School Data Processing Addendum

1. Purpose

This Addendum sets out additional obligations that apply when the Service is used by or on behalf of a school, academy, multi-academy trust, or other educational institution ("School") with students who are under 18 years of age.

In the event of any conflict between this Addendum and the DPA, this Addendum shall take precedence to the extent of the conflict.

2. Children's Data Safeguards

The Processor acknowledges that the personal data processed under this Addendum includes data relating to children. The Processor shall:

• Not use student personal data for any purpose other than providing the educational Service as instructed by the School.
• Not use student data for marketing, advertising, profiling, or behavioural targeting.
• Not sell, rent, or otherwise commercially exploit student data.
• Not use student audio data to create voice prints, biometric templates, or any form of biometric identifier.
• Not retain student data longer than necessary to provide the Service, subject to the retention periods in the DPA.

3. Consent and Parental Notification

The School is responsible for:

• Obtaining appropriate consent from parents or guardians before directing students to use the Service, where required by the School's own policies or by law.
• Informing parents and guardians about the School's use of Tête-à-Tête, including what data is collected and how it is processed.
• Responding to parental enquiries and requests regarding their child's data, with assistance from the Processor where needed.

The Processor shall provide the School with information and materials to support parental notifications, including a link to the Privacy Notice for Schools and the Child-Friendly Privacy Summary.

4. AI Processing Transparency

The Processor shall maintain transparency about how AI is used in the Service:

• Student audio is streamed in real time to OpenAI for transcription and AI response generation. Audio is not permanently stored.
• AI-generated feedback and scores are indicative and should not be treated as formal assessment. The School is responsible for any educational decisions based on the Service.
• A visible recording indicator is displayed whenever audio capture is active.
• No automated decisions with legal or similarly significant effects are made about students based on AI processing.

5. Log and Monitoring Safeguards

To protect the confidentiality of student interactions:

• Transcript content (what students said) is excluded from application logs and error monitoring systems.
• Audio content is excluded from all logging and monitoring systems.
• Error reports sent to third-party monitoring services (Sentry) are scrubbed of transcript and audio content before transmission.
• Technical logs retain only metadata (session IDs, timestamps, error codes) and are deleted within 90 days.

6. Deletion on Termination

When a School ceases to use the Service:

• The School may request deletion of all student data by emailing privacy@tete-a-tete.ai.
• The Processor shall delete all student personal data within 90 days of the request, unless retention is required by law.
• The Processor shall provide written confirmation of deletion upon request.
• Anonymised and aggregated data that cannot identify individual students may be retained for service improvement purposes.

7. Safeguarding

If during the normal operation of the Service the Processor becomes aware of content that suggests a student may be at risk of harm, the Processor shall notify the School's designated safeguarding lead promptly, in accordance with any contact details provided by the School.

The Processor does not actively monitor student conversations for safeguarding purposes. The AI system is designed for French language practice only and does not perform content moderation or behavioural analysis.

8. School Reporting

Where the Service includes reporting features for teachers:

• Teachers can view aggregate and individual student progress within their own school's data only.
• Schools cannot access data belonging to other schools or to students who signed up independently.
• The Processor shall ensure appropriate access controls to enforce data segregation between Schools.

9. Governing Law

This Addendum is governed by the laws of England and Wales. Any disputes arising under this Addendum shall be subject to the exclusive jurisdiction of the courts of England and Wales.

10. Contact

For questions about this Addendum or to execute it alongside the DPA: