on the applicable agreement and the circumstances of the disclosure.

Where Learning Economy receives education records under the school-official exception, the relevant arrangements must satisfy the applicable requirements, including direct institutional control over the use and maintenance of education records, limits on use, and restrictions on redisclosure.

Learning Economy will process education records in accordance with the applicable contractual instructions and legal requirements.

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COPPA

Where the Children's Online Privacy Protection Act (COPPA) applies, Learning Economy will comply with the applicable requirements relating to children's personal information, including notices, verifiable parental consent where required, parental rights, security, disclosure, and retention. Parental consent is required for children under 13.

School involvement will be relied upon only where permitted by applicable law and subject to the relevant conditions.

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LEARNCARD TERMS OF SERVICE

Learner Sovereignty & Education Infrastructure Edition
Last Updated: February 4, 2026

TABLE OF CONTENTS

1. Agreement to These Terms
2. Our Mission and Role
3. Eligibility and Account Responsibility
4. LearnCard, LearnCloud, and the Ecosystem
5. Learner Data, Credentials, and Ownership
6. Consent, Data Connections, and Portability
7. Connected Applications and App Marketplace
8. AI-Assisted Learning and Training Features
9. Credential Issuance and Interpretation
10. Acceptable Use
11. Third-Party Services and Integrations
12. Suspension and Termination
13. Privacy and Data Protection
14. Data Retention and Deletion
15. Disclaimers
16. Limitation of Liability
17. Indemnification
18. Changes to the Services or Terms
19. Governing Law
20. Contact Information

HOW TO READ THESE TERMS (SIMPLE OVERVIEW)

Component

What It Means

LearnCard Wallet

Your personal learning and employment passport

LearnCloud

Secure infrastructure that stores encrypted records and consent metadata

Consent Layer

You decide what data connects to which apps, and for how long

App Ecosystem

Optional third-party tools (education, jobs, productivity) you can connect

AI Features

Optional tools to explore skills, learning, and pathways — not decision-makers

Our Role

Infrastructure steward, not data owner, employer, or authority

Your Role

Owner of your data and decisions

1. Agreement to These Terms

These Terms of Service (“Terms”) govern your access to and use of LearnCard and LearnCloud, including our websites, applications, APIs, and related services (collectively, the “Services”).

By accessing or using the Services, you agree to these Terms.
If you do not agree, you may not use the Services.

If you use the Services on behalf of a minor, school, district, or other organisation, you represent that you have the legal authority to do so. These Terms bind that minor or organisation only to the extent permitted by applicable law and any applicable agreement. Use of the Services by a school, district, or other organisation may also be governed by a separate written agreement, which will govern in the event of a conflict concerning the institutional services it covers.

2. Our Mission and Role

Learning Economy Foundation, LLC is a U.S.-based nonprofit organization, recognized under Section 501(c)(3) of the Internal Revenue Code, dedicated to learner agency, guardian authority, and data sovereignty.

LearnCard and LearnCloud are designed as public-good infrastructure to:

• Enable individuals to hold and share their learning and employment records
• Allow guardians and schools to manage access for minors
• Support lifelong learning and workforce mobility
• Prevent the sale or monetization of learner data

We act as a technical steward and service provider, not as:

• An employer
• A school
• A credentialing authority
• A hiring decision-maker
• A guarantor of outcomes

Learning Economy processes personal data as described in the Privacy Policy. Depending on the Services and the relevant processing activity, Learning Economy may act as a controller of personal data or as a processor acting on the documented instructions of a school, district, or other organisation. Its role and responsibilities are determined by the actual processing activities, applicable law, and relevant contractual arrangements.

3. Eligibility and Account Responsibility

LearnCard may be used by adults, minors where permitted by applicable law and the relevant authorisation requirements, and schools, districts, and organisations under applicable agreements.

Where an account is used by or on behalf of a minor, the applicable guardian, school, district, or other authorised party is responsible for the account-related actions within its lawful authority. 

Users must provide accurate information where required, safeguard their access credentials, and use the Services lawfully and responsibly. Users must not misrepresent their age, authority, identity, or permission to act for another person or organisation.

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4. LearnCard, LearnCloud, and the Ecosystem

LearnCard is a digital wallet and passport for learning and employment data.
LearnCloud provides secure infrastructure that supports storage, encryption, and consent-based access.

Together, they function similarly to:

• A bank account + budgeting apps (for financial data), or
• A payments platform + connected services (for transactions)

Except applied to learning, skills, and employment records.

5. Learner Data, Credentials, and Ownership

5.1 Learner Ownership

5.1 Learner Data and Credentials

As between Learning Economy and the learner, Learning Economy does not claim ownership of learner-provided credentials or personal records solely because they are stored or processed through the Services.

Ownership of particular credentials, documents, content, and other materials depends on the applicable rights and laws. Nothing in these Terms transfers ownership of a learner's materials to Learning Economy merely through use of the Services.

These Terms do not determine or replace the legal rights of data subjects, the responsibilities of data controllers, or the rights of credential issuers and other third parties.

5.2 Limited Permission to Operate the Services

You grant Learning Economy a limited, non-exclusive, worldwide, royalty-free permission to host, store, reproduce, transmit, and technically process content you submit, solely as necessary to provide, secure, maintain, and support the Services and to comply with applicable law and the relevant contractual arrangements.

This permission does not transfer ownership of your content to Learning Economy and does not authorise Learning Economy to sell your personal data or use learner content for unrelated advertising.

Where you use the Services through a school, district, or other organisation, the applicable agreement and authorisations govern the processing of information supplied or controlled by that organisation.

5.3 Learning Economy Intellectual Property

Learning Economy and its licensors retain their respective rights in the Services, including platform software, source code, APIs, designs, documentation, trademarks, and other intellectual property, except to the extent expressly licensed or otherwise agreed in writing.

Use of the Services does not transfer ownership of Learning Economy's intellectual property to a user. Any open-source components remain subject to their applicable open-source licences.

Except for the limited rights expressly granted under these Terms or an applicable licence, no rights in Learning Economy's intellectual property are transferred to you.

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6. Consent, Data Connections, and Portability

LearnCard is built around explicit, revocable consent.

You control:

• Which data is shared
• With which applications or systems
• For what purpose
• For what duration

You may revoke consent where technically feasible.

Data portability is a core principle: credentials are designed to be usable beyond LearnCard, using open standards.

7. Connected Applications and App Marketplace

LearnCard and LearnCloud may enable you to connect your data to third-party applications and services, including:

• Learning management systems
• Workforce and HR systems
• Job platforms
• Productivity and career tools
• Educational and training applications

These connections are:

• Initiated by you (or your guardian or school)
• Governed by your consent
• Subject to the third party’s own terms and policies

Learning Economy does not control or operate third-party applications and is not responsible for how connected systems use data once access has been authorized.

8. AI-Assisted Learning and Training Features

LearnCard may offer optional AI-assisted features to help users:

• Explore skills and competencies
• Practice learning and training
• Navigate educational and career pathways

Important Clarifications

• AI features are intended to assist learning and exploration and do not constitute authoritative determinations of a user's skills, qualifications, eligibility, or suitability for an opportunity.
• AI outputs may be inaccurate, incomplete, or inappropriate for a particular purpose and should be reviewed critically.
• Learning Economy does not permit learner data to be used to train AI models where this restriction is applicable under its policies and contractual arrangements.
• AI features may involve external providers processing prompts, contextual information, and outputs on Learning Economy's behalf. The relevant processing, retention, deletion, and permitted uses depend on the provider, configuration, and applicable contractual safeguards.
• AI features may be restricted or disabled for minors or for particular school and district deployments.

Where AI processing involves personal data, it remains subject to the Privacy Policy, applicable law, and relevant institutional agreements. AI features will be enabled only where the applicable legal, contractual, and technical requirements have been addressed.

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9. Credential Issuance and Interpretation

Credentials stored or shared through LearnCard are issued by third-party organizations or individuals.

Learning Economy:

• Does not independently verify credential accuracy beyond cryptographic checks
• Does not guarantee acceptance, recognition, or outcomes
• Does not determine how credentials are interpreted or used by receiving parties

10. Acceptable Use

You agree not to:

• Misuse the Services to harm others
• Circumvent security or consent controls
• Impersonate another person
• Interfere with system integrity
• Use the Services for unlawful surveillance, exploitation, or harassment
• Attempt unauthorized data extraction or re-identification

Commercial resale or exploitation of the Services without written permission is prohibited.

You must also not:

• Use the Services to collect, disclose, or process another person's information without appropriate authority or a lawful basis.
• Use the Services to bypass applicable restrictions on access to student or other protected information.
• Upload malicious code or attempt to gain unauthorised access to accounts, systems, APIs, or data.
• Use the Services in a way that infringes intellectual property rights or violates applicable privacy, safeguarding, or data protection laws.

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11. Third-Party Services and Integrations

The Services may rely on third-party hosting, infrastructure, authentication, monitoring, AI, and integration providers.

Where such providers process personal data on Learning Economy's behalf, Learning Economy will apply the contractual and technical safeguards required by applicable law. Where a third party receives information and processes it independently, its own applicable terms and privacy practices may govern that processing.

Learning Economy does not guarantee the availability, accuracy, security, or continued operation of independently operated third-party services and is not responsible for their acts or omissions except to the extent required by applicable law or an applicable contract.

The use of a third-party service does not remove Learning Economy's responsibility for its own processing activities or contractual obligations.

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12. Suspension and Termination

We may suspend or terminate access if:

• These Terms are violated
• Use poses a security, safety, or legal risk
• Required by law
• Requested by a guardian or educational institution

Where feasible and appropriate, especially in educational contexts, we aim to provide notice and an opportunity to address issues.

13. Privacy and Data Protection

The LearnCard Privacy Policy explains how personal data is collected, used, disclosed, protected, and retained in connection with the Services.

Where LearnCard is provided under a school, district, or organisational agreement, additional privacy notices and data processing terms may apply. Those agreements govern the relevant institutional processing to the extent specified in them, subject to mandatory applicable law.

Nothing in these Terms removes or limits any data protection right or obligation that cannot lawfully be excluded.

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14. Data Retention and Deletion

• Subject to applicable law and the relevant contractual arrangements, users or their authorised guardians may request deletion of account information through the available controls or by contacting privacy@learningeconomy.io.
• Deletion may include profile information, credential metadata, and consent or account records, as applicable to the service and the request.
• Some information may need to be retained for a limited period where necessary for legal compliance, security, audit requirements, the establishment or defence of legal claims, or other lawful purposes.
• Information may also remain temporarily in protected backups or in systems operated by service providers, subject to applicable retention and deletion procedures.
• Deleting information from LearnCard does not necessarily delete copies already disclosed to third parties or credentials held independently by their recipients. Requests concerning those copies may need to be directed to the relevant recipient.
• For school and district deployments, return and deletion of data will be handled in accordance with the applicable institutional agreement and documented instructions, subject to applicable legal obligations.

15. Disclaimers

To the extent permitted by applicable law, the Services are provided on an "as available" basis. Learning Economy does not guarantee uninterrupted availability, error-free operation, compatibility with every third-party system, or acceptance of credentials by any particular recipient.

Learning Economy does not warrant that AI-generated outputs, third-party credentials, or information supplied by users or issuers will be accurate, complete, or suitable for every intended purpose.

Nothing in these Terms excludes or limits any warranty, representation, liability, or consumer right that cannot lawfully be excluded or limited under applicable law.

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16. Limitation of Liability

To the maximum extent permitted by applicable law, Learning Economy will not be liable for indirect, incidental, special, consequential, exemplary, or punitive damages, or for loss of profits, revenue, business opportunities, or goodwill, arising out of or relating to the Services or these Terms.

Nothing in these Terms excludes or limits liability to the extent that it cannot lawfully be excluded or limited, including liability for fraud or fraudulent misrepresentation where applicable, or any mandatory rights or remedies available to consumers.

Any further limitation or cap on liability must be set out in a manner permitted by applicable law and, where relevant, the applicable institutional agreement

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17. Indemnification

To the extent permitted by applicable law, you are responsible for claims, losses, and reasonable costs arising from your unlawful use of the Services, infringement of third-party rights, or material breach of these Terms.

Any indemnification obligation applies only to the extent the relevant claim or loss results from the conduct giving rise to that obligation.

Nothing in this section requires an individual to indemnify Learning Economy for Learning Economy's own negligence, wilful misconduct, or violation of applicable law, to the extent such an obligation would be unenforceable under applicable law.

This section does not override any separate indemnification provisions agreed in writing with a school, district, organisation, or other contracting party.

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18. Changes to the Services or Terms

Learning Economy may modify the Services to address operational, security, legal, technical, or product requirements.

We may update these Terms from time to time. The updated version will identify its effective or last-updated date. Where changes are material, we will provide reasonable notice through appropriate channels and obtain renewed agreement or consent where required by applicable law.

Changes will not retrospectively remove rights that have already accrued or override a separate written agreement except as permitted by that agreement and applicable law.

If you do not agree to a material change, you should discontinue use of the affected Services, subject to any applicable rights and contractual arrangements.

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19. Governing Law

These Terms are governed by the laws of the State of Tennessee, United States, without regard to its conflict-of-law principles, except to the extent that mandatory applicable law requires otherwise.

Nothing in these Terms deprives a consumer of protections that cannot lawfully be excluded under the laws applicable to that consumer.

Any dispute resolution or jurisdiction provisions must be interpreted subject to applicable law and any separate written agreement governing the relevant Services.

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20. Contact Information

Learning Economy Foundation, LLC
📧 privacy@learningeconomy.io
🌐 https://www.learncard.app

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