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Privacy policy

Introduction

  1. Qlix (“Qlix”, “we”, or “us”) values your privacy. This Privacy Policy explains how we collect, use, protect and disclose information and data when you use Qlix mobile app (the “App”) and our website at qlixapp.com (the “Website”) (collectively referred to as the “Services”). Any capitalized terms used but not defined herein shall have the meaning ascribed to them in our Terms and Conditions.
  2. The policy does not apply to information that you provide to or is collected by any third party whether through or in connection with your use of the Services or otherwise, including information Members may exchange between each other. Third parties may have their own privacy policies, which we encourage you to inquire about before providing information to them. You agree and acknowledge that Qlix has no duty or responsibility to maintain and safeguard any information you may provide to or is collected by any third party whether through or in connection with your use of the Services or otherwise.
  3. This Privacy Policy is incorporated by reference into our Terms and Conditions.
  4. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. This policy also explains your choices for managing information preferences, including your right to opt out of certain uses of your information. If you do not agree with our policies and practices, do not use the Services. By downloading and using the App and/or registering with us through the Website, you agree to this privacy policy. This policy may change from time to time. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check this policy periodically for updates.

Our Two Roles

  1. Qlix processes personal data in two different capacities. Which one applies determines who is legally responsible for what.
  2. We are a controller for the data we decide how to use: your account credentials, your name and email address, billing and subscription records, product usage and error logs, support correspondence, and anything you choose to publish on your QlixSocial profile. This Privacy Policy governs that processing.
  3. We are a processor for data we handle on someone else's instructions:
    • If you use Qlix through your school or trust, your school is the controller for student data, class and timetable structures, and the teaching content you produce in the course of your work. We process it only on the school's documented instructions, under a Data Processing Agreement.
    • If you are an independent private tutor, you are the controller for your students' data and we are your processor, under our Data Processing Agreement.
  4. Summary of roles by data category:
    • Account credentials and authentication - Controller
    • Billing and subscription - Controller
    • Product usage and error logs - Controller
    • Support correspondence - Controller
    • QlixSocial profile and public resources - Controller
    • Timetable, classes and teaching groups - Processor
    • Student names and identifiers - Processor
    • Student submissions, marks and outcomes - Processor
    • Teacher notes about students, including SEN - Processor
    • Lesson plans created in the course of school work - Processor
    • AI prompts and outputs containing any of the above - Processor
  5. What this means in practice. If you are a student, parent or guardian and want to access, correct or delete student data, contact the school in the first instance - the school decides, and we act on its instruction. If you are a teacher and want to access or delete your own account data, contact us directly.
  6. Where our role in respect of a particular category of data is unclear, we treat ourselves as processor.

Information We Collect

  1. Personal Information: We may ask you to provide us with certain categories of personal information, which is information that could reasonably be used to identify you personally, such as your name, e-mail address, home address, mobile number, credit card, financial account information and other payment information (“Personal Information”). You may be asked to provide us with Personal Information when you register with the Website, App or use any of the Services. The decision to provide this information is optional; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Services. We may also receive Personal Information and other information from third parties, such as social media services.
  2. Non-Personal Information: When you download the App, use the Website and access and use the Services, we may use technology to automatically collect:
    • Usage Data: When you access and use the Services, we may automatically collect certain details of your access to and use of the Services, including communication data and the resources that you access on or through the Services.
    • Device Information: We may collect information about your desktop or mobile device and internet connection, including the device's unique device identifier, IP address, operating system, browser type, and for mobile devices certain network information and the device's telephone number.
    • Approximate location: We derive an approximate country or region from your IP address in order to display prices in the correct currency and to apply territorial availability restrictions. We do not collect precise or real-time device location, and we do not track your location in the background.
    • Stored Information and Metadata: The Services also may access metadata and other information associated with other files stored on your device when you choose to upload or attach files.
  3. If you do not want us to collect this information do not download the App or otherwise access the Website or the Services.

Children and Student Data

  1. Qlix accounts are for adults. You must be 18 or over to register for and hold a Qlix account.
  2. Students under 18 may access QlixGo - a limited surface for completing and submitting work set by their teacher - without registering an account. Where this happens through a school, the school is the data controller and Qlix acts only as a processor on that school's instructions. Where an independent private tutor uses QlixGo with their students, the tutor is the controller and Qlix is the processor under our Data Processing Agreement.
  3. What student data we process:
    • a name or identifier set by the teacher (this may be a first name, an initial, or a code)
    • class or group membership
    • work, answers and submissions made through QlixGo
    • marks, scores and assessment outcomes
    • teacher-recorded notes, which may include special educational needs and learning support information
  4. What we do not collect from students: email addresses, postal addresses, telephone numbers, dates of birth, payment information, device location, or any advertising or behavioural tracking identifiers.
  5. What we never do with student data:
    • use it to train, fine-tune or improve any AI model
    • serve advertising, or use it for marketing, commercial profiling or audience targeting
    • sell, rent or licence it
    • disclose it to any party other than the sub-processors listed below, or where legally compelled
  6. AI and student data. Where an AI feature is used, student names are replaced with pseudonymous tokens before any content is sent to the AI model. The model receives context such as “Student A requires dyslexia support” - it does not receive real names. AI processing takes place in the United Kingdom.
  7. Retention. Student personal data is retained while the school's account is active and for 30 days after termination, after which it is deleted, unless the school instructs earlier deletion. Schools may request export or deletion at any time and we will action the request within 30 days.
  8. Special category data. Special educational needs and health-related support notes are special category data under UK GDPR Article 9. Schools must ensure they have an appropriate Article 9 condition in place before entering such data. We apply the same technical and organisational measures to this data as to all other student data and restrict internal access to it.
  9. Attainment analysis. Marks and assessment outcomes are analysed over time to show attainment against learning objectives, progress across a term, and class-level patterns such as missing work or commonly misunderstood topics. This is done to help teachers decide what to teach next. It is academic evaluation only - we do not predict behaviour, attendance or any characteristic beyond performance on work the student has submitted, and no decision about a student is made automatically. A teacher reviews and can override everything.
  10. Sharing and student data. Qlix separates teaching resources from student records. Lesson plans, worksheets and activities can be shared with colleagues or published publicly. Student names, submissions, marks and teacher notes are held separately in assessment records, which cannot be shared or published under any setting. Publishing a resource never exposes a student's data.

Automatic Information Collection (Tracking Technologies)

  1. The technologies we use for automatic information collection may include:
    • Cookies: Pages of the Services and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages (or opened an e-mail) and for other related Services statistics (for example, recording popularity of certain App content and verifying system and server integrity).
    • Web Beacons: We may collect information about your desktop or mobile device and internet connection, including the device's unique device identifier, IP address, operating system, browser type, and for mobile devices certain network information and the device's telephone number.
    • Embedded Scripts: An embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third party service provider, is active only while you are connected to the Services, and is deactivated or deleted thereafter.

Profile information you make available to others

  1. By using the Services you may make certain of your Personal Information available to others. For example, other users may see your name, the city you live in and other information from your profile that you provide. The information you provide in your profile may be accessed by users who use the Services and may be accessed by commercial search engines such as Google, Yahoo!, and Bing to the extent that such engines are permitted to access the Services. You will also be providing certain Personal Information to professionals or clients, as applicable, when using the Services to set up appointments, communicate with other users, and take advantage of other functionalities of the Services.
  2. Public sharing on QlixSocial applies to teaching resources only (for example lesson plans and activities). Resources are not intended to contain student personal data. Marks, grades and other student records are kept in Markbook and related student features and cannot be published to a public profile. If a teacher includes a student name in a resource that they then make public, that is a misuse of the resource feature and is the teacher's responsibility.

Accessing & Correcting Your Personal Information

  1. You can review and change your personal information by logging into the Services and visiting your account settings page.
  2. You may also send us an email at privacy@qlixapp.com to request access to, correct or delete any personal information that you have provided to us.
  3. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
  4. If your request relates to student data held by a school using Qlix, the school is the data controller and you should contact the school in the first instance.
  5. You also have the right to complain about how we have handled your personal data. See “How to Complain” below, or contact privacy@qlixapp.com.

Third Party Information Collection

  1. When you use the Services, certain third parties may use automatic information collection technologies to collection information about you and your device. These third parties may include:
    • analytics companies,
    • your mobile device manufacturer,
    • your mobile service provider and
    • our credit card and payments processor.
  2. These third parties may use technologies to collect information about how the Services are used - for example analytics events or payment processing metadata. They do so under our instructions or their own privacy notices as applicable. We do not use advertising networks or interest-based advertising. Analytics on the marketing website and teacher application is limited to pseudonymous account identifiers; see Sub-processors below. No analytics or behavioural tracking operates on QlixGo.
  3. We do not control every third party's own systems. If you have questions about a specific provider's collection, you should also read that provider's privacy notice.

Links To Other Websites

  1. Our Services may contain links to other websites or allow others to send you such links. A link to a third party's website does not mean that we endorse it or that we are affiliated with it. We do not exercise control over third-party websites. You access such third-party websites or content at your own risk. You should always read the privacy policy of a third-party website before providing any information to the website.

How We Use Your Information

  1. We use information that we collect about you or that you provide to us, including any personal information for internal purposes only, including to:
    • Provide you with the Services, and any other information, products or services that you request from us.
    • Fulfill any other purpose for which you provide it.
    • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including our billing and collection.
    • Notify you when Service updates are available, and of changes to any products or services we offer or provide through the App and Website.
  2. The Usage Data we collect helps us to improve the Services and to deliver a better and more personalized experience by enabling us to:
    • Estimate our audience size and usage patterns.
    • Store information about your preferences, allowing us to customize the Services according to your individual interests.
    • Recognize you when you use the Services.
    • Use approximate location derived from IP address to display prices in the correct currency and apply territorial availability restrictions.
  3. We may use your email address to contact you about Qlix product updates, service changes and relevant teaching content. You may opt out at any time using the unsubscribe link in any email or by contacting support. We do not send you marketing on behalf of third parties. If you do not want us to use your information in this way, please email us on support@qlixapp.com.

Disclosure Of Your Information

  1. We may disclose aggregated information about our Members and information that does not identify any individual or device, without restriction. In addition, we may disclose personal information that we collect or you provide:
    • To our subsidiaries and affiliates.
    • To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
    • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us is among the assets transferred.
    • To fulfill the purpose for which you provide it.
    • For any other purpose disclosed by us when you provide the information.
    • With your consent.
    • To comply with any court order, law or legal process, including to respond to any government or regulatory request.
    • To enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  2. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Qlix, our Members or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Sub-processors

  1. We use the following sub-processors. We maintain contracts with each requiring equivalent data protection standards, and we give schools 30 days' notice before adding or replacing one.
    • Amazon Web Services - Hosting, storage, backups - United Kingdom (London)
    • Amazon Bedrock - AI model inference - United Kingdom (London)
    • Stripe - Payment processing (account holders only) - EU / US
    • Mailgun (Sinch) - Transactional and product email - EU
    • Mixpanel - Product usage analytics - pseudonymous staff account ID only, no email address - EU
    • Google Analytics - Marketing site and staff application analytics - pseudonymous staff account ID only - US
    • Featurebase (CORDNET OÜ) - In-app support, help centre, feature requests - EEA (Germany)
    • Sentry - Application error and performance monitoring - EU
    • OneSignal - Push notification delivery - stored EU, accessed from US
  2. No analytics, advertising or behavioural tracking technologies operate on QlixGo, the student-facing surface. Error monitoring (Sentry) operates on QlixGo to detect faults. It does not send authentication data, student identifiers, or session content in those error events.
  3. Student personal data is not shared with our payment provider.

Retention

  1. We retain personal data as follows:
    • Teacher account and lesson plan data - Life of the account; deleted 30 days after closure
    • Student submissions and marks - While the school account is active; deleted 30 days after termination or on instruction
    • Billing records - 7 years (statutory)
    • Server and access logs - 90 days

Personal Data Breaches

  1. Where we act as processor, we will notify the controller without undue delay and in any event within 24 hours of becoming aware of a personal data breach affecting their data, and will provide the information the controller needs to meet its own 72-hour notification obligation to the ICO. Where we act as controller, we will notify the ICO within 72 hours where the breach meets the reporting threshold.

Your Choices About Our Collection, Use & Disclosure of Your Information

  1. We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.
  2. Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Services may then be inaccessible or not function properly.
  3. Product communications by the Company. If you do not want us to use your email address to contact you about Qlix product updates, service changes and relevant teaching content, you can opt-out by using the unsubscribe link in any email, by logging into the Services and adjusting your preferences, or by sending us an e-mail stating your request to support@qlixapp.com.

Data Security

  1. We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Site or Services, we cannot and do not guarantee the security of any information you transmit on or through the Site or Services, and you do so at your own risk.
  2. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
  3. Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Where Your Data Is Stored and Processed

  1. Qlix data is stored and processed in the United Kingdom, in Amazon Web Services' London region. AI processing also takes place in the United Kingdom. Daily backups are held in a separate location within the same jurisdiction.
  2. Qlix Limited is registered in Hong Kong SAR - this is our place of incorporation only. We have no personnel based in Hong Kong SAR, and no data is accessed from there. Members of our team are located in the United Kingdom and Thailand. Where personnel in Thailand require access to data for support or engineering purposes, that access constitutes a restricted international transfer under UK GDPR. Such transfers are made under the UK International Data Transfer Agreement (IDTA), supported by a Transfer Risk Assessment, and are subject to the following safeguards:
    • access is limited to named personnel on a need-to-know basis
    • access is logged and time-limited
    • support personnel do not routinely access student personal data
  3. Our Transfer Risk Assessment is published at qlixapp.com/legal/tra. The International Data Transfer Agreement is the ICO's standard template: download the IDTA from the ICO.

Our Regulatory Status

  1. Qlix Limited has an establishment in the United Kingdom and is subject to the direct supervision of the Information Commissioner's Office.

How to Complain

  1. If you believe we have handled your personal data in a way that does not comply with data protection law, you have the right to complain to us directly.
  2. How to complain. Email us at privacy@qlixapp.com. We accept complaints however they reach us, including by in-app message. You do not need to use a particular form of words.
  3. What happens next. We will acknowledge your complaint within 30 days of receiving it. We will investigate and respond substantively without undue delay, and we will tell you the outcome and the reasons for it.
  4. If you are not satisfied. You may complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113. You do not have to complain to us first, but we would prefer the chance to put things right.
  5. Student data. If your complaint relates to a student's data held by a school using Qlix, the school is the data controller and the complaint should go to the school. If you send it to us, we will forward it to the school within 3 working days and let you know we have done so.

English Version To Prevail

  1. In the event of any inconsistencies or discrepancies between the English version and other translated versions of this policy or the information on the Platform and/or Service, the English website version shall prevail.

Contact

  1. To ask questions or comment about this privacy policy and our privacy practices, contact us at privacy@qlixapp.com or support@qlixapp.com.