Privacy policy

Who we are

The service is operated by STEPROLE LIMITED. Our full legal name, registration number and registered address are in the footer of every page on this site.

For anything to do with personal data — a question, a request or a complaint — write to info@level-up-class.com. Requests are handled by the company's management and we answer within one month at the latest.

If the request is complex and we need more time, we will respond within 30 days.

Our two roles — and why it matters to you

For the data a school enters into the platform — students, guardians, teachers, classes, attendance, grades, fees — and for what someone sends it through its public forms (enrolment, appointments), the school is the data controller. The school decides what is recorded, for what purpose, and who may see it.

For that data we are the processor: we process it only to make the service work, and only according to the school's written instructions as set out in the data processing agreement.

There is other data for which we are the controller: the contact details of people who request access or ask us about the product, and of the media outlets we send information about the service to, the billing details of our customers, and the technical records we keep to secure the service.

This distinction is not a formality. It decides who you talk to: if you are a guardian, a student or a teacher and you want something done about your data, ask your school first, because the school decides. If you get no answer in reasonable time, write to us and we will help.

What data is involved

For a student: name, date of birth, contact details, classes and enrolments, attendance and absences, grades and assessments, homework, participation notes, teacher comments, and fee records, and the files uploaded to the application: course materials, graded papers, homework submissions.

For a guardian: name, email, phone, the relationship to the student, and their preferences about when they want to be notified.

For a teacher or school administrator: name, email, phone, role and permissions, the classes they teach, and — if the school records it — pay details.

For every account: email and an encrypted fingerprint of the password, language, when they signed in and when they were last active, and which data-changing actions were taken inside the application.

For those who send a school's public enrolment form, without an account: the child's name and, where the school's form asks for them, date of birth, school year and current school; name, email, phone and relationship of up to two guardians; the subjects or classes they ask for, preferred times, how they found the school, a note, and the language of the page. The school may also add its own questions to the form, up to twenty, for each child or once for the family; what it asks there is the school's decision, and we keep each answer together with the question as it was worded when the form was sent. For a guardian who asks to re-enrol their child from their account: whatever the form asks for among subjects or classes, preferred times, a note and answers to the school's questions, together with the child's details and the guardian's name, email and phone, as the school already holds them. For those who book an appointment on a school's public page: name, email, phone and an optional message.

Only if the school has the health record turned on: the student's allergies, medical notes and medical certificate expiry, who may collect the child (name, relationship, phone), and what the guardian answered about photos and video. Health details are special-category data. Among the school's users, only the administration, the child's teachers and the child's guardian can see them.

For those who approach us as prospective customers: school name, contact name, email, phone, the notes of our conversation, which emails we sent them and whether they followed a link in one. The same list also holds media outlets, to which we send information about the service: the outlet's name, the general newsroom email the outlet itself publishes, which emails we sent them and whether they followed a link in one.

We do not ask for and do not keep: identity card numbers, card or bank account details of students, religious or other special-category data beyond the health details described above, biometrics, or student profile photographs. If a school types such data into a free-text notes field, or asks for it in one of its own enrolment form questions, it does so on its own responsibility and against our terms of use.

If a school uploads a file that shows people, such as a photo from an event, it is responsible for having the consent that this requires.

Where we get it from

Most of the data does not come from you: your school enters it. The law requires us to say so plainly, and it is right that you know.

The source is the school, when it enrols a student and guardian or uploads a file through bulk import. The source is you, when you complete your account or your child's details, when you send a school's public enrolment or appointment form, when you ask to re-enrol your child, or when you write to us. The source is the system itself, for what use produces — when you signed in, what changed.

On the enrolment form you may give details of other people too: the second guardian, or those who collect the child. Only include people who know you are giving their details to the school.

We do not buy data from third parties and we do not collect it from social networks. The details of media outlets come from a public source: the contact or about page that the outlet itself publishes on its website.

On what legal ground we process it

To perform a contract: to run the service the school asked for and to maintain your account. Without this data there is no service.

For our legitimate interests: keeping the service secure, detecting abuse and technical faults, answering when something goes wrong, contacting schools that showed interest in the product, and presenting the service to media outlets. In each case we weigh our interest against your rights, and you may object.

To comply with the law: tax and accounting records, and responses to lawful requests from authorities.

The school records the details of students and guardians to perform the enrolment contract, and informs the guardian in writing at enrolment. Where consent is needed for something beyond teaching — photos or promotional messages, for example — the school obtains and documents it. We do not base our processing on consent given by you to us.

When you send a school's public form, the school uses the details to consider the enrolment or appointment you asked for, that is, at a stage before a contract and at your request. The same applies to a re-enrolment you ask for from your account for the new year. The form accepts health details and the people who collect the child only with your explicit consent to the school. You withdraw it by asking the school.

We do not use data for advertising, we do not sell it, we do not trade it and we do not give it to third parties for their own purposes. Not ever, at any price.

Children's data

Most of what passes through the platform concerns minors. We take that seriously and the product was designed around it.

No child creates an account on their own: every account is born from an invitation issued by the school. A school's public enrolment form does not create an account. It sends an application to the school, and the child becomes a student only when the school approves it.

Student data is not visible to search engines, never goes to advertising networks, and is not used to build behavioural profiles.

Every account sees only what belongs to it: a guardian sees only their own children, a teacher only the classes they teach. The separation is enforced by the server on every request, not by the screen.

The school informs the guardian in writing at enrolment: what it records about the child, why, and what rights the guardian has.

Where the data lives

The application runs on servers in Germany and the database is in the Netherlands. Both are inside the European Economic Area.

We do not transfer data outside the European Economic Area. If that ever changes, we will tell schools before it happens and it will rest on an approved legal basis for transfers.

The connection to your browser is encrypted, and the application's connection to the database runs through an encrypted tunnel.

Files uploaded to the application are kept in storage configured to keep them inside the European Union. They go from the browser straight there, and open only through the application, for those entitled to see them.

Who else is involved

To run the service we rely on a small number of providers. None of them processes data for its own purposes, all are bound by contract, and all are inside the European Union.

The infrastructure provider, where the application runs and backups are held.

The database provider, where the service's data is stored.

The email provider, so notifications reach guardians, staff and those who send a school's public form, along with the emails we ourselves send to prospective customers and media outlets. It receives the recipient's address and the content of the message.

The file storage provider, where the files uploaded by the school and its users are kept. It receives the file itself, never the name of the person it concerns.

A technical error-logging service, which receives only the type of error and the place in the code. Never a name, an email or a student's data.

Beyond these, we disclose data only where the law or a court order requires it. If that happens and we are allowed to say so, we will tell the school.

How long we keep it

For as long as a school is our customer we keep its history, because that is the reason the application exists: to remember what happened last year.

When the relationship ends, we keep the data for a short transition period so the school can take a copy. After that we delete it permanently, and the backups containing it expire in turn within a few weeks.

Tax and accounting records we keep for as long as the law requires, whether or not the relationship continues.

The details of a prospective customer who did not become one are deleted when there is no longer a reason to keep them, or immediately if they ask. The same applies to the details of media outlets.

An application from the public form, or a re-enrolment, that was not approved, because it was declined, put on the waiting list or never answered, is deleted together with its notifications 180 days after it last changed. When the school approves it, the application loses the guardians' details, the health details, the email and the phone, and from then on they are treated like any student's. The answers to the school's own questions do not move to the student: they stay on the approved application, together with the child's name and what was requested, and only those at the school who handle applications see them. If the school deletes the student, their applications and the answers in them are deleted along with the student.

The details of someone who books an appointment on a school's public page are deleted 180 days after the appointment. Only the fact that an appointment took place remains. In both cases the school may ask for a different period, from 30 days to two years.

If a guardian or student asks for deletion, the school decides first: there may be a legal duty to keep something, or an open fee record.

Technical errors in the service are recorded on our own server, without keeping which user ran into them, and are deleted 7 days after they last occurred. The server's log files have a fixed maximum size: the oldest entries are deleted automatically as new ones are written.

How we protect it

Passwords are never stored in readable form. The secrets the service needs are held encrypted.

Every request for data passes an identity and permission check, and is filtered by school without exception. Separation between schools is not a setting that can be forgotten: it is structural.

Actions by the school's users that change data are written to an action log, visible to the school's owner.

Anyone on our side with the technical ability to see data is bound in writing by a duty of confidentiality, and that ability is granted only to those who need it for their work.

We keep backups and we test them. No technique makes a system impossible to breach, however, and we will not claim otherwise.

What you can ask for

To learn whether we hold data about you or your child, and to receive a copy of it.

To have anything wrong or incomplete corrected.

To have your data erased, where there is no lawful reason to keep it.

To have processing restricted while a dispute is pending.

To receive the data you provided in a machine-readable file, and to ask for it to be sent elsewhere.

To object to processing that rests on our legitimate interests.

Remember the distinction in the second section: for data entered by the school, the request goes to the school first. We do not delete or alter a student's data on our own initiative — that would be exactly the breach we promised not to commit.

We charge nothing for any of this, and we do not ask you to justify why you are asking.

Automated decisions

We do not make decisions about people by automated means. We do not build profiles either, with one small exception for our list of prospective customers and media outlets, described below.

The application calculates — averages, balances, attendance rates — but the results are information for the person who will judge, not the judgement itself. No decision about a student is taken by the system.

We do not train artificial intelligence models on schools' data, neither our own nor anyone else's.

The exception concerns only those on our list of prospective customers and media outlets. When someone follows a link in an email we sent them about our service, or unsubscribes from our list through the email, their entry in our own list may change status automatically, to show that they followed a link or that they unsubscribed. The change sends no email by itself, and a person can always change the status. Once someone has unsubscribed, their clicks no longer count. You can object by writing to us, as with any processing based on our legitimate interests.

Cookies and tracking

We use no tracking cookies and no advertising pixels. We only count how many people see each page, in total and without cookies, with a tool that runs on our own server. The details are on the cookies page. One exception: when we email a prospective customer or a media outlet about our service, the links in it to this website carry an identifier, so that we know the recipient opened one. It uses no cookies, does not measure whether the email was opened, and stops as soon as they unsubscribe from our list.

We load nothing from advertising networks, social media or external font services. What the page loads comes from us.

The only cookies we set are the ones that keep you signed in, remember your display choices and remember your language. They are described one by one on the cookies page.

If there is a breach

If data is exposed, we notify the affected school without undue delay, with what we know: what happened, which data it concerns, what we did and what we recommend.

Because the school is the controller of student data, notifying the authority and the people affected is done by the school. We support it with whatever it needs, within the deadlines set by law.

For the data of which we are the controller, we notify the authority and the people affected ourselves.

If you disagree with how we handled it

Tell us first, at info@level-up-class.com. Most issues are settled with one message, and we want to know when we got it wrong.

Independently of us, you have the right to lodge a complaint with the Office of the Commissioner for Personal Data Protection of Cyprus, and with any other supervisory authority in the country where you live or work.

Coming to us first limits none of your rights and is a precondition for nothing.

Changes to this page

If something material changes, we tell schools by email before it takes effect, so they have time to read it and respond.

Small corrections — a word, a clarification — go in without notice.

The date at the top shows when this text last changed.