Effective date: 1 October 2026
Who this notice is for
This notice supplements the Edukamentas Privacy Policy when a school or another educational organisation provides access to “Edukamentas Mokykloms” for students, teachers, parents/guardians or administrators, including trial and paid access. The school provides this notice to its community before they begin using school-provided access. Separately held personal access may be used under the Terms of Service; a school account does not, in itself, give a student under 14 such independent access.
Who is responsible for the data
MB “Uncascade”, trading as “Edukamentas”, company registration number 307057505, V. Nagevičiaus g. 3, LT-08237 Vilnius, email [email protected], is the data controller where it determines the purposes and means of processing: for personal accounts, platform operation, access, support, security, payments, its own analytics and product quality. The school is a separate data controller for its educational and administrative purposes: it decides who receives school access, which registration details to provide and how to use the learning results and reports available to it. Using the platform alone does not make the school and MB “Uncascade” joint controllers. Where we process particular school data solely on its documented instructions, the relevant agreement and law apply.
The school normally provides the first name, surname, email address and class or subgroup needed for access. To correct a class, group or membership record supplied by the school, you may contact the school; for matters concerning an Edukamentas account, platform data or your rights, you may write to us. The end of school access does not, in itself, delete a separately and lawfully held personal account or subscription, but a school account for a student under 14 does not automatically become independent personal access.
What data is used and why
Data is used to provide an account and school access, display assignments, tests, learning progress and school reports, provide support, maintain security and prevent abuse. The specific categories, AI features, mobile app data, recipients and their purposes are described in more detail in the Privacy Policy. Taking account of its status and activities, the school determines and explains its own legal basis under GDPR Article 6 for assigning access, transferring the necessary student data and processing data for education. Where applicable, Article 6(1)(e) or 6(1)(c) may be relevant to a public task or legal obligation; there is no single basis suitable for all organisations. Where we process school data solely on its documented instructions, a data processing agreement applies. Where we determine our own purposes for account administration, platform security, support or legal obligations, we act as a separate controller: depending on the purpose, we rely on legitimate interests (6(1)(f)), after assessing necessity and children's rights, a legal obligation (6(1)(c)), or, where we actually request separate consent, 6(1)(a). Performance of a contract under 6(1)(b) applies to a student only where that student is a party to the relevant contract; the school's contract with Edukamentas alone does not establish this.
Who can see or receive the data
Authorised school staff can see educational data provided to the organisation according to their roles and permissions; when school-provided access ends, the staff's right to view a student's data on that basis ends. A student's progress summary may be visible to the person managing the family-plan seat assigned to that student, or to a person with separate parent/guardian access. If the student also uses the same account at school, this summary may include school activity. Other users can see information only in accordance with the feature, group and privacy settings described in the Privacy Policy.
We use the providers listed in the Subprocessor List and Privacy Policy. For any transfer outside the European Economic Area, we apply the appropriate legal transfer mechanisms and any additional measures required for the particular case. We normally notify the school's designated contact by email at least 7 calendar days before material changes to subprocessors or policies that may significantly affect school-product data. Urgent changes needed for security or service continuity may be made sooner, with notice as soon as possible afterwards. The school may raise a reasoned objection to a particular new subprocessor; we address its practical consequences under the applicable agreement and for the feature concerned.
How long we keep data
We may automatically delete an account and its associated personal learning history after three years without a website sign-in or authenticated use of the mobile app, provided the account no longer has a personal subscription or active paid or trial organisation access, and deletion can be performed safely and automatically. The period runs from the later of the last website sign-in or authenticated app use; if neither occurred, it runs from account creation. While the school is paying for a member's access or has active trial access, that member's prolonged inactivity alone is not a basis for automatic deletion.
We do not automatically delete accounts with staff, administrator, moderator or other special privileges. Accounts with unfinished payments, financial or family relationships, or other dependencies that cannot safely be handled automatically may also be skipped. The owners of these accounts may request deletion where applicable law allows. Cleanup runs periodically, so we do not promise a specific deletion date.
While an account is in use, we do not automatically delete its saved personal work or learning history solely because of the age of a record. The return or deletion of data processed on the school's behalf is also governed by the applicable agreement and law. Technical and security records have separate retention periods set out in the Privacy Policy; records required for accounting, a dispute or another legal obligation may be retained separately, but only to the extent and for the time necessary. Identifiable beta research records are subject to the purpose review and normal three-year participant inactivity rule, with justified exceptions, described in the Privacy Policy and Beta Terms. Irreversibly anonymised findings may be kept longer.
Minors and communications
Students under 14 cannot register independently with Edukamentas. Where an agreement with Edukamentas gives a school or another educational organisation a way to provide access for students of this age, it may assign learning access on an appropriate legal basis. A teacher or administrator does not become a child's legal representative by providing access, and a school invitation is not parental/guardian consent. Parents/guardians may also separately provide family access under the Terms of Service. School access does not, in itself, enable the Forum, friend requests, a public profile or rankings for a younger child; these optional features have separate legal bases and age-appropriate restrictions. We do not send marketing messages to users under 14; necessary service messages are described in the Privacy Policy. A child's fourteenth birthday does not, in itself, change the basis of school access or a family seat separately paid for by a parent/guardian. From age 14, the child may manage their own consent in cases covered by GDPR Article 8, as explained in the Privacy Policy.
Your rights and contact details
Under the GDPR, you have rights of access, rectification, erasure, restriction of processing, data portability, objection and withdrawal of consent where processing is based on consent. For data processed by Edukamentas, a remaining copy of data or account deletion, write to [email protected] or [email protected]. If a request concerns educational decisions or records independently controlled by the school, we may refer it to the school. Withdrawing consent does not end processing that has another valid legal basis.
You may lodge a complaint with the State Data Protection Inspectorate. This notice, the Privacy Policy and the Terms of Service together explain the relevant use of the Service; a separate agreement may apply to a particular school order or data processing.
