Privacy Policy

1. Introduction

Welcome to Clevra ("we", "us", or "our"). Clevra is a performance-based assessment platform designed for high school teachers. Our platform enables teachers to create assignments, have students perform teaching demonstrations, and evaluate student understanding — all in one place.

We are based in the Netherlands and committed to protecting your privacy in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws. This Privacy Policy explains how we collect, use, and protect your personal data when you use our platform.

2. Data Controller

Clevra, based in the Netherlands, is the data controller responsible for processing your personal data. If you have any questions about this Privacy Policy or our data practices, please contact us at the details provided at the bottom of this page.

3. Information We Collect

We collect the following categories of personal data:

3.1 Information You Provide

• Account information: Full name, email address, school or organization name, role, grade level, and subject area when you sign up for early access or create an account.
• Assignment data: Topics, instructions, and rubric selections created by teachers.
• Student submissions: Materials designed by students (diagrams, slides, multimedia), recorded teaching demonstrations (screen recordings or camera recordings), self-reflections, and peer feedback.
• Evaluation data: Teacher evaluations, rubric scores, and feedback provided through our platform.

3.2 Information Collected Automatically

• Usage data: How you interact with our platform, including pages visited, features used, and time spent.
• Device information: Browser type, operating system, and device type.
• Cookies: We use essential cookies to keep the platform functional and may use analytics cookies to improve our service.

4. How We Use Your Information

We use your personal data for the following purposes:

• To provide and operate the Clevra platform, including assignment creation, student performance workflows, and evaluation tools.
• To manage your account and communicate with you about the service, including early access and pilot program updates.
• To enable teachers to review student materials, recorded performances, reflections, and peer feedback.
• To improve and develop our platform based on usage patterns and feedback.
• To ensure the security and integrity of our platform.
• To comply with legal obligations.

5. Legal Basis for Processing

Under the GDPR, we process your personal data based on the following legal grounds:

• Contract performance: Processing necessary to provide you with our platform and services.
• Legitimate interest: Improving our platform, ensuring security, and communicating service updates.
• Consent: Where required, such as for analytics cookies or marketing communications.
• Legal obligation: Where processing is required by applicable law.

6. Data Sharing and Transfers

We do not sell your personal data. We may share your data with:

• Service providers: Trusted third parties that help us operate our platform (e.g., hosting, analytics), bound by data processing agreements.
• Legal requirements: When required by law, regulation, or legal process.

If any data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, such as Standard Contractual Clauses.

7. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes described in this policy, or as required by law. Account data is retained while your account is active. Student submission data, including recordings, materials, and evaluations, is retained for the duration needed to complete the assessment cycle and provide feedback. You may request deletion of your data at any time.

8. Your Rights

Under the GDPR, you have the following rights regarding your personal data:

• Access: Request a copy of the personal data we hold about you.
• Rectification: Request correction of inaccurate or incomplete data.
• Erasure: Request deletion of your personal data.
• Restriction: Request restriction of processing in certain circumstances.
• Portability: Request your data in a structured, machine-readable format.
• Objection: Object to processing based on legitimate interests.
• Withdraw consent: Where processing is based on consent, you may withdraw it at any time.

To exercise any of these rights, please contact us using the details below. You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. This includes encryption, access controls, and regular security assessments.

10. Children's Privacy

Our platform is designed for use by high school teachers and their students. Where students are under the age of 16, we rely on the school or teacher to ensure appropriate consent and authorization is obtained in accordance with applicable law.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any significant changes by posting the updated policy on our platform and updating the "Last updated" date. We encourage you to review this page periodically.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at: