Privacy Notice

Last updated: 29 June 2026

This privacy notice covers the use of the Chalk Learning web platform ("Chalk"), a not-for-profit enterprise by Poteris. Chalk Learning is a trading name of Poteris Ltd, hereafter referred to as "we".

Service Transition Notice

Chalk Learning was previously known as "Pedagogical". This represents a continuation of the same service under a new name rather than a new or separate platform. All existing users of the Pedagogical platform are automatically users of Chalk Learning, as these are the same service.

All user accounts, data, and privacy preferences established under the Pedagogical name remain valid and unchanged under the Chalk Learning name. This privacy policy applies to all users regardless of when they originally joined the platform, whether under the Pedagogical or Chalk Learning name.

No action is required from existing users regarding this name change. Your account access, generated content, and privacy settings remain exactly as they were.

Introduction

We provide an online platform that is for use by teachers, educators and others to generate visual learning materials. This Privacy Notice explains the personal data we collect, how we use it and how we keep it secure.

When processing personal data for our testing purposes, allowing schools to have their teachers volunteer to test Chalk, we act as a Data Controller. When Chalk is purchased as a service on behalf of a school or educator or when it is being funded by another organisation we will be their data processor.

We are registered with the Information Commissioner's Office (ICO) with registration code: ZB178575.

We will use personal data in accordance with this Privacy Notice, complying with current data protection law and taking safeguards to ensure all personal data is kept safe.

We reserve the right to update our Privacy Notice in line with our charitable goals. If users have any questions or concerns relating to this Privacy Notice, they are encouraged to get in touch at phil@chalklearning.io.

Using Chalk and research & development

We approach schools who give their teachers and teaching staff the opportunity to use Chalk voluntarily. This means we collect personal data directly from people who would like to use Chalk, also known as "Users". We are the controller for this personal data. We collect:

• First name, last name, email address, job title, school name (collected directly from the User)
• Interview and/or survey answers and any digital communications (such as emails or direct messages with the Chalk team) (collected directly from the User)
• Opinions, ideas and concerns raised about the Chalk platform (collected directly from the User)
• Level of engagement with Chalk, quality of prompt, security flags raised by OpenAI's Omni moderation tool (collected within the platform)

We ensure that Users understand they are able to use Chalk on the basis of providing us feedback by asking them to agree to using Chalk on the basis of providing us feedback for our own research and development of Chalk.

The lawful basis we rely on for the use of User's personal data when testing, is the obligations of a contract of which they are entering (UK GDPR Article 6.1(b)). We could not provide access or gain feedback about Chalk without the User's personal data.

We will also use the above data to conduct research on all uses and effectiveness of Chalk. We will conduct research on the basis of our legitimate interests of a data controller (UK GDPR 6.1(f)). Where possible we anonymise all personal data before research is conducted.

Chalk being used in Schools

When Chalk is purchased as a service by a client (a school or educational body etc.), where we are acting as a data processor on their behalf, we collect the following information from their Users:

• First name, last name, email address, job title, school name (either collected directly from the User or from the client)
• Opinions, ideas and concerns raised about the Chalk platform (collected directly from the User)
• Level of engagement with Chalk, quality of prompt, security flags raised by OpenAI's Omni moderation tool (collected within the platform)

Where there may be pupils or learner's personal data held in Chalk to help teachers track a child's progress; to use Chalk to build bespoke educational tools based on specific needs a child may have; and to measure the academic attainment against any bespoke educational tools created by the User, we collect children's:

• First name, last name, teacher name, school name, class name and year (collected from the school or the teacher)
• Bespoke educational tool aligned to the child which may suggest the child is considered as having SEND or another type of learning style (collected from the school or the teacher)

We rely on the school / educational body's (client's) lawful basis for the use of teacher and pupil user data which has been communicated to them on the client's privacy notice. This will typically be, use of personal data for a task in the public interest (UK GDPR Article 6.1(e)) and, for special categories of personal data e.g. SEND data, use of personal data for substantial public interest (UK GDPR Article 9.2(g)).

Where we are collecting feedback through surveys, questionnaires, invitations to interact with us, and to report on the effectiveness of Chalk we rely on our legitimate interest as a data controller for this use of personal data which may or may not be a contractual term but will always be voluntary for the User.

The Users we collect this personal data from are typically teachers or teaching assistants – the people using Chalk to create visual learning resources to use in the classroom.

Website visitors

When you visit our website, we will collect the following information about you. We collect information from users' use of our website. Like all organisations we are able to see details of the user's web browser, operating system, and geographical region, among other details. We may use this information to improve the services we offer. Please also refer to our Cookies information below.

We use tracking pixels and analytics tools (including Facebook Pixel) to understand how users interact with our website, measure the effectiveness of our advertising campaigns, and improve our marketing efforts.

When we do this, we do so based on our legitimate interest as a data controller.

Use of Generative AI Services within Chalk

Our platform uses third-party generative artificial intelligence services to create educational content. If you use Chalk's AI-powered features, your inputs may be processed by:

• OpenAI (ChatGPT/GPT models) - Privacy Policy
• Anthropic (Claude) - Privacy Policy
• Google AI (Gemini) - Privacy Policy
• Groq (Qwen models) - Privacy Policy
• Black Forest Labs (Flux) - Privacy Policy

We have opted out of having user data used for training these AI models.

Marketing and Outreach

To work towards our goals, we may reach out to organisations and public bodies. We do this only where we see necessary and have balanced our needs with the interests of those receiving the direct communications.

We may contact those we believe have closely aligned aims, and schools and other educational establishments where we believe we can support their learners and help toward our goals. Our database is reviewed regularly, and contacts are removed where necessary. We also respect the rights of our contacts to withdraw their details in accordance with our data storing processes. We do this on the basis of our legitimate interests as a data controller for the marketing we do.

Other marketing materials and updates require opt-in consent from the contact.

Recruitment

For any recruitment we may do, please see the Poteris website for the current privacy information: https://poteris.co.uk/privacy/

Keeping data secure

Our platform is hosted on Vercel and Supabase, and information is stored there. The services are ISO27001 or SOC 2 compliant. The personal data is encrypted.

This may include in spreadsheets and word processing documents as well as processing via the services listed below. All systems are password protected and restricted to relevant users, and staff laptops are encrypted so that loss would not be expected to result in loss of user data. We operate in a generally paperless environment and do not print documents containing personally identifiable information.

Processors

To be notified of updates to the list of processors, users can register using the form at the bottom of the page.

Sharing Data

We will keep personal information confidential and not sell or disclose information to advertisers or external parties, except where users have explicitly given permission to do so.

There are some unlikely circumstances in which we would be required to share data outside of a contract or without requesting explicit permission from the user. These include if we believe in good faith that we are required to in order to comply with a regulator or court in order to comply with law, regulation, legal process and court order. We may also share information in order to enforce terms of the contract.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded by implementing at least one of the following safeguards:

• Transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK (the UK also recognises the European Commission list of adequate countries). For further details, see European Commission: Adequacy of the protection of Personal Data in non-EU countries.
• Specific contracts/agreements approved by the UK which give personal data the same protection it has in the UK. For further details, see UK International Data Transfer Agreements. We will also assess in-country standards as part of this process.

We may also share your personal data if we choose to sell, transfer, or merge parts of our business or our assets in the future. Or we may seek to acquire other businesses or merge with them. During any such process, we may share your data with other parties. We will only do this if they agree to keep your data safe and private. If a change such as this happens, then other parties may use your data in the same way as set out in this notice.

How long we keep your data

We will only store personal data for as long as is necessary and in line with the original purpose that it was collected. This is typically twelve (12) months from the point of last use of personal data within Chalk. All personal data is either anonymised or deleted at that time.

Rights of the Data Subject

This is a list of your data protection rights.

• You can see your personal data and can request copies of it and details about how we use it.
• You can ask us to fix or change your personal data if it is wrong or incomplete.
• You can take back your consent for us to use your personal data at any time.
• You can say no to us using your personal information if we use it for our own purposes.

Additionally:

• We never use your personal data for marketing without your consent.
• You can ask us to limit how we use your personal data if:
  • it is not correct,
  • it has been used against the law but you do not want us to delete it,
  • we do not need it anymore, but you want us to keep it for legal reasons,
  • you have already asked us to stop using it but you are waiting for us to confirm.
• In some circumstances you can ask us to delete your personal data and request a copy in a format that can be used by other services.
• You have the right not to have decisions made about you by a computer, if those decisions significantly affect you (e.g. legally).

You will not have to pay a fee to access your personal data (or to use any of the other rights). However, we might charge a fair fee if your request is unreasonable or excessive. Also, we may refuse to comply with the request in such circumstances.

How to Complain

Please submit any complaints you have about how we are handling your personal data or meeting your expectations around data protection laws to: phil@chalklearning.io

If you are not happy with how we have handled your complaint, you can then complain to the Information Commissioner's Office. This is their information:

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://ico.org.uk/concerns/

Cookies

Cookies are small text files that are placed onto a device when users first visit a website which monitors interactions with the site.

We use cookies to:

• Recognise you when you return.
• Keep you logged in.
• Embed content hosted by third parties.
• Provide a support chat service (coming soon).
• Improve your experience on our websites through monitoring content and feature usage.
• Track advertising effectiveness and user behaviour through Facebook Pixel and similar technologies.

There are four categories of cookies we set:

• Necessary cookies – these cookies are necessary for the website to function properly. Some of the following actions can be performed by using these cookies: keeping you logged in; serving video content we host on Vimeo; storing your cookie consent preferences.
• Performance cookies – these cookies are used to gather statistical information about the use of our websites, also called analytics cookies. We use this data for performance and website optimisation.
• Functional cookies – these cookies enable more functionality for our website visitors and can be set by our external service providers or our own website. The following functionalities may or may not be activated when you accept this category: support live chat; social media content feeds and sharing.
• Advertising cookies – these cookies are used to track user behaviour across websites for advertising purposes. We use Facebook Pixel and similar technologies to measure the effectiveness of our advertising campaigns, understand user interactions, and provide relevant advertising experiences.

The full list of cookies we use across our sites can be viewed via the cookie information panel on our website.

Changes to this Policy

We will notify users when this Privacy notice changes and provide a jargon-free summary of the changes. In order to receive notification of changes users should register at the bottom of this page.

Queries

If you have any questions or queries about our data privacy, please get in touch at phil@chalklearning.io