Legal
Effective Date: April 28, 2026
Cues Technologies Inc. | 9171 Wilshire Blvd, Ste 500, Beverly Hills, CA 90210
Applicable Jurisdictions: European Economic Area (EEA) and United Kingdom
GradingPal offers an AI-powered grading and feedback tool for educators that automates rubric-aligned scoring, provides feedback generation across multiple assignment types including written work, handwritten submissions, essays, exams, worksheets, quizzes, problem sets, presentations, audio, video, art and design, and other instructional content, as well as performance analytics and other instructional productivity tasks (the “Service”).
This European and UK Privacy Notice (this “Privacy Notice”) sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you (your “personal information”) when you access or use our website at www.gradingpal.com (the “Website”) or the Service from the European Economic Area (“EEA”) or the United Kingdom (“UK”).
Please ensure that you have read and understood this Privacy Notice before accessing or using the Service. If you have any questions, comments or requests regarding this Privacy Notice, please contact us using the details set out in Section 4 below.
Our Service is intended for providers of educational services, such as schools, school districts and local education authorities. When we work with these entities, we mostly use personal information as a processor on behalf of the relevant school or, where applicable, the local authority or education board responsible for managing suppliers and service providers for the school. For ease, we refer to these administrative bodies collectively in this Privacy Notice as “Schools.”
Where we act as a processor for a School, the School determines and is responsible for how we process personal information. For further information about how we process personal information as a processor, you can view the descriptions in our Data Processing Addendum. However, if your School uses the Service and has uploaded your personal information to the Service, you should consult that School's privacy notice for information about how that personal information is used.
We do also process some personal information through our Website and our Service as a controller as described in this Privacy Notice. This means that, with respect to the processing of personal information described in this Privacy Notice, Cues Technologies Inc. (“GradingPal,” “we,” “us,” or “our”) determines and is responsible for how your personal information is used.
When you create a free account on our Service, you should make sure that you have the relevant School's authorisation to do so. When you sign up with your School's authorisation — which we will assume is the case where you sign up using your School email address — we will process personal information uploaded to the Service as a processor on behalf of your School.
However, if you sign up independently or without the School's authority, such as where you purchase a GradingPal Premium subscription using your own payment details, you will be the controller of, and responsible for, the processing of personal information relating to students that you or they upload to the Service. Save as set out in the section headed “Information Collected Automatically About All Users of the Service” below, we will use such personal information as a processor on your behalf as set out in our Data Processing Addendum.
GradingPal (Cues Technologies Inc.)
9171 Wilshire Blvd, Ste 500
Beverly Hills, CA 90210
Email: hello@gradingpal.com
Website: www.gradingpal.com
EU/UK Data Protection Representative
GradingPal has appointed DataRep (Data Protection Representative Limited) as our data protection representative in the EU, EEA, UK and Switzerland, in accordance with Article 27 of the GDPR and Article 27 of the UK GDPR.
If you are located in the EU, EEA, UK or Switzerland and wish to raise a question or exercise your data protection rights, you may contact our representative DataRep by:
The above contact details are for data protection enquiries directed to our EU/UK representative only. For general support, please contact us directly at hello@gradingpal.com.
The personal information we collect and how we use it depends on your role and how you use the Service. The sections below cover each user category separately.
If you contact us to express an interest in the Service, or if another user refers you to our Service by submitting your contact details to us, we will collect and use your personal information as follows:
| Personal Data Collected | How We Use It | Lawful Basis |
|---|---|---|
| Your contact information, such as your name, email address and the name of the school board, district or administration you work for. | To communicate with you, including responding to your queries and requests for further information about the Service. To send you updates about our Service if you sign up to our waitlist or newsletter. To send you promotional emails in accordance with your preferences. | The processing is necessary for our legitimate interests, namely communicating with prospective customers. We will only send promotional messages to the extent you give us your consent to do so. |
| The content of any queries or comments that you submit to us. | To respond to and address your questions, issues and concerns. | The processing is necessary for our legitimate interests, namely communicating with prospective customers. |
We automatically collect certain personal information about how you access and use our Website, and about the device you use to access the Website:
| Personal Data Collected | How We Use It | Lawful Basis |
|---|---|---|
| Information about the device you use to access the Website, such as IP address, unique device identifying numbers, type of device, operating system, screen size, browser type and version, and your approximate location derived from your IP address. | To present the Website to you on your device. To monitor and detect fraud or suspicious activity on our Website. To aggregate and monitor the performance of the Website and identify improvements. | The processing is necessary for our legitimate interests, namely to provide the Website to users and to monitor fraud and suspicious activity. Performance analytics require your consent. |
| Information about how you interact with the Website, such as pages you view, features you use, and any errors that occur. | To present the Website to you. To monitor and detect fraud or suspicious activity. To aggregate and improve the Website and develop new features. | The processing is necessary for our legitimate interests, namely to provide the Website and monitor fraud. Improvement analytics require your consent. |
If you are the main point of contact for a School's use of the Service, we will collect and use your personal information as follows:
| Personal Data Collected | How We Use It | Lawful Basis |
|---|---|---|
| Your contact information, such as your name, email address and the School that you work for. | To manage and administer your School's account, communicate with you about your School's account, and send service-related emails and invoices. To send you promotional emails in accordance with your preferences. | The processing is necessary for our legitimate interests, namely administering our contracts and relationships with our customers. Promotional emails require your consent. |
| Questions, comments and other correspondence you send us, such as support requests or queries relating to the Service. | To manage and administer your School's account, respond to requests, and identify ways to improve the Service. | The processing is necessary for our legitimate interests, namely administering our contracts and informing our product development. |
If you are a teacher and your School has given you access to the Service, or you create an account with your School's permission, we will mostly use your personal information as a processor on behalf of the relevant School. This includes your name and contact details, authentication credentials, subjects and grades taught, content and materials created through the Service, websites you visit when you activate the Service, and feedback on content created by the Service.
We will also collect and use personal information about you as a controller for our own purposes as follows:
| Personal Data Collected | How We Use It | Lawful Basis |
|---|---|---|
| Your contact information, such as your name, email address and the School that you work for. | To send you promotional emails in accordance with your preferences. | We will only process your personal information in this way to the extent you have given us your consent to do so. |
| The features and functionalities you use on the Service. | We aggregate this information to identify popular features and inform how we can improve our Service. | The processing is necessary for our legitimate interests, namely informing our product development and improvement. |
| Questions, comments and other correspondence you send us. | To identify ways to improve the Service, including fixing errors and developing new features. | The processing is necessary for our legitimate interests, namely informing our product development and improvement. |
If you sign up to the Service independently (i.e., without a School's authorisation, or using your own payment details), we will collect and use your personal information as follows:
| Personal Data Collected | How We Use It | Lawful Basis |
|---|---|---|
| Your contact information, such as your name, email address and the School that you work for. | To set up and authenticate your account. To send you service-related communications. To send you promotional emails in accordance with your preferences. | Necessary for performance of our Terms of Use. Promotional emails require your consent. |
| Your account tier (free or premium) and payment details (credit/debit card and billing address, processed by Stripe). | To grant access to Service features in accordance with your account tier and to process your subscription payment. | Necessary for performance of our Terms of Use. |
| The subjects you teach and the year groups or grades of your students. | To generate statistics about how our Service is used and inform Service improvements. | The processing is necessary for our legitimate interests, namely informing our product improvement. |
| Content and materials you create through the Service, including rubrics, graded assignments, and feedback generated through the Service. | To provide you the features and functionalities of the Service, including AI-powered grading and feedback tools. To tailor the content generated for you. We do not use this information to train or improve our AI models. | Necessary for performance of our Terms of Use. |
| Feedback you provide in relation to content generated through the Service. | To tailor the content generated for you. We do not use this information to train or improve our AI models. | Necessary for performance of our Terms of Use. |
| Your communication preferences for service-related and promotional emails. | To send communications in accordance with your preferences and comply with our legal obligations. | Necessary for performance of our Terms of Use and compliance with legal obligations. |
| Questions, comments and other correspondence you send us. | To respond to your questions and support requests. To identify ways to improve the Service. | Necessary for performance of our Terms of Use and our legitimate interests in product improvement. |
We automatically collect certain personal information about the device you use to access and use the Service, such as IP address, unique device identifying numbers, type of device used, operating system, screen size, browser type and version, and your approximate location derived from your IP address.
We use this personal information as a processor on behalf of the relevant School to provide the Service to the relevant user, including facilitating logins and remedying login problems.
If you are a teacher on a free account and use the Service without authorisation from your School, we use this information for the above purposes as a controller. The lawful basis we rely on for processing personal information in this way is that it is necessary for the performance of a contract with you, namely our Terms of Use.
We also use this information to ensure the security and integrity of the Service, including ensuring that the Service is not overloaded. When doing so, we act as a controller of that personal information. The lawful basis we rely on is that it is necessary for our legitimate interests, namely ensuring the security and integrity of the Service.
When the Service is used by a School or teacher for educational purposes, we process personal information about students as a processor on behalf of the relevant School or teacher. The categories of student personal information we process are: identity information (name and email address); academic information (grade level, subject, course name); submitted assignments and coursework across all supported content types; AI-generated grades and feedback; performance analytics derived from submissions and grades; and technical data (IP address and device information). Student data is provided by teachers, submitted by students directly when joining a teacher-invited classroom, or imported from Google Classroom where the teacher has connected their account.
GradingPal integrates with Google Classroom. When a teacher connects their account, GradingPal may read class rosters, course details, and student submissions from Google Classroom, and may write AI-generated scores and feedback back to Google Classroom on the teacher's instruction. GradingPal's use of data received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.
The lawful basis for processing Student Data is performance of GradingPal's agreement with the School. GradingPal does not use Student Data to train AI models, for advertising, or for any purpose unrelated to the provision of the Service. For full details of how Student Data is handled, please refer to our Student Data Privacy Addendum.
Our Website uses cookies and similar technologies such as pixels and Local Storage Objects (LSOs) to distinguish you from other users of our Website and our Service. Please see our Cookie Policy for information about the cookies and similar technologies we use on our Website and our Service.
Other than cookies that are strictly necessary to operate our Website or our Service (such as cookies used to keep you logged in), we will only place cookies on your device where you have given your consent to us doing so. You can customise your cookie preferences at any time by accessing the cookie preferences centre through the cookie widget on our Website.
Information we process as a processor on behalf of a School is retained in accordance with the retention periods set by the relevant School, school administration, or as required by applicable law and the terms of the relevant school agreement.
Where we process personal information as a controller, we retain your personal information for as long as necessary to provide the Services and fulfill the purposes described in this Privacy Notice, or as required by applicable law. The specific periods depend on your relationship with GradingPal:
Regardless of the above, we may retain personal information where required by applicable law, court order, or to bring or defend a legal claim. If you wish to request deletion of your personal information, please contact us at hello@gradingpal.com.
We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. Our security controls include encryption of data at rest (AES-256) and in transit (TLS 1.2 or higher), role-based access controls, multi-factor authentication, intrusion detection systems, and a documented data breach response plan.
We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.
We may share your personal information as follows:
| Recipients | Why We Share | How They Use It |
|---|---|---|
| AI Service Providers — Anthropic PBC, OpenAI OpCo LLC, Google LLC (Gemini), Microsoft Corporation (Azure AI Foundry), Mistral AI SAS | We share personal information with AI providers that power our grading and feedback features. These providers are contractually prohibited from using your data to train their own models. | These recipients use personal information as processors on our instructions to provide AI-powered features. |
| Infrastructure & Hosting Providers — Amazon Web Services Inc. (AWS S3), Supabase Inc., Vercel Inc., Render Services Inc., Google Cloud Platform, Upstash Inc. | We share personal information with infrastructure and hosting providers necessary to operate and deliver the Service. | These recipients host and process data as necessary to operate and deliver the Service, as processors on our instructions. |
| Other Service Providers — analytics, customer support, fraud prevention, IT services | We share personal information with companies providing analytics, customer support, fraud prevention, IT services, and related services. | These recipients use personal information as processors on our instructions. |
| Payment Processors — Stripe, Inc. | We share payment information with Stripe, Inc. to process subscription payments. | Stripe processes payment data subject to its own privacy policy and applicable payment card industry standards. |
| Email Providers — Resend Inc., Loops Inc. | We use Resend Inc. and Loops Inc. to deliver transactional and lifecycle emails to teachers. | These providers receive teacher name and email address only. No Student Data is shared. The lawful basis is our legitimate interests in communicating with our users. |
| Analytics and Monitoring Providers — Mixpanel Inc., Sentry (Functional Software Inc.), Axiom Inc. | We use Mixpanel Inc. for internal product analytics. Mixpanel receives teacher interaction data and student-related usage data including student identifiers and submission metadata, used solely for internal product improvement. We use Sentry for error tracking and Axiom for application log management. | Mixpanel: student identifiers and submission metadata for internal analytics. Sentry and Axiom: technical error and log data. Lawful basis: legitimate interests in maintaining and improving the Service. Where Student Data is involved, processing is also governed by GradingPal's agreement with the relevant School. |
| Collaboration and Real-time Providers — Ably Realtime Ltd., Velt Inc. | We use Ably Realtime Ltd. for WebSocket infrastructure and Velt Inc. for collaborative annotation features on student submissions. | Ably processes session and connection metadata only. Velt renders annotation interfaces on student submission content for teacher feedback purposes. The lawful basis is performance of our contract with Schools and teachers. |
| Internal Operations Providers — Notion Labs Inc., Slack Technologies LLC, Linear Orbit Inc. | We use Notion Labs Inc., Slack Technologies LLC, and Linear Orbit Inc. for internal project management, communications, and operations. Personal data may occasionally be referenced in these tools in the course of investigating technical issues, debugging, or internal communications. | Access to personal data in these tools is limited to authorised GradingPal personnel on a need-to-know basis. The lawful basis is our legitimate interests in managing our internal operations. |
| Customer Support Providers — Chatwoot Inc. | We use Chatwoot Inc. to provide in-app support to teachers. | Chatwoot receives teacher contact information and support correspondence only. No Student Data is shared. The lawful basis is our legitimate interests in providing customer support. |
| Buyers of Our Business | We may share personal information in connection with a merger, acquisition, bankruptcy, or sale of assets. | These recipients use personal information to complete the transaction. The lawful basis is our and the recipient's legitimate interests in completing the transaction. |
| Law Enforcement, Regulators and Other Parties | We may share personal information as required by law or to: (i) comply with law enforcement requests; (ii) detect and investigate illegal activities and breaches of agreements; and/or (iii) exercise or protect the rights, property, or personal safety of GradingPal, its users or others. | These recipients use personal information in the performance of their regulatory or law enforcement role. The lawful basis is compliance with a legal obligation or our legitimate interests in enforcing our rights. |
From time to time we may contact School account administrators and teachers with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services. We will only send you marketing messages if you have given us your consent to do so. You can withdraw your consent at any time by clicking on the “unsubscribe” link at the bottom of our marketing emails.
We may work with online advertising networks and advertising partners to serve advertisements about GradingPal on other websites that you visit. Any online advertising we conduct on our Website is subject to your cookie consent. We will only collect and share information about your use of our Website for advertising purposes to the extent you have given us your consent to do so through our cookie preferences centre.
By default, the personal information we collect may be transferred to and stored in countries outside of the EEA or UK where we and our third-party service providers have operations, including in the United States.
In the event of such a transfer, we ensure that it is made in accordance with applicable data protection law, including by relying on one or more of the following lawful transfer mechanisms as appropriate: (i) an adequacy decision confirming the destination country provides equivalent protection; (ii) certification of the recipient under an approved data privacy framework such as the EU-US Data Privacy Framework or the UK-US Data Bridge; (iii) Standard Contractual Clauses adopted by the European Commission or approved under applicable UK law; or (iv) such other lawful transfer mechanism as may be recognised under applicable law from time to time.
When we transfer your personal information to recipients in the United States, the majority of our service providers are certified under the EU-US Data Privacy Framework and/or the UK-US Data Bridge, which provides a lawful basis for these transfers. Where a recipient is not covered by such a framework, we rely on Standard Contractual Clauses or other appropriate safeguards.
If you wish to enquire further about the safeguards we use, please contact us using the details set out in Section 4 above.
In accordance with applicable privacy law (including the EU GDPR and UK GDPR), you have the following rights in respect of your personal information that we hold:
If you wish to exercise one of these rights, please contact us using the contact details set out in Section 4. Due to the confidential nature of data processing, we may ask you to confirm your identity when exercising the above rights.
If you believe we have not complied with our obligations under applicable privacy law, you have the right to lodge a complaint with your local data protection authority.
We would, however, appreciate the opportunity to deal with your concerns before you approach your data protection authority, so please contact us in the first instance using the contact details in Section 4 above.
We may update this Privacy Notice from time to time and so you should review this page periodically. When we change this Privacy Notice, we will update the “Effective Date” above. We will notify you of any material changes using the contact details you have provided to us. Changes to this Privacy Notice are effective when they are posted on this page.