1.1 TUTOR is an artificial intelligence-powered educational tutoring platform operated by Avifiji Ltd, a company registered in the Republic of Fiji ("we", "us", "our", or "the Company").
1.2 Our platform is accessible at tutor.avifiji.com and through WhatsApp and Viber messaging channels. We provide AI-powered educational tutoring services aligned with the Fiji National Curriculum Framework (NCF).
1.3 This Privacy Policy governs how we collect, use, store, protect, and disclose personal information in connection with our services. It applies to all users, including parents, guardians, and children whose learning activity is managed through parent accounts.
1.4 We are committed to compliance with the Fiji Data Protection Act and applicable international privacy standards including principles drawn from the General Data Protection Regulation (GDPR) and the Children's Online Privacy Protection Act (COPPA) as best-practice frameworks for the protection of children's data.
| Category | Data Collected | Who Provides It |
|---|---|---|
| Account Registration | Parent/guardian full name, email address, password (hashed — never stored in plaintext), phone number (optional) | Parent/Guardian |
| Child Profile | Child's first name, year level (1-13), school name (optional), avatar selection. No email address, date of birth, or identifying information is required from or about the child. | Parent/Guardian on behalf of child |
| Payment Information | Payment card details processed by our third-party payment processor (Stripe). We do not store complete card numbers. We retain transaction identifiers and subscription status only. | Parent/Guardian |
| Communications | Messages sent to our support team via email or contact form | Parent/Guardian |
| Category | Data Generated | Purpose |
|---|---|---|
| Chat Conversations | Questions asked by the child to TUTOR, and TUTOR's responses. Saved per child profile for continuity and parental review. | Providing tutoring service; parental oversight |
| Learning Progress | Subjects and topics covered, mastery levels, frequency of questions per topic, streak data, points accumulated | Progress tracking; personalised learning |
| Activity Data | Date and frequency of platform use, number of interactions per session | Activity heatmap; parent dashboard |
| Device and Technical Data | IP address, browser type, device type, operating system, pages viewed, session duration | Security; platform improvement |
| Safety Event Logs | Instances where content moderation was triggered, including redacted details of the flagged content and action taken | Child safety compliance; safeguarding |
3.1 We use personal information only for the following lawful purposes:
3.2 We do not use personal data for targeted advertising, behavioural profiling for commercial purposes, or sale to data brokers.
4.1 Parental Control Architecture. Our platform is structurally designed so that all child accounts are created and managed exclusively by a verified parent or guardian. Children do not register, provide an email address, or agree to any terms directly. The parent's account is the legal consent mechanism for the child's use.
4.2 Verifiable Parental Consent. By creating a child profile under your family account, you as parent or guardian confirm that:
4.3 Minimum Age. Children under 6 years of age may not use TUTOR. Our service is designed for Years 1–13 (ages 6–18 approximately). Use by children under 6 is not permitted.
4.4 Data Minimisation for Children. We deliberately collect the minimum personal information necessary to provide the tutoring service. A child's profile requires only a first name and year level. This is intentional. We do not need more information to teach effectively.
4.5 No Profiling or Targeting of Children. We do not build commercial profiles of children. We do not display advertising to children. We do not share children's data with advertisers or marketing platforms. The AI does not attempt to sell, upsell, or influence children toward any commercial action.
4.6 Content Moderation and Safety Monitoring. All conversations on TUTOR are subject to automated content moderation. Conversations that trigger safeguarding alerts (including disclosures of abuse, self-harm indicators, or exploitation signals) are reviewed by trained safeguarding personnel. This monitoring is a child protection measure, not a surveillance mechanism.
4.7 Parental Access and Deletion. At any time, a parent or guardian may:
5.1 We do not sell, rent, or trade your personal information or your child's information to any third party.
5.2 We may disclose personal information only in the following limited circumstances:
6.1 All data is stored on secure servers located in Singapore (Hetzner data centre), protected by industry-standard security measures including:
6.2 Despite these measures, no system is completely impenetrable. In the event of a data breach that creates a risk to your rights, we will notify affected users within 72 hours of discovery and take immediate remedial action.
6.3 Access to personal data is restricted to authorised Company personnel on a strict need-to-know basis. Access to children's data is additionally restricted to safeguarding-trained personnel only.
| Data Type | Retention Period | Basis |
|---|---|---|
| Parent account data | Duration of subscription + 2 years after account closure | Legal and financial record-keeping obligations |
| Child chat history | Duration of child profile existence. Deleted within 30 days of profile deletion. | Service provision; parental oversight |
| Child progress data | Duration of child profile existence. Deleted within 30 days of profile deletion. | Service provision |
| Payment records | 7 years from transaction date | Fiji tax and financial compliance obligations |
| Safety event logs | 5 years | Child safeguarding obligations; legal defence |
| Technical/server logs | 90 days rolling | Security monitoring |
| Anonymised analytics | Indefinite (not personal data) | Platform improvement |
8.1 As the account holder (parent or guardian), you have the following rights with respect to personal data held about you and your child:
8.2 To exercise any of these rights, contact us at legal@tutor.avifiji.com. We will respond within 30 calendar days. We may require identity verification before processing requests.
9.1 We use essential cookies and browser localStorage for session management (keeping you logged in) and user preferences. These are strictly necessary for the platform to function.
9.2 We do not use advertising cookies, third-party tracking pixels, social media tracking scripts, or behavioural analytics tools that profile individual users. We do not use Google Analytics or Facebook Pixel.
10.1 We use the following third-party services, each subject to their own privacy policies:
11.1 We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal obligations. We will notify you of material changes by email to your registered address and by prominent notice on our platform at least 14 days before the change takes effect. Your continued use of TUTOR after the effective date constitutes acceptance of the updated policy.
11.2 For changes that materially reduce your privacy rights or expand our use of children's data, we will seek fresh verifiable parental consent before proceeding.
12.1 If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us:
12.2 If you are not satisfied with our response, you may lodge a complaint with the relevant Fiji regulatory authority. For matters involving children's safety, you may also contact Fiji Police (917) or Lifeline Fiji (132) directly.
1.1 TUTOR is an AI-powered educational tutoring platform designed to support students in Years 1 through 13 in the Republic of Fiji, with educational content aligned to the Fiji National Curriculum Framework (NCF) as administered by the Ministry of Education, Heritage and Arts.
1.2 The Service includes: AI conversational tutoring accessible via web browser and WhatsApp/Viber messaging; curriculum exploration tools; career pathway guidance; sports and real-world skills information; a parent monitoring dashboard; a child progress tracking system; and a moderated year-level class forum.
1.3 TUTOR is a private supplementary educational service. We are not affiliated with, endorsed by, or an agent of the Fiji Ministry of Education, Heritage and Arts. We do not issue formal educational qualifications.
1.4 We reserve the right to modify, suspend, or discontinue any part of the Service at any time. Where changes are material, we will provide at least 14 days' advance notice by email.
2.1 Subscriber Eligibility. To register a TUTOR family account, you must be:
2.2 Account Accuracy. You agree to provide accurate, current, and complete information during registration and to update your information promptly if it changes. Providing false information, including misrepresenting your relationship to a child, is a material breach of these Terms.
2.3 Account Security. You are responsible for maintaining the confidentiality of your account credentials. You are liable for all activity that occurs under your account. You must notify us immediately at support@tutor.avifiji.com if you suspect unauthorised access to your account.
2.4 One Account Per Family. Each family is permitted one account. Creating multiple accounts to circumvent subscription limits or trial restrictions is prohibited and will result in immediate account termination without refund.
2.5 Child Profiles. Child profiles are created by the parent account holder. A maximum of ten (10) child profiles may be active under one family account. Child profiles do not constitute separate legal accounts — they are sub-profiles owned and managed by the parent subscriber.
3.1 Subscription Plans. TUTOR operates on a monthly subscription model:
| Plan | Price | Includes |
|---|---|---|
| Family Plan | FJD $10.00 per month | Unlimited children (up to 10 profiles), all subjects, all features, 24/7 access, parent dashboard |
| Free Trial | Free — 10 questions | 10 AI tutoring questions to try before subscribing. No payment required. No credit card required for trial. |
3.2 Billing. Subscriptions are billed monthly in advance. Payment is processed on the same calendar date each month as your initial subscription date. If that date does not exist in a given month (e.g., the 31st), billing occurs on the last day of that month.
3.3 Payment Methods. We accept Visa, Mastercard, and other payment methods as displayed at checkout, processed through Stripe. By providing payment details, you authorise us to charge your nominated payment method for the applicable monthly subscription fee on a recurring basis until you cancel.
3.4 Price Changes. We reserve the right to change subscription prices. We will give you at least 30 days' written notice of any price increase. Price increases will not take effect until your next billing cycle after the notice period. If you do not cancel within the notice period, you agree to the new price.
3.5 Failed Payments. If a payment fails, we will retry up to three times over seven days. If payment remains unsuccessful after all retries, your account will be suspended (not deleted) until payment is resolved. You will retain full access to your account data for 30 days after suspension to arrange payment or export your data.
3.6 Taxes. Subscription prices are inclusive of any applicable Fiji Value Added Tax (VAT/SVAT). You are responsible for any other taxes applicable in your jurisdiction.
4.1 Cancellation. You may cancel your subscription at any time through your account settings or by contacting support@tutor.avifiji.com. Cancellation takes effect at the end of the current paid billing period. You retain full access until that date. We do not charge cancellation fees.
4.2 Refunds — General Rule. Given the digital nature of our service and the fact that full access is provided immediately upon payment, subscription fees are generally non-refundable once a billing period has commenced.
4.3 Refunds — Exceptions. We will provide a full refund in the following circumstances:
4.4 Refund Process. Approved refunds are processed to your original payment method within 5-10 business days. To request a refund, contact support@tutor.avifiji.com with your account email and reason for refund.
4.5 Termination for Breach. If your account is terminated by us due to a material breach of these Terms (including violations of the Acceptable Use policy), no refund will be issued for any remaining subscription period.
5.1 You agree that neither you nor any child using your account will use TUTOR to:
5.2 Academic Integrity. TUTOR is a learning tool, not an assignment completion service. Using TUTOR to generate content for submission as your own academic work in violation of your school's academic integrity policy is solely your responsibility. We encourage students to use TUTOR to learn and understand content, not to copy and submit AI responses as their own work.
6.1 As the account holder, you accept full parental responsibility for:
6.2 We provide a monitoring dashboard as a tool to assist parental oversight. This does not transfer to us the parental duty of care that remains with you as the legal parent or guardian.
6.3 If you become aware that a child is using your account without your knowledge or authorisation, contact us immediately. We will assist you in securing your account.
7.1 TUTOR is powered by artificial intelligence. While we have designed our system to deliver accurate, curriculum-aligned educational content, AI systems can and do make errors, produce outdated information, or generate responses that are incomplete or contextually imperfect.
7.2 TUTOR's responses are intended to supplement, not replace, instruction by qualified human teachers. For critical academic decisions — including interpreting examination results, formal assessment advice, or medical, legal, or psychological matters — always consult a qualified human professional.
7.3 We make no warranty that TUTOR's responses will be error-free, up to date with the most current version of the Fiji curriculum, or sufficient to guarantee any particular academic outcome. We do not guarantee that use of TUTOR will result in improved examination performance, passing grades, or academic advancement.
7.4 Career pathway, salary, and professional sports information provided on this platform is provided for general guidance and informational purposes only and does not constitute professional career, financial, or legal advice. Salary figures are estimates based on publicly available reports and may not reflect current market conditions.
7.5 Mental Health and Crisis Content. TUTOR is programmed to direct users experiencing distress to appropriate professional resources. TUTOR is not a mental health service and its responses do not constitute professional counselling or psychological support. If your child is in crisis, contact Lifeline Fiji (132) or Fiji Police (917) immediately.
8.1 All intellectual property in the TUTOR platform — including but not limited to software, code, visual design, brand assets, curriculum content structure, animation systems, and proprietary AI prompting architecture — is owned by or licensed to Avifiji Ltd. All rights reserved.
8.2 We grant you a limited, non-exclusive, non-transferable, revocable licence to access and use TUTOR solely for personal, non-commercial educational use by your family during the term of your subscription.
8.3 Curriculum Content. Educational content delivered by TUTOR in tutoring conversations is generated for the individual user and does not constitute a licence to republish, distribute, or commercialise that content.
8.4 User Content. You retain ownership of any content you input into TUTOR (your questions, uploaded documents, etc.). By submitting content to TUTOR, you grant us a limited licence to process that content for the sole purpose of providing the tutoring service. We do not claim ownership of your content.
9.1 Service Warranty Disclaimer. THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTY OF ANY KIND, EXPRESS OR IMPLIED. TO THE MAXIMUM EXTENT PERMITTED BY FIJI LAW, WE DISCLAIM ALL WARRANTIES INCLUDING IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT.
9.2 Limitation of Liability. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, OUR TOTAL AGGREGATE LIABILITY TO YOU FOR ALL CLAIMS ARISING OUT OF OR RELATING TO THESE TERMS OR THE SERVICE SHALL NOT EXCEED THE TOTAL AMOUNT YOU PAID TO US IN THE THREE (3) MONTHS IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO LIABILITY.
9.3 IN NO EVENT SHALL WE BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, INCLUDING LOSS OF DATA, LOSS OF PROFITS, OR LOSS OF EDUCATIONAL OPPORTUNITY, EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
9.4 Exceptions. Nothing in these Terms limits our liability for: (a) death or personal injury caused by our negligence; (b) fraud or fraudulent misrepresentation; (c) any matter that cannot be excluded by law. Consumer protection rights under Fiji law remain unaffected.
10.1 You agree to indemnify, defend, and hold harmless Avifiji Ltd, its directors, employees, agents, and licensors from and against any claims, liabilities, damages, judgments, penalties, costs, and expenses (including reasonable legal fees) arising out of or relating to:
11.1 Termination by You. You may terminate your account at any time by cancelling your subscription and requesting account deletion via support@tutor.avifiji.com.
11.2 Termination by Us. We reserve the right to suspend or terminate your account immediately and without prior notice if:
11.3 Effect of Termination. Upon termination, your licence to use the Service ends immediately. Your right to access your data continues for 30 days post-termination for export purposes, after which all data will be deleted in accordance with our retention policy.
12.1 These Terms are governed by and construed in accordance with the laws of the Republic of Fiji, without regard to its conflict of law principles.
12.2 Dispute Resolution — Negotiation First. Before initiating any formal dispute, you agree to contact us at legal@tutor.avifiji.com and attempt to resolve the matter informally. We will respond within 15 business days. Both parties agree to engage in good-faith negotiations for at least 30 days before commencing formal proceedings.
12.3 Jurisdiction. If informal resolution fails, both parties submit to the exclusive jurisdiction of the courts of the Republic of Fiji sitting in Suva for the resolution of any dispute arising from or related to these Terms.
12.4 Class Action Waiver. You agree that all disputes must be brought in your individual capacity and not as a plaintiff or class member in any class action, collective action, or representative proceeding.
13.1 Entire Agreement. These Terms, together with our Privacy Policy and Children's Safety Policy, constitute the entire agreement between you and us regarding the Service and supersede all prior understandings, representations, and agreements.
13.2 Severability. If any provision of these Terms is found to be unenforceable, the remaining provisions will remain in full force and effect, and the unenforceable provision will be modified to the minimum extent necessary to make it enforceable.
13.3 No Waiver. Our failure to enforce any right or provision of these Terms will not be deemed a waiver of those rights.
13.4 Assignment. You may not assign your account or any rights under these Terms without our prior written consent. We may assign our rights and obligations to an affiliate or successor entity without restriction.
13.5 Force Majeure. We will not be liable for any failure or delay in performance due to circumstances beyond our reasonable control, including acts of God, natural disasters, cyclones (given Fiji's exposure to tropical weather events), pandemic, government action, power outages, or telecommunications failures.
13.6 Contact. All legal notices to us must be sent to legal@tutor.avifiji.com. Legal notices from us to you will be sent to your registered email address.
TUTOR serves children as young as 6 years old. We have built every aspect of our platform with the recognition that these children trust us, their parents trust us, and we must be worthy of that trust. This is not a compliance document — it is a statement of our values and our operational commitments.
The following content categories are absolutely prohibited on TUTOR under all circumstances and will never be generated, facilitated, or permitted:
Our AI system monitors all conversations for safeguarding signals and responds according to the following tiered protocol:
| Tier | Signal Type | Automated Response | Human Response |
|---|---|---|---|
| Tier 1 | General distress (stress, sadness, school pressure) | Warm redirection; encouragement to speak to a trusted adult | No mandatory escalation. Logged for monitoring. |
| Tier 2 | Bullying, ongoing harm, unsafe situation disclosure | Emergency contacts provided (Fiji Police 917, Lifeline Fiji 132). Serious language used. | PRIORITY ALERT to platform administrator. Response required within 4 hours. |
| Tier 3 | Self-harm ideation, abuse disclosure, immediate danger | Immediate crisis resources. Clear statement: "Your safety matters most." | CRITICAL ALERT. Designated safeguarding officer notified within 15 minutes. Session transcript preserved. Potential report to authorities. |
A named, trained safeguarding officer is designated to receive and act upon Tier 2 and Tier 3 alerts. This person is contactable 24 hours a day for critical alerts. Contact: safeguarding@tutor.avifiji.com
Our class forum is a public, moderated bulletin board. Children cannot send private messages to each other. All posts are visible to administrators and parents. This design decision is intentional — it eliminates the primary vector for grooming and exploitation on educational platforms.
All forum posts are subject to automated filtering that blocks:
If you believe a child is in immediate danger, contact Fiji Police on 917 first. For non-emergency child safety concerns related to our platform, contact us at safeguarding@tutor.avifiji.com. We will respond within 24 hours.
We commit to conducting an annual review of our child safeguarding policies, procedures, and technical controls, with findings reported to our management and used to improve our protections. The next review is scheduled for March 2027.
This Children's Safety Policy is designed to be consistent with and to support compliance with:
These legal documents were adopted by the management of Avifiji Ltd and are effective from 1 April 2026.