Privacy notice
It exists in two versions. They say the same things: one is written for whoever signs, the other for someone who is thirteen. Neither is a summary of the other: it is the same notice, written twice.
Market: Italy. Compliance documents are written per market. The AI Act layer is the same across all 27 member states; the age of digital consent and the grading scale are not, and each market gets its own folder before it opens.
Notice given under articles 13 and 14 of Regulation (EU) 2016/679, concerning the processing of students' data in the classroom activity carried out with Dialectica.
01Data controller
The data controller is the school the student attends, which decides the purposes of the teaching activity and keeps the relationship with families.
Dialectica processes data as a processor, on the school's instructions and within the limits of the agreement signed under art. 28 GDPR.
Institution name, controller and processor details — entered by the school.
02Purpose of processing
Data is processed to carry out the teaching activity: assigning debate assignments, letting the student complete them, producing a proposed rubric assessment and giving the student a report on their work.
It is not processed for commercial purposes, does not feed advertising profiling, and is not used to train artificial intelligence models.
03Legal basis
Processing is based on carrying out a task in the public interest connected with education. For lower-secondary students, authorisation from whoever holds parental responsibility is also required, collected by the school.
Precise references to the applicable legal bases — to be drafted with Italian legal counsel.
04Categories of data processed
Display name chosen by the school, class and institution, class code used to sign in, texts written by the student during debates, analysis scores and the report confirmed by the teacher.
Not processed: the student's email address, photographs, phone number or other contact details, geolocation data.
05Recipients
A student's texts and scores are visible to their class teacher and to authorised school staff. No other student can access them.
The providers that process data on Dialectica's behalf are four, and are listed by name, purpose, place of processing and guarantees on the compliance page.
06Place of processing
Database, authentication and application hosting are located in the European Union. The language model that analyses submissions belongs to a European provider and inference runs in France, EU. We do not claim that all processing happens in the EU: the provider's control plane is not regional, and limited, protected transfers to sub-processors remain possible.
07Retention period
Section not publishable until scheduled deletion is active in the system: actual periods go here, not a promise.
08Data subject rights
Whoever holds parental responsibility can request access, rectification, erasure and restriction of processing, and object to processing where provided for. The request is made to the institution, which is the controller.
Dialectica acts on requests forwarded to it by the school, within the timeframe set by the agreement.
09Contacts
To exercise your rights: the institution's data protection officer.
For technical questions about the application: hello@dialectica.education, or the form on the Contact page.
The full list of providers that process data on Dialectica's behalf, with place of processing and guarantees, is on Privacy, security and compliance.