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Data Processing Addendum
Last Updated: April 5, 2025
This DPA supplements our Terms of Service and Privacy Policy, outlining specific data protection obligations when processing educational data through our platform.
1. Definitions
- Data Controller: The educational institution or individual determining processing purposes
- Data Processor: Wisdom Link AI Limited providing the Service
- Educational Data: Academic records, performance metrics, and learning materials
- Processing Activities: Collection, storage, analysis, and AI-driven transformation
2. Processing Scope
a. Permitted Uses
- Personalized learning delivery
- Educational content generation
- Progress tracking and reporting
- Service improvement and research
b. Restrictions
- No processing beyond documented instructions
- No secondary commercial use of raw data
- No disclosure to unauthorized third parties
3. Security Measures
We implement comprehensive protections including:
- Encryption in transit and at rest
- Access controls and audit logging
- Regular security testing
- Data minimization principles
- Incident response protocols
4. Subprocessing
- We may engage specialized subprocessors for cloud hosting, AI processing, and analytics
- All subprocessors are contractually bound to equivalent protections
- Current subprocessor list available upon request
5. Data Subject Rights
We assist Controllers in fulfilling:
- Access and rectification requests
- Erasure and restriction obligations
- Data portability requirements
- Objection handling procedures
6. International Transfers
- Data may be processed globally to ensure service continuity
- We implement Standard Contractual Clauses or equivalent mechanisms
- Hong Kong PDPO compliance maintained for all processing
7. Audit & Compliance
- We undergo regular independent security audits
- Educational institutions may request compliance documentation
- We cooperate with regulatory inquiries
8. Data Return & Deletion
- Upon termination, data is deleted within 90 days
- Anonymized aggregate data may be retained
- Specific retention periods may apply to educational records
9. Breach Notification
- We notify affected Controllers within 72 hours of confirmed incidents
- Notification includes nature, scope, and remediation measures
- We cooperate fully with breach response efforts
10. Governing Terms
This DPA supplements but does not replace our Terms of Service or Privacy Policy. In case of conflict, the most protective terms apply.
Contact Information
Data Protection Officer
Wisdom Link AI Limited
Email: dpo@eduq.ai
Address: Unit 1201, Building Name, 123 Business Road, Central, Hong Kong
Phone: +852 XXXX XXXX