Privacy Policy

Redpen AI | Privacy Notice

Last updated – June 2025

About this notice

This privacy notice explains what personal data we collect from or about you.  

It sets out why we collect, use, and protect your personal data, and what rights you have over that data.

Who we are

We are Redpen AI Ltd, registered in England under company number 15971890.

What we do

We provide an AI-powered formative assessment platform that helps teachers provide high quality, personalised feedback to students against the standards set in the national curriculum.

We aim to provide teachers a tool to save time, whilst improving quality of feedback, to allow them the space to do what they do best; teach.

Our role

Typically, we act as a processor of your personal data. This means that we only process data about you to provide our service to our customers, or on the instructions of our customers that use us to provide their services. For information on how our customer uses your personal data, including how we fit into that processing, you should review their privacy notice or contact them for more information.

This notice applies to the personal data we process as a controller (this means when we are responsible for deciding how we collect, use and store information about you), and as a processor (when we process personal data provided by a teacher or school on their instructions).

We are registered with the Information Commissioner’s Office (ICO) under number ZB883899.

How we collect and use your information

How we collect and use your personal data will depend on how you interact with us or the services you use. To better understand we use your data, please click on the role that best describes you.

You’re just browsing your website

If you are just browsing our website, we may collect your data using cookies or other tracking technology which.  

Cookies are small text files that are placed on your device, such as your computer, phone or tablet, when you view pages on our website. These cookies allow us to track some of your browsing preferences and optimise how website works.

While we are not looking identify you using cookies as the focus is on your device, it may be possible for use to identify you or infer information about you. Unless the cookies are “strictly necessary” to make our website function, we will always ask for your consent before they are placed on your device.

For more information on the cookies we use, please read our cookie notice (LINK HERE)

You’ve signed up to use our product

Purpose your data is used

Type of data used

Legal basis

Register your interest in the platform

Name

Email address

Name of school you work at

Contract

Create your teacher/school account

Name

Email address

Name of school you work at

Contract

To manage your customer account with us

Name

Email address

Name of school you work at

Contract

Analysing previous feedback to improve suggested feedback in platform

Name

Previous generate teacher feedback

Teacher edits to suggested feedback

Contract

Send you feedback surveys to help understand how to improve our product

Name

Email address

Legitimate interests

Send you relevant marketing emails regarding our new products or services

Name

Email address

Legitimate interests

You’re school is using our product

When your teacher or school our product, we need to process some of your information so that we can provide our services. To find out more information about how our product, and therefore your data, is processed by the platform you need to speak to your teacher or school. We only use your data for this purpose on the instructions of your teacher or school.  

Below we have outlined the reasons Redpen AI uses your data when we provide our services to your teacher or school. When we do so, this is under the instruction of the school, and therefore we do not decide the legal basis that is used, or the length of time the data is kept.

Purpose your data is used

Type of data used

Setting up a new lesson on our platform

Teacher name

Student name

Processing work submitted to our platform

Student name

Image of student work

Providing suggested feedback to teacher

Student name

Analysis of student work

What do we mean by “legal basis”?

We are only able to use your personal data when the law allows us to. This is called the legal basis. Regarding the above purposes, the legal basis listed for each are explained below:

Consent – You have given us your consent to process your personal data for the specific purpose we have explained to you. You have the right to withdraw your consent at any time. To do so please contact the Data Protection Officer via the details supplied below.

Contract – We need to use your data to fulfil a contract you have with us. Alternatively, it’s necessary to use your data because we have asked you to, or you have taken yourself, specific steps before entering that contract.

Legal Obligation – We need to use you’re your data to comply with the law.

Vital Interests – Processing your data is necessary to protect your vital interests or of another person. For example, to prevent you from serious physical harm.

Public Task – Using your data is necessary for the performance of a task carried out in the public interest, or because it is covered by a task set out in law, for example, for a statutory function.

Legitimate Interests – Processing your data is necessary to support a legitimate interest we or another party has, only where this is not outweighed by your own interests.

Above we have listed two legitimate interests. One, sending of feedback surveys, and two sending of relevant marketing. In both cases, we will only send these where you have not objected to their receipt. In each email, we will give you the opportunity to opt out of these emails, as required to under the law.

How long do we keep your information?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data.

Sometimes we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Who is the information shared with?

As with most organisations, we use service providers to help us deliver our services and keep your data secure. When we use these service providers, it is necessary for us to share your personal data with them.  

We have agreements in place with all our providers that oblige them to protect your data  

Where your data is transferred outside of the UK, we make sure that your data is given the given the same level of protection, either because that country have a comparable data protection standard (Adequacy), or by using another safeguard such as an enhanced contractual agreement (IDTA).

Sometimes, we may be legally obliged to supply copies of personal information to other organisations. For example, to supply information to the police. We might not be always able to tell you that we have shared your information in this way, however we will ensure this is only shared in accordance with the law.

You can find more details on how your data is shared below:

Provider

Reason your data is shared

Location of Data

How we protect your data when transferred outside the UK

Microsoft Azure

To enable our product

UK

N/A

Your rights

Under data protection legislation, in certain circumstances you have the following rights over the processing of your personal data as described in this notice:

  • right to be informed about how your data is used;
  • right of access to your personal data;
  • right to correction or rectification of your data;
  • right to request deletion of your data; and  
  • the right to data portability.

In most cases, when we provide our services, we at as a processor and therefore you should submit your requests to your school.  

Where we act as a controller, namely for account setup and management purposes, we will respond to a request to exercise these rights within one month if not before. If you would like to submit a request, please contact us at team@redpenai.co.uk.  

Complaints

If you are unhappy with any aspect of this privacy notice, or how your personal data is being processed, please contact us at team@redpenai.co.uk.

If you are still not happy, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO):

By post: Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

By live chat: https://ico.org.uk/global/contact-us/live-chat  

By email: casework@ico.org.uk

By phone: +44303 123 1113

https://ico.org.uk/global/contact-us/