Privacy Policy
01 //1. Who we are
This Privacy Policy applies to the services and platforms operated by Resseti Ltd ("Resseti", "we", "us", or "our"), registered in England and Wales with registered office at 3 Bannold Court, Waterbeach, Cambridge. Our data protection registration number with the UK Information Commissioner's Office (ICO) is [ZA ].
If you have any questions about this Privacy Policy, our data practices, or how your personal data is handled, you can contact our Data Protection lead at privacy@resseti.com.
Depending on how you interact with our platform and diagnostic tools (such as Lumina), we operate under two distinct roles under UK and EU data protection law:
| Context | Our Role | Data Subjects | Details |
|---|---|---|---|
| School contracts (Lumina pilot / institutional license) | Data Processor | Students, teachers, school administrators | We process student work, marks, and teacher feedback strictly on the written instructions of the school under a Data Processing Agreement (DPA). The school remains the Data Controller. |
| Website visitors, school enquiry contacts, individual pilot signups | Data Controller | Website visitors, prospective partner staff, enquiry submitters | We determine the purposes and means of processing contact details, technical logs, communication records, and prospective pilot inquiries. |
02 //2. Data we collect
We only collect personal data that is necessary to fulfill our institutional service commitments, maintain platform security, and respond to educator enquiries.
| Category | Types of Data | Source |
|---|---|---|
| School / Teacher Contact Data | Name, school email address, school name, job title / role, department, enquiry message details | Provided directly by you via forms, emails, or pilot agreements |
| Student Assessment & Work Data | Student pseudonymised identifier / student ID, assessment responses, typed answers, step-by-step working, marks awarded, diagnostic failure-point classifications [Delete or amend if handwriting upload is added.] | Provided by the school or entered by the student through the Lumina interface under the school's account |
| Technical & Usage Data | IP address, browser type, device information, operating system, page views, session timestamps, diagnostic error logs [List any analytics tool used on 10Web.] | Collected automatically via server logs and essential cookies when you access the platform |
| Communications Data | Correspondence between you and Resseti regarding support, pilot feedback, or product enquiries | Direct communications |
We do not intentionally collect any special category personal data (such as health data, biometric data, or racial/ethnic origin) or criminal convictions data.
03 //3. How we use data and our lawful bases
Under the UK GDPR and EU GDPR, we must have a valid lawful basis to process your personal data. Where we act as a Data Controller, the table below outlines our purposes and lawful bases. Where we act as a Data Processor on behalf of a school, our processing is governed by our contract with the school (Article 28 DPA).
| Purpose | Data Used | Lawful Basis (GDPR / UK GDPR) |
|---|---|---|
| Providing the Lumina diagnostic engine to schools | Student assessment data, teacher accounts | Performance of contract (where school is controller, processed under DPA / Art. 28) |
| Responding to pilot enquiries and school demonstrations | School / teacher contact data, communications | Legitimate interests (evaluating and establishing institutional partnerships) or Contract preparation |
| System security, error diagnosis, and infrastructure stability | Technical & usage logs | Legitimate interests (maintaining platform resilience and security) / Legal obligation |
| Diagnostic model evaluation and rule-layer refinement (using aggregated, de-identified data only) | De-identified assessment step patterns | Legitimate interests (ensuring diagnostic precision; individual personal data is never used for external model training) [confirm] |
| Legal and regulatory compliance | All categories where required | Compliance with a legal obligation |
04 //4. Children, schools and AI
The short version for students:
We only see the work you type or submit to find where you lost marks in an exam question. We do not sell your data, we do not track you across other websites, and we do not use your answers to train public AI models. Your school controls your data.
School-Governed Architecture
When Lumina is deployed within an educational institution, the school is the Data Controller. We process student responses strictly as instructed by the school. Students cannot create public consumer profiles, interact with unregulated external forums, or share content publicly through our diagnostic engine.
No Advertising, No Commercial Profiling
We maintain an absolute prohibition on advertising and commercial tracking. We do not display third-party advertisements, do not build behavioral profiles for commercial exploitation, and do not broker or monetize user data under any circumstance.
Diagnostic Inference & AI Infrastructure
Lumina maps student answers to mark-scheme criteria (such as M1, A1, B1 criteria) and isolates process errors at specific method steps. Where artificial intelligence models or rule layers are utilized:
- Inputs submitted for diagnostic inference are strictly confined to the academic response and marking criteria.
- We contractually enforce zero-retention and zero-training policies with our inference infrastructure providers [confirm with provider terms]. Student submissions are not ingested into open training corpora.
- Diagnostics serve solely to assist teachers and students in understanding procedural step errors, not to generate autonomous, unreviewable disciplinary decisions.
05 //5. Who we share data with
We do not sell, rent, or trade personal data. We share data only with trusted third-party sub-processors necessary to deliver our services, enforce security, or comply with statutory legal mandates.
| Sub-processor | Purpose | Location | Safeguards |
|---|---|---|---|
| Vercel | Hosts the Setura app | UK (London) | [confirm] |
| Anthropic | Runs the Claude AI model that classifies steps the rules cannot. Receives working only, no names or IDs. | US | [confirm transfer safeguard] |
| Supabase [planned, confirm] | Stores accounts and diagnostic records | UK (London region) | [confirm] |
| 10Web | Hosts resseti.com | US | [confirm] |
| Microsoft (Exchange Online) | Business email, including correspondence with schools, enquiries and invoices | UK | Data processing agreement, encryption in transit |
| Tide, with Adyen N.V. for card payments | Issues invoices and receives payments. Card payments made through Tide Payment Links are processed by Adyen. | UK (Tide), Netherlands (Adyen) | PCI-DSS compliant, DPA |
Where personal data is transferred outside the UK or European Economic Area, we implement required legal transfer mechanisms including UK International Data Transfer Agreements (IDTA) or European Commission Standard Contractual Clauses (SCCs).
06 //6. Retention, security and your rights
Data Retention Schedule
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by statutory record-keeping obligations.
| Data Type | Retention Period | Rationale / Trigger |
|---|---|---|
| Student Assessment Data (under school contract) | Deleted within 24 months of school contract termination or upon school request | School control and contract lifecycle |
| School Enquiry & Pilot Contact Records | Retained for 5 years from last active correspondence | Maintaining institutional relationship history and pilot audit |
| Technical Server & Security Logs | Retained for 12 months | Threat monitoring, diagnostic troubleshooting, and incident response |
| Inactive User Accounts | Removed or anonymised after 2 years of total inactivity | Data minimisation principles |
Security Measures
We implement technical and organizational security controls designed to protect information from unauthorized access, accidental loss, disclosure, or alteration:
- Encryption: All data in transit is encrypted using modern TLS (Transport Layer Security 1.3), and stored data is encrypted at rest using AES-256 standard encryption.
- Access Controls: Role-based access control (RBAC), multi-factor authentication for administrative staff, and strict principle-of-least-privilege access.
- Monitoring & Audit: Continuous logging and security reviews of infrastructure components.
Your Statutory Rights
Under UK and EU data protection laws, individuals hold specific statutory rights regarding their personal data:
- Right of access: You can request a copy of the personal data we hold about you.
- Right to rectification: You can ask us to correct inaccurate or incomplete data.
- Right to erasure: You can ask us to delete your personal data under certain conditions.
- Right to restrict processing: You can ask us to pause processing your personal data.
- Right to data portability: You can request transfer of your data to another organization.
- Right to object: You can object to processing based on legitimate interests.
How to exercise your rights:
For students using Lumina through a school: Because the school is the Data Controller, requests should be submitted directly to your school's data protection officer. We will assist your school in fulfilling valid requests.
For direct enquiries and website users: Email us at privacy@resseti.com. You also maintain the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk or your relevant European supervisory authority.