Minors, Guardian Consent and Student Records Policy

VeyJet — InfiniNova Limited (星天域有限公司) · legal-privacy-ofac@infini-nova.com

Most of the students we work with are minors. This policy says who consents, what we collect about a student, and what a student may ask for themselves.

1. The guardian is the contracting party

Where the student is under 18 (or under the age of majority where they live), the parent or legal guardian enquires, consents, contracts, pays and receives the deliverables. A minor cannot engage us and cannot be asked to agree to these terms.

The guardian confirms, in the “Guardian Authority, Student Original Work and Safety Acknowledgment”, that they hold that authority and will tell us immediately if it changes — for example on a change of custody.

2. Children under 13 — COPPA

This site is not directed to children under 13 and we do not knowingly collect personal information from them.

If we learn that a child under 13 has submitted information without verifiable parental consent, we delete it promptly. If we knowingly serve a student under 13, we obtain verifiable parental consent before collection, give the parent the notice COPPA requires, collect only what the service actually needs, and give the parent the right to review the information, refuse further collection and require deletion — at legal-privacy-ofac@infini-nova.com.

We never condition participation on disclosing more than is reasonably necessary.

3. What we collect about a student

Course record and grade trend; AP/IB choices; SAT/ACT and English test timing; activities, projects and portfolio; project and research work; application progress; meeting notes and feedback; and the student's own contact details only where the guardian authorises direct contact.

We do not collect, and ask you not to send: government ID or passport, financial account numbers, health or diagnostic records, disciplinary records, or any credential (Academic Integrity and Student Original Work Policy §4).

Accessibility or learning-support needs are processed only with separate, specific, revocable consent (the “Consent Form — Collection, Sensitive Information, Cross-Border Transfer and Marketing” Part B), only to adapt how we work with the student, and never to infer or profile.

4. FERPA — and why it mostly does not apply to us

FERPA binds schools that receive US Department of Education funding, not a private consultant retained by a family. We are not a school and FERPA does not make us a custodian of an education record.

Two practical consequences: a transcript or report you give us is yours to give, and we hold it under this policy and Privacy Policy, not under FERPA; and we cannot obtain records from a school on your behalf — a school releases a record to the parent or eligible student, not to us, unless you give the school its own written authorisation.

If we ever contract with a school or a school district rather than a family, FERPA's school-official exception, state student-privacy laws (New York Ed. Law §2-d, California SOPIPA and equivalents) and a wholly different contract set apply. We do not do that today, and must not start without counsel.

5. Direct communication with the student

Effective mentorship needs direct contact with the student. We do that only with the guardian's written authorisation (the “Guardian Authority, Student Original Work and Safety Acknowledgment” §1), and on these standing rules:

• Communication uses channels the guardian can access or be copied into on request.
• We do not meet a student one-to-one in a private physical setting.
• We do not discuss the family's finances, the fee, or a billing dispute with a student.
• We do not ask a student to conceal anything from their guardian, and we will not act on a student's request to do so.
• Where a student discloses something that suggests risk of serious harm, we will tell the guardian, and where necessary emergency services. We tell students this in advance so it is never a surprise.

6. The student's own rights

A student may ask what we hold about them, have it explained in terms they can understand, and correct it. Where a student is old enough to exercise privacy rights personally under their local law, we honour that directly. Where the request is made by the guardian and concerns the student, we will normally comply, but we will not use a privacy request as a tool in a family dispute — where a request appears to be one, we may decline to disclose a student's confidences and will say so.

7. Custody, separation and disputes

If guardians disagree, we act on the instruction of the guardian who signed the Agreement and pays, and we do not take sides. We do not produce records for use in a custody proceeding except under a valid legal order, and we will tell the signing guardian unless the order forbids it. If a court order changes authority, send it to us and we will act on it.

8. Safeguarding

Everyone working with students is bound by contract to the conduct rules in §5. Sessions are arranged through our channels, and a parent may sit in or ask for the record (§5).

Report a concern about anyone acting for us to support@infini-nova.com, or for anything urgent, +852-6418-1625.

9. Retention and deletion

A student's file is kept per Privacy Policy §8 and deleted or anonymised at the end of the period. A guardian may request deletion at any time; we will explain what we must keep (payment and accounting records, and anything needed to defend a claim) and delete the rest.

10. Contact

legal-privacy-ofac@infini-nova.com · support@infini-nova.com