ARLOS privacy policy

ARLOS is operated by Penguin Legion Lda, Lagos, Portugal (“ARLOS”, “we”, “us”). We are the data controller for the personal data described in this policy. Contact us at support@arlos.school for anything in this policy, or hello@arlos.school for legal notices. This policy forms part of our Terms and Conditions. Words defined there (Account Holder, learner profile, Home School subscription, Founding Family Offer, Studio Pass) mean the same here.

1. The short version

Parents create and control everything. We collect what we need to teach your child and show you their progress, and nothing more. Voice capture is off by default and only active at marked points in a lesson. We never sell personal data. We never use children’s data for advertising. You can see, export, or delete your family’s data at any time.

2. Who this policy covers

• Account Holders: the adults who create accounts, subscribe, and manage the family’s use of ARLOS.
• Learners: children aged 11 to 14 whose profiles are created and managed by their Account Holder.
• Visitors: people who browse our website, join our email list, or register for a Studio Pass.

We only process a child’s data after their parent or guardian creates their learner profile, which is how we obtain and record parental consent. Children are unable to create accounts themselves (Terms, Section 2.1).

3. What we collect

From Account Holders:

• Account details: name, email address, password (stored as a secure hash), country, and household learner profiles you create.
• Billing details: subscription tier, payment history, and billing status. Card details are collected and stored by our payment processor, never on our servers.
• Communications: messages you send to support, survey responses, and your email preferences.
• Settings you choose: GEMS reward goals, delivery preferences, community display name.

From Learners (only what teaching requires):

• Profile basics set by the parent: first name or chosen display name, year group or Cambridge stage, and optional interests used to personalise lessons.
• Learning activity: lesson progress, answers, quiz results, stars, mastery levels, GEMS and Tickets earned.
• Handwriting: stylus input on worksheets, processed to read the learner’s working.
• Voice: audio captured only during marked checkpoints when the microphone is on, processed to hold the tutoring conversation. The microphone state is always visible to the learner and is off outside checkpoints.
• Lesson transcripts: a record of tutor conversations, available for parents to review in the Parent Dashboard.

From Visitors:

• Email address and the information you give us when joining our list, registering a Studio Pass (including children’s ages, so we know when your family becomes eligible), or booking a demo.
• Basic technical data: device type, browser, and usage analytics as described in Section 9 (Cookies).

We do not collect: children’s contact details, children’s precise location, biometric identifiers, or any data for advertising profiles.

4. Why we process it, and the legal basis

• Providing the Service (contract): teaching, generating lessons and projects, tracking mastery, running your dashboard, operating GEMS, Tickets and leaderboards, and billing under the Terms.
• Children’s learning data (consent): we process learner data on the basis of parental consent, given when the parent creates the learner profile. Consent can be withdrawn at any time by deleting the profile or contacting support, without affecting the lawfulness of prior processing.
• Improving and securing the Service (legitimate interests): fixing bugs, preventing abuse of the platform (Terms, Section 5), measuring what works, and keeping the Service safe. Where we analyse learning data for improvement, we use aggregated or de-identified data wherever possible.
• Communications (consent and legitimate interests): service emails (receipts, activation notices, security alerts) are sent as part of the contract. Marketing emails go only to adults who opted in, and every one includes an unsubscribe link. We never send marketing to children.
• Legal obligations: tax and accounting records, and responding to lawful requests.

We do not make automated decisions about you or your child that produce legal or similarly significant effects. The AI tutor adapts lessons to your child’s progress; that adaptation is the educational service itself, is always visible in your dashboard, and never affects your rights, pricing, or access.

5. AI processing, plainly explained

ARLOS uses AI systems to teach. When your child speaks at a checkpoint, the audio is converted to text and processed by our AI providers to generate the tutor’s response. Handwriting is processed by vision AI to read the working. Lesson and project generation in ARLOS Studio processes the inputs the parent provides.

Our AI providers act as our processors: they process your family’s data to provide the Service to us, under contracts that prohibit them from using it for their own purposes. We do not permit our providers to train their general models on your family’s identifiable data.

6. Who we share data with

We share personal data only with processors who help us run ARLOS, under data processing agreements:

• AI providers: Anthropic (tutoring language model), OpenAI (handwriting and vision processing), ElevenLabs (voice generation).
• Infrastructure: Supabase (database and storage) and our cloud hosting providers.
• Payments: our payment processor (such as Stripe), which handles card data under PCI-DSS.
• Email: our email service provider, for the communications described above.
• Analytics: privacy-respecting usage analytics as described in Section 9.

We never sell personal data. We never share children’s data with advertisers, data brokers, or social media platforms. We may disclose data if required by law, or in a corporate transaction, in which case this policy continues to apply and you will be notified.

7. International transfers

Some of our processors are located outside the EEA, including in the United States. Where data leaves the EEA, we rely on the EU-US Data Privacy Framework where the provider is certified, and on the European Commission’s Standard Contractual Clauses otherwise, together with technical protections such as encryption in transit and at rest.

8. How long we keep it

• Account and learning data: for as long as your account is active. Mastery history is the product’s memory of your child’s learning, so it stays while you stay.
• Raw voice audio: processed to run the conversation, then retained no longer than 90 days for quality and safety review, after which transcripts remain (reviewable by you) and audio is deleted.
• Deleted accounts: personal data is deleted or anonymised within 30 days of a deletion request, except records we must keep by law.
• Billing records: kept for the period required by Portuguese tax law (currently 10 years), limited to what the law requires.
• Backups: encrypted backups roll off within 35 days.
• Studio Pass and email list: until you unsubscribe or ask us to delete you.

9. Cookies and analytics

Our website uses strictly necessary cookies (login sessions, security) and, with your consent via the cookie banner, analytics cookies that help us understand how the site is used. We do not use advertising cookies, and we do not run third-party ad trackers anywhere a child uses the Service. You can change cookie choices at any time via the banner settings.

10. Leaderboards and community

Global leaderboards display pseudonymous display names by default, never a child’s real name, school, or location (Terms, Section 5.4). Parents choose the display name and can opt a learner out of global leaderboards entirely in the Parent Dashboard. Community channels (such as WhatsApp or Telegram groups) are adult spaces for Account Holders; their platforms’ own privacy policies apply there.

11. Security

Data is encrypted in transit and at rest. Access to personal data is limited to team members who need it to run the Service, under confidentiality obligations. We maintain logging, backups, and incident response procedures. If a breach affects your family’s data, we will notify you and the supervisory authority as required by law.

12. Your rights

You can, at any time: access the data we hold on you or your child; correct it; export it in a portable format; delete it; restrict or object to processing based on legitimate interests; and withdraw consent for children’s data processing. Exercise any of these by emailing support@arlos.school, or use the export and deletion tools in your account. We respond within one month.

You can also complain to a supervisory authority. Ours is the Comissão Nacional de Proteção de Dados (CNPD), Portugal, at cnpd.pt, and you may also contact the authority in your own country.

Parents hold and exercise these rights on behalf of their children. Where a learner asks us directly about their data, we will involve their parent.

13. Changes to this policy

We will notify Account Holders by email at least 30 days before material changes take effect, consistent with Section 1.3 of the Terms. The current version always lives at this page.

14. Contact

Penguin Legion Lda, Lagos, Portugal. Privacy questions: support@arlos.school. Legal notices: hello@arlos.school.