Data Processing Agreement

A school that uses voice.school with its students is the data controller for the students' personal data, and we are the data processor. This agreement covers that processing. It follows the Danish Data Protection Agency's (Datatilsynet) template of standard contractual clauses under Article 28(3) GDPR (January 2020 version), with our choices and the appendices filled in. The Danish version is the original; this English version is a translation.

How to accept or sign

The agreement is made between your school's legal entity and Edaptio II ApS. For a Danish public school (folkeskole), the legal entity is usually the municipality. Choose one of two ways:

1. Sign it. Print this page or save it as a PDF (see the top of the page), fill in your school's details in clauses 14.5 and 15, sign it and email the signed copy to privacy@edaptio.com. We countersign and send it back.

2. Accept by email on behalf of the school. If you are authorised to enter agreements for your school, for example as head teacher or as head of IT or data protection, send an email to privacy@edaptio.com from your school email address with:

the school's legal name, CVR number (or EAN or institution number) and address
your name and job title
a contact person for data protection matters, with name and email address
this sentence: "We accept the voice.school data processing agreement, version of 3 November 2026, on behalf of [the school's name]."

We confirm by email, normally within two working days. The agreement takes effect on the date of our confirmation. Your email, our confirmation and this version of the text together make up the signed agreement (see Appendix D).

If you are a teacher and cannot sign for your school, send this page to your school leadership or your data protection officer. If your school or municipality uses its own data processing agreement, send it to us and we will look at it.

Standard Contractual Clauses

for the purposes of compliance with Article 28(3) of Regulation 2016/679 (the GDPR) for the processing of personal data by the data processor

between

the data controller: the school or other legal entity named in clause 14.5 or in its acceptance email

and

the data processor:
Edaptio II ApS
CVR 43660578
H.C. Andersens Boulevard 33, 4. th.
1553 København V
Denmark

each a "party"; together "the parties"

HAVE AGREED on the following Contractual Clauses (the Clauses) in order to meet the requirements of the GDPR and to ensure the protection of the privacy and fundamental rights and freedoms of natural persons.

1. Contents

Preamble
The rights and obligations of the data controller
The data processor acts according to instructions
Confidentiality
Security of processing
Use of sub-processors
Transfer of data to third countries or international organisations
Assistance to the data controller
Notification of personal data breach
Erasure and return of data
Audit and inspection
The parties' agreement on other terms
Commencement and termination
Data controller and data processor contacts

Appendix A: Information about the processing
Appendix B: Authorised sub-processors
Appendix C: Instruction pertaining to the use of personal data
Appendix D: The parties' terms of agreement on other subjects

2. Preamble

These Contractual Clauses (the Clauses) set out the rights and obligations of the data processor when processing personal data on behalf of the data controller.
The Clauses have been designed to ensure the parties' compliance with Article 28(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
In the context of the provision of voice.school, a service for spoken and written assignments in teaching, the data processor will process personal data on behalf of the data controller in accordance with the Clauses.
The Clauses shall take priority over any similar provisions contained in other agreements between the parties.
Four appendices are attached to the Clauses and form an integral part of the Clauses.
Appendix A contains details about the processing of personal data, including the purpose and nature of the processing, the type of personal data, the categories of data subject and the duration of the processing.
Appendix B contains the data controller's conditions for the data processor's use of sub-processors and a list of sub-processors authorised by the data controller.
Appendix C contains the data controller's instructions with regard to the processing of personal data, the minimum security measures to be implemented by the data processor and how audits of the data processor and any sub-processors are to be performed.
Appendix D contains provisions for other activities which are not covered by the Clauses.
The Clauses along with the appendices shall be retained in writing, including electronically, by both parties.
The Clauses shall not exempt the data processor from obligations to which the data processor is subject pursuant to the General Data Protection Regulation (the GDPR) or other legislation.

3. The rights and obligations of the data controller

The data controller is responsible for ensuring that the processing of personal data takes place in compliance with the GDPR (see Article 24 GDPR), the applicable EU or Member State data protection provisions and the Clauses. References to "Member States" in the Clauses shall be understood as references to "EEA Member States".
The data controller has the right and obligation to make decisions about the purposes and means of the processing of personal data.
The data controller shall be responsible, among other things, for ensuring that the processing of personal data which the data processor is instructed to perform has a legal basis.

4. The data processor acts according to instructions

The data processor shall process personal data only on documented instructions from the data controller, unless required to do so by Union or Member State law to which the processor is subject. Such instructions shall be specified in Appendices A and C. Subsequent instructions can also be given by the data controller throughout the duration of the processing of personal data, but such instructions shall always be documented and kept in writing, including electronically, in connection with the Clauses.
The data processor shall immediately inform the data controller if instructions given by the data controller, in the opinion of the data processor, contravene the GDPR or the applicable EU or Member State data protection provisions.

5. Confidentiality

The data processor shall only grant access to the personal data being processed on behalf of the data controller to persons under the data processor's authority who have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality, and only on a need-to-know basis. The list of persons to whom access has been granted shall be kept under periodic review. On the basis of this review, such access to personal data can be withdrawn if access is no longer necessary, and the personal data shall then no longer be accessible to those persons.
The data processor shall, at the request of the data controller, demonstrate that the persons concerned under the data processor's authority are subject to the abovementioned confidentiality.

6. Security of processing

Article 32 GDPR stipulates that, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, the data controller and data processor shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk.
The data controller shall evaluate the risks to the rights and freedoms of natural persons inherent in the processing and implement measures to mitigate those risks. Depending on their relevance, the measures may include the following:
a. pseudonymisation and encryption of personal data
b. the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services
c. the ability to restore the availability of and access to personal data in a timely manner in the event of a physical or technical incident
d. a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.
According to Article 32 GDPR, the data processor shall also, independently of the data controller, evaluate the risks to the rights and freedoms of natural persons inherent in the processing and implement measures to mitigate those risks. To this effect, the data controller shall provide the data processor with all information necessary to identify and evaluate such risks.
Furthermore, the data processor shall assist the data controller in ensuring compliance with the data controller's obligations pursuant to Article 32 GDPR, by inter alia providing the data controller with information concerning the technical and organisational measures already implemented by the data processor pursuant to Article 32 GDPR, along with all other information necessary for the data controller to comply with its obligation under Article 32 GDPR.
If, in the assessment of the data controller, mitigation of the identified risks requires further measures than those already implemented by the data processor, the data controller shall specify these additional measures in Appendix C.

7. Use of sub-processors

The data processor shall meet the requirements specified in Article 28(2) and (4) GDPR in order to engage another processor (a sub-processor).
The data processor shall therefore not engage another processor (sub-processor) for the fulfilment of the Clauses without the prior general written authorisation of the data controller.
The data processor has the data controller's general authorisation for the engagement of sub-processors. The data processor shall inform the data controller in writing of any intended changes concerning the addition or replacement of sub-processors at least 30 days in advance, thereby giving the data controller the opportunity to object to such changes prior to the engagement of the sub-processor(s) concerned. Longer periods of prior notice for specific sub-processing services can be provided in Appendix B. The list of sub-processors already authorised by the data controller can be found in Appendix B.
Where the data processor engages a sub-processor for carrying out specific processing activities on behalf of the data controller, the same data protection obligations as set out in the Clauses shall be imposed on that sub-processor by way of a contract or other legal act under EU or Member State law, in particular providing sufficient guarantees to implement appropriate technical and organisational measures in such a manner that the processing will meet the requirements of the Clauses and the GDPR.
The data processor shall therefore be responsible for requiring that the sub-processor at least complies with the obligations to which the data processor is subject pursuant to the Clauses and the GDPR.
A copy of such a sub-processor agreement and subsequent amendments shall, at the data controller's request, be submitted to the data controller, thereby giving the data controller the opportunity to ensure that the same data protection obligations as set out in the Clauses are imposed on the sub-processor. Clauses on commercial terms that do not affect the data protection content of the sub-processor agreement shall not require submission to the data controller.
The data processor shall agree a third-party beneficiary clause with the sub-processor whereby, in the event of the bankruptcy of the data processor, the data controller shall be a third-party beneficiary to the sub-processor agreement and shall have the right to enforce the agreement against the sub-processor engaged by the data processor, e.g. enabling the data controller to instruct the sub-processor to delete or return the personal data.
If the sub-processor does not fulfil its data protection obligations, the data processor shall remain fully liable to the data controller for the fulfilment of the obligations of the sub-processor. This does not affect the rights of the data subjects under the GDPR, in particular those foreseen in Articles 79 and 82 GDPR, against the data controller and the data processor, including the sub-processor.

8. Transfer of data to third countries or international organisations

Any transfer of personal data to third countries or international organisations by the data processor shall only occur on the basis of documented instructions from the data controller and shall always take place in compliance with Chapter V GDPR.
In case transfers to third countries or international organisations which the data processor has not been instructed to perform by the data controller are required under EU or Member State law to which the data processor is subject, the data processor shall inform the data controller of that legal requirement prior to processing, unless that law prohibits such information on important grounds of public interest.
Without documented instructions from the data controller, the data processor therefore cannot, within the framework of the Clauses:
a. transfer personal data to a data controller or a data processor in a third country or in an international organisation
b. transfer the processing of personal data to a sub-processor in a third country
c. have the personal data processed by the data processor in a third country.
The data controller's instructions regarding the transfer of personal data to a third country, including, if applicable, the transfer tool under Chapter V GDPR on which they are based, shall be set out in Appendix C.6.
The Clauses shall not be confused with standard data protection clauses within the meaning of Article 46(2)(c) and (d) GDPR, and the Clauses cannot be relied upon by the parties as a transfer tool under Chapter V GDPR.

9. Assistance to the data controller

Taking into account the nature of the processing, the data processor shall assist the data controller by appropriate technical and organisational measures, insofar as this is possible, in the fulfilment of the data controller's obligations to respond to requests for exercising the data subject's rights laid down in Chapter III GDPR.
This entails that the data processor shall, insofar as this is possible, assist the data controller in the data controller's compliance with:
a. the right to be informed when collecting personal data from the data subject
b. the right to be informed when personal data have not been obtained from the data subject
c. the right of access by the data subject
d. the right to rectification
e. the right to erasure ("the right to be forgotten")
f. the right to restriction of processing
g. the notification obligation regarding rectification or erasure of personal data or restriction of processing
h. the right to data portability
i. the right to object
j. the right not to be subject to a decision based solely on automated processing, including profiling.
In addition to the data processor's obligation to assist the data controller pursuant to Clause 6.3, the data processor shall furthermore, taking into account the nature of the processing and the information available to the data processor, assist the data controller in ensuring compliance with:
a. the data controller's obligation to notify a personal data breach without undue delay and, where feasible, not later than 72 hours after having become aware of it, to the competent supervisory authority, Datatilsynet (the Danish Data Protection Agency), or the supervisory authority competent for the data controller if that is another authority, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons
b. the data controller's obligation to communicate the personal data breach to the data subject without undue delay when the breach is likely to result in a high risk to the rights and freedoms of natural persons
c. the data controller's obligation to carry out an assessment of the impact of the envisaged processing operations on the protection of personal data (a data protection impact assessment)
d. the data controller's obligation to consult the competent supervisory authority, Datatilsynet or the supervisory authority competent for the data controller, prior to processing where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the data controller to mitigate the risk.
The parties shall define in Appendix C the appropriate technical and organisational measures by which the data processor is required to assist the data controller, as well as the scope and extent of the assistance required. This applies to the obligations foreseen in Clauses 9.1 and 9.2.

10. Notification of personal data breach

In case of any personal data breach, the data processor shall, without undue delay after having become aware of it, notify the data controller of the personal data breach.
The data processor's notification to the data controller shall, if possible, take place within 48 hours after the data processor has become aware of the personal data breach, to enable the data controller to comply with its obligation to notify the personal data breach to the competent supervisory authority, cf. Article 33 GDPR.
In accordance with Clause 9.2.a, the data processor shall assist the data controller in notifying the personal data breach to the competent supervisory authority, meaning that the data processor is required to assist in obtaining the information listed below which, pursuant to Article 33(3) GDPR, shall be stated in the data controller's notification to the competent supervisory authority:
a. the nature of the personal data breach, including where possible the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned
b. the likely consequences of the personal data breach
c. the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.
The parties shall define in Appendix C all the elements to be provided by the data processor when assisting the data controller in the notification of a personal data breach to the competent supervisory authority.

11. Erasure and return of data

On termination of the provision of personal data processing services, the data processor shall be under obligation to delete all personal data processed on behalf of the data controller and certify to the data controller that it has done so, unless Union or Member State law requires storage of the personal data.
Not applicable: no Union or Member State law requires the data processor to store the personal data after the termination of the services.

12. Audit and inspection

The data processor shall make available to the data controller all information necessary to demonstrate compliance with the obligations laid down in Article 28 GDPR and the Clauses, and allow for and contribute to audits, including inspections, conducted by the data controller or another auditor mandated by the data controller.
Procedures applicable to the data controller's audits, including inspections, of the data processor and sub-processors are specified in Appendices C.7 and C.8.
The data processor shall be required to provide the supervisory authorities, which pursuant to applicable legislation have access to the data controller's and data processor's facilities, or representatives acting on behalf of such supervisory authorities, with access to the data processor's physical facilities on presentation of appropriate identification.

13. The parties' agreement on other terms

The parties may agree other clauses concerning the provision of the personal data processing service specifying e.g. liability, as long as they do not contradict directly or indirectly the Clauses or prejudice the fundamental rights or freedoms of the data subject and the protection afforded by the GDPR.

14. Commencement and termination

The Clauses shall become effective on the date of both parties' signature.
Both parties shall be entitled to require the Clauses renegotiated if changes to the law or inexpediency of the Clauses should give rise to such renegotiation.
The Clauses shall apply for the duration of the provision of personal data processing services. For the duration of the provision of personal data processing services, the Clauses cannot be terminated unless other clauses governing the provision of personal data processing services have been agreed between the parties.
If the provision of personal data processing services is terminated, and the personal data is deleted or returned to the data controller pursuant to Clause 11.1 and Appendix C.4, the Clauses may be terminated by written notice by either party.
Signature

	On behalf of the data controller	On behalf of the data processor
Organisation		Edaptio II ApS
Name		Andreas Piculell
Position		Director (direktør)
Telephone
Email		privacy@edaptio.com
Date
Signature

15. Data controller and data processor contacts

The parties may contact each other using the following contacts:
The parties shall be under obligation continuously to inform each other of changes to contacts.

	Data controller	Data processor
Name		Andreas Piculell
Position		Director (direktør)
Telephone
Email		privacy@edaptio.com

Appendix A: Information about the processing

A.1. The purpose of the data processor's processing of personal data on behalf of the data controller is:

To provide voice.school to the data controller's teachers and students. Teachers create classes and assignments. Students answer the questions by voice recording in the browser, or in writing where the assignment allows it. The answers are transcribed automatically. Teachers review the answers, transcripts and integrity signals and give grades and feedback. Users receive emails about their account and their assignments. In addition: to operate, secure and support the service, and to produce pseudonymised statistics on how the service is used.

A.2. The data processor's processing of personal data on behalf of the data controller shall mainly pertain to (the nature of the processing):

Collection (recording in the student's browser and upload), storage, structuring, automated transcription (speech to text) with an AI model, display to the teacher and the student concerned, sending of emails, logging of integrity events, backup and erasure, including automatic erasure under the retention rules in Appendix C.4.

A.3. The processing includes the following types of personal data about data subjects:

Students:

account data: name, email address, password (stored only as a hash), Google account ID if the student signs in with Google, preferred language, notification setting, and when the account was created and last used
class membership: which classes, and when the student joined or was removed
voice recordings of answers (audio) and their length
typed answers
automatic transcripts of the recordings
progress: which questions the student was given, and when the student started, answered and completed
grades, written feedback and comments from the teacher
integrity events: switching away from the tab or window and for how long, blocked paste attempts, copy attempts, blocked right-clicks, and the microphone being muted, unmuted or disconnected, each with the time and the question
technical data in logs: IP address and browser and device information

Teachers and other staff using the service for the data controller:

account data as above
the content they create: classes, assignments, questions, grades, feedback and comments

The processing is not intended to include special categories of personal data (Article 9 GDPR) or data about criminal offences (Article 10 GDPR). Recordings are not processed to identify anyone by their voice. Students may still mention such information in their answers; the data controller is responsible for designing assignments that do not ask for it, unless the data controller has a legal basis for doing so.

A.4. Processing includes the following categories of data subjects:

Students (pupils) at the data controller, including children, and teachers and other staff at the data controller who use the service.

A.5. The data processor's processing of personal data on behalf of the data controller may be performed when the Clauses commence. Processing has the following duration:

The processing lasts for as long as the data controller uses voice.school, and ends when the data has been deleted under Clause 11 and Appendix C.4.

Appendix B: Authorised sub-processors

B.1. Approved sub-processors

On commencement of the Clauses, the data controller authorises the engagement of the following sub-processors:

Name	Address	Description of processing	Location
Amazon Web Services EMEA SARL	38 Avenue John F. Kennedy, L-1855 Luxembourg	Database (Amazon Aurora PostgreSQL) with all account and class data, and its backups; storage of voice recordings (Amazon S3); sending of emails (Amazon SES)	Frankfurt, Germany (database and recordings); Ireland (email)
Cloudflare, Inc.	101 Townsend Street, San Francisco, CA 94107, USA	Hosting and running of the website and the API (Cloudflare Workers), the queue for transcription jobs, the connection to the database (Hyperdrive, through a tunnel protected by Cloudflare Access), content delivery, DNS, TLS and protection against attacks; short-lived technical logs	Cloudflare's global network; each request is handled in a data centre near the user
PostHog Inc.	2261 Market Street #4008, San Francisco, CA 94114, USA	Pseudonymised product analytics: events without names, email addresses, recordings, transcripts or answers	EU cloud, Frankfurt, Germany

On commencement of the Clauses, the data controller authorises the engagement of the abovementioned sub-processors for the processing described for that party. The data processor shall not be entitled, without the data controller's explicit written authorisation, to engage a sub-processor for a different processing than the one agreed upon, or to have another sub-processor perform the described processing.

B.2. Prior notice for the authorisation of sub-processors

The data processor gives notice of changes by email to the data controller's contact person (Clause 15) at least 30 days before a new sub-processor starts processing, and updates the sub-processor list. If the data controller objects on reasonable grounds and the parties cannot find a solution, the data controller may stop using the service and have its data deleted under Clause 11.

Appendix C: Instruction pertaining to the use of personal data

C.1. The subject of/instruction for the processing

The data processor's processing of personal data on behalf of the data controller shall be carried out by the data processor performing the following:

storing the data and showing it to the data controller's teachers and students as the functions of the service require: a teacher sees the classes the teacher created and the students' work in them; a student sees their own work and, once it is returned, the grade and feedback
having each voice recording transcribed automatically by an AI model and storing the transcript
logging integrity events while a student answers and showing them to the teacher
sending emails about the account (email confirmation, password reset, warning before deletion) and notifications (new assignment, returned feedback, reminder 24 hours before a deadline), which each user can switch off
deleting data under Appendix C.4 and when users delete it
producing pseudonymised usage statistics (product analytics) without names, email addresses, recordings, transcripts or answer content
looking at data only when needed to answer a request from the data controller's users or to fix an error
logging and monitoring to protect the service

The data processor does not use the data for any other purpose. In particular, it does not sell the data, does not use it for marketing or advertising, and does not use it to train AI models.

C.2. Security of processing

The level of security shall take into account that the processing concerns data about children, including voice recordings and information about their schoolwork and their behaviour during assignments (integrity signals). By design it does not include special categories of personal data. A high level of security is therefore required.

The data processor shall hereafter be entitled and under obligation to make decisions about the technical and organisational security measures that are to be applied to create the necessary (and agreed) level of data security.

The data processor shall however, in any event and at a minimum, implement the following measures that have been agreed with the data controller:

Pseudonymisation and encryption. The database, including its backups, is encrypted at rest (AES-256, managed by AWS). Voice recordings are encrypted at rest with S3 server-side encryption (AES-256) and are stored under random identifiers, not under names. Passwords are stored only as bcrypt hashes, and login refresh tokens only as hashes. Product analytics are pseudonymised.

Ongoing confidentiality, integrity, availability and resilience. Every request is checked against the logged-in user: a teacher can only reach the teacher's own classes, and a student only their own answers. Logins use short-lived access tokens (30 minutes) and rotating refresh tokens (30 days) that can be revoked. Login, signup and password reset are rate limited. Google sign-in requires a verified email address and is protected against forged requests. Administrative access to the production systems (AWS, Cloudflare and the database) is limited to named persons at the data processor, using personal accounts. The service runs on managed platforms with built-in redundancy (Cloudflare Workers, Amazon Aurora and Amazon S3).

Timely restoration after an incident. The database is backed up automatically, with point-in-time recovery, and the encrypted backups are kept for 14 days. Amazon S3 stores the recordings redundantly across several data centres.

Regular testing, assessment and evaluation. Automated tests (unit, integration and end-to-end) run on every change, and a production smoke test runs after deployments that affect uploads, transcription, email or deletion. Dependencies are kept up to date. The data processor reviews these measures at least once a year and after significant changes.

Access via the internet. The service can only be reached over HTTPS. The database is not open to the internet. The service connects to it only through Cloudflare Hyperdrive over a tunnel protected by Cloudflare Access. The database server's firewall accepts connections only from a few named servers in the data processor's AWS environment and from one named administrator IP address, and the voice.school data is kept in a separate database with its own credentials. Recordings are kept in a non-public storage bucket and are uploaded and played through signed links that expire after one hour.

Protection of data during transmission. TLS between the browser and the service, between the service and the database, and to AWS and PostHog.

Protection of data during storage. See encryption above. The database and recordings are stored in EU regions, and access is limited as described above.

Physical security of locations where data is processed. The data processor has no physical servers of its own. Everything runs in data centres operated by AWS and Cloudflare, whose physical security is covered by their ISO/IEC 27001 certifications and SOC 2 reports.

Home and remote working. The data processor's staff work remotely. They access production systems only with personal accounts over encrypted connections. Personal data is not kept on local computers, except temporarily when a specific task requires it (for example a support request), and is deleted afterwards. Computers used for the work have disk encryption and a screen lock.

Logging. Requests and errors are logged by the hosting platform for troubleshooting and security and kept for at most 30 days. Deletions of recordings are recorded in the database, and pending deletions of files are kept in a queue until they have been carried out.

C.3. Assistance to the data controller

The data processor shall, insofar as this is possible and within the scope and extent of the assistance specified below, assist the data controller in accordance with Clauses 9.1 and 9.2 by implementing the following technical and organisational measures:

Self-service in the app. Teachers can see all data about their students in their own classes and can delete a submission, an assignment or a class. Every user can change their name and language and delete their own account in Settings.
Requests the app does not cover. On request from the data controller to privacy@edaptio.com, the data processor helps with access to and copies of a student's data (recordings, transcripts, typed answers, grades, feedback and integrity events, in a common format), correction, restriction and deletion, without undue delay and at the latest within 10 working days.
Requests from data subjects. If a data subject contacts the data processor directly about the data controller's data, the data processor forwards the request to the data controller without undue delay and does not answer it itself unless the data controller asks it to.
Personal data breaches. The data processor notifies the data controller under Clause 10 by email to the contact person in Clause 15 and provides, as far as it is available: what happened and when; which data and roughly how many students and teachers are affected; the likely consequences; what the data processor has done and proposes to do; and a contact person. The information may be provided in stages as it becomes available.
Impact assessments and prior consultation. The data processor provides a description of the processing, the data flows, the sub-processors and the security measures, which the data controller can use in its data protection impact assessment, and answers the data controller's questions.
While the service is free to use, this assistance is also free of charge.

C.4. Storage period/erasure procedures

Voice recordings are deleted automatically 12 months after they were recorded. A storage rule also deletes any recording still left after 372 days.
Transcripts, typed answers, grades, feedback, comments and integrity events are kept until a teacher deletes the submission, assignment or class, or until the account they belong to is deleted.
Accounts that nobody has logged into for 24 months are deleted with all their data. The user is warned by email 30 days in advance.
Deleting a teacher account deletes the teacher's classes and all students' work in them. A student account can belong to classes at several schools; it is deleted when the student deletes it or after 24 months without use.
Expired login tokens, signup confirmations and password reset links are deleted daily. Sent notification emails are deleted after 30 days.
Deleted data disappears from the database backups within 14 days.
On termination of the service, the data processor deletes the data controller's data within 30 days and confirms the deletion in writing. This covers the teacher accounts the data controller names, with their classes, assignments, submissions, recordings, transcripts and integrity events, and the student accounts that as a result no longer belong to any class. If the data controller asks before termination, the data processor first hands over a copy of the data in a common format.

C.5. Processing location

Processing of the personal data under the Clauses cannot be performed at other locations than the following without the data controller's prior written authorisation:

Amazon Web Services: region eu-central-1 (Frankfurt, Germany) for the database, its backups and voice recordings; region eu-west-1 (Ireland) for the sending of emails
Cloudflare: Cloudflare's global network, where each request is handled in a data centre near the user
PostHog: EU cloud, Frankfurt, Germany
The data processor: Denmark (remote access by its staff)

C.6. Instruction on the transfer of personal data to third countries

The data controller instructs the data processor to use the sub-processors in Appendix B, which may involve the following transfers to third countries:

Cloudflare, Inc. (USA). Requests and technical data may be handled in data centres outside the EU and accessed by Cloudflare in the USA for support and security. Transfer tool: the EU-US Data Privacy Framework (Commission Implementing Decision (EU) 2023/1795), under which Cloudflare, Inc. is certified, and otherwise the European Commission's standard contractual clauses (Decision (EU) 2021/914) in Cloudflare's data processing addendum.
PostHog Inc. (USA). Analytics data is stored in the EU. Any access from outside the EU is covered by the standard contractual clauses in PostHog's data processing agreement.
Amazon Web Services. Data is stored in the EU regions in C.5. Any access from outside the EU is covered by the EU-US Data Privacy Framework and by the standard contractual clauses in the AWS data processing addendum.

If the data controller does not in the Clauses or subsequently provide documented instructions pertaining to the transfer of personal data to a third country, the data processor shall not be entitled within the framework of the Clauses to perform such transfer.

C.7. Procedures for the data controller's audits, including inspections, of the processing of personal data being performed by the data processor

Once a year, the data controller may ask the data processor for a written statement on how it complies with the GDPR and the Clauses, covering the measures in C.2, the sub-processors used and any personal data breaches in the period. The data processor sends the statement within 30 days and free of charge. While the service is free to use, the data processor does not obtain an independent auditor's report (such as an ISAE 3000 report); if the data controller requires one, the parties agree on its scope, and the data controller pays for it.

Based on the statement, the data controller may request further measures to ensure compliance with the GDPR, the applicable EU or Member State data protection provisions and the Clauses.

The data controller or its representative may also carry out an inspection, including a physical inspection, of the locations from which the data processor processes personal data, when the data controller considers it necessary, with at least 30 days' notice. The data controller pays its own costs. The data processor sets aside the time needed for the inspection.

C.8. Procedures for audits, including inspections, of the processing of personal data being performed by sub-processors

The sub-processors in Appendix B are large providers that do not let individual customers audit or inspect them. The data processor therefore supervises them by reviewing, at least once a year, their independent audit reports and certifications (for example ISO/IEC 27001 certificates and SOC 2 Type II reports) and their data processing terms. On request, the data processor gives the data controller documentation of this review and the certifications the sub-processors make available.

Appendix D: The parties' terms of agreement on other subjects

Acceptance by email. The data controller can accept the Clauses by signing them (Clause 14.5) or by email, as described at the top of this page. In the latter case, the data controller's acceptance email and the data processor's written confirmation together count as both parties' signature, and the Clauses take effect on the date of the confirmation.
Versions. The Clauses apply in the version the data controller accepted. A new version applies only once both parties have accepted it. The data processor keeps a copy of every version.
Unlawful instructions (Clause 4.2). If the data processor considers an instruction unlawful, it may suspend the processing the instruction concerns until the data controller has confirmed, changed or withdrawn it.
Relation to the Terms of Service. For the data controller's personal data, the Clauses take precedence over the voice.school Terms of Service.
Costs. While the service is free to use, the data processor's assistance under Clauses 9 and 10 and Appendices C.3 and C.7 is free of charge.
Liability. The parties' liability follows the general rules of Danish law. This does not limit the rights of data subjects under Article 82 GDPR.
Governing law and venue. The Clauses are governed by Danish law. Disputes go to the Danish courts, with the Copenhagen City Court (Københavns Byret) as the first instance.