Privacy Policy

1. Who this policy covers

This Privacy Policy applies to Gagner Solutions Limited ("Gagner," "we," "us"), our website at gagnerapp.com, and Gagner for Schools. As we launch Gagner for Agriculture and Gagner for Health, each will be added to this policy with any product-specific practices called out separately, because the data involved (farm operational data, health information) carries different sensitivities and, in Health's case, different regulatory obligations.

This policy is written for three audiences at once: the schools and institutions that contract with us, the educators and administrators who use our tools day to day, and the students whose learning data passes through our systems. Where our obligations differ between these groups, we say so explicitly.

2. Our role: controller and processor

This distinction matters, so we are stating it up front rather than burying it. When a school signs up for Gagner for Schools, the school is the data controller for the student and staff data entered into the platform, and Gagner acts as a data processor (service provider) acting on the school's instructions under our institutional agreement. We do not independently decide what to do with student data beyond operating the product the school asked us to provide.

For information collected directly through our marketing website, for example when someone requests a demo, subscribes to updates, or applies for a job, Gagner is the data controller and this policy describes our own practices directly.

3. Information we collect

From schools and institutions

• Institution name, address, and billing contact details
• Names, roles, and contact details of administrators who set up and manage the account
• Enrollment and roster information the school provides to configure classes, subjects, and student accounts

From educators

• Name, email address, and role, provided at account creation by the school or the educator
• Content created while using Gagner, such as lesson materials, gradebook entries, and quizzes built in AI Quiz Master

From students, generated through use of the product

• Study Buddy: the questions students ask and the study sessions they complete
• AI Quiz Master: quiz responses, scores, and gamification data such as points and achievement badges
• Idea Lab: the ideas students submit and the AI-assisted refinements generated in response
• Homework Coach: the assignments and working steps a student enters while being guided through a problem
• General usage data such as login times, features used, and progress across the school management system

Students do not create Gagner accounts on their own. Their accounts are provisioned and controlled by their school, consistent with the school-authorized model described in section 6.

Automatically collected information

• Device and browser type, IP address, and approximate location derived from it
• Log data such as pages visited, features used, and timestamps
• Cookies and similar technologies, described in section 12

Information you give us directly

• Contact details submitted through our "Book a demo" form: full name, email, phone number, school name, school type, and approximate student count
• Any correspondence you send us, including support requests

4. How we use information

• To provide, operate, and maintain Gagner for Schools, including grading assistance, lesson planning support, and progress tracking
• To power Study Buddy, AI Quiz Master, Idea Lab, and Homework Coach as the school has configured them
• To personalize the learning experience within a class, for example adjusting Homework Coach's guidance to a student's demonstrated level
• To generate the impact and progress reports schools and educators rely on
• To respond to demo requests, support inquiries, and other communications
• To maintain the security and integrity of our systems, including detecting abuse
• To meet legal, regulatory, and contractual obligations
• To improve Gagner's products, using aggregated or de-identified data wherever a direct identifier is not required for the improvement in question

5. Our legal basis for processing

Where applicable data protection law requires a stated legal basis, ours are typically:

• Contract: processing needed to deliver the product a school has subscribed to
• Legitimate interests: for example, securing our systems or improving reliability, balanced against your rights and interests
• Consent: where we ask for it specifically, such as certain optional communications
• Legal obligation: where we must retain or disclose information to comply with the law

Where student data is concerned, the school's own authority to enroll students in educational tools, consistent with its responsibilities to parents and guardians, is what permits processing under this agreement; see section 6.

6. Student data and school accounts

Gagner for Schools is built to be used under a school's authority, not signed up for directly by a child. This mirrors how most responsible education technology operates: the school, acting in its role in loco parentis and under its own obligations to parents and guardians, authorizes the use of Gagner as part of instruction, and Gagner processes student data solely to deliver that instruction.

• We use student data only for the educational purposes the school has configured, never to build a marketing profile of a student
• We do not require a student to provide more information than is reasonably needed for the functionality the school has enabled
• Schools can request export or deletion of their students' data; see section 13
• Where local law grants parents or guardians rights to inspect or request correction of their child's data, we work through the school to fulfil those requests, since the school holds the enrollment relationship

7. How our AI features process information

Study Buddy, AI Quiz Master, Idea Lab, and Homework Coach are built on artificial intelligence models that process the text a student or teacher submits in order to generate a response, a refined idea, or guided steps toward an answer.

• Inputs and outputs are processed to deliver the specific feature being used and to maintain quality and safety of that feature
• We do not use student inputs to train general-purpose, public AI models
• Where we use a third-party AI provider to power part of a feature, that provider processes data under a contract that prohibits them from using it to train their own models and requires them to meet our security requirements
• Homework Coach is deliberately designed to guide reasoning rather than output finished answers; this is a product design choice as much as a privacy one, intended to support genuine learning

AI-generated output can be imperfect. Section 7 of our Terms of Service covers the disclaimers that apply to AI-assisted content in more detail.

8. How we share information

We do not sell personal information, student or otherwise. We share information only in these circumstances:

• Service providers: vendors who host our infrastructure, process payments, send transactional email, or provide the underlying AI models, bound by contract to protect the data and use it only to provide their service to us
• The school itself: administrators and educators at a student's own school can see data relevant to their role, for example a teacher viewing their own class's quiz results
• Legal compliance: where required to comply with a valid legal request, protect rights, safety, or property, or enforce our agreements
• Business transfers: if Gagner is involved in a merger, acquisition, or asset sale, in which case we will ensure continuity of the protections described here
• With consent: any other sharing we ask your permission for first

9. Data security

We use administrative, technical, and physical safeguards designed to protect information against unauthorized access, alteration, disclosure, or destruction, including encryption of data in transit, access controls limiting who at Gagner can view identifiable student data, and regular review of our security practices. No system is completely immune to risk, and we will notify affected schools promptly if we become aware of a breach affecting their data, consistent with our contractual and legal obligations.

10. Data retention

We retain student and school data for as long as the school's account is active, and for a limited period afterward to allow for account recovery and to meet legal or contractual retention requirements. When a school's contract ends, the school may request export of its data and deletion of remaining copies, subject to backups being purged on our standard rotation schedule and any data we are legally required to keep.

11. International data transfers

Gagner may process and store data in countries other than the one where a school or user is located. Where we do, we use recognized safeguards, such as contractual data protection commitments with our infrastructure and service providers, designed to ensure information continues to receive an appropriate level of protection wherever it is processed.

12. Cookies and similar technologies

Our website uses cookies and similar technologies to:

• Keep you signed in and remember your preferences
• Understand how visitors use our site so we can improve it
• Measure the effectiveness of our own marketing, where enabled

You can control cookies through your browser settings. Blocking some cookies may affect how parts of the website function. Gagner for Schools uses only the cookies strictly necessary to keep users signed in and the product functioning; it does not use third-party advertising cookies.

13. Your rights and choices

Depending on where you are located and your relationship to Gagner, you may have the right to:

• Access the personal information we hold about you
• Request correction of inaccurate information
• Request deletion of your information, subject to legal and contractual retention requirements
• Object to or restrict certain processing
• Request a copy of your data in a portable format
• Withdraw consent where processing is based on consent

If you are a student or parent, please direct requests about student data to your school first, since the school controls the enrollment relationship and can usually resolve the request directly within Gagner for Schools. If your school is unable to assist, contact us and we will support the school in fulfilling the request.

If you are a school administrator, contact us directly using the details in section 17 to request export or deletion of your institution's data.

14. Children's privacy

Gagner for Schools is used by students of varying ages, including children under 13, but only under a school's authorization and configuration, never through direct sign-up by a child. We rely on the school's own authority and consent processes with parents and guardians, consistent with the frameworks that govern school-authorized education technology in the regions we operate, including protections comparable to the U.S. Family Educational Rights and Privacy Act (FERPA) and Children's Online Privacy Protection Act (COPPA), the Nigeria Data Protection Act, the Kenya Data Protection Act, and the EU/UK General Data Protection Regulation where applicable.

We do not knowingly collect personal information directly from a child outside of a school-authorized Gagner for Schools account, and we do not use student data for behavioral advertising, as stated in section 4.

15. Agriculture and Health, when they launch

Gagner for Agriculture and Gagner for Health are not yet available. Farm operational data and, especially, health information carry different sensitivities and, for health data, additional regulatory obligations that student data does not. Before either product launches, we will publish a dedicated section of this policy, or a standalone policy where appropriate, describing exactly what we collect and how it is protected for that product, rather than retrofitting generic language after the fact.

16. Changes to this policy

We may update this policy as our products, legal obligations, or practices change. If a change is material, we will notify affected schools directly and update the "last updated" date at the top of this page. Continued use of Gagner after a change takes effect means you accept the updated policy.

17. Contact us

Questions about this policy, or requests relating to your data, can be sent to hello@gagnerapp.com.

Gagner Solutions Limited