Privacy policy

NethGuide is a learning-support service presented by Elokins Innovation & DigiPolis. For school-managed accounts, the school and service operator define their data-protection responsibilities in the applicable school agreement, according to the purposes of processing and local law.

Privacy enquiries can be raised with the school’s designated privacy lead or linked support team through Messages/Ask for escalation to the platform administrator. This review edition does not replace a school agreement or an approved operator privacy notice; a dedicated public privacy contact is required for final adoption.

Account and profile information can include name, email, role, profile photo, school affiliation and linked family, school and emergency contacts. Learning information can include tasks, submissions, goals, progress, support preferences, mood check-ins, messages, saved diagrams and report discussions.

Uploaded school, IEP, Section 504, specialist or health-related documents may contain sensitive information. Share only information necessary for the learner’s support, and only when you have authority to do so. Confirm the lawful basis and any additional condition for sensitive-data processing with the responsible school or operator.

AI requests may include learner-provided text, task images, selected support context or audio. Operational records include activity events, safety indicators, account information and access/audit records. The exact technical logging and provider practices must be documented in the final notice.

The app uses information to manage accounts and relationships, deliver personalised learning support, assign and review work, create progress reports, communicate with linked supporters, and administer privacy or safety requests. Support suggestions are not medical diagnoses and require human confirmation before they become confirmed profile or formal-plan information.

For UK and EEA use, the controller must identify and communicate a lawful basis for each purpose, and a separate condition where special-category data is involved. A school’s public task, an appropriate contractual purpose or valid consent may apply in different circumstances; the applicable basis is recorded for each processing purpose. Where consent is relied on, explain how it can be withdrawn without unfairly restricting unrelated support.

Before enrolling children, the responsible school and operator must establish age-appropriate information, parental notices and any required authorisation. An account or a parent acknowledgement in a report is not proof of verifiable parental consent.

COPPA applies to certain US services collecting personal information from children under 13. A school may authorise collection only within the conditions allowed for an educational purpose; it does not authorise unrelated commercial use. Applicable notices, consent verification, parental review and deletion rights must be implemented and documented before relying on that authority.

FERPA-covered schools must control access and disclosure of education records. Any reliance on the school-official exception requires the relevant criteria, direct control and restricted use/redisclosure to be satisfied. Parents and eligible students should use their school’s process to inspect records and seek amendment; FERPA obligations depend on the school’s legal status and disclosure arrangements. State student-privacy laws and IDEA/Section 504 record-confidentiality duties may add requirements.

For UK users, consider UK GDPR, the Data Protection Act 2018 and the ICO Children’s Code where applicable. For EEA users, consider EU GDPR and local rules, including varying ages for a child’s consent to online services. The Children’s Code calls for the child’s best interests, understandable notices, data minimisation and high-privacy defaults; writing these principles here does not verify their implementation.

Depending on local law and the processing basis, people may have rights to access, correct, erase, restrict, object, receive portable information and withdraw consent. Requests can be subject to lawful exceptions, identity checks and school record obligations. The final operator notice must name its contact and the applicable response times. UK users may complain to the ICO; EEA users may contact their supervisory authority. Other countries’ applicable privacy and child-protection requirements also need local review.

NethGuide sends relevant requests through a managed AI service to the model provider used by the selected feature. Conversation history, observed learning patterns and learner-saved visuals can be stored to support continuity. AI observations are distinct from confirmed facts. Speaking practice processes audio for feedback; recording and retention practices, including those of providers, must be verified in the final provider schedule.

AI output may be inaccurate, incomplete or unsuitable. A qualified person must review consequential educational or safeguarding decisions; do not use AI as the sole basis for diagnosis, placement, disciplinary action or a formal plan. Browser speech and voice features can also involve browser/platform services depending on the device.

The app has role-based access and linked-supporter permissions for learner records, with separate platform administration. These application controls are not an independent security certification. Sharing and export permissions must be reviewed by the school, especially for downloaded reports and external Google Doc links.

Service categories include secure cloud hosting, account and file services; managed AI services and the selected model providers; and Google Fonts. An enabled WhatsApp integration can involve a messaging provider. The owner must publish a complete current provider list, purposes, processing locations and contract safeguards. No claim of no-sale, no-training, encryption certification or zero retention is made without verified evidence.

The original games built into NethGuide run locally without ABCya embeds. Any external website or document has its own policy; do not upload learner data there without the school’s authorisation.

The app uses browser storage for sign-in state and preferences such as voice, accessibility settings, reading drafts, game deadlines and school checklist choices. Shared-device users should sign out and clear locally saved content where appropriate. A complete cookie/storage inventory and any required optional-cookie consent must be confirmed before the final notice.

Retention periods, backup deletion schedules, account-closure processes and statutory school-record exceptions require an agreed schedule. Deletion requests are assessed against the applicable retention schedule and legal obligations. Request retention information or deletion through the school/privacy escalation process. The operator must explain any international transfers, destinations and applicable safeguards, including adequacy decisions, standard contractual clauses or UK transfer mechanisms as appropriate; no regional hosting guarantee is asserted.

NethGuide’s safeguarding approach is guided by the child’s best interests, equal protection, listening to learners, prevention and shared adult responsibility, consistent with the child-protection principles described by the Association of International Schools in Africa (AISA). References to AISA do not imply endorsement or certification.

When NethGuide detects a potential child-protection concern in a learner’s message or text conversation with Neth—including indicators of self-harm, threats, abuse, bullying, grooming or exploitation—it automatically creates a restricted safety record and sends an in-app notification to the learner’s designated linked support team, including teachers, support staff or parents. Alerts identify the learner and the need for a safeguarding check-in without copying the learner’s message. Access is limited to authorised recipients.

Schools and families are responsible for maintaining accurate supporter links and designating appropriate safeguarding contacts. Authorised adults review alerts and act under their safeguarding procedures and local reporting duties. Automated detection supports, rather than replaces, adult oversight: it may miss a concern or flag language that requires clarification. Additional WhatsApp delivery is available only where the service is configured and valid contacts are supplied.

Learners can report a concern directly to a trusted adult or the school’s safeguarding lead, whether or not an alert has been raised. In immediate danger, contact local emergency services without waiting for an app notification. Safeguarding information should be shared privately, using only what is necessary to protect the child.

This policy is reviewed when the service or applicable requirements change. Material changes are communicated in an age-appropriate way, with additional authorisation where required. School-specific processing arrangements and mandatory local rights remain applicable.