Privacy Policy

Version 2.0, effective 27 September 2026. Previous version: 13 August 2026.

This policy explains how Scholé handles personal data when you use the Scholé learning platform (app.schole.ai, the sites we run for organisations, and guest lesson links) and when we email you. The Olé browser extension has its own privacy notice at /privacy-browser.

Summary

• We store your data in Switzerland. Product analytics and error monitoring run in the EU.
• AI features send your messages to AI providers. Some of them process data in the United States. We tell you who they are and how the transfer is protected.
• We do not sell your personal information, and we do not use your content to train AI models.
• Scores and mastery estimates are there to help you learn. No decision with legal or similarly significant effects on you is made by AI alone.
• You can download your data and delete your account yourself in Settings. For anything else, write to privacy@schole.ai.

1. Who we are

Two companies operate Scholé:

In this policy "Scholé", "we" and "us" mean the company responsible for you under the table above. This is the same split as in our Terms of Service: it follows your country or, if your account comes from an organisation, that organisation's billing country.

If you signed up on your own (with your email address or Google), that company is the controller of your personal data: it decides why and how your data is used.

If your account comes from your employer, school or another organisation (an invitation, a bulk upload, our Integration API, a launch from your organisation's learning system, or an HR system sync), that organisation is the controller of the data it gives us and of your learning data. We process that data on its behalf and on its instructions, under our Data Processing Agreement. This policy still tells you what we do, but your organisation's own privacy notice applies too, and requests about your data should normally go to your organisation. If you send them to us, we pass them on (see section 9).

Contact. For any privacy question or request, write to privacy@schole.ai. The same address reaches the people at Scholé who handle data protection. We have no establishment in the EU or the UK.

2. What we collect

We do not ask for sensitive data such as health information, religion or political opinions. Please do not type such information into lessons or conversations. If you do, it is processed like the rest of your learning content.

3. Why we use your data and on what legal basis

Under the EU and UK GDPR we need a legal basis for each purpose. Swiss law uses similar principles.

Where we rely on legitimate interest, you can object (section 9). Where we rely on consent, you can withdraw it at any time; this does not affect what happened before you withdrew.

4. AI, scores and automated decisions

You are interacting with AI. Lesson conversations, feedback, role-play characters and Olé are produced by AI systems, not by a person. AI output can contain mistakes.

What the platform works out about you. To adapt your learning, the platform evaluates your answers and conversations. This is profiling:

• Mastery estimates. For each skill in a course's knowledge graph, the platform keeps a probability estimate of how well you have mastered it, updated from your answers. The estimates are formative: they decide what to practise next and they expire if they are not refreshed.
• Role-play grades and feedback. AI grades practice conversations and writes feedback. You see it, and you can try again.
• Scores and progress are shown to you and, if your account comes from an organisation, to that organisation's administrators in dashboards and in exports to their own systems.
• Recommendations and lesson order suggest what to learn next. You can change them. Mandatory lessons are set by your organisation, not by AI.

No decision by AI alone. Scholé does not take decisions that have legal or similarly significant effects on you based only on automated processing. No score by itself grants, refuses or removes anything of consequence, such as a job, pay or access to the service. If your organisation uses your results, that is its decision, made by its people and under its responsibility.

Ask for a human review. If you think an AI grade, score or piece of feedback about you is wrong, write to privacy@schole.ai or to support. A member of our team reviews it and replies with the outcome. You can also tell us your point of view and contest the result.

Training. We do not use your content to train AI models. Requests we send through OpenRouter can only go to the seven model hosts on our allowlist (section 10), none of which keeps or trains on prompts (zero data retention). Some of our other AI providers keep prompts for a limited time, for example to monitor abuse; the sub-processor page shows what each one publishes.

5. Who receives your data

Service providers (sub-processors). We use service providers to host the platform, run AI features, send email and take payments. They may only use your data to provide their service to us. The full, current list, with each provider's country, region of processing, purpose and transfer safeguard, is at app.schole.ai/sub-processors. In short:

We give organisation customers 30 days' notice before we add or replace a sub-processor.

Your organisation. If your account comes from an organisation, its administrators see your progress, scores, mastery and role-play results, and can export them to their own HR or learning systems.

Prolific. If you take part in a research study recruited through Prolific, Prolific receives only your participant ID and whether you completed the study.

Academic research partners. We may share de-identified learning data (names, email addresses and other direct identifiers removed) with academic research partners for the research described in section 3, under a written agreement that limits its use to that research and forbids any attempt to re-identify you. We never share the data of people who have opted out of research, or of organisation-managed accounts whose organisation's agreement with Scholé does not allow it.

Authorities. We disclose personal data to authorities only where the law requires it.

No selling. We do not sell your personal information.

6. Cookies, analytics and your privacy choices

Necessary storage. The platform stores a few items in your browser that it needs to work, such as keeping you signed in, your language and your cookie choice. These do not need your consent.

Analytics only with your consent. On your first visit a banner asks whether you accept analytics. Until you accept, PostHog's analytics script does not load. If you accept:

• PostHog (EU, Frankfurt) receives how you use the platform;
• PostHog also receives the full text of your prompts and of the AI's answers whenever you use an AI feature. This stops as soon as you withdraw consent.

Feedback surveys. At the end of some lessons we show a short PostHog survey. It loads whatever your choice. Your answers are linked to your account only if you accepted analytics; otherwise they are anonymous.

Signup count. When you create an account, we record a signup event in PostHog. Unless you have already accepted analytics, it carries no email address and no identifier that links it to you.

Error monitoring. Sentry (EU, Germany) receives error reports, including technical context such as the request and your IP address, whatever your cookie choice, because we need them to keep the platform secure and working.

Global Privacy Control. If your browser sends a Global Privacy Control (GPC) signal and you have not made a choice yet, we treat it as a refusal of analytics and record it on your account. If you later accept analytics yourself, your own choice applies.

Change your mind at any time. Use Your Privacy Choices on the sign-in and signup pages, Manage cookie preferences on this page in the app, or the privacy card in Settings. Each opens the choice again.

7. Marketing email

We send learning tips and product news by email only if you have said yes: by ticking the box when you sign up, by turning on "Tips & product news" under Profile, Email notifications, or by answering yes when the app asks you. You can withdraw at any time with the unsubscribe link in any of these emails or with the same switch. Withdrawing does not affect emails about your account and your lessons.

We ask account holders we had not asked before 25 September 2026 once, in the app. If you do not say yes, you receive no marketing email.

8. How long we keep your data

We delete or de-identify data when it is no longer needed. A job runs every day and deletes records older than these periods:

When you delete your account. You can delete your account in Settings. We lock it immediately. For 30 days you can still ask support to cancel the deletion; nothing is deleted during that time. After 30 days we erase your identity: your name, email, username, phone number, date of birth, avatar, employer and job details, the AI summaries about you and the assistant's memory of you are overwritten or emptied, and every other copy of your email address in the platform is rewritten. In the same run we delete your person and events from PostHog, cancel any running Stripe subscription and remove your details from the Stripe customer record, and delete your HubSpot contact and support tickets. If a provider cannot be reached, we retry until it confirms.

What stays after erasure. Your conversation and role-play transcripts are kept with your identity removed, for research and product improvement, and are deleted at the end of the normal 2-year period above. We do not rewrite what you typed inside a transcript, so a detail you wrote into a conversation yourself (for example your own name) stays in it until that deletion. Invoices stay with Stripe and in our accounts for the period required by law. Organisation audit logs and consent records stay with your email address removed.

9. Your rights

Depending on where you live, you have some or all of these rights:

• Access: get a copy of your data and information about how we use it.
• Portability: receive the data you gave us in a machine-readable format.
• Correction: fix inaccurate data. You can edit most of your profile yourself.
• Deletion: have your data erased (section 8).
• Restriction: ask us to pause processing while a question is resolved.
• Objection: object to processing based on legitimate interest, and to marketing at any time.
• Opt out of research: stop the use of your data for research at any time, by writing to privacy@schole.ai.
• Withdraw consent for analytics, marketing or a research study, at any time.
• Human review of an AI grade or score (section 4).
• Complain to a data protection authority (see below).

Do it yourself. In Settings you can download your data (Download my data gives you a JSON file with everything linked to your account, once every 24 hours), delete your account, change your email preferences and your cookie choice.

Or write to us at privacy@schole.ai. Requests are free. We reply first within 2 business days. We may ask you to write from the email address of your account, so that we do not give your data to someone else. You can use an authorised agent; we then ask for your signed permission and confirm it with you.

If your account comes from an organisation, the organisation decides on most requests. We tell you that we have passed your request on, and we inform the organisation within 5 business days.

How fast we answer and where you can complain:

If we refuse a request, we tell you why and how you can complain.

10. Where your data is processed and how transfers are protected

• Storage. Your data is stored in Switzerland, in Microsoft Azure's Switzerland North region, with backup copies in Switzerland.
• Analytics and error monitoring run in the EU: PostHog in Frankfurt, Sentry in Germany. Text extraction from uploaded documents runs in the EU (West Europe).
• AI features. To answer you, we send your messages and the context the lesson needs (for example your role and goals) to AI providers:
  • Microsoft Azure OpenAI and Azure AI Foundry. Our accounts are in the United States and Switzerland, and most of our models are deployed globally, so a request may be processed in any Azure region in the world, including the United States. Data at rest stays in the account's region.
  • OpenRouter (United States), which may send a request only to the seven model hosts on our allowlist: Cerebras, Groq, SambaNova, Nebius, Microsoft Azure, Google Vertex AI and Amazon Bedrock. Each is headquartered in the United States or the EU and keeps no prompts (zero data retention). They may serve a request from any of their regions: Microsoft, Google and Amazon from regions worldwide, some also from Canada, and Groq also from Saudi Arabia; OpenRouter does not say which region serves a given request.
  • Speech-to-text by Groq and OpenAI, and some text-to-speech by OpenAI, in the United States. Other text-to-speech runs on Microsoft Azure as described above.
• EU-only AI processing. We are introducing EU-only processing of AI requests for customers in the EU, Switzerland and the UK. Until it is switched on for your organisation, the paragraph above applies.
• Other providers in the United States include HubSpot, Google Workspace, Mercury and GitHub (section 5).

Switzerland and the EU recognise each other's level of data protection, and both recognise the UK. When data goes to the United States or another country without such recognition, we rely on the European Commission's Standard Contractual Clauses, with the UK Addendum for UK data and the Swiss addendum for Swiss data, and on the EU-U.S. Data Privacy Framework (and its UK and Swiss extensions) where a provider is certified. The safeguard for each provider is on the sub-processor page. You can ask for a copy at privacy@schole.ai.

11. Children

Scholé is not intended for anyone under 16. When you create an account, we ask you to confirm that you are 16 or older, and we keep a record of that confirmation, with its date and the version of this policy in force, as evidence that you gave it. Accounts created for you by your employer or school also ask you to confirm your age the first time you sign in. Organisations that set up accounts through our Integration API cannot create an account for anyone whose date of birth shows they are under 16, and we do not store that date of birth. If you believe someone under 16 has an account, contact privacy@schole.ai.

12. Security

• Data is encrypted in transit (TLS) and at rest.
• The platform runs on a private Kubernetes cluster in Microsoft Azure, behind a web application firewall. The database accepts only private network connections, and public access to file storage is disabled.
• Staff accounts for Google Workspace and GitHub require multi-factor authentication.
• Security logs are kept for 365 days.
• Our ISO 27001 audit is completed and the certificate is pending. Our SOC 2 Type 1 audit is in progress.
• If a data breach affects you, we notify the authorities and you where the law requires it.

No system is perfectly secure, but we work to protect your data and review our measures regularly.

13. Additional information for California residents

This section applies to Scholé Inc. and California residents, under the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA).

Categories we collect (section 2 has examples): identifiers (name, email, IP address, account ID); customer records (billing email, phone number); commercial information (plan and subscription history); internet or network activity (use of the platform); audio (voice in voice features, not stored); professional or employment information (job title, company, department); inferences (mastery estimates, recommendations, AI summaries); and sensitive personal information limited to your account login (email and password). We collect it from you, your organisation, Google (if you sign in with Google), Prolific (for study participants) and your use of the platform.

Purposes. The purposes in section 3. We use sensitive personal information only to provide the service and keep it secure, not to infer characteristics about you.

Disclosure. We disclose these categories to the service providers in section 5, for the business purposes in section 3, and to your organisation if it provides your account.

No sale. We do not sell your personal information. If any of our analytics counted as "sharing" for cross-context behavioural advertising under the CCPA, turning analytics off opts you out of it. We honour Global Privacy Control signals as that opt-out (section 6), and the Your Privacy Choices link lets you opt out at any time.

Retention. Section 8.

Your rights. To know what we collect and disclose, to delete, to correct, and to opt out of sale or sharing. Because we use sensitive personal information only to provide the service and keep it secure, there is no further use of it to limit. Use Settings or write to privacy@schole.ai; section 9 explains verification, authorised agents and response times. We will not discriminate against you for using these rights.

14. Additional information for the United Kingdom

For UK users, "GDPR" in this policy means the UK GDPR and the Data Protection Act 2018. Scholé Sàrl is responsible for you (section 1). Transfers from the UK to countries without UK adequacy regulations use the UK Addendum to the Standard Contractual Clauses (section 10). You can complain to the Information Commissioner's Office (ico.org.uk).

15. Additional information for Switzerland

For Swiss users, Scholé Sàrl in Lausanne is responsible for your data under the Federal Act on Data Protection (FADP). Your data may be disclosed to recipients in the EEA (Germany, Ireland, the Netherlands, Poland), the United Kingdom and the United States, and, for AI requests on globally deployed Azure models, to any country where Microsoft runs Azure OpenAI, and, for AI requests routed through OpenRouter, to the countries its allowlisted hosts serve from (section 10), including Canada and Saudi Arabia. Disclosures to countries the Federal Council does not recognise as adequate, such as the United States, rely on the Standard Contractual Clauses with the Swiss addendum, or on the Swiss-U.S. Data Privacy Framework where a provider is certified. You can complain to the Federal Data Protection and Information Commissioner (edoeb.admin.ch).

16. Additional information for Canada

For Canadian users, the Personal Information Protection and Electronic Documents Act (PIPEDA) applies. Scholé Inc. is accountable for your personal information (section 1); if your account comes from an organisation, that organisation is accountable for the data it gives us. Our privacy contact is privacy@schole.ai. We collect, use and disclose your information for the purposes in section 3, with your consent: by creating an account you agree to the processing needed to provide the service, and we ask separately before analytics, marketing email and research studies. You can withdraw consent at any time, subject to legal or contractual limits.

Your information is stored in Switzerland and processed in Switzerland, the EU and the United States (section 10), where it may be accessible to courts and authorities under local law. Organisations that need their data kept in Canada can choose Canadian data residency as a paid option. You can access and correct your information (section 9) and complain to the Office of the Privacy Commissioner of Canada (priv.gc.ca).

17. Changes to this policy

When we change this policy, we publish the new version here with a new date and version number. When a change matters for how we use your data, we tell you in the app and ask you to review the new version before you continue.

18. Contact

Email: privacy@schole.ai

Post: Scholé Sàrl, EPFL, Bâtiment INF, Station 14, 1015 Lausanne, Switzerland, or, for customers and learners outside Switzerland, the EEA and the United Kingdom, Scholé Inc., 1209 Orange Street, Wilmington, Delaware 19801, USA.