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PRIVACY POLICY — STUDENTAN (Corrected Version) Last Updated: February 18th, 2025 This Privacy Policy explains how Studentan (“we”, “us”, “our”), operated by Junesco Evaluation, Conseil et Formation SA, collects, uses, stores, and protects your personal data when you use our platform and services. We comply with the Swiss Federal Act on Data Protection (FADP), the EU General Data Protection Regulation (GDPR), and other applicable laws. By using Studentan, you agree to this Privacy Policy. 1. Data Controller Junesco Evaluation, Conseil et Formation SA Optingenstrasse 53, 3013 Bern, Switzerland UID: CHE-470.633.968 Email: nextgenlearning@studentan.com 2. Data We Collect Studentan collects only the minimum personal data required to operate the platform and deliver AI tools. 2.1 Account Data Name Email Password (encrypted) 2.2 Technical Data (Basic Only) Automatically collected for security and platform function: IP address Browser, device type Basic logs for performance and troubleshooting We do not collect or analyse: learning progress study behaviour educational results usage patterns for profiling performance analytics 2.3 Payment Data Subscription information Payment processor reference IDs We do not store credit card numbers. 2.4 Content You Provide When using tools (e.g., text generation, transcription), you may input text or files. These are processed only to deliver the requested output. They are not stored or analysed beyond what is technically needed to generate the result. Studentan does NOT: use user content to train models store prompts for later analysis review content manually aggregate data for behavioural insights 3. Purpose of Data Processing We process only what is necessary for: 3.1 Providing the Service Creating and managing accounts Delivering AI-powered features Ensuring the platform runs smoothly 3.2 Security and Fraud Prevention Basic logs to detect misuse and ensure system integrity 3.3 Transaction Management Handling subscriptions and payments Maintaining required accounting records We do NOT process data for: ❌ usage analysis ❌ learning analytics ❌ behavioural tracking ❌ educational profiling ❌ AI model training based on user content 4. Legal Basis (GDPR) We process data under: Contractual necessity: to provide services Legitimate interest: for security and fraud monitoring Legal obligation: for accounting and compliance We do not use your data for marketing without explicit consent. 5. Data Sharing We share data only with essential service providers such as: Cloud hosting Payment processors Email delivery services AI processing partners (e.g., OpenAI), used only to generate results, not to store or analyse content All partners follow strict confidentiality and data protection rules. We do NOT sell personal data. 6. International Transfers Some services (e.g., cloud or AI providers) may process data outside Switzerland or the EU. We ensure protection via: Standard Contractual Clauses (SCCs) Adequacy decisions Additional safeguards 7. Data Retention We retain only what is required for: account operation legal obligations User-generated content is not stored, except temporarily for technical processing. 8. Security We use: Encryption Access controls Secure infrastructure Regular monitoring No system can be 100% secure, but we apply industry-standard protection. 9. Cookies We use only essential cookies necessary for: authentication session stability platform functionality We do not use tracking, analytics, or advertising cookies. 10. Your Rights You can request: access to your data correction deletion restriction data portability withdrawal of consent Contact: nextgenlearning@studentan.com 11. Children’s Privacy Users under 13 must have parental or guardian consent. We do not knowingly collect unnecessary data from minors. 12. Third-Party Links External links may exist. We are not responsible for third-party privacy practices. 13. Changes to This Policy We may update this Privacy Policy. Major changes will be announced. Continued use indicates acceptance. 14. Contact For questions or requests: Junesco Evaluation, Conseil et Formation SA Optingenstrasse 53 3013 Bern, Switzerland Email: nextgenlearning@studentan.com