Privacy Policy

1. Introduction

Grade Drive Ltd ("we", "our", or "us") operates the GradeDrive exam marking service. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website and services, and sets out our obligations under the UK General Data Protection Regulation (UK GDPR) and the EU General Data Protection Regulation (GDPR). Please read it carefully.

We act as a Data Controller in respect of account and billing information held about our subscribers, and as a Data Processor in respect of any student data uploaded by users of the service. Our processing of student data is governed by the Data Processing Addendum described in our Terms of Service.

2. Information we collect

We collect information that you provide directly and information that is generated when you use our service:

• Account data (Controller): Name, email address, and password when you register; the date and version of the Terms of Service you agreed to; profile preferences (e.g. language, theme) that you set. Billing and payment information (e.g. card details, billing address) is collected and stored directly by our payment processor, Stripe, on our behalf; we do not store full card details on our own servers.
• Student data (Processor): Student names, PDF content, candidate numbers, and centre numbers uploaded by teachers or institutions. We process this data strictly to provide the marking service on the instructions of the relevant teacher or institution.
• Assessment and submission data: Mark schemes, exam papers, and student submissions you upload; results, scores, and feedback produced by our marking service.
• Usage and technical data: How you use the service (e.g. pages visited, actions taken), usage limits and quotas, and standard log data (IP address, browser type, timestamps).
• Product usage events (Controller): when you are signed in, our servers record the main steps you take in the service, such as signing up, verifying your email, logging in, opening a page in the app, starting or confirming an assessment, getting marks back and subscribing. Each record carries your account ID, the time, and counts such as how many submissions an assessment has. It never includes your name, email address, file names, student information, or marks.
• Where you came from (Controller): if you register on the page you first arrived at, we save that page's address, the website that sent you, any campaign tags in the link, and any Google advert click ID. We read these from the page itself when you sign up; nothing is stored on your device to do this. If you accept analytics, we keep these from the first page you visit until you register.
• Analytics data (only if you accept analytics): how you move around our website and app, recorded as masked recordings with all text, typing and images hidden, and linked to your account when you sign in.
• Anonymous statistics: counts of page visits that can't identify you.
• Advertising measurement data (only if you accept advertising cookies): an identifier for the Google advert that brought you to our website, and whether you went on to view our pricing page, sign up, or become a paying subscriber. For a new subscription this includes the amount paid and a Stripe checkout reference. We do not give Google your name or email address.

3. How we use your information

We use the information we collect to:

• Provide, operate, and improve the exam marking service
• Process mark schemes and submissions to generate marks and feedback
• Manage your account and enforce our terms
• Send you service-related communications (e.g. security or policy updates)
• Comply with legal obligations and protect our rights
• Understand how people find and use the service, including where they stop, so we can improve it
• Learn which of our Google adverts lead to sign-ups and new subscriptions, if you accept advertising cookies

No AI training: We do not use uploaded student work, PDFs, or any student data to train our AI models or the underlying Google Cloud APIs. Assessment and submission content is processed solely to deliver marking results to you.

Legal basis for processing: We process account data on the basis of Contractual Necessity (to fulfil our agreement with you). Schools and teachers process student data on the basis of Public Task or Legitimate Interests; our role as Processor is to facilitate that processing under a Data Processing Addendum (DPA) with the relevant Data Controller. We measure our adverts only with your Consent, which you can withdraw at any time (see section 7). We record product usage events and where you came from on the basis of our Legitimate Interests in understanding and improving the service. You can object at any time (see section 8). We use analytics only with your Consent, which you can withdraw at any time. We count anonymous statistics under the statistics exception in UK law; you can turn it off from Cookie settings.

4. Data location & retention

Storage: All data is hosted on secure servers located in the EU/EEA. The one exception is advertising measurement data, which Google holds if you accept advertising cookies (see sections 6 and 9).

Retention:We retain student data for 18 months from the time of upload, or until the user manually deletes the records, whichever is earlier. Account and billing data is retained for as long as your account is active and for such further period as required by law. Users are responsible for adhering to their institution's own data retention policies. Product usage events are kept for up to 12 months and then deleted.

If you use the self-service account deletion flow, we will cancel any active subscription immediately, delete stored assessment files and results associated with your account, and anonymise the account record so it no longer identifies you. We may retain minimal scrubbed billing and usage audit data where required for legal, accounting, fraud-prevention, or security purposes.

5. Security

We implement appropriate technical and organisational measures to protect your data against unauthorised access, loss, or misuse, including high-level encryption standards. Data in transit is encrypted (e.g. TLS); data at rest is stored in secure, access-controlled environments.

6. Sharing and third parties

We may share data with service providers that help us operate the platform (e.g. hosting, email delivery, payment processing, and AI processing). Such providers are bound by confidentiality and data-processing obligations. We do not sell your personal data. We may disclose information where required by law or to protect our rights, safety, or property.

Payment processing (Stripe): All payment transactions are processed by Stripe, Inc., our third-party payment processor. When you make a purchase, your billing information (such as card details and billing address) is transmitted directly to and stored by Stripe. We receive only limited billing metadata (e.g. last four card digits, expiry, billing postcode) necessary to manage your subscription. Stripe processes this data in accordance with its own Privacy Policy. Where Stripe processes data of EU/UK residents, it does so under appropriate safeguards including Standard Contractual Clauses.

Advertising measurement (Google Ads): If you accept advertising cookies, our website loads Google's advertising tag, provided by Google Ireland Limited and Google LLC. It tells Google when someone who arrived from one of our adverts views our pricing page, signs up, or becomes a paying subscriber, so we can see which adverts work. We have turned off ad personalisation, so this is not used to show you personalised ads. Google uses this data as described in How Google uses information from sites that use its services and its Privacy Policy. If you reject advertising cookies, nothing is sent to Google.

Product analytics (PostHog): we send product usage events to PostHog Inc., which processes them on our behalf under a data processing agreement and stores them in its EU region (Frankfurt, Germany). From our servers, PostHog receives your account ID only, never your name, email address or IP address, and never any student data. If you accept analytics, or while anonymous statistics are on, PostHog receives your IP address. It uses it only to make the scrambled code or to work out your country, and we've told it not to store it.

Bot protection (Cloudflare Turnstile): when you sign up with an email address or ask for a password reset, the form runs a check from Cloudflare, Inc. to tell people apart from automated programs. We use it because programs have been signing other people's email addresses up to send them unwanted emails. Cloudflare receives your IP address and information about your browser, and uses it only to tell people from bots and to improve that check, not to identify, profile or target you. See Cloudflare's Turnstile Privacy Addendum. Signing in with Google or Microsoft does not use this check.

7. Cookies and similar technologies

We use essential cookies and similar technologies to run the service, such as keeping you signed in and remembering your preferences. These do not need your consent.

With your consent, and only then, we also use PostHog analytics cookies to see how people use the service, and Google Ads advertising cookies to measure which of our adverts lead to sign-ups and subscriptions (see section 6). We ask before setting any of them, rejecting is as easy as accepting, and the service works the same either way. We use analytics cookies only if you accept them, and we do not use advertising cookies to show you personalised ads. We count visits anonymously without cookies unless you turn that off.

You can change your choice at any time from Cookie settings, in the footer of our website or the account menu in the app. Withdrawing consent deletes those cookies. We ask again after 12 months. Our Cookie Policy lists each cookie and how long it lasts.

8. Your rights

Under the UK GDPR and EU GDPR, individuals have the right to:

• Access and receive a copy of your personal data
• Correct or update inaccurate data
• Request erasure of your data
• Object to or restrict certain processing
• Data portability
• Withdraw consent where processing is consent-based
• Lodge a complaint with a supervisory authority (in the UK, the ICO)

Because we act as a Processor for student data, requests relating to student records should be directed to the relevant school or teacher (the Data Controller). We will assist in fulfilling such requests manually upon verification. For requests relating to your own account data, contact us using the details on our Contact page.

To object to product usage events, email us using the details on our Contact page. Once we have recorded your objection, we record no further events about you, and on request we delete the ones already held.

9. International transfers

All data is stored within the EU/EEA, except advertising measurement data if you accept advertising cookies: Google may process that in the United States and elsewhere. Where any processing involves transfers outside the UK or EU/EEA, we ensure appropriate safeguards (e.g. standard contractual clauses, adequacy decisions or the UK-US data bridge) are in place as required by applicable law.

10. Changes to this policy

We may update this Privacy Policy from time to time. We will post the revised version on this page and update the "Last updated" date. Continued use of the service after changes constitutes acceptance of the updated policy. For material changes, we may provide additional notice (e.g. by email or in-product).

11. Live Chat

Our website offers an optional Live Chat widget for talking to support. It is not shown on every page and does not appear unless it has been enabled for the site.

What we collect: the text of the messages you send, and (if you choose to give one) a contact email address. If you are signed in to your GradeDrive account when you use the widget, we also read your user id and email address from your session and attach them to the conversation so support can identify your account.

Where it goes: your messages and any contact email are stored in our AWS DynamoDB database in the EU (eu-west-1). Each message is also posted into a private Slack workspace, where a support person reads it and can reply. If you ask for a reply by email, we send it using our email provider, Resend.

Retention: Live Chat conversations are kept for 30 days from the last message and then deleted automatically.

Requesting deletion: To ask us to delete a Live Chat conversation before it expires, contact us using the details on our Contact page.

12. Contact

For privacy-related questions or requests, contact us at the address or email provided on our Contact page.