Privacy Policy

Last updated: February 2026

1. Data Controller Identity

The data controller responsible for your personal information is Euphorbia Limited, a company registered in England and Wales under company number 16422872.

Registered address: 82a James Carter Road, Mildenhall, United Kingdom, IP28 7DE.

If you have any questions or require a data protection contact, please reach out to us at [email protected].

2. Children's Privacy and Age Requirements

GradeGen.AI is designed for use by students and we take the privacy of younger users seriously. You must be at least 13 years old to use our service. We do not knowingly collect personal data from children under 13. If we become aware that we have collected data from a child under 13, we will delete it promptly.

3. What Information We Collect and Our Lawful Basis

When you interact with GradeGen.AI, we collect specific categories of data for specific purposes. Under UK GDPR, we rely on the following lawful bases:

• Performance of a Contract: When you create an account, we collect your name, email address, and authentication credentials to provide the platform to you and send account-related communications (like password resets).
• Legitimate Interests: We collect usage data and learning activity to improve your experience, ensure platform security, and perform analytics to develop our services.
• Consent: With your permission, we may occasionally process your data to send you optional marketing communications.

4. AI Data Processing Disclosure

GradeGen.AI utilises artificial intelligence to help generate revision materials. We do not use your personal data to train or fine-tune AI models.

5. Third-Party Processors

We do not sell your personal data. We use a limited number of third-party service providers to help operate our platform securely, including for hosting, data storage, and email delivery. Each provider is contractually required to protect your data.

6. Data Security

We have implemented appropriate technical and organisational measures to protect your personal data against accidental loss, unauthorised access, alteration, or disclosure. We limit access to your data to those who have a genuine need to access it.

7. International Data Transfers

Some of the third-party providers we use may be located outside of the United Kingdom or the EEA (European Economic Area). Where your data is transferred internationally, we ensure appropriate safeguards are in place in accordance with UK data protection law.

8. Data Retention Periods

We retain your personal data only as long as necessary for the purpose it was collected:

• Account Data: Retained while your account is active. After deletion, your data is permanently removed within a reasonable period.
• Logs and Analytics: Retained for no longer than necessary to ensure platform performance and security.
• Legal Obligations: We may retain certain data for longer periods if required by law.

9. Your Data Subject Rights

Under the UK GDPR, you hold significant rights regarding your data:

• Right to be informed: Through this privacy policy.
• Right of access: You can request a copy of the data we hold about you.
• Right to rectification: You can ask us to correct factually inaccurate data.
• Right to erasure (Right to be forgotten): You can request deletion of your account and related data.
• Right to restrict processing: You can ask us to temporarily suspend the processing of your data.
• Right to data portability: You can request your data in a structured, commonly used format.
• Right to object: You can object to data processing based on legitimate interests or direct marketing.
• Rights regarding automated decision-making: You have rights around algorithms making decisions without human involvement.

To exercise any of these rights, email us at [email protected].

10. Third-Party Links

Our platform may link to external websites that are not operated by GradeGen.AI. We have no control over and assume no responsibility for the privacy practices, content, or terms of third-party sites.

11. Cookies

We use essential cookies to maintain your session, keep you logged in securely, and ensure the basic functionality of the platform. By default, we do not deploy non-essential third-party tracking or advertising cookies without your consent.

12. Marketing Communications

If you have opted in, we may occasionally send you details about new features or revision advice. You have the right to opt-out of these marketing communications at any time by clicking the "unsubscribe" link in the email or updating your account settings.

13. Important: Your Right to Complain to the ICO

If you are unhappy with how we have handled your personal data, you have the right to make a complaint directly to the UK’s supervisory authority, the Information Commissioner's Office (ICO). The ICO can be contacted online at ico.org.uk or by calling their helpline at 0303 123 1113.

14. Changes to This Policy

We may update this privacy policy from time to time. Any changes will be reflected on this page with an updated revision date.