Privacy Policy

Effective date: 5 November 2025

1. Who we are

Lingjo (“we”, “us”, “our”) provides learning and assessment tools for students, teachers, and educational providers. For most processing described here, we act as the data controller. Where we process data strictly on behalf of a school or institution, we may act as a data processor under contract.

Registered business name: Lingjo. Contact details are in Section 16.

2. Scope

This policy covers personal data processed through Lingjo’s websites, applications, and related services. It includes student and teacher data, account data, learning records, support interactions, and usage analytics as described below.

3. Lawful bases

  • Performance of a contract: providing secure access, core app functionality, account administration.
  • Legitimate interests: improving services, security monitoring, preventing abuse, and learning analytics consistent with user/educational expectations.
  • Consent: optional features (e.g., marketing communications, certain cookies) and, where required, parental consent for under-13s.
  • Public task: where we process on behalf of schools carrying out tasks in the public interest.

4. Data we collect

We collect the minimum necessary data to operate and secure the service:

Categories of personal data
CategoryExamplesPurposeLawful basis
Account & IdentityEmail, name (optional), role (student/teacher/admin), school/class associationsCreate/manage accounts, role-based accessContract; Legitimate interests; Public task (schools)
Authentication (via Clerk)Session tokens, sign-in logs, MFA statusSecure login and session managementContract; Legitimate interests
Education RecordsAssignments, submissions, scores, teacher feedback, progressDeliver learning features & reportsContract; Public task (schools)
Usage & DeviceApp interactions, timestamps, IP address, device/browser metadataSecurity, debugging, service improvementLegitimate interests; Consent for non-essential analytics
Support & CommunicationsSupport tickets, email threads, in-app messagesResolve issues; provide service updatesContract; Legitimate interests; Consent (marketing)

Special category data is not intentionally collected. If provided inadvertently, we will delete or protect it appropriately.

5. How we use data

  • Provide and maintain the service and user accounts.
  • Authenticate users and secure sessions.
  • Operate learning, assessment, and reporting features.
  • Prevent fraud and abuse; maintain platform integrity.
  • Improve performance, reliability, and user experience.
  • Communicate service updates; respond to support requests.
  • Use aggregated or anonymised data to understand trends and improve features.

6. Cookies & tracking

We use strictly necessary cookies for core functionality (e.g., authentication). With your consent, we may use analytics cookies to understand usage and improve the service. You can manage preferences via your browser or our in-product cookie controls (where available).

7. Sharing & processors

We do not sell personal data. We share data with trusted service providers (“processors”) under contract, limited to what’s necessary to deliver the service. Each processor is bound by confidentiality, security, and UK GDPR-compliant terms.

Our core processors
ProcessorRoleData handledPrimary region
ClerkAuthentication & identitySign-in data, sessions, MFA statusEU region (e.g., eu-west)
Cloud/Hosting ProviderInfrastructure & databasesApp data, encrypted at restUK/EU
AI/LLM Provider (e.g., OpenAI)Language processing for selected featuresPseudonymised prompts and content snippets; no direct identifiers sent by defaultEU/UK where available; otherwise safeguarded by SCCs

We will disclose data if required by law, to protect users, or to defend our legal rights, following due process.

8. Third-party AI & API services (anonymised)

Some features of Lingjo use third-party API services (for example, language models such as OpenAI’s API) to process text and generate feedback or suggestions. We design these integrations with privacy by default and apply strict minimisation and anonymisation practices.

  • No direct identifiers by default: we remove or pseudonymise names, emails, IDs, and similar fields before sending requests. We use per-session or per-request pseudonymous tokens.
  • Minimum necessary content: only the text strictly required to fulfil the feature (e.g., a paragraph of an essay) is sent; we avoid full records or unrelated context.
  • Provider settings: where providers offer controls, we configure them so API inputs are not used to train or improve the provider’s models, and we request the shortest feasible retention.
  • Regional processing & safeguards: we prefer UK/EU processing where available. If processing occurs outside the UK/EU, we rely on adequacy mechanisms or Standard Contractual Clauses and additional safeguards.
  • School controls: for school customers, we can disable third-party AI features or restrict them to specific cohorts on request.
  • User-generated content: avoid including special category data in free-text inputs. If included inadvertently, we handle and protect it in line with this policy.

For details about specific providers in use (and their regions), please contact us or see the vendor list in Section 7.

9. International transfers

We endeavour to store and process personal data in the UK/EU. Where access or transfer outside the UK/EU is necessary, we rely on adequacy regulations (where available) or Standard Contractual Clauses and implement additional safeguards as appropriate.

10. Retention & deletion

  • We retain personal data only as long as needed for the purposes described or as required by law/contract.
  • Schools/teachers may request deletion following course or contract completion.
  • Backups are encrypted and retained for limited periods before secure deletion.

11. Security

We apply technical and organisational measures appropriate to the risk, including:

Technical
  • TLS for data in transit; encryption at rest.
  • Secrets management; no hard-coded credentials.
  • Role-based access control (RBAC); least privilege.
  • Audit logging for admin access.
  • Regular patching and dependency scanning.
  • Secure webhooks with signature verification (e.g., Clerk).
Organisational
  • Data Protection Impact Assessments (where required).
  • Staff confidentiality & access training.
  • Documented incident response and disaster recovery.
  • Vendor due diligence and DPAs with processors.
  • Privacy by design & default.

12. Children’s Code (Age-Appropriate Design Code)

For under-18 users, we apply high-privacy defaults and design choices that protect young people, including:

  • Minimal data collection and profiling.
  • Clear, age-appropriate explanations of features and settings.
  • Parental consent for under-13 account creation where required.
  • Geolocation and social features disabled unless strictly needed.

13. Your rights

Under UK GDPR, you have rights to access, correct, erase, restrict, or object to processing, and to data portability. Where processing relies on consent, you can withdraw consent at any time. To exercise rights, contact us using the details in Section 16. We may need to verify your identity and, where we act as a processor for a school, may redirect your request to the controller.

14. Breaches & reporting

We assess all personal data incidents and will notify the ICO within 72 hours where required, and affected users without undue delay when there is a high risk to their rights and freedoms.

15. Changes to this policy

We may update this policy to reflect changes in law, guidance, or our services. We will post updates here and, when appropriate, notify you in-app or by email.

16. Contact & Data Protection Officer

If you have questions or wish to exercise your rights, contact:

Data Protection Officer (DPO): [Name], dpo@lingjo.com. If you are unsatisfied with our response, you can lodge a complaint with the UK Information Commissioner’s Office (ICO).

Clerk Authentication Notice

We use Clerk as our authentication provider. Clerk acts as our data processor under UK GDPR and stores authentication data in the EU region. We do not store user passwords.

  • EU region configured for authentication data.
  • MFA available and enforced for admin accounts.
  • Session security, device management, and webhook signing used.

For more information about how authentication data is processed, contact us or consult Clerk’s security documentation.