AI Policy

DRAFT — to be reviewed by a lawyer before publication. Last updated: 2026-10-24

Two different assistants

1. The AI tutor in lesson rooms helps students learn (hints, explanations, reading the board). It processes lesson data and is available to a student only after the parent/legal guardian or adult student consents. The tutor decides whether to switch it on and at what level.
2. The help assistant (the chameleon) answers questions about how to use TutorHabitat, based on our help pages. It does not see lesson content, boards or students' data. Before the first question every user gives a one-time consent to sending questions to the US AI provider (Privacy Policy §5); the consent is remembered in your browser and can be withdrawn with "Withdraw consent" in the assistant window.

Intended purpose

The AI tutor gives hints and explanations during lessons. It is not intended to evaluate learning outcomes, assess a student's level, steer admission or proctor exams (EU AI Act, Annex III point 3). CHECK: documented Art. 6(3) assessment; keep the product within this purpose

Transparency

• Every AI answer is clearly marked as coming from AI (EU AI Act, Art. 50(1)). CHECK: Art. 50(2) machine-readable marking of AI-generated text/audio from 2 August 2026, incl. text-to-speech; possible exemption for assistive functions Users talk to an AI system, not to a person, and we say so.
• AI answers can be wrong or incomplete. The AI tutor is designed to guide rather than give final answers; the tutor remains responsible for teaching.
• We do not use AI to make decisions with legal or similarly significant effects on students (no automated grading or profiling decisions).

Your data and AI models

• We do not use your content to train AI models, and we will not enable a provider for lesson data unless its terms prohibit training on that data. CHECK: confirm in each provider's current API terms / DPA ({{AI_PROVIDERS)}}
• Providers may keep requests for a limited time for abuse monitoring (for example 30 days at xAI), as shown in Sub-processors.
• Only what is needed for the answer is sent: the question, the relevant part of the board, the student's first name and school year, and — if recording consent was given — lesson transcripts.
• Nothing goes to AI on its own. Files uploaded to a room are lesson materials; they are read by AI only after someone clicks “Load into AI” (student materials only with AI consent). The pronunciation tool sends a board fragment to AI only when the user selects it to have handwriting read aloud. The calculator sends a board fragment to AI (a fast model) only when the user selects it, to read it; it needs AI consent and uses credits.

Your own AI key

The account administrator can connect an API key from a supported provider (AI_PROVIDERS). The key is checked with the provider when saved, stored encrypted and never shown again (only its last four characters).

• While the key is connected, AI requests of your workspace go to that provider under your own agreement with it. Where you have that direct agreement, the provider acts under it and is not our sub-processor. If you are a consumer, you contract with the provider directly and our role is to transmit requests on your instruction.
• We transmit requests only on your instruction, with the same data minimisation and AI-consent rules, and remain your processor for the lesson data we transmit. We stay the controller of your account, billing, technical logs, the help assistant and the stored key.
• Before the key is used for lesson data, you must confirm in the service that the provider's terms or settings prohibit training on your content. Without that confirmation we do not send lesson data with your key. CHECK: role analysis
• Credits are paused; usage is still shown in credits so you can compare.
• The help assistant (chameleon) always uses our own key and never your key.

Limits and transparency

AI use is measured in credits to keep the service affordable and fair. The account administrator sees every AI call (time, function, room, student, person, credits) in AI usage, can export it and can set a monthly AI budget per room; students see what is left of their room's budget. The usage log does not contain the text of questions or answers; it covers the last 12 months, after which only monthly totals per function remain (number of calls, cost, number of active rooms), with student, room and user identifiers removed; the totals stay linked to the customer account and are deleted with it.