Privacy Policy

Cognya is a worksheet and homework platform operated by Fayyad Uddin trading as Cognya, at 159 Micklefield Road, High Wycombe, HP13 7HA, United Kingdom. In this policy, “we”, “us” and “Cognya” mean that operator.

For privacy questions or requests, email support@cognya.co.uk or write to the address above. You do not need a Cognya account to contact us about your information.

This policy explains information about adult tutors and education professionals, students using assigned homework, visitors and people who contact us. Student homework features are intended only for students aged 14 or over, with a principal focus on GCSE and A-level students. A Year 9 student must already have turned 14; school year alone is not an age check.

We act as a controller when we decide the purposes of using tutor account information, subscription and support information, and information needed for our own security and administration.

For student records and homework processed to provide a tutor’s service on their instructions, the tutor or their organisation is the controller and Cognya is a processor. Our Data Processing Addendum governs that work. The tutor should explain their own purposes and lawful basis to students and parents where appropriate.

We also act as a controller for limited manual service-quality checks: reviewing submitted answers and marks to investigate whether Cognya works correctly, identify marking errors and fix defects. This is distinct from assessing a particular student’s progress for our own purposes. Section 5 explains the purpose and limits.

Tutors and visitors

• Account and sign-in information, including email address, authentication identifiers and password-authentication records where email/password sign-in is used.
• Profile information, including name, subjects and teaching levels.
• If you choose Google sign-in, the identity and authentication information Google supplies to sign you into Cognya. We use this connection only to create or authenticate your tutor account, not to access your Gmail, Google Drive or other Google content. We do not receive your Google password. Google handles the sign-in interaction under its own applicable privacy information.
• Worksheet choices and instructions, generated questions and mark schemes, saved worksheets, plan status and usage counts.
• Subscription and payment references and billing information supplied by our payment provider. Card entry is handled by Stripe; Cognya does not receive or store full card numbers.
• Support and feedback messages, account contact details and relevant information you include in them.
• Records of terms versions accepted and when, technical generation records, security counters and technical information involved in requests to the service.

Cognya does not currently accept uploaded reference files. Avoid including personal information in worksheet instructions or feedback unless necessary to resolve a particular issue.

Students

• Information entered by the tutor: student name or identifying label, year group, subjects and exam boards, topic ratings and permitted notes.
• Homework information: assignments, passcode-related records, typed answers, marks, attempts, submission times, AI marking feedback and flagged questions or comments.
• Age-eligibility confirmation for the student, including which tutor confirmed the student is 14 or over and when. The confirmation is separate from the student’s school-year selection.
• Limited technical information needed to deliver and secure the homework portal, including request data handled by our hosting providers.

Students do not create accounts and are not asked for email addresses. Their work is nevertheless personal information where it can be linked to them through the tutor’s records.

For processing for which Cognya is controller, we use the following lawful bases:

We rely on legitimate interests only where the processing is necessary and those interests are not overridden by people’s rights, giving particular weight to children. You may object as explained in section 12.

Information required to create and secure an account or process a payment is necessary for those functions; without it we may be unable to supply them. Feedback is optional. We do not sell personal information or use student records for advertising.

The tutor chooses the lawful basis for the student processing we carry out solely on their instructions. Our contract with a tutor is not, by itself, a contract with a student.

Cognya’s operator may view submitted homework answers and their marks in the administrator interface solely to check and improve Cognya’s functionality and reliability. This includes understanding common answer patterns, investigating apparently incorrect marking, distinguishing a student’s incorrect answer from a service error, and fixing bugs. An answer can remain linked to a student in that interface. The purpose is to evaluate whether the questions and marking work correctly, not to follow an individual child’s progress for Cognya’s own purposes or use their work for advertising.

Tutors can separately send feedback through the support button, including reports of missing topics or features that do not work as expected.

These quality checks take place in the administrator interface. They are not a separate programme for following an individual pupil’s progress, and this purpose does not include creating an external training dataset or sending historic answers to another AI service for experimentation. We use only the information reasonably needed for the check and do not use student identity to assess whether an answer is correct.

Rule-based marking compares answers with accepted numbers, keywords or other configured rules. Eligible written answers may be assessed by OpenAI against the question and mark scheme. These include some explanations, “show that” questions and longer written responses.

For AI marking, the request contains the question, mark scheme, typed answer and limited marking information such as subject and available marks. Student names, codes, tutor details and internal account or student identifiers are not intentionally included. An answer is sent as typed. If a student includes identifying or sensitive information, that information may therefore be sent too. Removing a name from the request does not necessarily make the answer anonymous.

Tutors can review and adjust AI-awarded marks. They cannot currently override rule-based marks through the interface. Suspected marking errors can be reported to support. Both methods may produce incorrect results.

Homework marks and topic-progress information help the tutor identify strengths and areas for further teaching. Results may be generated through automated marking, including AI, and should be considered with the tutor’s own assessment. These educational evaluations may constitute profiling; they are not advertising profiles. We do not use the marking feature to award formal qualifications, determine admission or make employment decisions.

OpenAI processing

OpenAI processes AI-marking requests under its applicable API data-processing terms. API inputs and outputs are not used to train OpenAI models by default. Cognya has not opted into that use. We do not intentionally submit student identity information for marking.

OpenAI’s published API documentation describes abuse-monitoring retention of up to 30 days by default, subject to stated legal and safety exceptions. Other retention depends on the API features and settings used. Turning off response storage is not the same as Zero Data Retention. Contact us for information about the safeguards and retention arrangements applying to Cognya’s marking service.

The service’s student homework features are restricted to ages 14 and above. We require tutors to check eligibility before access is enabled and notify us of an incorrect confirmation. We investigate known underage access and may suspend it.

Students aged 14 or over use the service under a tutor’s direction. Before enabling homework access, tutors must check and separately confirm eligibility for each student. We record the tutor’s confirmation and time, rather than relying on a school-year label. Tutors should share the student privacy explanation and relevant parent information before assigning homework. Students aged 14–17 are still children and do not lose their privacy rights because they do not have an account.

We aim to collect only information needed for the educational service, limit access and provide an understandable explanation of marking and data sharing. Do not include contact details or unrelated personal information in answers. We do not use student records for behavioural advertising.

Provider roles depend on their actual activities and contracts; not every provider acts solely as our processor for everything it does. Relevant subprocessors for student processing are identified in the Data Processing Addendum.

An adult tutor sees the student information associated with their own account. Cognya’s operator can access records for support, security and the manual checks described above. We may disclose information where required by law, to protect legal rights or respond appropriately to a serious safety concern. We will limit any disclosure to what is justified.

Generated questions and mark schemes may enter a shared pool and be reused or adapted for other tutors. This is part of Cognya and tutors cannot currently opt out. The pool is not intended to contain tutor instructions, support feedback, student identities, student answers or student records.

Cognya’s Supabase project is hosted in eu-west-1 (Ireland). This identifies the core project’s hosting region; it does not mean every provider, support operation or technical log is processed exclusively in Ireland or within the EU.

Some providers process information outside the UK, including in the United States. For relevant transfers, we use applicable adequacy arrangements or contractual safeguards, including Standard Contractual Clauses with the UK Addendum or the UK International Data Transfer Agreement where applicable. Supabase and OpenAI publish the transfer provisions in their data-processing terms. You may contact support@cognya.co.uk for information about a particular transfer and a copy or explanation of the relevant safeguards.

Provider terms: Supabase, Vercel, OpenAI and Anthropic. Links identify the providers’ documents; their application depends on the relevant account and service agreement.

After cancellation, your paid plan remains available until the end of your current billing period, when your account moves to Free. When your free beta ends, your account moves to Free unless you have separately subscribed to a paid plan. Moving to Free does not itself delete student information or close the account. A paid account continues to renew until cancelled, even if unused.

Tutors can delete students, student homework and their account using the available controls. There is currently no self-service data export. A lack of an export button does not remove applicable rights to access or portability; requests may be sent to support.

Before deleting an account, the tutor must cancel any paid subscription themselves. Cognya prompts them to do this before deletion. Deleting the account is not a substitute for cancelling billing. Account deletion removes the account and associated student and homework records, subject to justified legal retention and relevant provider-held copies described below.

For active accounts, student and homework records are kept to provide the service until deleted through the available controls or under the account-deletion rules. Worksheet expiry or hiding is distinct from deletion.

When a paid plan ends, worksheets beyond the Free allowance are archived: kept but locked until the tutor resubscribes. Archived worksheets are deleted 12 months after they are archived. Homework results and reviews for them stay on the student’s record, as they do when a tutor deletes a worksheet.

Free-account inactivity

A Free account is deleted after 30 consecutive days with neither a tutor sign-in nor student homework activity associated with the account. Either type of activity restarts the inactivity period. We email the tutor a warning before deletion, explaining when it will happen and how to keep the account active. Deletion covers the Free account and its associated student and homework records, subject to the limited legal-retention exceptions described below.

This automatic rule does not apply while a paid subscription or invited Pro beta is active. When an account moves to Free, its first inactivity period starts on the downgrade date, giving it a full 30 days before deletion unless subsequent qualifying activity restarts that period. Inactivity on a paid account does not cancel billing.

Backups and other retained copies

Cognya currently uses the Supabase Free plan and does not have a customer-accessible project-backup or restore facility included in that plan. Providers may retain operational, security, recovery or log records under their applicable arrangements. Deletion from the live account is therefore not a promise that every provider-held copy is erased immediately.

Support and feedback messages are retained for as long as needed to investigate the issue, provide follow-up and resolve any related dispute. Quality-check records and technical logs are retained only as long as necessary for the investigation, service-security or reliability purpose for which they are held. Agreement records are retained where needed to evidence the relationship and deal with claims; financial records are retained for applicable legal accounting periods. We review continued need and delete or anonymise records that are no longer necessary. Any exception to ordinary account deletion is limited to justified information and purpose.

Reusable question and mark-scheme content may be retained independently of an account where it contains no retained personal information. Deleting a tutor’s account removes its personal account and student records; it does not necessarily withdraw non-personal educational material already reused in the shared pool.

Depending on the processing and legal basis, you may have rights to access, correction, erasure, restriction, objection and portability. Where consent is used, it may be withdrawn without affecting earlier lawful processing. These rights have legal conditions and are not all unconditional.

Contact support@cognya.co.uk. We may need proportionate information to verify identity or a person’s authority to act for a child. For student information processed on a tutor’s behalf, we will promptly coordinate with the relevant tutor; we should not disclose a child’s records to someone without authority. For our own controller activities, including the quality-check purpose, we handle the request ourselves.

We normally respond within one month. Where the law permits an extension or adjustment, we will explain the reason and applicable timeframe. You may object specifically to our controller use of student information for quality checks. We will assess that objection and stop the relevant use unless we can establish grounds permitted by law to continue; this does not automatically cancel the tutoring service.

You can complain to the Information Commissioner’s Office at ico.org.uk. You may also complain to us first so we can investigate, but that is not a condition of contacting the ICO.

Our Cookie Policy describes sign-in, administrator-session and display-preference storage. Google sign-in and Stripe payment pages also involve those providers’ own authentication or payment technologies. We do not use student information for advertising or sell it.

The service uses HTTPS. Access controls separate tutors’ student and homework records so that one tutor cannot access another tutor’s students or homework. Access to the administrator interface is restricted. No online service can guarantee absolute security.

If we change this policy materially, we will give appropriate notice, explain the changes and identify the effective version. Asking a tutor to acknowledge a new policy does not itself supply a new lawful basis for processing student information.