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Privacy Policy

Learn how we collect, use, and protect your data

Modality Learning

Last Updated: March 2026 Version: 2.1

Who We Are

Modality Learning is operated by Modality Learning Ltd
Company Number: 17006152
Registered in: England and Wales
ICO Registration: ZC037607
Data Protection Contact: Email: privacy@modalitylearning.ai

Introduction

This Privacy Notice explains how we collect, use, store, and protect your personal data when you use Modality Learning, an adaptive learning platform.
We take your privacy seriously and are committed to protecting your personal information in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
Please read this notice carefully. By using Modality Learning, you agree to the data practices described here.

What Data We Collect

1. Account Information

  • Email address (required for account creation)
  • Authentication credentials (securely hashed, managed by Firebase Authentication)
  • Account creation date
  • Last login date
  • Authentication method (Google OAuth or username/password)

2. Learning Activity Data

  • Module enrollments: Which courses you're registered for
  • Progress tracking: Topics completed, current progress percentages
  • Interaction history:
    • Questions you answered
    • Explanations you provided
    • Analogies or connections you made
    • Content you viewed and when
    • Time spent on activities
  • Assessment results: Scores, completion dates, attempts

3. Cognitive Modeling Data

Our platform tracks understanding through our "Three C's" framework:
Cover (Understanding):
  • Coverage scores (0-1) indicating demonstrated understanding of facts
  • Quality of explanations provided
  • Accuracy of connections made between concepts
Crystallise (Memory):
  • Stability scores indicating memory strength
  • Review history and timing
  • Predicted optimal review dates
Conquer (Mastery):
  • Assessment attempts and results
  • Mastery status by topic
  • Performance trends over time

4. Behavioral Interaction Data

  • Pages visited and navigation patterns
  • Features used
  • Errors encountered
  • Help requests or support interactions
  • Device type and browser (anonymised)

5. Feedback and Communications

  • Feedback you provide about the platform
  • Support emails or inquiries
  • Survey responses (if you choose to participate)

What We Do NOT Collect

We do not collect:
  • Plain-text passwords (if you use username/password authentication, passwords are securely hashed by Firebase and we never see the actual password)
  • Google password (if you use Google OAuth, we never see your Google password)
  • Precise location data
  • Biometric data
  • Health data (unless you voluntarily include it in responses)
  • Data from other websites or apps

How We Use Your Data

Legal Basis for Processing

We process your personal data under the following legal bases:
1. Consent
  • You explicitly consent to create an account and use the platform
  • You consent to behavior tracking for personalized learning
  • You can withdraw consent at any time
2. Legitimate Interests
  • Improving our platform and algorithms
  • Preventing fraud and abuse
  • Ensuring platform security
  • Conducting research (using anonymised data)

Specific Uses

To Provide the Service:
  • Authenticate your login
  • Track your learning progress
  • Save your place in courses
  • Display your personalized dashboard
To Personalize Your Experience:
  • Recommend next topics based on your progress
  • Schedule spaced repetition reviews
  • Adjust content difficulty to your level
  • Identify knowledge gaps and suggest bridging content
To Improve Our Platform:
  • Analyze interaction patterns to improve algorithms
  • Identify bugs and usability issues
  • Test new features and improvements
  • Train our cognitive modeling systems
To Conduct Research:
  • Study effective learning patterns (anonymised)
  • Publish academic research (you will never be identified)
  • Validate adaptive learning approaches
  • Improve educational technology
To Communicate with You:
  • Send important service updates and notices
  • Request feedback
  • Provide support
  • Notify about account or service changes

Automated Decision-Making

What Decisions Are Automated

Modality Learning uses automated systems to make decisions about your learning experience:
Content Recommendations:
  • Algorithm analyzes your progress and understanding
  • Suggests next topics to study
  • Identifies prerequisite gaps
Review Scheduling:
  • Spaced repetition algorithm calculates optimal review timing
  • Predicts which facts need reinforcement
  • Schedules review sessions
Difficulty Adjustment:
  • System adapts content complexity based on performance
  • Adjusts challenge level to maintain engagement
  • Balances learning pace

Your Rights Regarding Automated Decisions

You have the right to:
  • Explanation - Understand why certain content was recommended or scheduled
  • Alternative access - Use Explore mode to work through content sequentially rather than following AI-driven recommendations
  • Human review - Request your facilitator review your progress or recommendations
Mastery assessments are not AI-generated — they are set by your course facilitator and based on your performance in structured assessments.
To exercise these rights: Contact support@modalitylearning.ai or your course facilitator

How We Share Your Data

Who We Share With

Course Facilitators:
  • Your enrollments and progress in their courses
  • Your assessment results and mastery status
  • Your interaction patterns (to help them improve teaching)
  • Sentiment and engagement insights derived from your interactions (e.g., how you are approaching learning), but NOT your individual messages or explanations (unless the facilitator specifically requests to review them for educational purposes)
Service Providers:
Infrastructure & Hosting:
  • Vercel - Platform hosting and content delivery (data stored in UK/EU region)
  • Firebase (Google) - Authentication, database, and file storage (data stored in UK/EU region)
  • Google Cloud - Document processing and infrastructure (UK/EU region)
Authentication:
  • Firebase Authentication (Google) - Secure account management
  • Google OAuth - Optional sign-in method (subject to Google's privacy policy)
AI & Learning:
  • Vercel AI Gateway - AI model routing and management for Anthropic, OpenAI, and Google models
  • OpenAI - AI-powered tutoring and content generation
  • Anthropic (Claude) - AI-powered content generation and analysis
  • Google AI - AI model services
  • ElevenLabs - Text-to-speech for accessibility features
Analytics & Monitoring:
  • Supabase - Analytics database (with your consent)
  • Google Analytics - Usage analytics (with your consent)
  • Sentry - Error tracking and platform reliability monitoring
Communications:
  • Resend - Transactional emails (invites, notifications)
Each service processes data in accordance with their privacy policies and our Data Processing Agreements.
We do NOT:
  • Sell your data to anyone
  • Share with advertisers
  • Provide to third parties for marketing
  • Share your data with unrelated third parties without consent

International Transfers

  • Primary data storage: UK/EU data centers
  • Some processors may be outside UK/EU but we ensure they provide adequate protection through:
    • Standard Contractual Clauses
    • Adequacy decisions
    • Other approved transfer mechanisms

How Long We Keep Your Data

During Active Use

We keep your data for as long as you actively use the platform and maintain your account.

After You Delete Your Account

If you delete your account:
  • Immediate deletion: We delete personal identifiers within 30 days
  • Anonymised retention: If you consent, we keep anonymised learning patterns for research (no way to identify you)

Inactive Accounts

Accounts inactive for more than 24 months may be:
  • Flagged for review
  • Archived (data retained but account access suspended)
  • Deleted after notification to your registered email

Institutionally Provisioned Accounts

If your account was provisioned by your institution and is subsequently de-provisioned, we will delete your personal data within 90 days unless you contact us to request otherwise.

Legal Obligations

We may retain data longer if:
  • Required by law (e.g., financial records, legal disputes)
  • Necessary to defend legal claims
  • You've consented to longer retention

Your Rights Under UK GDPR

These rights apply regardless of whether you created your own account or your institution provisioned it for you.

Right to Access

Request a copy of all personal data we hold about you.
  • Response time: 30 days
  • Cost: Free

Right to Rectification

Correct inaccurate or incomplete data.
  • Update your email or course enrollment information
  • Correct errors in progress tracking

Right to Erasure ("Right to be Forgotten")

Request deletion of your personal data.
  • We'll delete within 30 days
  • Anonymised research data may be retained
  • Some data may be required for legal purposes

Right to Restriction

Ask us to stop processing your data while issues are resolved.
  • Your account will be frozen
  • Data won't be deleted but won't be used

Right to Data Portability

Receive your data in a structured, machine-readable format.
  • We'll provide JSON or CSV export
  • Includes all your progress and interaction data
  • Can transfer to another platform

Right to Object

Object to processing based on legitimate interests.
  • We'll stop unless we have compelling legitimate grounds
  • You can always object to marketing (though we don't do any)

Right to Withdraw Consent

Withdraw consent at any time.

Right to Lodge a Complaint

Complain to the Information Commissioner's Office (ICO).
ICO Contact:
  • Website: ico.org.uk
  • Helpline: 0303 123 1113
  • Address: Information Commissioner's Office, Wylde House, Water Lane, Wilmslow, Cheshire SK9 5AF

How to Exercise Your Rights

Email us at: privacy@modalitylearning.ai
Include:
  • Subject line stating your request (e.g., "Data Access Request")
  • Your registered email address
  • Specific request details
We will:
  • Verify your identity
  • Respond within 30 days (may extend to 60 days for complex requests)
  • Provide requested information or explain why we can't

Data Security

How We Protect Your Data

Technical Measures:
  • Encryption in transit: HTTPS/TLS for all connections
  • Encryption at rest: Database encryption
  • Access controls: Role-based access, need-to-know basis
  • Regular backups: Automated, encrypted backups
  • Security monitoring: Logging and alerting for suspicious activity
Organizational Measures:
  • Staff training: Team members trained on data protection
  • Confidentiality agreements: All staff sign NDAs
  • Limited access: Only necessary personnel access personal data
  • Regular reviews: Security assessments and updates

Data Breaches

If we discover a data breach that poses high risk to your rights:
  • We'll notify you within 72 hours
  • We'll report to the ICO as required
  • We'll explain what happened and what we're doing about it
  • We'll advise you on protective steps
To report suspected breaches: security@modalitylearning.ai

Children's Privacy

Age Requirements

  • Minimum age: 13 years old
  • Under 18: Parental awareness recommended

Special Protections for Minors

If you're under 18:
  • We use age-appropriate language
  • We limit data collection to essential purposes
  • We don't use data for profiling or marketing
  • Parents can request access to or deletion of their child's data

Parental Rights

If your child is using Modality Learning, you have the right to:
  • Access their data
  • Request correction or deletion
  • Remove them from the platform
  • Ask questions about how data is used
Contact: privacy@modalitylearning.ai with "Parental Inquiry" in subject line

Cookies and Tracking Technologies

What We Use

Essential Cookies:
  • Authentication session (keeps you logged in)
  • Security tokens (prevents CSRF attacks)
  • User preferences (settings you've chosen)
Analytics (with your consent):
  • Anonymised usage statistics
  • Feature adoption tracking
  • Error reporting

Your Choices

Essential cookies: Cannot be disabled (required for platform to function)
Analytics cookies: You can opt out via browser settings or our cookie preferences
We do NOT use:
  • Advertising cookies
  • Social media tracking pixels
  • Cross-site tracking

Cookie Policy

For detailed cookie information, see our Cookie Policy.

Changes to This Privacy Notice

How We Update

We may update this Privacy Notice to reflect:
  • Changes in data processing practices
  • New features or services
  • Legal or regulatory requirements
  • User feedback

How We Notify You

If we make significant changes:
  • We'll email you at your registered address
  • We'll update the "Last Updated" date at the top
  • We'll give you at least 14 days' notice before material changes take effect
  • We'll highlight material changes in the notification
Continued use after the notice period means you accept the updated notice.
If you don't agree with changes, you may close your account.

Research Use of Data

Anonymisation Process

When we use your data for research:
We remove:
  • Names and email addresses
  • Account identifiers
  • Timestamps (replaced with relative times)
  • Any information that could identify you
We retain:
  • Learning patterns and progress trajectories
  • Interaction types and quality
  • Anonymised performance data
  • Aggregated statistics

Research Publications

Your anonymised data may appear in:
  • Academic papers and conferences
  • Internal research reports
  • Public demonstrations (aggregate statistics only)
  • Open datasets (fully anonymised, if released)
You will NEVER be personally identified in any publication.

Opting Out of Research

You can opt out of research use:
  • Email research@modalitylearning.ai with "Opt out of research"
  • We'll flag your account
  • Your data will be used only to provide you the service
  • Doesn't affect your ability to use the platform

Contact Us

Questions or Concerns

If you have any questions about this Privacy Notice or how we handle your data:
Email: privacy@modalitylearning.ai Response time: We aim to respond within 5 working days

Data Protection Contact

Modality Learning Ltd Data Protection Officer privacy@modalitylearning.ai

Company Information

Modality Learning Ltd Company Number: 17006152 Registered in England and Wales
ICO Registration: ZC037607

Summary: Key Points

  • We collect your email, learning progress, and interaction data
  • We use it to personalize your learning and improve the platform
  • We use automated decisions for recommendations and scheduling
  • Your data is encrypted and stored securely in UK/EU
  • You can access, correct, or delete your data anytime
  • Anonymised data may be used for research
  • You can close your account at any time
  • We comply with UK GDPR and Data Protection Act 2018
This Privacy Notice is effective as of the date stated above and applies to all Modality Learning users.
Thank you for trusting us with your data. We take this responsibility seriously.