Privacy Policy

Effective date: 24 July 2026

Version 2026-07-24 · replaces the notice of 17 July 2026

This notice explains how Axiom Intelligence Partners LLC ("EdSmartly", "we", "us") handles personal data in the EdSmartly service at edsmartly.com and app.edsmartly.com. It describes what the platform actually does — not what it might one day do.

1. Who we are, and who is responsible for your data

Axiom Intelligence Partners LLC is a limited liability company registered in the State of Wyoming, United States, at 30 N Gould St, Ste R, Sheridan, WY 82801. edsmartly.com and app.edsmartly.com are services of Axiom Intelligence Partners LLC.

Responsibility depends on how EdSmartly is being used, and this is not a technicality — it changes who you go to.

• Your school is the Data Controller for the accounts and teaching content inside its EdSmartly workspace. Your school decides who may use the service, what role each person holds, how long teaching history is kept, and whether an account is closed. We act as the Data Processor, on your school's documented instructions.
• We are the Data Controller for website enquiries (waitlist and brochure requests), for contacts a referral partner registers with us, and for our own business records. In those cases there is no school standing between you and us — you come to us directly.

2. The laws we follow

EdSmartly serves schools in the Gulf. This notice is written to meet Qatar's Personal Data Privacy Protection Law (Law No. 13 of 2016) and the United Arab Emirates Personal Data Protection Law (Federal Decree-Law No. 45 of 2021).

We are not established in the European Union and we do not offer the service to people in the EU or EEA, so the GDPR does not apply to us as a matter of law. We hold ourselves to GDPR-grade standards anyway — data minimisation, purpose limitation, transparency, and accountability we can actually demonstrate — because a school should not have to take our word for how its teachers' data is handled.

3. What we collect

• Website enquiries — your name, email address, role, country, organisation and stated interest, when you join the waitlist or request the brochure. These reach us as an email and nothing more: we do not add you to a mailing list, and they are not stored in a marketing platform. To have an enquiry deleted, write to hello@edsmartly.com.
• Ask Edi support chat — if you use the "Ask Edi" bubble on this site, we receive the question you type, and — only if you choose to give them — your name and email address. No account or sign-up is needed. We use these solely to answer your question and, if you left an email, to reply to you. We do not build a profile from it, and the conversation is not used to train AI models.
• Account data — your name, email address, password (stored only as a secure hash by our authentication provider), interface language, and your role and school membership.
• Teaching content — the lesson plans, assessments, question ladders, report drafts and weekly modules you generate, the inputs you provide to create them, and any rating you give an output. These are stored in your account history.
• Student practice data — when you run a Student Practice session, the student's first name (transient; no surname or identifier required), the text of each answer they give, and the AI's automated diagnosis and misconception label are stored in your account for as long as your school's data retention policy allows. No student email address, password, roster or persistent record is created. School administrators can see aggregate misconception statistics on the dashboard, but cannot read individual student responses.
• Referred contacts — if one of our referral partners registers your school as a lead, we receive your school's name, your name, your role and your business contact details before you have heard from us. Partners are contractually required to register only people they already have a business relationship with or whose agreement they have, and are forbidden from sending us any teacher's or student's personal data. We use these details for one purpose: to assess and pursue that referral. If you would rather we did not hold them, tell us and we will erase them — see section 9.
• Usage and administrative records — generation counts against fair-use quotas, and an audit log of administrative actions (for example, when a school or group administrator assigns an administrator or changes a quota).

4. Children's privacy and minor data

We treat anyone under the age of 18 as a minor. This section sets out our position now, and the commitments we make before anything changes.

Today: students do not use EdSmartly

EdSmartly is a tool for teachers and school staff. There are no student accounts. Students do not sign in, and they do not interact with the service.

There is one exception, and we would rather state it plainly than bury it. The Report Writer lets a teacher type a student's first name so that a report reads naturally. That first name is sent to the AI provider with the request, and it is stored in the generated report in the teacher's history. In the context of a single class, a first name can identify a child — so we treat it as personal data and say so, rather than claiming we hold none.

What we never do with a minor's data

• No advertising, and no profiling for commercial purposes.
• No sale, and no sharing beyond the processors listed in section 6.
• No use for training AI models — ever, under any tier.
• No automated decision that produces a legal or similarly significant effect about a child. Every output is a draft, and a teacher reviews and decides.

Before any student-facing feature launches

We intend to introduce a student-facing Socratic practice mode in a future phase. We are stating our governance posture now, before we build it, rather than after:

• Students would reach it only through their school. The school remains the Data Controller, and is responsible for the lawful basis for processing a child's data and — where the law requires it — for obtaining the consent of a parent or guardian. Both Qatar's PDPPL and the UAE PDPL impose heightened obligations on the processing of children's data.
• We would act only as Processor, on the school's documented instructions.
• We would collect the minimum needed for the teaching dialogue and nothing else.
• Student interaction data would never be used to train AI models.
• It would be retained under the school's retention setting (section 7) and archived or deleted on the same terms as all other data.
• We will publish an updated notice and a specific children's addendum before the feature goes live— not afterwards.

If you believe a child's data has been entered into EdSmartly in a way this notice does not permit, write tohello@edsmartly.com and we will remove it.

5. Why we use it, and on what basis

We do not rely on your consent to process your teaching account data, and we do not ask for it.Where someone uses a product because their employer provides it, consent is rarely a free choice — so it would be the wrong basis to claim. We do not sell personal data, and we do not use it for advertising.

6. AI processing

Generation requests are processed by third-party AI model providers — Anthropic, andOpenAI as a fallback — under agreements that do not permit them to train models on your content. A request carries the teaching context you enter: subject, grade, topic, your notes, and (if you use the Report Writer) the student first name you typed.

Questions asked through the Ask Edi support bubble are answered the same way: the text of your question is processed by the same providers under the same no-training terms, grounded in the official EdSmartly manuals. Your optional name and email are not sent to the AI provider.

Outputs are drafts. They are produced by a model, they can be wrong, and you remain responsible for reviewing and personalising them before they are used with, or about, any student. EdSmartly makes no automated decision about any student.

7. Who processes data for us, and where

Cross-border transfers. Your school's database is hosted in the European Union. Several of the providers above operate from the United States, so data reaches them there. Each is bound by a written data-processing agreement that permits them to process it only to provide their service to us, prohibits them from using it for their own purposes — including training AI models — and requires appropriate security. Qatar's PDPPL and the UAE PDPL both regulate transfers of personal data across borders, and we transfer only to providers that are contractually bound to the protections described in this notice.

8. How long we keep it

This is the section most privacy notices get wrong, so we are being exact. EdSmartly does not simply "delete on request" — it archives first, and here is what that means.

• Teaching history. Your school chooses how long generation history is retained — 12 months, 36 months, or indefinitely. History older than the school's chosen period is removed automatically.Items your school has approved into its School Library are kept as school assets and are not purged.
• When an account is closed. Your school administrator approves the request, and we thenarchive the account. Archived data is immediately removed from every view, dashboard and roster — nobody at your school, and nobody at EdSmartly, sees it in the product. It is then retained for up to 10 years for audit, legal and contractual-defence purposes, and is permanently deleted at the end of that period. It is not used for anything else in the meantime.
• Website enquiries are kept while they remain relevant to our correspondence with you, and for up to 24 months after our last contact.
• Referred contacts. A partner's registration protects their claim for six months. If the school does not become a customer we erase the contact details within 24 months of the last contact, and sooner if you ask. If it does, the record becomes part of the account and contractual records above. This is one of the few things we erase outright rather than archive: there is no audit or contractual reason to keep the details of someone who never became a customer.
• Backups persist for a limited period after deletion.

9. Your rights, and how to exercise them

You may ask for access to your personal data, its correction, itserasure, a copy in a portable form, and you may object to or ask us to restrict certain processing.

Two of these you can exercise yourself, immediately, inside the app:

• Access and portability — Account → Download my data. You get a copy of your profile, your memberships and every generation you have created.
• Erasure / account closure — Account → Request account closure. Yourschool administrator reviews it, because your school is the Controller. Once approved, we archive the account as described in section 8.

Otherwise, write to hello@edsmartly.com. We respond within 30 days.

Complaints. If you are not satisfied with our response, you may complain to the competent data-protection authority — in Qatar, the national authority responsible for Law No. 13 of 2016; in the United Arab Emirates, the UAE Data Office.

10. Security

Data is encrypted in transit. Each school's data is isolated at the database level by row-level security, and access is restricted by role. Two-factor authentication is available to every user, not only administrators. Administrative actions across a school group are written to an audit log that the group's administrator can read and export.

11. Cookies and analytics

We use only the cookies needed to sign you in and to remember which campus you are working in. For visitor numbers we use Cloudflare Web Analytics, which is cookieless: it sets no cookies, stores nothing on your device, and cannot follow you to other websites. Because nothing is stored on or read from your device, no consent is required — but you can still switch it off in Cookie preferences, and the script will not load at all. Full detail is in our Cookie Policy.

12. Who owns what you create

You do. The school and its teachers retain full ownership of the inputs they provide, the outputs they generate and any curriculum framework they upload. Axiom Intelligence Partners LLC takes no ownership of that content and no right to use it for any purpose other than running the service for you — expressly including no AI model training. The full clause is in the Terms of Service.

13. Changes to this notice

When this notice changes we publish it as a new version with a new effective date, and record that version in the app, where you will be asked to confirm you have read it. We do not silently edit a version that people have already been shown.

14. Contact

Axiom Intelligence Partners LLC
30 N Gould St, Ste R, Sheridan, WY 82801, United States
hello@edsmartly.com