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Data protection ·Student data stays in the EU.

Made in Sweden.
Kept in Europe.

A Swedish company, European infrastructure, and a promise that's never compromised: student data stays within the EU/EEA, always.

Terms and conditions

Four things to know about student data in Gradr

  • 100% of student data stays in the EU

    Student work is stored with Hetzner in Helsinki, and the AI runs in EU regions at Microsoft (Sweden) and Google (Belgium). Neither storage nor AI processing leaves the EU.

  • 0 identity details sent to the AI

    When the AI drafts feedback, the student’s name, email, class, school and user ID are never sent – only the task, the teacher’s instructions and the answer.

  • 0 grades set by the AI

    The AI cannot write to the grade field, and no feedback reaches the student until the teacher returns the submission.

  • 30 days of point-in-time recovery

    The database can be restored to any point in the last 30 days, and a copy is mirrored every night to a separate provider in Paris.

GDPR and the EU

Gradr complies with GDPR, and all student data stays within the EU/EEA – stored, processed and backed up.

  • 100% EU/EES

    All storage and AI processing

  • Hetzner · Finland

    Self-hosted European infrastructure

  • AES-256 + TLS

    Database and backups at rest, TLS in transit

  • GDPR art. 28.3

    Processing agreement with every school

Data storage

Student data is stored on Gradr's self-hosted infrastructure at Hetzner in Finland (EU): database, authentication, and file storage. The database and the backups are encrypted at rest — the database volume with LUKS/AES-256 and the backups before they leave the server — and all communication uses TLS. Using PITR backups combined with daily mirroring to external storage provider within the EU. Hetzner is a European company — a deliberate choice, so that student data is not exposed to US legislation such as the CLOUD Act.

AI processing — EU only

AI processing happens exclusively within the EU: Microsoft Azure OpenAI (EU data zone, data at rest in Sweden) and Google Vertex AI (Belgium). No personal data is transferred outside the EU/EEA. Neither provider uses prompts or outputs to train or fine-tune AI models — Microsoft does not process customer data for training, and Google's terms do not permit it without explicit instruction.

  • No foundation model training

    Under our data processing agreement, student and user data may never be used to train AI models.

  • No summative assessment

    Gradr never sets grades. Summative assessment is an exercise of public authority and always stays with the teacher.

The teacher decides — not the AI

The AI drafts formative feedback suggestions based on the teacher's own instructions and criteria. The teacher reviews and approves every suggestion; nothing reaches a student without the teacher's action. The AI never sets grades, points, or summative assessments — multiple-choice questions are scored deterministically against the teacher's answer key. No automated decision-making within the meaning of GDPR Article 22 therefore takes place.

  • You own your data

    You control your data and can delete it at any time.

  • User authentication

    Sign-in through the school’s SSO, with mandatory two-factor authentication (2FA) on request.

Your data. Your decisions.

The school owns its data and decides over it, all the way.

  • Data minimisation

    An AI call for feedback contains no identity fields for the student: name, email, class, school, year group and internal user number are separated before the answer is sent for AI inference. What is sent is the question with the teacher's marking criteria and accompanying material, plus the student's answer. The student's answer is sent verbatim and can therefore contain information the student wrote themselves. The measure is data minimisation — the answer is sent without being replaced by any identifier at the provider.

  • Data Gradr does not process

    The platform has no fields intended for personal identity numbers (personnummer) or for special-category data under GDPR Article 9, and Gradr does not ask for such data. Because students and teachers write in free text, such data can still occur unintentionally; there is no technical filtering that prevents it. The platform also has no fields for secondary identifiers such as home address, phone number, date of birth, gender, photo, audio, or video.

  • Your rights

    Data subjects can exercise their rights under the GDPR by contacting us. Complaints can be lodged with the Swedish Authority for Privacy Protection (IMY).

    privacy@gradr.se · imy.se

  • Retention periods

    This is how long the data is kept in the platform. Beyond that, processing runs for the term of the agreement.

    Logs of user activity
    6 calendar months
    Operational logs
    7 days
    Recovery window for backups
    30 days

    Logs are purged by a daily job with a one-day safety margin. As a consequence, the right to review logs in hindsight is limited to six months back in time.

Data sovereignty

Your data never leaves the EU

Every byte is stored and processed within the EU/EEA. Database, authentication and file storage in Finland; AI inference in the EU data zone and Belgium; backups in France. No personal data crosses the union's border — it's built into the architecture, not a setting that can be changed.

  • Hetzner · Finland (EU)
  • Azure OpenAI · Sweden (EU data zone)
  • Vertex AI · Belgium (EU)
  • Scaleway · France (EU)
Data processing within the EU/EEA

All sub-processors process data within the EU/EEA.

Sub-processors

Gradr uses four sub-processors, all processing within the EU:

Sub-processorData locationPurpose
Hetzner Finland (EU)All rented infrastructure for running the platform: servers, object storage and networking
Microsoft Azure OpenAI Sweden (EU data zone)AI inference in the EU data zone: formative feedback, exam parsing, name extraction
Google Vertex AI Belgium (EU)AI inference: assessment, insights, language review, parsing and text-to-speech
Scaleway France (EU)External cold storage of database backups

Agreements and DPIA

The school organiser (huvudman) – the school, its administration or its group – is the data controller; Gradr is the data processor. Gradr provides and signs a data processing agreement (GDPR Art. 28(3)) with every school customer, and provides documentation to support the organiser's data protection impact assessment (DPIA).

Frequently asked questions

Student data is stored on Gradr's self-hosted infrastructure at Hetzner in Finland (EU). The database and the backups are encrypted at rest, all communication uses TLS, and the backups are mirrored nightly to an external storage provider within the EU. Hetzner is a European company, so student data is not exposed to US legislation such as the CLOUD Act.

That is why schools choose Gradr over general AI tools that are not built to process student data on a school's instructions.

Try Gradr with your own class!

Book a short demo – we'll show you how it works, you decide if it fits.