Privacy Policy
NAIGURU Platform
NAIGURU, S.L., (hereinafter, the Company
) is committed to protecting your privacy. Through this privacy policy (hereinafter, the Privacy Policy
) we inform you how the Company processes the personal data that we obtain within the framework of the activity of this platform (hereinafter, the Platform
).
Please note that anonymised information or merely statistical data used by the Company will not be considered personal data.
Please read this Privacy Policy carefully before accessing and using the Platform.
1. Who is responsible for the processing of your data?
The Company is the data controller of the personal data indicated in this Privacy Policy, which implies that we are responsible for taking care of the privacy of the personal data of the Platform. We will use your personal data fairly, lawfully and transparently and in accordance with the relevant regulations.
Our contact details are as follows:
- Address: Calle Hoyos del Espino, 6, 28035, Madrid, Spain.
- Registered company information: Registry of Madrid – Volume 35055, IRUS 1000426368888, Electronic Folio Entry 1 with sheet M-829877
- Email address: info@materact.com
If you have any questions about this section, or any aspect related to the processing of personal data, you can contact the person responsible for privacy matters of the Company at the email address indicated above.
2. Understanding data roles: your school vs. the Company
If your school (hereinafter, the School
) registered you on the Platform, the School is solely responsible for processing your personal data within the Platform. This means that any processing of your personal data is done under the School’s privacy policy, and the School assumes full responsibility and risk for that processing.
In this scenario, the Company acts only as a data processor, following the School’s instructions.
If you wish to exercise your data protection rights as described in section 9, you must contact your School directly, as it is responsible for responding to such requests.
Please consult your School directly for additional information regarding their processing of your personal data.
The Company will only act as a data controller for the purpose of securing the data by its anonymisation. Once anonymised, the data may be used indefinitely to improve the Platform and its services, or to create a fully anonymous and marketable database.
3. Users of the Platform
By reading this Privacy Policy, the user (hereinafter, the User
or Users
) is informed about the circumstances in which their personal data will be processed. Within the Platform we must distinguish the following categories of Users:
- Student User: is a student of any of the corresponding educational cycles of the English education system.
- Teacher User: is a teacher duly qualified to exercise his or her profession in the corresponding educational cycles of the English education system.
The data requested through the forms are generally mandatory (unless otherwise specified in the required field) to comply with the purposes for which they are being collected.
Therefore, if they are not provided or are not provided correctly, we will not be able to properly deal with your request.
4. What data do we process?
User Data provided by Users
This is the data you provide to us by filling in forms on the Platform, or through any interaction you make on the Platform.
Student User Data
- Identification data: name and surname, email, date of birth, and profile picture.
- Communication Data: messages about queries relating to the Platform or its services and any data you provide to us when you contact us.
- Data related to the services of the Platform:
- Academic data: educational level or cycle in which the student is enrolled
- Technical Profile Data: list of modules to which you are enrolled, Assigned Teacher Users
- Progress Data: Information about students' academic progress, including areas for improvement and skills developed.
- Submitted Responses: Student-generated content on the digital whiteboard when solving exercises and exams.
- Corrections: detail of the corrections made by the virtual tutor, including analysis and explanations.
- Interactions with the virtual tutor: doubts resolved, queries made and messages exchanged between students and the virtual tutor.
- Personalised recommendations: Suggestions generated by the virtual tutor to support learning and strengthen specific areas.
- Task-related data: results from exercises, homework and exams completed on the Platform, delivery, completion status and results of assigned exercises, homework and exams.
- Platform interaction data: Access logs, usage times, and general patterns of interaction with available functionalities.
Data of Teacher Users
- Identification data: name and surname, professional email, profile picture.
- Communication Data: messages about queries relating to the Platform or its services and any data you provide to us when you contact us
- Data related to the services of the Platform:
- Professional data: educational cycle in which you teach
- Technical Profile Data: list of modules you are enrolled in, Assigned Student Users
- Student User Data: identity of the Student Users in your charge
- Task-related data: due date, completion status, and results of exercises, homework, and exams assigned to your Student Users.
- Platform interaction data: Access logs, usage times, and general patterns of interaction with available functionalities.
User Data We Obtain from Third Parties
- Data from cookies: inserted in the Platform, where applicable, and from the use of similar technologies (see Cookie Policy for more information).
- School data: data provided by the School that we need for the purposes indicated under Section 5 of the Privacy Policy, these are name and surname, email, date of birth, list of modules in which you are enrolled, educational cycles and Student Users assigned to Teacher Users, as well as any other data that may be relevant for the provision of services through the Platform, such as: degree of satisfaction of Users with the services and the Platform, or surveys.
Data of third parties provided by Users
- Parent/legal guardian data: name and surname, email
If you provide personal data belonging to third parties for any purpose, you confirm that you have previously informed the individuals concerned and obtained their explicit consent to share their data with the Company.
If the personal data you provide relates to minors, you guarantee that you are legally authorised to do so. This includes having obtained:
- The minor’s consent, if they are under sixteen years of age, and
- The consent of the individuals holding parental authority or legal guardianship, as required.
You also confirm that the information provided is accurate and truthful.
The Company reserves the right to verify the consent of the affected individuals by sending a non-commercial email requesting confirmation of the authorisation you have declared.
If any liability arises due to a breach of these conditions, you will be solely responsible for the consequences.
5. What are the purposes and legal bases for the processing of User Data?
We will process your personal data for the following purposes:
| Processing and purpose | Legal basis |
|---|---|
Management and maintenance of the Platform and its services
|
The development of the existing pre-contractual and/or contractual relationship. Or, where applicable, the legitimate interest in efficiently managing the business and fulfilling our contractual obligations with the Schools. |
Offer personalised services through artificial intelligence systems
For example, we process data related to the questions and exercises completed by Users, as well as their interactions with the AI-powered virtual tutor, in order to provide relevant responses and support based on their requests. Please note that all answers and corrections provided by the virtual tutor are generated automatically by artificial intelligence systems, without human intervention. These interactions are designed to help Users improve their math skills and are based on data sourced from official exams and textbooks. |
The development of the existing contractual relationship. Or, where applicable, the legitimate interest in efficiently managing the business and fulfilling our contractual obligations with the Schools. |
Improvement of the Platform and its services and development of new functionalities
For example, we will process data from exercises performed by Users and their interactions with the AI tutor to improve the performance and capabilities of the AI tutor and identify optimal teaching methodologies. |
The legitimate interest in efficiently managing the business. Or, the legitimate interest in optimising the operation and quality of the Platform and it |
6. With whom will your data be shared?
We do not share your personal data that with other organisations without your express consent, except in the following circumstances:
- Suppliers or collaborators who provide services on behalf of the Company (data processors), i.e. natural or legal persons who process personal data under the instructions and responsibility of the Company. You can request the updated list of the Company's data processors at the email address indicated in the first section of this Privacy Policy.
- School: if the User has been registered on the Platform at the request of a School, the School will have access to the personal data generated within the Platform and will be solely responsible for its processing, insofar as it is used for the School’s own purposes.
- Teacher Users: the Teacher Users assigned by the School in charge of one or more Student Users, may access the following data of the Student Users: Academic Data, Progress Data, Submitted Responses, Task-related data, Identification Data. Likewise, they will also be able to view the profile picture of other Teacher Users.
- Student Users: Student Users will be able to view the profile picture of the Teacher User to whom they are assigned.
- Parents/legal guardians: If a User has been registered on the Platform at the request of a School, the parents or legal guardians of the Student User will receive information regarding the Student User’s academic progress. Additionally, even if the Student User was not registered by a School, when the User is under 16 years of age, their parents or legal guardians may still access the User’s information.
- Authorities: such as public authorities and official bodies for compliance with applicable legal obligations.
7. Is my data transferred outside the European Union?
International data transfers may be made to the United Kingdom, as this is where our Amazon Web Services servers are hosted. Data transfers to the United Kingdom are based on the European Commission's adequacy decision of 28 June 2021 (Implementing Decision (EU) 2021/1772).
Any other transfer to other countries that are not considered secure will be made by protecting your data through the appropriate guarantees in accordance with the applicable regulations, which may consist of the signing of Standard Contractual Clauses approved by the European Commission between the exporter and the importer of data.
You can request additional information from the Company at the email address indicated in the first section of this Privacy Policy.
8. For how long will the Company keep your personal data?
Your personal data will be kept for as long as necessary to fulfil the purposes we collected it for, or until you exercise your right to object, delete, limit processing, and/or revoke your consent, as appropriate.
In addition, once the relationship with you has ended, your data will not be kept unless we are required to keep such data for regulatory compliance purposes, or in case of potential claims.
9. How can you exercise your rights?
You may (i) send a letter to the Company, at the postal address indicated in the header; or (ii) send an email to the address info@materact.com, identifying themselves and specifying the exercise of one or more of these rights. In the event that the Company has reasonable doubts about your identity, it may request a photocopy of your ID card or other equivalent document to confirm your identity. You can exercise your rights at any time and free of charge.
Below, we remind you of your rights in terms of data protection:
- The right to access. You have the right to access and receive a copy of your personal data, and other supplementary information. Whenever possible, you may access, update, or request deletion of your personal data directly in your account settings section on the applicable Service. If you are unable to perform these actions yourself, please contact us for assistance.
- Right to correction. You have the right to rectify inaccurate or incomplete data.
- Right to erasure. You have the right to request the deletion of your data when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
- Right to restrict. You have the right to obtain from the Company the restriction of data processing when any of the conditions provided for in the data protection regulations are met.
- Right to object. You have the right to object to our processing of your personal data on the basis of our interest for reasons relating to your particular situation. In addition, you can object to our processing of your personal data for marketing and commercial purposes at any time.
- Right to data portability. You have the right to obtain and reuse your personal data for your own purposes across different services.
- Right to withdraw consent. You also have the right to revoke your consent at any time when the Company legitimises the processing of your personal data in your consent.
In any case, if you consider that your data protection rights have been violated and/or that the Company does not comply with its obligations in terms of privacy, you may file a complaint with your competent data protection authority.
We remind you that if your registration on the Platform has been made at the request of your School, you must exercise your rights through the School.
10. Changes to the Privacy Policy
We may update our Privacy Policy from time to time.
We will notify you by email and/or by means of a prominent notice through the Platform, prior to the change becoming effective, and we will update the Last Update
date at the bottom of this Privacy Policy.
We advise you to review the Privacy Policy periodically for any changes. Changes are effective when they are posted on the Platform.