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Privacy Policy

Effective date: 8 October 2025
Last updated: 8 October 2025

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Introduction

Keenu Ltd (“Keenu”, “we”, “us”, “our”) is committed to protecting the privacy of students, teachers, and schools that use our services. This Privacy Policy explains what personal information we collect, why we collect it, how we use it, who we share it with, how we protect it, and your rights in relation to that data.

This policy applies to all personal data processed through Keenu’s websites, mobile apps, and platforms (collectively, the “Services”).

 

 
1. Information We Collect

We collect the following categories of personal information:

 

Student information

  • Name, email address, nationality, first language, country of origin, perceived English level, reason for taking an exam, exam history, test scores.

  • Voice recordings created during speaking tests and transcripts derived from those recordings.
     

Teacher information

  • Name and email address.
     

School information

  • School name, billing contact, and other school-level details.
     

Payment information

  • Billing details processed via Stripe. Keenu does not store full card numbers; payment processing is handled by Stripe in accordance with Stripe’s policies.
     

Technical information

  • IP addresses, device and browser information, usage data and cookies collected via analytics tools (Google Analytics, Wix Analytics, Mixpanel, Hotjar, and similar).
     

How we collect information

  • Directly from student accounts and school accounts (students can join via QR or invite codes provided by schools).

  • When schools/teachers sign up or purchase subscriptions.

  • Automatically through cookies, analytics, and server logs.
     

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2. How We Use Your Information

We use personal data for the following purposes:

  • Platform operation: create and manage student, teacher, and school accounts; record test results; produce AI-based feedback and scoring; display dashboards and reports to schools and teachers.

  • AI development & improvement: to train and refine our AI scoring models. We may use anonymised or partially anonymised voice recordings and related data. In limited cases we may use identifiable data where necessary to verify or improve model accuracy.

  • Customer support & communications: to respond to enquiries, provide technical support, and send account-related notifications.

  • Billing & administration: to process payments and manage subscriptions for schools.

  • Analytics & product development: to measure product performance, understand usage patterns, and improve our services.

  • Marketing & engagement: to send product updates, reminders, and promotional messages to schools and, where appropriate, to students. Users can opt out at any time.

  • Legal & security compliance: to meet legal obligations and to detect and prevent fraud or misuse.

  • Aggregated & anonymised data: we may create aggregated, anonymised datasets (which do not identify individuals) for internal research, product development, or eventual anonymised commercial use.
     

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3. How We Share Your Information

We do not sell personal data. We do, however, share personal data with trusted third parties who process data on our behalf (processors) and with schools (as appropriate):

 

Service providers / processors (examples)

  • Amazon Web Services (AWS) — secure hosting and storage.

  • Stripe — payment processing.

  • OpenAI and other AI providers — AI scoring, analysis, or verification.

  • Google Analytics, Wix Analytics, Mixpanel, Hotjar — website and product analytics.

  • Email/CRM and support tools — communications and customer service platforms.
     

These providers process personal data only as instructed by Keenu and under contractual obligations to protect the data.

 

Access by schools

  • Teachers and school administrators can view student performance data, including scores, recordings, and transcripts, for students enrolled in their classes. Schools are responsible for ensuring they have the lawful basis to share or process student information with Keenu.
     

Controller vs Processor

  • Where a school uploads or supplies student data to Keenu about its pupils, the school is usually the data controller and Keenu acts as a data processor performing services on the school’s behalf.

  • When students register directly with Keenu (outside school provisioning), Keenu acts as the data controller for those student accounts.
     

International transfers

  • Some third-party processors may be located outside the UK/EEA. Where data is transferred outside the UK/EEA, we put in place appropriate safeguards such as UK International Data Transfer Agreements (IDTAs) or Standard Contractual Clauses (SCCs) to protect your data.
     

 

4. Data Storage & Security

Storage location

  • We store personal data on AWS servers located in the United Kingdom or the European Economic Area (EEA).
     

Retention

  • We retain personal data as long as necessary to provide our services (generally while the school subscription is active) and for a limited period afterwards to allow for account reactivation, support, and legitimate business needs.

  • Anonymised or aggregated data may be retained indefinitely for research, product development, and model improvement.
     

Deletion & export

  • Users (or their schools) may request deletion of personal data or recordings by contacting us. We will delete or anonymise data unless retention is required for legal, security, or technical reasons.

  • Users may request a copy of their data in a commonly used machine-readable format.
     

Security measures

  • We implement appropriate technical and organisational measures to protect personal data, including encryption in transit and at rest, secure cloud infrastructure (AWS), restricted employee access on a need-to-know basis, one-time-password (OTP) authentication or similar modern auth approaches, and regular security reviews.
     

 

5. Legal Basis for Processing

We process personal data only where we have a lawful basis:

 

For schools & teachers

  • Contract: to deliver the Keenu platform and fulfil paid services.

  • Legitimate interests: for product improvement, security, and analytics.
     

For students

  • Consent: for processing voice recordings, transcripts, and related personal data where consent is required. (In school-provisioned cases the school will typically ensure appropriate lawful basis or consent.)

  • Legitimate interests: to operate and enhance the AI scoring system and to analyse aggregated trends.

  • Contract: where a student directly registers and purchases services from Keenu, processing is necessary for account provision and service delivery.
     

You may withdraw consent at any time; withdrawal will not affect the lawfulness of processing before withdrawal.

 

 

6. Your Rights

Under UK GDPR, you have rights in relation to your personal data. You can exercise these rights by contacting us at hello@keenu.io. We will respond to valid requests within one month unless an extension is permitted by law.

 

Your rights include:

  • Access — request a copy of the data we hold about you.

  • Correction — ask us to correct inaccurate or incomplete data.

  • Deletion — ask us to delete your personal data (subject to our legal obligations).

  • Data portability — request your data in a machine-readable format.

  • Restriction — ask us to restrict processing in certain circumstances.

  • Objection — object to processing based on legitimate interests where applicable.

  • Withdraw consent — where processing is based on consent, you may withdraw it.
     

Automated decisions

  • Our AI scoring provides indicative, automated feedback. It is not a guaranteed or final decision. We do not rely on automated decision-making that produces legal or similarly significant effects; however, you may contact us if you would like human review or have concerns.
     

Marketing & cookies

  • Both schools and students can opt out of marketing communications via unsubscribe links included in emails.

  • Our site shows a cookie banner that allows users to accept or reject non-essential cookies.
     

Complaints

  • If you are unhappy with our handling of your data, please contact hello@keenu.io. You may also lodge a complaint with the UK Information Commissioner’s Office (ICO): www.ico.org.uk.
     

 

7. Children & Under-18s

Keenu may be used by under-18 learners when their school provides the service. Schools must ensure they have the necessary consents from parents or guardians where required. If a parent or guardian believes their child’s data has been processed inappropriately, please contact us and we will investigate and take appropriate action.

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8. Consent / Sign-up Acknowledgement

When students first sign up to Keenu, they will be presented with a clear notice and must acknowledge that:

  • Their test scores, voice recordings, and transcripts may be shared with the school and teachers for assessment and feedback.

  • They have read and agree to this Privacy Policy and the Terms of Use.
     

This one-click acknowledgement helps ensure transparency and supports lawful processing.

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9. Changes to this Policy & How We Notify You

We may update this Privacy Policy from time to time. The most current version will always be published on our website. Where changes are material, we may notify account holders (schools and registered users) by email.

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10. Contact Information & Company Details

Keenu Ltd (registered in England & Wales)
Registered office: 2 Tarvin Avenue, Withington, Manchester, M20 1DA
Company number: 16384183

For privacy questions or to exercise your rights, contact: hello@keenu.io

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11. Additional information

Data processors list

  • A full list of processors and subprocessors (and any updates) can be provided on request. Contact hello@keenu.io to request the current list.
     

Legal & regulatory

  • This policy is prepared in line with the UK GDPR and the Data Protection Act 2018. For specific legal advice, consult your legal counsel.

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