Data-processing agreement

The school is the controller. Fluency EI is the processor and acts only on the school's documented instructions. Fluency EI does not use student data for its own purposes.

Processing covers the assessment of written and spoken language responses and the reporting of CEFR levels and progress. It lasts for the term of the service agreement, after which data is returned or deleted at the school's choice.

• Data subjects: students enrolled by the school, and the teachers who review their results.
• Data: name, class, school, optional external student ID, target level; the prompt, the written response, the audio recording and its transcript; scores, CEFR proposals, rationales and teacher notes.
• No payment data, no special-category data is requested. Schools should not submit health, religious or other sensitive content in response text.

• Recordings are held in a private storage location with no public access; playback links are short-lived and generated only for authorised staff.
• Assessment data is protected by row-level database access rules; administrative access is restricted to named Fluency EI staff.
• Access to the administration panel requires an individual account with an explicit role grant.
• Transport is encrypted end to end; data is encrypted at rest by the hosting provider.

• Audio recordings are deleted automatically 20 days after the assessment.
• Transcripts, scores and progress history are kept for the term of the agreement and deleted on request.
• On termination, all school data is exported to the school and then erased within 30 days.

• Lovable (hosting, database, storage, AI gateway) — Runs the platform, stores the roster, assessments and recordings, and routes AI requests. (European Union / United States)
• OpenAI — Speech-to-text transcription of oral responses (via the AI gateway). (United States)
• Google — Language evaluation and CEFR scoring of the response (via the AI gateway). (United States)

The school will be notified before any new sub-processor is added and may object. Student responses are never used to train Fluency EI's or any provider's models.

• Access and portability: Fluency EI exports everything held about a named student as a machine-readable file on request.
• Erasure: Fluency EI permanently deletes a named student together with every assessment, recording, transcript and derived insight.
• Incidents: Fluency EI notifies the school without undue delay, and in any event within 48 hours of becoming aware of a personal-data breach.
• Audit: Fluency EI provides the information a school reasonably needs to demonstrate compliance.

Some sub-processors operate outside the European Economic Area. Those transfers rely on the providers' standard contractual clauses and their supplementary safeguards.

Data-protection contact: valeriabm68@gmail.com. See also the privacy notice and terms of use.