Who is responsible for your data

Velyra Digital, based in the Netherlands, is the data controller for the personal data described here. You can reach us at legal@edustello.com.

We have not appointed a Data Protection Officer, because the scale and nature of our processing does not require one. Privacy requests go to the address above and are handled by a person.

What we store, and why we may

Your account — email address, display name, plan, credit balance, referral code, the channel you arrived through (a short label such as `google.com` or `direct`, recorded once when the account is created), and the optional answers you give about your studies. Held to give you an account and to run the service you asked for. Legal basis: performance of our contract with you. The study questions are optional and are held on the basis of your consent; clearing an answer removes it.

What you agreed to — that you accepted the terms and confirmed you are 16 or over, when you did so, and which version of the terms was live at the time; whether you asked for marketing email and when that last changed. Held because consent and acceptance have to be demonstrable rather than merely acted upon. Legal basis: our legal obligation under Article 7(1) GDPR, and performance of our contract with you.

Your study material — the text you paste, the documents you upload, and the text extracted from links you give us. Held so you can generate more exams from the same material without uploading it again. Legal basis: performance of our contract with you.

Your exams and results — generated questions, your answers, your scores and the feedback produced for you. Legal basis: performance of our contract with you.

Feedback you send us — what you wrote, the screen you wrote it from, the language you were reading, what you said it was about, and, when it concerns an exam, that exam's support reference so we can find it. Your address is attached so we can credit you if we act on it. Held on the basis of our legitimate interest in improving the service, and deleted with your account.

Abuse-prevention data — a hashed device signature and a hashed IP address, used only for rate limiting and to stop one person taking free credits repeatedly. We do not store raw IP addresses. Legal basis: our legitimate interest in keeping a free tier that is not drained by abuse.

Billing records — the plan or credit pack you bought, the amount, the billing country and any VAT number Stripe collected to work out the tax, a Stripe customer identifier, and the record of your confirming at checkout that you wanted immediate access. Legal basis: performance of our contract, and our legal obligation to keep tax records.

Operational and audit records — account-linked generation and grading status, duration, model-token totals, estimated cost, credit movements, and security or billing actions. These records exclude study text, private answers, credentials, raw card data and raw IP addresses. Legal basis: our legitimate interests in operating, securing and accounting for the service, and legal obligations where they apply.

Privacy-safe analytics — a small, allowlisted set of versioned events, such as whether a generation completed and its duration, reconciled into daily aggregates. These events contain no study text, private answers, credentials, raw payment data, raw IP addresses or account identifiers. Legal basis: our legitimate interest in understanding service reliability and cost without profiling people.

What we do not do

We do not sell your data, ever, to anyone.

We do not run advertising, ad networks, or third-party analytics that profile you across sites.

We do not show your material to other users, and we never use your material to generate exams for anyone else.

We do not make automated decisions with a legal or similarly significant effect on you. AI grades your practice answers; nothing about that decides anything outside Edustello.

Who else processes it

OpenAI — receives your study material and your answers in order to generate questions and grade them. Under our agreement your content is not used to train their models.

Google (Firebase) — stores your account, projects, material and results, and handles sign-in.

Stripe — handles payments, calculates the VAT and issues the invoice. Card details go directly to Stripe; Edustello never sees or stores a card number.

Resend — delivers the email we send you: address confirmations, password resets, security alerts, and the notices you have asked for. It receives your address and the message itself, and nothing else about you.

Cloudflare — runs the Turnstile check on the sign-up and generation screens that tells a person from a script. It sees the request and returns a token; it is given no account, no material and no answers.

Vercel — hosts the application and serves it to your browser.

Google (Analytics) and Microsoft (Clarity) — only if you agree to measurement on the cookie banner. They receive page views and interaction data, never your study material or answers. Refuse, and neither ever loads. Both are certified under the EU-US Data Privacy Framework.

Each of these acts on our instructions under a data processing agreement. Some process data outside the European Economic Area; where they do, transfers are covered by the European Commission's standard contractual clauses.

How long we keep it

Projects, material, exams and results are kept until you delete them or close your account, because their whole purpose is to still be there when you come back to revise.

When you close your account, deletion is queued immediately for the account, projects, material, exams, attempts, grading cache and stored files. Durable retries keep processing until those product records and the sign-in identity are removed. Security and billing audit records are retained separately for the limited period below.

Anonymous guest allowance records are kept for 30 days. Coarse hashed network and source signals used for abuse prevention are kept for seven days. We do not store raw IP addresses.

Account-linked operational usage and model-call records, and unidentifiable analytics events, are kept for 180 days. Daily anonymous aggregate analytics are kept for up to two years.

Security and billing audit records, which may include an account identifier and hashed IP address, are kept for up to one year where needed to investigate abuse, accounting or legal obligations. Stripe may retain transaction and tax records under its own legal obligations.

Security

Data is encrypted in transit and at rest. Access rules are enforced at the database, not only in the app, so one account cannot read another's material even if the interface is bypassed.

Answer keys for an exam in progress are never sent to the browser. Staff access to production data is limited to what is needed to run the service and is logged.

If a breach ever puts your rights at risk, we will notify the Dutch Data Protection Authority within 72 hours and tell you directly where the law requires it.

Your rights

You may ask for a copy of your data, correct it, delete it, restrict or object to our processing of it, or receive it in a portable format. Where we rely on consent, you may withdraw it at any time.

You can do most of this yourself: view and delete any project, delete your account, or download the privacy export from account settings. That self-service export is a metadata-and-ledger manifest; it deliberately omits source text, credentials, payment data and private answer keys. Ask us for a fuller copy where your rights require one.

For anything else, write to legal@edustello.com. We answer within 30 days.

If you think we have handled your data badly, you can complain to the Autoriteit Persoonsgegevens in the Netherlands, or to the supervisory authority where you live. We would rather you came to us first.

Cookies

Edustello sets four cookies of its own: your session, a marker that recognises a browser for security notices, your language, and your answer to the cookie banner. None of them advertise, and none of them follow you to another site.

Measurement is separate and optional. Where it is switched on for a deployment, a banner asks first and nothing is fetched until you agree. The Cookie policy lists every cookie, everything your browser stores locally, and what refusing changes.

Children

Edustello is for people aged 16 and over. Creating an account requires you to confirm that you are, and that confirmation is stored with your acceptance of the terms. We do not knowingly collect personal data from anyone younger, and there is no parental-consent route: nowhere in the product can a child be signed up with permission.

If you believe a child under 16 has an account, write to legal@edustello.com. We will close it and delete the data, and we do not need proof of guardianship to act on a credible report.

Changes

If we change this policy in a way that affects your rights, we will tell you in the app or by email before it takes effect. The date at the top always reflects the current version.