Privacy Policy

This Privacy Policy explains how Edulga collects, uses, shares and protects your personal data when you use our website and our AI-powered personalized learning platform. In this policy, “we”, “us” and “our” refer to Edulga.

For the purposes of Egypt's Personal Data Protection Law No. 151 of 2020 and its Executive Regulations, the controller of your personal data is Edulga, located at District 11, 6th of October City, Giza, Egypt. This means we decide how and why your personal data is processed.

You can contact us about this policy or your personal data at any time at code@edulga.com.

Depending on how you use Edulga, we collect the following personal data:

• Account and profile data: your name, email address and profile picture. Sign-in with a one-time code sent to your email is handled by our authentication provider, Clerk.
• CV data: the CV file you upload during onboarding and the information we read from it, such as your skills, experience and goals.
• Learning resources: the PDFs, videos, links and other materials you upload, and whether you have made each one public.
• Conversations with Lula: the messages you send to our AI tutor, Lula, and the replies you receive.
• Learning activity: the roadmaps, modules and lessons generated for you, the assessments you take and their results, and the mastery and progress graph we build from your activity.
• Plan and billing data: your plan, billing period, credit balances and credit transactions, and records of your payments, such as order references, amounts and dates. We never receive or store your full card number.
• Organization data: the organizations you belong to, your membership, role and invitations, and the credits your organization admin grants you.
• Device and usage data: the pages you visit, your clicks and other interactions, session recordings, your approximate location based on your IP address, information about your browser and device, and error reports.

We collect this data directly from you, automatically when you use the service, and from our service providers, such as Clerk for sign-in and our payment processor for the status of your payments. If an organization invites you, we also receive your email address from that organization.

Please do not include sensitive personal data, such as health information or national ID numbers, in your CV, uploaded resources or conversations with Lula unless it is necessary for your learning.

We use your personal data to:

• create and manage your account and let you sign in securely;
• personalize your learning, including using your CV and activity to generate roadmaps, lessons and assessments that match your goals;
• provide conversations with Lula, including general chat and tutor chat;
• store and process the resources you upload, and show the resources you make public in the community library;
• track your progress and estimate your mastery of topics;
• manage your plan, credits, payments, renewals, cancellations and refunds;
• let organizations manage their members and credits, and show organization admins their members' learning progress and credit usage;
• respond to your requests and send you messages about your account, your subscription and important changes to the service;
• understand how people use Edulga and improve it, including through analytics and session recordings;
• monitor, investigate and fix errors, keep the service secure, and prevent fraud and misuse; and
• comply with our legal obligations, such as tax and accounting requirements, and respond to lawful requests from competent authorities.

We process your personal data only where the Personal Data Protection Law allows it. Depending on the purpose, we rely on one or more of the following lawful bases:

• Performance of our contract with you: to provide your account, the learning features, Lula, credits and any paid plan you choose.
• Your consent: for example, for analytics and session recordings where the law requires consent. You can withdraw your consent at any time, and this does not affect processing carried out before you withdrew it.
• Our legitimate interests: to keep the service secure, prevent fraud and misuse, fix errors and improve the service, provided these interests do not override your rights.
• Legal obligations: for example, to keep the billing and transaction records required by tax and accounting laws, and to respond to lawful requests from competent authorities.

Edulga uses artificial intelligence to personalize your learning. To do this, we send the content you submit, such as your uploaded materials, the text of your CV and your messages to Lula, to OpenAI, which processes it for us to generate lessons, assessments, embeddings and chat answers. Embeddings are numerical representations of content that help us find material relevant to you.

Under our agreement with OpenAI, content sent through its API is not used to train OpenAI's models. We do not sell your personal data.

Lessons, assessments, answers and mastery estimates are generated automatically and can be inaccurate. We use them to personalize your learning. If you believe any information about you is wrong, you can ask us to correct it as described in the Your rights section.

We do not sell your personal data. We share it only as needed to provide and protect Edulga, with the following service providers, which process it on our behalf under contracts with us:

• Amazon Web Services: hosting, databases and file storage, including the resources you upload.
• Clerk: sign-in and account authentication.
• OpenAI: processing the content you submit to generate lessons, assessments, embeddings and chat answers.
• PostHog: product analytics, including session recordings.
• Microsoft Clarity: usage analytics and session recordings.
• Sentry: error monitoring.
• Our payment processor: handling card payments and refunds. The payment processor is PCI DSS certified, and we never receive or store your full card number.

If you are a member of an organization on Edulga, that organization's admins can see your learning progress and credit usage within the organization. Resources you make public can be seen by other users, as described in the Public resources in the community library section.

We may also disclose personal data where required by law, a court order or a competent authority, or where necessary to protect the rights and safety of our users or Edulga. If Edulga is involved in a merger, acquisition or sale of assets, personal data may be transferred to the new owner, subject to the protections in this Privacy Policy.

Edulga is hosted on Amazon Web Services in data centers in the United States (the us-east-1 region). Our other service providers, including Clerk, OpenAI, PostHog, Microsoft Clarity and Sentry, may also process personal data outside Egypt.

This means your personal data is transferred from Egypt to other countries, whose laws may not offer the same level of protection as Egyptian law. We protect transferred data through contractual commitments with our service providers and the security measures described in this policy.

We keep your personal data for as long as your account is active, subject to the following:

• Account deletion: you can delete your account from your account settings. Deletion permanently removes your account and its associated data, including your profile, conversations with Lula, uploaded resources (including public ones), assessments and progress. It cannot be undone.
• Backups: deleted data may remain in our database backups for up to 7 days, after which the backups are overwritten.
• Application logs: we keep application logs for 3 days.
• Billing records: we keep billing and transaction records for as long as tax and accounting laws require, even after your account is deleted.

Data held by our service providers, such as analytics data, session recordings and error reports, is deleted according to the retention periods that apply under their agreements with us.

Resources you upload stay private unless you choose to make them public. When you make a resource public, it appears in the community library, where other Edulga users can see it.

Before making a resource public, check that it does not contain personal data, about you or anyone else, that you do not want other users to see, and that you have the right to share it. If you delete your account, your public resources are deleted along with your other data.

Under the Personal Data Protection Law, you have the right to:

• know what personal data we hold about you and obtain access to it;
• have inaccurate or incomplete personal data corrected or updated;
• have your personal data deleted, including by deleting your account;
• restrict or object to the processing of your personal data in the circumstances the law allows;
• withdraw your consent at any time, where we rely on consent;
• receive your personal data in a structured, commonly used format, where applicable; and
• be informed of any personal data breach that affects your data.

To exercise any of these rights, email us at code@edulga.com from the email address on your account. We may need to verify your identity before acting on your request, and we will respond within the time limits set by law.

Some rights have limits. For example, we may need to keep billing and transaction records that tax and accounting laws require us to retain, even if you ask us to delete your data.

We use technical and organizational measures to protect your personal data, including:

• encryption of data in transit;
• access controls that limit who can access personal data;
• hosting our systems in private networks; and
• leaving card payments to a PCI DSS certified payment processor, so that we never receive or store your full card number.

No method of transmission or storage is completely secure. If a personal data breach affects your data, we will notify you and the Personal Data Protection Center as required by law.

You can help protect your account by keeping your email account secure and never sharing the one-time codes we send you.

Edulga is not directed at children under 18 without the involvement of a parent or guardian. If you are under 18, you may use Edulga only with the consent and supervision of a parent or legal guardian.

If we learn that we have collected personal data from a child under 18 without that consent, we will delete it. A parent or guardian who believes this has happened can contact us at code@edulga.com.

We use cookies and similar technologies, such as your browser's local storage, for the following purposes:

• Strictly necessary: Clerk session cookies that keep you signed in, and a theme setting, stored in a cookie or in local storage, that remembers your display preference. The service cannot work properly without these.
• Analytics: PostHog and Microsoft Clarity collect information such as the pages you visit, your clicks and interactions, and session recordings, to help us understand how Edulga is used and improve it.
• Work in progress: local storage in your browser keeps track of work in progress, such as the progress of tasks you have started.

Session recordings capture how you interact with our pages, such as mouse movements, clicks and scrolling. PostHog and Microsoft Clarity are listed in the Who we share data with section.

You can block or delete cookies and clear local storage in your browser settings. If you block strictly necessary cookies, you will not be able to sign in. Where the law requires your consent for analytics, you can withdraw it at any time, including by blocking analytics cookies in your browser.

If you have a concern about how we handle your personal data, please contact us first at code@edulga.com so that we can try to resolve it.

You also have the right to file a complaint with Egypt's Personal Data Protection Center (PDPC).

We may update this Privacy Policy from time to time. The date of the latest update is shown on this page.

If we make material changes, we will notify you by email or through the service before the changes take effect.

If you have questions about this Privacy Policy or want to exercise your rights, contact us at code@edulga.com.

Address: Edulga, District 11, 6th of October City, Giza, Egypt.