Data processing agreement

When this applies

This agreement applies when a tutor or a centre uses the service for their students. It is part of the terms for those accounts, so no separate signature is needed. If you want a signed copy, email [to be completed] and we can provide one.

Who is who

The tutor or centre is the controller of their students’ data. We are the processor. We process that data only on the controller’s documented instructions. Using the service as it is designed is the instruction.

What we process, and for how long

We process the student data listed in the privacy policy, to give the controller and their students the service. We process it while the account exists. Then we delete it, as the privacy policy describes under closing your account: 14 days to reopen, and deletion within 30 days of the request.

What we commit to

• Everyone with access to the data keeps it confidential.
• We use the security measures in the privacy policy: private storage, short-lived file links, access rules in the database, encrypted connections and encrypted backups.
• We use only sub-processors from the list described below.
• We help with students’ rights requests. Export, correction and deletion are built into the app.
• We tell the controller about a personal-data breach without undue delay.
• When the account is closed, we delete the data.
• On request, we give the controller the information needed to show we comply.

Sub-processors

We use only the companies on the sub-processor list. We update the list before a new company receives any data. You can object to a new one. If we cannot meet your objection, you can close the account.

Where data goes

Where data is processed is set out in the privacy policy. Our database, files and server are in the European Union (Frankfurt). DeepSeek is in the People’s Republic of China, and its terms allow it to train its models on what it receives. Anthropic and GitHub are in the United States.

DeepSeek receives a page only when someone in the account uploads it: uploading is what starts the reading. The controller decides whether pages are uploaded. Marking work yourself and logging the marks sends nothing to an AI provider.

What the controller commits to

• You have a lawful basis for the data you put in, and any consent needed, such as a parent’s consent for a younger student.
• You have permission from each student, and from a parent where needed, before you add them.
• Students are told what is processed. You can share our privacy policy with them.

Contact

[to be completed], [to be completed], Austria. Email [to be completed].